Whistleblower & Ethics Policy

Policy Statement

The Company is committed to conducting its business with integrity, transparency, and accountability. The Whistleblower & Ethics Policy provides a secure mechanism for employees and stakeholders to report concerns related to unethical behavior, misconduct, or violations of laws and policies without fear of retaliation. This policy supports the Company's commitment to maintaining the highest ethical standards and a culture of openness.

Objective

• Encourage employees to report any unethical practices, violations, or concerns in good faith.
• Provide a confidential and accessible process for reporting concerns.
• Protect whistleblowers from retaliation, harassment, or victimization.
• Ensure proper investigation and resolution of all reported concerns.

Scope and Applicability

This policy applies to all employees, directors, contractors, consultants, interns, and third-party associates of the Company It covers all suspected violations of laws, regulations, company policies, ethical standards, and instances of fraud, corruption, or discrimination.

Definitions

• Whistleblower: Any person who reports unethical, illegal, or improper conduct in good faith.
• Protected Disclosure: A concern raised by a Whistleblower under this policy that evidences misconduct or a violation of policy.
• Investigation Committee: A group of officials designated to review, investigate, and take action on whistleblower complaints.

Reportable Matters

• Financial irregularities, fraud, or misappropriation of funds.
• Corruption, bribery, or conflicts of interest.
• Violation of legal or regulatory obligations.
• Harassment, discrimination, or workplace misconduct.
• Breach of company policies or ethical standards.
• Any act endangering employee safety or company reputation.

Reporting Mechanism

Employees and stakeholders may report their concerns through any of the following channels:

• Directly to the Whistleblower Officer or the Compliance Officer.
• By email to: compliance@yourcompany.com (or the official whistleblower email ID).
• Through a sealed letter addressed to the HR & Governance Department.
• Anonymously, if preferred, through the internal whistleblower portal.

All disclosures must include sufficient details to allow a proper investigation.

Investigation Process

• The Compliance Officer or designated Investigation Committee will review all reported disclosures.
• Preliminary assessment will be conducted to determine the validity of the complaint.
• A formal investigation will be carried out confidentially and objectively.
• Findings will be shared with senior management and the Audit Committee for appropriate action.

Confidentiality

The identity of the whistleblower and the information provided shall be kept strictly confidential. Disclosure of information will only occur when required by law or during legal proceedings. Anonymous complaints will also be investigated if supported by credible evidence.

Protection Against Retaliation

No employee shall suffer retaliation, discrimination, or harassment for reporting a concern in good faith. Any retaliatory act against a whistleblower will be treated as a serious disciplinary offense, warranting strict action against the responsible person.

Malicious Allegations

While genuine concerns made in good faith are encouraged, any whistleblower who makes a false or malicious allegation with intent to harm others will be subject to disciplinary action.

Roles and Responsibilities

• Board of Directors: Oversees the implementation and effectiveness of this policy.
• Audit Committee: Reviews complaints and ensures independent investigations.
• Compliance Officer: Serves as the primary point of contact for whistleblower reports.
• Employees: Expected to act ethically and report misconduct responsibly.

Awareness and Communication

The Company shall communicate this policy to all employees through onboarding programs, intranet publication, and regular training sessions. Employees are encouraged to familiarize themselves with the procedures for reporting concerns.

Policy Review

This policy shall be reviewed annually by the Compliance Department and approved by the Board of Directors. Necessary amendments will be made to address regulatory updates or organizational changes.

Employee Acknowledgment

I acknowledge that I have read and understood the Whistleblower & Ethics Policy of the Company I agree to uphold ethical conduct and report any misconduct or violation of this policy without fear of retaliation.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________