WHISTLEBLOWER POLICY

PURPOSE

Anviti (the “Company”) is committed to complying with all laws that apply to it, satisfying the Company’s Code of Conduct and Ethics, and particularly to assuring that business is conducted with integrity and that the Company’s financial information is accurate. If potential violations of Company policies or applicable laws are not recognized and addressed promptly, both the Company and those working for or with the Company could face governmental investigation, prosecution, fines, and other penalties. Consequentially, and to promote the highest ethical standards, the Company maintains a workplace that facilitates the reporting of potential violations of Company policies and applicable laws. Colleagues are free to raise concerns regarding such potential violations easily and free of any fear of retaliation.

APPLICABILITY

This policy comes into play under any of the following circumstances:

  • Violation of any law or regulation, not limited to corruption, bribery, fraud, coercion & willful omission
  • Manipulation/misappropriation of company assets/resources/data/records
  • Misrepresentation or false statements made to a senior officer of the Company regarding any matter contained in the financials / financial reports / audit process / reports
  • Deliberate falsification of company records
  • Activities violating Company policies, Code of Business Conduct and Ethics
  • Unofficial use of company assets and resources
  • Failure to comply with legal obligation
  • Deliberate concealment of information relating to any of the above

REPORTING

Reporting is crucial for early detection, proper investigation and remediation, and deterrence of acts that violate this policy. Everyone is required to report without fear of any negative consequences for reporting reasonably suspected violations because retaliation for reporting suspected violations is strictly prohibited by Company policy. Failure to report any reasonable belief that a violation has occurred or is occurring is itself a violation of this policy and such failure will be addressed with appropriate disciplinary action.

An incident should be immediately reported in any of the following ways:

  • Via an email to the PPC Head, Compliance Head or CEO or to whistleblower@anviti.in
  • Via a letter (typed or handwritten) to the PPC Head, Compliance Head or CEO
  • Via a phone call with all the relevant details to the PPC Head, Compliance Head or CEO. This will however require to be put into writing by the person receiving the complaint and signed or agreed to by the individual making the complaint

The report should include as much information about the suspected violation as can be provided. Where possible, it should describe the nature of the suspected violation, the identities of persons involved in the suspected violation, a description of documents that relate to the suspected violation, and the time frame during which the suspected violation occurred.

Anonymous complaints are not encouraged and may not be actioned by the Management unless they are adequately supported by documentary evidence of the suspected violation.

Complete confidentiality of the details and of the individual submitting the complaint will be maintained by the Company.

A quarterly report on the proceedings, if any, received under this policy, will be placed before the Board/CEO.

The Company will maintain, for a minimum period of 10 years, a complete record of the complaints, the procedure, the reports, the evidence and the action taken.

ACTION

Process

All reports under this policy are promptly and appropriately investigated by a Working Committee, which is made available for fact finding & investigation and submission of a report to the Steering Committee within 21 days.

All information disclosed during the course of the investigation is kept confidential, except as necessary to conduct the investigation and take any remedial action, in accordance with applicable law. Everyone working for or with the Company has a duty to cooperate in the investigation of reports of violations. Failure to cooperate in an investigation, or deliberately providing false information during an investigation, can be the basis for disciplinary action, including termination of employment. If, at the conclusion of its investigation, the Steering Committee (in consultation with the CEO) determines that a violation has occurred, the Company will take effective remedial action commensurate with the nature of the offense. This action may include disciplinary action against the accused party, up to and including termination. Reasonable and necessary steps will also be taken to prevent any further violations of Company policy.

COMMITTEES

Working Committee

A Working Committee is a committee of persons nominated / appointed to conduct a detailed investigation of the matter and submit a report. It comprises of a Compliance/Legal representative and a PPC representative (both at/above the level of Manager) to investigate and submit facts to the Steering Committee for decision making.

Steering Committee

A Steering Committee is a committee of persons nominated / appointed to give recommendations. The committee includes the Compliance/Legal Head, PPC Head and an external consultant (whenever required, whose appointment is approved by Compliance/Legal Head, PPC Head and CEO).

RETALIATION

No one may take any adverse action against any individual for complaining about, reporting, or participating or assisting in the investigation of, a reasonably suspected violation of any law, this Policy, or the Company’s Code of Conduct and Ethics. The Company takes reports of such retaliation seriously. Incidents of retaliation against any individual reporting a violation or participating in the investigation of a reasonably suspected violation will result in appropriate disciplinary action against anyone responsible, including possible termination of employment. Those working for or with the Company who engage in retaliation against reporting individuals may also be subject to civil, criminal and administrative penalties.