MINUTES OF INTERNAL DISCIPLINARY INVESTIGATION

A Formal Legal Record of Investigation Proceedings Conducted under the Authority of the Human Resources & Administration Department, pursuant to UAE Federal Decree-Law No. 33 of 2021 (Regulation of Labour Relations) and the Internal Code of Conduct & Disciplinary Policy of the Company.

محضر تحقيق تأديبي داخلي رسمي — يُحرَّر بموجب صلاحيات قسم الموارد البشرية والشؤون الإدارية، عملًا بأحكام المرسوم بقانون اتحادي رقم (33) لسنة 2021 في شأن تنظيم علاقات العمل وUئحته التنفيذية، واللوائح الداخلية للشركة

In the City of Ras Al Khaimah, United Arab Emirates, on this day, the Seventeenth (17th) of May, Two Thousand and Twenty-Six (), and pursuant to the powers vested in the Human Resources & Administration Department of Fala Road Contracting L.L.C. (hereinafter referred to as "the Company") under the provisions of UAE Federal Decree-Law No. 33 of 2021 concerning the Regulation of Labour Relations, its Executive Regulations, and the Company's Internal Code of Conduct and Disciplinary Policy, the undersigned investigator convened this formal disciplinary investigation against the employee whose particulars are set forth in Section (1) hereof, in order to examine and adjudicate the allegations of theft of public property brought to the attention of the Company through the Health, Safety & Environment (HSE) Incident Report bearing reference number MBD/INC-IN-R/01-26.

حُرِّر هذا المحضر في مدينة رأس الخيمة بدولة الإمارات العربية المتحدة، في يوم الموافق 17 مايو ، وبناءً على الصلاحيات المخوّلة لقسم الموارد البشرية والشؤون الإدارية لدى شركة فاله لمقاولات الطرق ش.ذ.م.م )المشار إليها فيما يلي بـ"الشركة(" بموجب أحكام المرسوم بقانون اتحادي رقم (33) لسنة 2021 في شأن تنظيم علاقات العمل ولائحته التنفيذية واللوائح الداخلية للشركة، انعقد هذا التحقيق التأديبي الرسمي مع الموظف المبيّنة بياناته في البند (1) أدناه، للنظر والفصل في الادعاءات المتعلقة بـسرقة ممتلكات عامة، والمحالة إلى الشركة بموجب تقرير الحادثة الصادر عن قسم الصحة والسلامة والبيئة، تحت الرقم المرجعي 6-MBD/INC.IN-R/01-2

ARTICLE (1) — PARTIES TO THE INVESTIGATION \| التحقيق أطراف
Full Name	Mr. Sher Mo Mustak	Emirates ID No.	784-1981-3501220-3
Nationality	Indian	Date of Birth	01 / 01 / 1991
Designation	Labour / Site Worker	Employing Entity	Fala Asphalt Industry
Project / Work Site	RAK Beach District — New Border Road Infrastructure (Phase 1)	Direct Supervisor	Engr. AbdulKareem Dawood — Projects Manager
Residential Address	Fala Labour Camp #10, Jazeera Al Hamra, RAK	Date of Joining	________________________________

ARTICLE (2) — LEGAL BASIS & JURISDICTION | ختصاصUوا القانوني السند

The present disciplinary investigation is conducted in accordance with, and derives its legal authority from, the following instruments:

1. UAE Federal Decree-Law No. 33 of 2021 concerning the Regulation of Labour Relations, in particular Article 39 (Disciplinary Sanctions) and Article 44 (Termination of the Employment Contract without Notice in cases of theft, forgery, or breach of trust).

2. Cabinet Resolution No. 1 of 2022 concerning the Executive Regulations of Federal Decree-Law No. 33 of 2021.

3. The Internal Code of Conduct and Disciplinary Policy of Fala Road Contracting L.L.C., approved by the Managing Director and in force at the time of the incident.

4. The Employment Contract concluded between the Company and the Subject Employee, including the standard clauses governing honesty, integrity, and protection of property.

ARTICLE (3) — STATEMENT OF FACTS & CHRONOLOGY OF EVENTS | الزمني وتسلسلها الحادثة وقائع

It is hereby formally recorded that, on Saturday, the Sixteenth (16th) day of May, , at approximately 08:00 hours, in the locality of Jazeera Al Hamra, immediately adjacent to the Company's labour accommodation known as "Fala Road Contracting Labour Camp No. 10," the following events transpired, as substantiated by the HSE Investigation Report and the testimony of the eyewitness:

3.1 The Subject Employee, Mr. Sher Mo Mustak, did willfully and without lawful authority enter the premises of a demolished villa — said property being legally classified as public property under the custody of the competent local authority — with the deliberate intent of unlawfully appropriating materials located therein.

3.2 The Subject Employee did proceed to remove from said premises a quantity of scrap reinforcement steel (rebar) and did conceal the said materials in a separate undisclosed location, with the manifest intention of subsequently disposing of the same to a scrap dealer for personal financial gain.

3.3 Whilst engaged in the said act of unlawful appropriation, the Subject Employee was observed by the villa site watchman, who, acting in the lawful discharge of his custodial duties, attempted to apprehend and detain the Subject Employee. The Subject Employee thereupon did flee the scene and sought concealment within the precincts of the labour camp.

3.4 The watchman subsequently presented himself at the labour camp and lodged a formal verbal complaint against the Subject Employee. The Camp Supervisor intervened and, in order to forestall the escalation of the matter to the competent governmental authorities, gave the

watchman an undertaking that the Company would impose strict disciplinary measures against the Subject Employee in accordance with its internal policies.

3.5 The matter was thereafter formally reported to the Health, Safety & Environment (HSE) Department by means of Incident Report bearing reference FALA HSSEMSP-17, and was duly referred to the Human Resources Department for the institution of disciplinary proceedings in accordance with the Company's policy and applicable labour legislation.

ARTICLE (4) — FORMAL CHARGES LEVIED | رسميًا الموّجهة التهم

Based upon the facts set forth in Article (3) above and the supporting evidence on record, the Subject Employee is hereby formally charged with the following violations:

First Charge: Theft and unlawful appropriation of public property — constituting Gross Misconduct within the meaning of Article 44 of Federal Decree-Law No. 33/2021.
Second Charge: Breach of the duty of honesty, integrity, and good faith owed to the Employer under the Employment Contract.
Third Charge: Conduct gravely prejudicial to the reputation and commercial standing of the Company within the local community.
Fourth Charge: Willful evasion from lawful apprehension by fleeing the scene of the incident, indicating consciousness of guilt (mens rea).
Fifth Charge: Violation of the Company's Internal Code of Conduct & Disciplinary Policy, specifically the provisions governing protection of property, honesty, and lawful behavior during off-duty hours within Company-provided accommodation.

ARTICLE (5) — NOTIFICATION OF RIGHTS TO THE SUBJECT EMPLOYEE | بحقوقه الموظف إخطار

Prior to the commencement of the interrogation, the Subject Employee was duly informed, in a language he understands, of the following procedural rights:

The nature, particulars, and legal characterization of the allegations brought against him;
His right to be heard and to present his version of the facts in full, without coercion, intimidation, or undue influence;
His right to submit any documentary, testimonial, or material evidence in his defense;
His right to refrain from answering any question that may incriminate him, without such refusal being construed against him save in accordance with law;
His right to receive a true copy of the present Minutes upon their finalization.

إقرار: أقرّ الموظف باستلامه إخطاراً رسمياً بطبيعة الاتهامات الموجهة إليه، وبأنه قد أُحيط علماً بحقوقه الإجرائية كاملةً قبل البدء في الاستجواب، وأن إفاداته صادرة عن إرادة حرة دون أي إكراه مادي أو معنوي.

ARTICLE (6) — FORMAL INTERROGATION OF THE SUBJECT EMPLOYEE \| رسميًا الموظف ṿاستجوا
Q1. Do you formally acknowledge being present at the premises of the demolished villa, situated adjacent to Fala Labour Camp No. 10, on Saturday 16-05- at or around 08:00 hours?
Q2. Do you admit or deny having removed scrap reinforcement steel (rebar) from the said premises? If admitted, please state the quantity removed and the purpose for which the said materials were taken.
Q3. Were you, at the material time, in possession of any authorization — whether from the Company, the lawful owner, or the competent public authority — empowering you to handle, remove, or otherwise dispose of any materials from the said site?
Q4. Kindly explain the reason for concealing the said scrap steel in a separate undisclosed location, rather than reporting the matter to your supervisor or the lawful custodian of the property.
Q5. Do you confirm that you fled from the scene upon being approached by the watchman? If so, please state the reasons that motivated your flight.
Q6. Were you acting in your individual capacity, or were any other employees, colleagues, or third parties involved in, aware of, or complicit in the said acts? If so, kindly identify them.
Q7. Do you acknowledge that the act of theft constitutes Gross Misconduct entailing immediate dismissal without notice or end-of-service gratuity under Article 44 of UAE Federal Decree-Law No. 33/2021 and the Company's Internal Disciplinary Policy?
Q8. Do you wish to present any defense, justification, mitigating circumstance, documentary evidence, or witness testimony in support of your position before the conclusion of these proceedings?
Q9. Do you confirm that the above statements have been recorded in your own words, freely and voluntarily, and that you have been given a fair opportunity to be heard?

ARTICLE (7) — PRIOR WARNINGS & DISCIPLINARY RECORD \| السابقة والمخالفات الإنذارات سجل
SR No.	Date	Nature of Warning	Issuing Authority	Remarks & Reference
1.
2.
3.

ARTICLE (8) — WITNESSES & DOCUMENTARY EVIDENCE \| المستندية والأدلة الشهود
Witness No. 1 (Complainant)		Capacity / Designation
Witness No. 2		Capacity / Designation
Investigation Prepared By		Capacity / Designation
Investigation Reviewed By		Capacity / Designation
Annexed Documentary Evidence	Annexure A: Photographic evidence of the incident scene Annexure B: Certified copy of Emirates ID of the Subject Employee Annexure C: HSE Incident Report (Doc No. FALA HSSEMSP-17, Rev. 00) Annexure D: Sworn written witness statements (to be obtained) Annexure E: CCTV footage (if available)

ARTICLE (9) — FINDINGS OF FACT & LEGAL DETERMINATION | القانوني والتكييف الواقعية النتائج

Having considered the totality of the evidence on record, including the HSE Incident Report, the testimony of the eyewitness, and the responses (or absence thereof) of the Subject Employee during the interrogation set forth in Article (6), the undersigned investigator concludes as follows:

Material Element (actus reus): It is established to the requisite evidentiary standard that the Subject Employee did perform the physical act of unlawfully removing scrap rebar steel from public property and concealing the same with intent to dispose of it for personal gain.
Mental Element (mens rea): The Subject Employee's act of fleeing the scene upon being confronted by the watchman, coupled with the deliberate concealment of the stolen materials, constitutes clear and unequivocal evidence of criminal intent and consciousness of guilt.
Legal Characterization: The conduct of the Subject Employee falls squarely within the ambit of Article 44 (Paragraph 5) of Federal Decree-Law No. 33/2021, which authorizes the Employer to terminate the employment contract without notice in cases where the employee is proven to have committed an act of theft, forgery, or breach of trust.
Aggravating Circumstances: The act was committed in the immediate vicinity of Company-provided accommodation, thereby exposing the Company to potential civil and reputational liability before the local community and the competent authorities.
Mitigating Circumstances: (to be completed by HR upon review of any defense submitted).

Statutory Reference: Article 44 of UAE Federal Decree-Law No. 33/2021 expressly provides that the employer may dismiss the employee without notice and without entitlement to end-of-service gratuity, inter alia, where "the worker is proven to have committed a theft, forgery, or breach of trust." The Company hereby reserves the right to pursue all civil and criminal remedies available under UAE law.

ARTICLE (10) — RECOMMENDATION OF THE INVESTIGATING AUTHORITY \| التحقيق جهة توصية
In the light of the foregoing findings, the undersigned lead investigator respectfully submits the following recommendation for the consideration and determination of the HR & Admin Director and the Managing Director:
	Verbal Reprimand	Suspension without Pay
	First Written Warning	Site Transfer / Reassignment
	Final Written Warning	Summary Dismissal without Notice (Art. 44)
	Salary Deduction (max. 5 days per Art. 39)	Referral to Competent Public Authorities

ARTICLE (11) — RESOLUTION OF THE HR & ADMIN DIRECTOR \| قرار مدير الموارد البشرية والإدارة
HR & Admin Director Remarks:
Final Determination:
	Recommendation Approved in full		Recommendation Approved with modifications
	Recommendation Rejected		Matter Adjourned for Further Investigation
	Salary Deduction (max. 5 days per Art. 39)		Referral to Competent Public Authorities
Effective Date of Disciplinary Action: _____/______/		End-of-Service Benefits: Forfeited (Art. 44) Payable

ARTICLE (12) — ACKNOWLEDGEMENT & DECLARATION OF THE SUBJECT EMPLOYEE | وتعهد إقرار الموظف

I, the undersigned, Mr. , holder of Emirates Identity Card No. 784-, do hereby solemnly declare and acknowledge as follows:

That the contents of the present Minutes have been read out to me in a language I fully understand, and that I have comprehended the nature and gravity of the allegations made against me.
That I was duly informed of my procedural rights, including my right to be heard, to present evidence, and to remain silent on matters which may incriminate me.
That my responses recorded herein were given freely, voluntarily, and without any coercion, duress, threat, promise, or inducement of any kind.
That I have been afforded a fair and adequate opportunity to present my defence and any mitigating circumstances.
That I acknowledge receipt of a true and accurate copy of these Minutes on the date set forth below.

أُقرّ أنا الموقع أدناه، السيد / شيرمو موستاك، حامل بطاقة الهوية الإماراتية رقم 784، بما يلي: أن مضمون هذا المحضر قد تُلي عليّ بلغة أفهمها فهماً تاماً، وأنني أحطتُ علماً بطبيعة وخطورة الاتهامات الموجهة إليّ، وأنه قد جرى إخطاري بحقوقي الإجرائية كاملةً، وأن الإفادات الواردة هنا قد صدرت عني بإرادة حرة دون أي إكراه مادي أو معنوي، وأنه قد أُتيحت لي الفرصة الكاملة لعرض دفاعي، وأنني تسلمتُ نسخة طبق الأصل من هذا المحضر في التاريخ المبيّن أدناه.

ARTICLE (13) — AUTHORISATION, ENDORSEMENT & OFFICIAL SIGNATURES | والتوقيعات عتمادU ا الرسمية

__________________________ __________________________ __________________________ ___________________________

Mr. Muhammad Rizwan Engr. AbdulKareem Dawood HR & Admin Director Managing Director

HSE Manager Projects Manager (Adjudicating Authority) (Final Endorsement & Seal)

(Lead Investigator) (Reviewing Officer)

ARTICLE (14) — DISTRIBUTION & FILING | والحفظ التوزيع

The original of these Minutes shall be retained in the personnel file of the Subject Employee. Certified copies shall be distributed as follows:

One (1) original copy — HR & Admin Department (Master File)
One (1) certified copy — Managing Director's Office
One (1) certified copy — Projects Department / Project File
One (1) certified copy — HSE Department (Incident File MBD/INC-IN-R/01-26)
One (1) true copy — Delivered to the Subject Employee against signed receipt

Fala HR Department