Whistleblowing & Non-Retaliation Policy

Whistleblowing & Non-Retaliation Policy

Public policy · Reporting channel activation pending

1. Purpose and Who Can Report

SpacePoint encourages employees, contractors, interns, instructors, learners, parents, suppliers, customers and other stakeholders to report reasonable concerns about misconduct safely and promptly. Reports may concern behavior involving SpacePoint, its activities, personnel, or business partners.

2. Matters That May Be Reported

Examples include bribery, fraud, theft, conflicts of interest, misuse of funds, serious policy or legal breaches, falsification of records, data misuse, cybersecurity incidents, serious health and safety risks, safeguarding concerns, harassment, discrimination, retaliation, and deliberate concealment of wrongdoing. Ordinary service requests and employment grievances may be redirected to the appropriate channel without disregarding a serious underlying concern.

3. Reporting Channels

Primary reporting channel: [email protected]. Alternative escalation: Abdullah AlSalmani, Co-Founder & CEO ([email protected]); where a concern involves the CEO, request referral to a non-conflicted company decision-maker. For urgent threats to personal safety, contact local emergency services or competent authorities immediately. These reporting channels must be operational and monitored before this policy is published as an active mechanism.

4. Anonymous Reports and Information to Include

A reporter may choose not to identify themselves, but ordinary email does not provide guaranteed anonymity. If anonymity is important, the reporter should consider appropriate alternative reporting routes available under applicable law; limited information may make follow-up difficult. Reports should include what happened, when, where, who may be involved, any supporting evidence, and a safe method for follow-up if the reporter chooses to provide one. Do not obtain evidence through unlawful access or share sensitive material more widely than necessary.

5. Handling Procedure and Target Timelines

The designated recipient logs and safeguards each report, screens for urgency and conflicts, and assigns a suitable impartial reviewer. Where contact details are provided, SpacePoint targets acknowledgement within five business days and an initial assessment within ten business days. Investigations are conducted as promptly as practical; periodic updates may be provided where lawful and appropriate. These are internal service targets, not guaranteed legal deadlines.

6. Confidentiality and Fairness

Information is shared only with those who need it to assess, investigate or resolve the matter, or where disclosure is legally required. The identity of a reporter will be protected to the extent reasonably possible, but absolute secrecy or anonymity cannot be guaranteed. Individuals named in allegations will be treated fairly and given an appropriate opportunity to respond where consistent with a sound investigation.

7. Non-Retaliation

SpacePoint prohibits dismissal, threats, harassment, intimidation, adverse assignments, denial of opportunities, supplier exclusion or other detrimental treatment because someone raises a concern in good faith or assists an inquiry. Suspected retaliation should be reported immediately and investigated separately. This commitment is a company policy and does not imply a particular statutory protected-disclosure status for every report.

8. Outcomes, Records and Escalation

The reviewer documents findings and recommended corrective actions, which may include process changes, training, disciplinary measures or appropriate referral to competent authorities. Cases and evidence are held securely with restricted access and retained according to legal requirements and a defined internal retention schedule. Management will review aggregate trends without exposing reporters unnecessarily.

9. Good-Faith Reports and Misuse

A report need not be proven correct to receive good-faith protection; reasonable concerns are sufficient. Knowingly false allegations or deliberately fabricated evidence may be treated as misconduct, following a fair review. Individuals are not discouraged from making reports to competent authorities where permitted or required by law.

10. Governance and Review

The designated governance owner administers this mechanism and reports material matters to non-conflicted company leadership. If a complaint concerns the designated recipient, it must be routed to the alternative independent contact. This policy will be reviewed at least annually and after serious incidents.

Policy accountability and approval

Policy owner: SpacePoint management (designated policy owner to be assigned internally). Approved by: Abdullah AlSalmani, Co-Founder & CEO. Review cycle: At least annually or sooner if legal or operational requirements change.

Publication, Contacts and Approval

Approved by: Abdullah AlSalmani, Co-Founder & CEO, SpacePoint.

Publication date: 25 October 2026. Review: At least annually and when relevant legal or operational changes occur.

Primary contact: [email protected]. Secondary contact / escalation: [email protected].

For concerns involving the usual recipient, contact the CEO using the secondary email. If the CEO is implicated, request reassignment to a non-conflicted responsible decision-maker. No channel can guarantee absolute confidentiality; access will be limited on a need-to-know basis.