Whistleblower Policy

Purpose

The purpose of this policy is to:

• Encourage employees and stakeholders to report unethical behavior
• Provide a secure and confidential reporting mechanism
• Ensure protection against retaliation
• Promote accountability and ethical business practices

Scope

This policy applies to:

• Employees (permanent, temporary, interns)
• Directors and management
• Vendors, consultants, and business partners associated with ITLC India Pvt Ltd

Reportable Concerns

Whistleblowers can report concerns including but not limited to:

Reporting Mechanism

Any individual can report concerns through:

• Email: info@itlcindia.com
• Written complaint: Direct submission to the management

Reports should include sufficient details and evidence, where possible, to facilitate investigation.

Confidentiality

ITLC India Pvt Ltd ensures that all whistleblower reports are treated with strict confidentiality. The identity of the whistleblower will be protected to the fullest extent possible.

Protection Against Retaliation

The company strictly prohibits any form of retaliation against whistleblowers who report concerns in good faith. Any act of retaliation will be treated as a serious violation and may result in disciplinary action.

Investigation Process

• All reported concerns will be reviewed promptly
• A fair and unbiased investigation will be conducted
• Appropriate corrective actions will be taken based on findings

False Complaints

While the company encourages genuine reporting, any false or malicious complaints made intentionally may lead to disciplinary action.

Compliance

ITLC India Pvt Ltd ensures compliance with applicable laws and regularly reviews this policy to maintain effectiveness.