ESDS Whistleblower Policy

Process

All the employees of this firm are encouraged to use the directions under this policy for reporting or raising complaints against improper activities in accordance with the following:

Policy Administration

The board of Directors appoints a particular individual who is the ‘Whistle Blower Administrator’, and his/her prime responsibility is to administer the company’s Whistle Blower Policy. The Whistle Blower Administrator’s reporting will be direct to the Audit committee in case any issues arise under this policy. The responsibilities of the Whistle Blower Administrator are as follows:

• Implementing, overseeing and administrating the policy.
• The necessary steps should be taken when the improper activities are reported, and those reports should be collected, reviewed and treated in a proper manner.
• The Whistle Blower Administrator should be available to discuss with the employee/s the compliant raised or reports filed.
• Notify the employee responsible for raising the complaint about receiving the report about the suspected violation.
• The reports should be promptly investigated, and appropriate disciplinary action should be taken.
• Submission of reports should be confidentially and anonymously when those are being sent to the higher authorities.

Requirements for Reporting

If any improper activities are noticed by an employee/s, then it is essential to report and raise a complaint against the wrongdoer. Reports can be submitted confidentially and anonymously. These reports can be written or can be either mailed to the Whistle Blower Administrator in the form of online or offline means. It is highly essential to keep these reports factual rather than being just speculative, and the proof should be submitted accordingly. Employee/s who wishes to raise a complaint should specify why the actions taken by another employee were improper and try to include name, date, place, address, events that took place in the report. Employee/s should not conduct their own investigation and obtain evidence which they do not have access to report a complaint. If any employee/s submits a report on an anonymous basis, then it is essential that the reporting employee/s present sufficient evidence of the improper activity. Broad allegations or insufficient evidence may not lead to an investigation.

Process to report improper activities

To submit a report of an inappropriate action, an employee can send an email to the authorities of the Auditing Committee with or without disclosing his/her identity. In case of sending an anonymous mail, the employee can submit their report by mailing on [email protected] and [email protected] which will be received directly by the Whistle Blower Administrator. Complaints which include any wrongdoing in the accounting or auditing matters should be submitted directly to the Auditing Committee. In case an employee feels that he/she could engage face-to-face in a conversation with the Whistleblower Administrator – Mrs Komal Somani, CPO, ESDS, then that option is available, and that action will be entertained if the employee feels that the matter is of urgency and needs quick attention. This process is primarily for the employee/s of the company who wants to raise complaints or feels that the previous complaints which were raised are not appropriately handled or resolved.

Final Decision

When the Whistle Blower Administrator concludes that an improper activity has been committed after a thorough investigation, then the Audit Committee should take disciplinary actions which deem fit. When an action has been initiated on the person responsible for misconduct, then it is expected that he/she should adhere to the application disciplinary action.

Document Retention

The company needs to retain the written documents along with the problem results for a minimum period of 3 years.

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Process for Non-Employee Stakeholders

In case a Non-Employee Stakeholder wants to report an improper activity, then, in that case, he/she should mail directly to the authorities of the auditing committee or the ethics committee, with or without disclosing his/her identity. The ethics committee can receive the complaint through offline means like the post, courier, telephonic call, written or oral communication. Charges which include any wrongdoing in the accounting or auditing matters should be submitted directly to the Auditing Committee. Accordingly, the chairman of the committee will work under the guidance of Whistle Blower Administrator when the complaint has been received through online or offline means. This process is primarily for the Non-Employee Stakeholder to raise complaints or check the status on previously raised issues or complaints.

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Employee Protection

• When an employee reports an improper activity, he/she will be protected against any type of discrimination including compensation or terms of employment and threats like retaliation or discharge. In case the employer refuses to take any action against the employee’s report, it will be constituted as corporate fraud or violation of the law.
• If any other employee assists in the investigation, then he/she should also be protected in the same extent as the Whistle Blower. Employee/s who reports unethical activities and provide evidence which they know are false, will not be protected by the authorities or the above statement and will be subject to legal and disciplinary actions.

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Amendments

ESDS’ Whistleblower policy is modified from time to time, and the Board of Directors must approve any amendments to the guidelines or procedures and communicate to the employees respectively.