Whistleblower Policy

Adopted by the Board of Directors of FinOne Industries India Private Limited on May 01 2023

Introduction

At FinOne Industries India Private Limited ("FinOne Industries India Private Limited"), a venture of the FINONE Group, we are committed to maintaining the highest standards of transparency, accountability, and ethical conduct. With operations spanning across 65 countries, we adhere to both local and international laws, ensuring our global compliance framework supports ethical practices worldwide. This Whistleblower Policy is designed to encourage and enable employees, stakeholders, and other associated parties to report genuine concerns about unethical practices or violations of company policies without fear of retaliation.

Objective

The primary objective of this policy is to:

1. Provide a structured framework for reporting concerns.

2. Protect whistleblowers from retaliation.

3. Ensure concerns are addressed promptly and effectively.

4. Uphold FinOne Industries India Private Limited's commitment to corporate ethics, integrity, and compliance.

5. Reinforce our commitment to international compliance standards, such as OECD Guidelines and UN Global Compact Principles.

Scope

This policy applies to:

• All employees (permanent, temporary, and contractual).

• Directors, suppliers, contractors, consultants, and other stakeholders associated with FinOne Industries India Private Limited.

• Any person who has knowledge of or suspects unethical practices, illegal activities, or policy violations.

Definitions

• Whistleblower: Any individual reporting a genuine concern in good faith.

• Reportable Concerns: Include but are not limited to:

  • Fraud, corruption, or bribery.

  • Financial mismanagement or manipulation.

  • Violation of company policies or ethical standards.

  • Harassment, discrimination, or other workplace misconduct.

  • Health and safety violations.

  • Environmental law violations.

Reporting Mechanisms

1. Dedicated Reporting Portal:

   • Employees and stakeholders must log in to the FinOne Industries India Private Limited Portal to access the Whistleblower Reporting feature.

   • The portal ensures secure and confidential submission of concerns.

2. Anonymous Reporting:

   • The portal also allows for anonymous submissions by disabling identity tracking during the reporting process.

3. Procedure for Reporting:

   • Log in to the portal using your credentials.

   • Navigate to the "Whistleblower Reporting" section.

   • Provide specific details of the concern (e.g., date, individuals involved, evidence).

   • Avoid baseless allegations to ensure the effectiveness of the process.

Training and Awareness

To ensure effective implementation, all employees will receive regular training on ethical practices, reporting mechanisms, and the importance of maintaining integrity in operations. Awareness programs will also be conducted to familiarize stakeholders with their roles and responsibilities under this policy.

Investigation Process

1. Acknowledgment: All complaints submitted via the portal will be acknowledged within five business days.

2. Preliminary Review: The Whistleblower Committee will conduct an initial review to determine the validity of the report.

3. Investigation:

   • Appointed investigators will handle the matter with strict confidentiality.

   • Investigations will follow applicable legal and ethical guidelines.

4. Resolution:

   • Upon conclusion, appropriate action will be taken, which may include disciplinary measures, legal proceedings, or policy changes.

5. Escalation: If the whistleblower feels the concern has not been adequately addressed, they may escalate the matter to the Board of Directors or an external legal authority as appropriate.

Protection for Whistleblowers

1. Confidentiality: The identity of the whistleblower will remain confidential unless legally required to be disclosed.

2. No Retaliation: Retaliation against whistleblowers is strictly prohibited. Any individual found guilty of retaliation will face disciplinary action.

3. Support: Counseling or additional support will be provided to whistleblowers if required.

Roles and Responsibilities

1. Whistleblower Committee:

   • Ensure the proper implementation of this policy.

   • Conduct impartial and thorough investigations.

   • Maintain detailed records of all complaints and resolutions.

2. Management:

   • Promote a culture of openness and accountability.

   • Take corrective actions as recommended by the Committee.

   • Monitor compliance across all operational regions.

3. Employees and Stakeholders:

   • Report genuine concerns promptly.

   • Cooperate with investigations, if required.

False Complaints

While the policy protects those who report genuine concerns, individuals knowingly making false accusations will be subject to disciplinary action, up to and including termination of employment or contract.

Review and Amendments

The Whistleblower Policy will be reviewed periodically by the Board of Directors or a designated committee to ensure its effectiveness and relevance. Amendments, if any, will be communicated promptly to all stakeholders.

Contact Information

For queries or additional information regarding this policy, please contact:

• Whistleblower Committee: Accessible via the FinOne Industries India Private Limited Portal