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The donation takes place "voluntarily". If one has donated, he obviously can not claim back as a matter of right.
Hence, the crux is to educate the employees about the dos & don'ts of the policy & make them doubly aware before they donate leaves.
In my earlier company, this policy is in force for the last 5 years or so without any hitch, even covering the blue collar employees.
Further, if v see all initiatives thru the legal lens, than v can do only as much as the law demands us to do, nothing else.

From India, Mumbai
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