Effivity Whistleblower Policy

 

Last updated on 16th of July 2025

 

1. Purpose

The purpose of this Whistleblower Policy is to provide a procedure for employees, contractors, and other stakeholders to report concerns about unethical, illegal, or improper conduct without fear of retaliation. This policy aims to ensure that such concerns are addressed appropriately and promptly.

2. Scope

This policy applies to all employees, contractors, consultants, and other individuals associated with Effivity Technologies Pvt Ltd.

3. Policy Statement

Effivity Technologies Pvt Ltd is committed to maintaining the highest standards of integrity and ethics in all its activities. Employees and other stakeholders are encouraged to report any concerns about unethical, illegal, or improper conduct, including but not limited to:

• Financial mismanagement
• Fraud or embezzlement
• Corruption
• Harassment or discrimination
• Violations of laws or regulations
• Breach of organizational policies

4. Reporting Procedures

4.1 Reporting Channels

To ensure concerns are addressed effectively, reports can be made through the following channels:

• Direct Reporting:
  1. Immediate Supervisor: Employees can report concerns directly to their immediate supervisor or manager.
  2. Human Resources Department: Reports can also be made to the Human Resources (HR) department for handling.
• Anonymous Reporting:
  1. Whistleblower Hotline: Concerns can be reported anonymously via the [Hotline Number/Service Name], which is available 24/7.
  2. Secure Email Address: Reports can be submitted anonymously to [secure email address] if preferred.
  3. Online Reporting System: Use the secure online platform at [website URL] to submit anonymous reports.

4.2 Information Required

When reporting a concern, please include as much information as possible, such as:

• Description of the Concern: Detailed account of the unethical, illegal, or improper conduct.
• Location and Date: Where and when the issue occurred.
• Individuals Involved: Names of individuals or groups involved in the conduct.
• Evidence: Any documents, emails, or other evidence supporting the report.
• Contact Information: While anonymous reporting is accepted, providing contact details may facilitate follow-up if the whistleblower is comfortable.

4.3 Reporting Process

1. Submission: Submit the report using one of the available reporting channels.
2. Acknowledgment: Upon receiving a report, Effivity Technologies Pvt Ltd will acknowledge receipt within [number] business days.
3. Initial Review: An initial review will be conducted to determine whether the concern warrants further investigation.
4. Investigation: If deemed necessary, a thorough and impartial investigation will be conducted by [designated investigation team/department].
5. Follow-Up: The whistleblower will be informed of the outcome of the investigation or the steps taken, to the extent permitted by confidentiality and privacy considerations.

4.4 Urgent or Serious Concerns

For concerns that are urgent or involve immediate risks, such as threats to health or safety, individuals are encouraged to report these issues immediately to emergency services or appropriate authorities.

5. Confidentiality

All reports will be treated with the utmost confidentiality. The identity of the whistleblower will be protected to the extent possible, and details of the report will only be disclosed on a need-to-know basis.

6. Protection Against Retaliation

Effivity Technologies Pvt Ltd prohibits retaliation against any individual who, in good faith, reports a concern or participates in an investigation. Retaliation includes any adverse action taken against the whistleblower, such as demotion, harassment, or termination.

7. Investigation Process

7.1 Acknowledgment of Receipt

Upon receiving a report, Effivity Technologies Pvt Ltd will:

• Acknowledge Receipt: Confirm receipt of the concern to the whistleblower within [number] business days, if contact information is provided.
• Initial Assessment: Conduct a preliminary review to determine whether the concern warrants a formal investigation.

7.2 Preliminary Review

• Scope and Nature: Assess the scope and nature of the concern to decide if it falls within the remit of this policy.
• Conflict of Interest: Identify any potential conflicts of interest among the investigation team.

7.3 Investigation

If a formal investigation is warranted:

• Investigation Team: Appoint a designated investigation team or individual with appropriate expertise, which may include HR personnel, legal counsel, or external investigators.
• Investigation Plan: Develop a plan outlining the steps and timeline for the investigation. This includes collecting evidence, interviewing witnesses, and reviewing relevant documents.
• Evidence Collection: Gather all relevant evidence, including documents, emails, and witness statements.
• Interviews: Conduct interviews with individuals involved, including the whistleblower (if known) and others who may have relevant information.

7.4 Resolution

• Findings: Analyze the collected evidence to determine the validity of the concern and the extent of any misconduct.
• Recommendations: Develop recommendations for corrective actions or disciplinary measures, if applicable.
• Report: Prepare an investigation report detailing the findings, conclusions, and recommendations. The report will be shared with relevant stakeholders, such as senior management or the board of directors, depending on the severity of the issue.

7.5 Communication

• Outcome Notification: Inform the whistleblower (if contact information is provided) of the outcome of the investigation, including any actions taken, to the extent permitted by confidentiality and privacy considerations.
• Follow-Up: Implement any corrective actions or improvements identified during the investigation. Monitor the situation to ensure that the issues have been effectively addressed.

7.6 Records and Documentation

• Record Keeping: Maintain comprehensive records of the investigation process, including evidence collected, interviews conducted, and final reports.
• Confidentiality: Ensure that all records are kept confidential and secure, with access limited to authorized personnel only.

8. Responsibilities

• Employees: Report concerns in good faith and cooperate with investigations.
• Supervisors/Managers: Ensure that concerns are reported and handled in accordance with this policy.
• Human Resources/Compliance Officer: Oversee the implementation of this policy, conduct investigations, and ensure compliance with this policy.