Whistle Blower Policy

Cyfuture

Methodology:

All the employees of the organization are educated about these guidelines and can use the procedure under the policy for reporting unethical activities.

Policy Administration:

The assigned authority of our organization appoints an individual, the ‘Whistle-Blower Administrator’. The prime obligation of the WBA is to monitor the organization’s Whistle Blower Policy. The Whistle Blower Administrator holds the account for direct communication with the Audit Committee in any scenario falling under the policy.

The responsibility and functionality of the Whistle Blower Administrator are listed below:

• Resolving, supervising and authorizing all situations falling under the policy.
• Reporting the required initiative to be taken in case of reporting of unethical activity. The report should be gathered, monitored and processed in the formulated manner.
• The availability of Whistle Blower Administrator is mandatory, in the hour of discussion with the employee regarding the registration of complaint.
• Informing the employee of an organization who is liable for raised complaint about the report of questionable infringement.
• The report should be monitored on an urgent basis and corrective actions are required to be taken.
• Confidentially should be maintained for the generated report during the process of transfer to superior jurisdiction.

Provisions for reporting:

In case of unethical activities, if witnessed by an employee/s, the need to raise a complaint is prominent. The submission of the report can be administered with an anonymous tag for maintaining confidentially. The submission of the raised complaint can be done in two ways i.e; either offline or online, directly to the account of Whistle Blower Administrator. The report should be based on factual proofs rather than false speculations. The reasons regarding the raising of the complaint should be clear enough, encompassing the complete set of data including name, date, place and immoral act. Employees are not allowed to carry out their own process of inquiry and judgement. If the employee/s want to maintain the submission as anonymous, then it is necessary to present an excellent set of evidence pertaining to the raised complaint. The process of inquiry and judgement can be adjourned, if the evidence presented is insufficient in nature.

The process of reporting unethical activities:

To submit a report of an irrelevant activity, an employee/s can send an email or hard copy to the superior officials of the Auditing Committee, as an open agenda or anonymously. In case of registering an anonymous mail, the employee/s can submit their report by mailing on [email protected], which will be directly monitored by the Whistle Blower Administrator. If the employee feels an urge for direct communication with the Whistle Blower Administrator, the person can contact Manish Agrawal. This methodology is basically applicable for employee/s of the organization, who want to highlight a report if they feel that the previous report was not handled judiciously.

Conclusive decision:

When the Whistle Blower Administrator delivers its judgement with an affirmation of the commitment of unethical activity after the complete process of investigation, then the Audit Committee enforces disciplinary action against the convicted person or team. After the process of disciplinary action, the convicted person is expected to adhere to the judgement.

Document detention:

Cyfuture will detain the set of documents for a minimum time span of three years.

The process of reporting for non-employee stakeholders:

If a non-employee stakeholder wants to report an unethical activity, in that scenario, the person is required to mail the issue directly to the respective organized authorities of the auditing committee, either with self-information or anonymously. The committee is capacble of accepting the complaint through offline means like posted documents and letters, national and international parcels, phone calls and verbal communication. Complaints regarding false means in auditing are to be submitted as a report directly to the Auditing Committee. Accordingly, the officials of the authorized committee will perform their role under the Whistle Blower Administrator. This process is exclusively for any Non-Employee Stakeholder to submit complaints and check the status of previously reported complaints.

Employee insurance:

• When an employee/s raises the report for an unethical activity, he/she will be provided with insurance against charges of inequity, comprising the allowance or terms and policy of employment and menaces like retribution or laying off. If the organization and its authority refuse to take any disciplinary action against the employee’s raised report, it will be considered as corporate fraud, and a violation of the law of the land.
• If any fellow employee is assisting in the process of inquiry, then he/she would also be provided with insurance in the equivalent degree as the Whistle Blower. Employee/s who raise the report for unethical practices and deliver the evidence and proofs which are proved false, will not be preserved by the official and authorities.

Reforms:

Cyfuture’s Whistleblower policy is kept up to date and amended at regular intervals, and the Board of Directors must affirm any amendments and reforms to the codes or protocols and relate them to the employees proactively.