WHISTLEBLOWER POLICY

BONGO BHUMI PROPERTY CONSULTANCY SERVICES (The "Company")

EFFECTIVE DATE: 22-Jul-2025

1. Policy Statement and Purpose

1.1. Commitment: BONGO BHUMI PROPERTY CONSULTANCY SERVICES ("Company") is committed to conducting its business with the highest standards of integrity, ethics, and full compliance with all applicable laws and regulations of the Republic of India.

1.2. Purpose: This Whistleblower Policy (the "Policy") is established to provide Directors, employees, contractors, consultants, and agents (collectively, "Personnel") with a secure, confidential, and protected mechanism for reporting known or suspected violations of law, regulations, or Company policies, including fraud, corruption, and unethical conduct, without fear of retaliation.

2. Scope of Reportable Conduct

2.1. Reportable Conduct includes, but is not limited to:

(a) Accounting, auditing, or financial fraud, including theft or misuse of Company assets.

(b) Bribery, kickbacks, or other forms of corruption (refer to the Code of Ethics).

(c) Violation of any law or regulation applicable to the Company's business, including real estate laws, taxation, and labor laws.

(d) Concealment or unauthorized destruction of Company records.

(e) Conflicts of interest not disclosed or managed properly.

(f) Substantial and serious violations of the Company’s Code of Ethics and Professional Conduct.

(g) Acts of retaliation against any individual who reports a genuine concern under this Policy.

3. Reporting Procedure

3.1. Initial Reporting: Personnel should typically raise concerns with their immediate supervisor or the Head of Department. However, if the supervisor or head is the subject of the concern, or if the Personnel feels uncomfortable reporting internally, the concern should be directed to the designated Reporting Authority.

3.2. Reporting Authority: The designated internal Reporting Authority for all whistleblowing concerns is:

* [Designated Person/Role, e.g., The Proprietor / The Managing Partner]

* Email: [Insert a dedicated, confidential email address for reports]

3.3. Report Content: All reports should be made in writing and should include, to the extent possible:

* The nature of the suspected violation or wrongdoing.

* The identity of the person(s) involved (if known).

* Dates, times, and specific locations of the events.

* Supporting evidence or documentation (if available).

* Contact information for follow-up (reporting may be anonymous, but identifying information assists investigation).

3.4. Anonymity: Personnel may report concerns anonymously. The Company will make every effort to protect the anonymity of the whistleblower, subject to legal requirements and the needs of the investigation.

4. No Retaliation and Protection

4.1. Non-Retaliation Guarantee: The Company strictly prohibits and will not tolerate any form of retaliation, discrimination, or harassment against any Personnel who, in good faith, reports a concern under this Policy, assists in an investigation, or testifies in a related proceeding.

4.2. Definition of Good Faith: A report is made in "good faith" if the Personnel genuinely believes the information reported is true. Personnel who make frivolous, malicious, or knowingly false reports will be subject to disciplinary action, which may include termination.

4.3. Whistleblower Protection: Any Personnel found to have engaged in retaliation against a whistleblower will be subject to severe disciplinary action, up to and including immediate termination of employment or contract.

5. Investigation and Resolution

5.1. Investigation: The Reporting Authority will immediately acknowledge receipt of the report and initiate a confidential, thorough, and objective investigation.

5.2. Confidentiality: The identity of the whistleblower, the alleged wrongdoer, and the facts disclosed will be kept confidential to the extent possible, consistent with the need to conduct a thorough investigation and comply with legal obligations.

5.3. Outcome: The Reporting Authority will communicate the outcome of the investigation to the whistleblower (where contact details are provided and confidentiality permits), without disclosing specific disciplinary actions taken to protect the privacy of others.

6. Contact Information

For inquiries related to this Policy, please contact:

BONGO BHUMI PROPERTY CONSULTANCY SERVICES

Address: VILLAGE - BEGAMPUR, P.O. - BEGAMPUR, P.S. - CHANDITALA, MULLICK MARKET, PIN - 712306, DISTRICT - HOOGHLY, WEST BENGAL, INDIA.