Philosophy

IDO Devices Pvt Ltd (hereinafter referred to as ‘IDO Devices’ or ‘Company’) believes that every employee and Founders of the Company must always conduct himself or herself in a professional, responsible, and ethical manner.

Purpose & Scope

The Whistleblower Policy (“Policy”) encourages Founders and employees of IDO Devices to promptly bring to the Company's attention, instances of illegal or unethical conduct, actual or suspected incidents of fraud, actual or suspected incidents of harassment at workplace, actions that affect the financial integrity of IDO Devices that could adversely impact the Company's operations, business performance and reputation.

IDO Devices will investigate such reported incidents in an impartial manner and take appropriate action to ensure that the requisite standards of professional and ethical conduct are always upheld.

Reporting Mechanism

• Complainant are encouraged to bring the attention of the IDO Devices incident pertaining to:
  1. Illegal or unethical conduct including that which adversely affects investors, shareholders, customers, suppliers, other employees, or the business performance or image or reputation of the Company
  2. Actual or suspected incidents of fraud
  3. Actions that affect the financial integrity of the Company
  4. Conflict of interest with the Company
  5. Disclosure of the Company's confidential or proprietary information
  6. Actual or suspected incidents of harassment at workplace
• The Complainant may send the complaint to the Whistleblower Complaints Committee* in writing, either by:
  1. Sending an e-mail to whistleblowing@idodevices.com or by
  2. Sending a letter sealed in an envelope (which is distinctly marked "Confidential"), to the following address:

*The following constitute the Whistleblower Complaints Committee (“Committee”) Members

• Complaints by or against Founders and members of the Whistleblower Complaints Committee (other than against the Chairman) shall be sent directly to the Chairman of the Whistleblower Complaints Committee, with a copy to the Directors of the Company / Board of Directors
• Complaint against the Chairman of the Whistleblower Complaints Committee shall be sent to the Board of Directors. If the Chairman of the Committee is not one of the Founders, then it may be sent to the founder not part of the Committee.
• Anonymous complaints are not encouraged. However, such complaints may be entertained if the complaint sets out specific allegations and verifiable facts and is accompanied with supporting evidence.
• Complaints that are mischievous, mala fide, made with oblique or ulterior motive and / or sans evidence shall not be covered under the purview of this Policy.
• To facilitate effective investigation, the complaint should be supported with documents evidencing the complaint and should include all relevant information about the incident as the complainant is aware of, including the following:
  1. Nature, period and other details of the incident including the location and business unit where such incident has occurred; and identity(ies) of the person(s) suspected to be involved in the incident.
  2. To facilitate investigation, complainants are encouraged to report incidents promptly upon becoming aware of the same, preferably within 30 days.

Investigation

• Complaints submitted via e-mail to the designated email address shall automatically be received by the Whistleblower Complaints Committee
• Upon receipt of a complaint within the scope of this Policy, the Whistleblower Complaints Committee shall review the same and if the complaint is found to be serious and credible, the Committee shall investigate such a complaint.
• For the purpose of conducting an investigation, the Whistleblower Complaints Committee is authorized to seek any information it requires from any employee, who shall cooperate with any such request made by the Committee, seek assistance from any employee for conduct of investigation, as may be considered appropriate obtain external legal or other independent professional advice and to secure the attendance of outsiders with relevant experience and expertise, if it considers necessary.
• The Whistleblower Complaints Committee can take decisions on further actions based on the investigation. A report shall be presented to the Board if the complaint is against a Whistleblower Complaints Committee member.
• Upon receipt of the investigation report and the recommendations of the Whistleblower Complaints Committee, the Board shall give directions for necessary actions to be taken.
• The information disclosed during an investigation, including the identity of the Complainant, shall be kept confidential, except as necessary or appropriate to be disclosed for the purpose of the investigation or where required by law.
• Any person against whom a complaint has been made shall recuse himself / herself from any investigating or reporting responsibility in connection with such complaint.

No Retaliation

• This Policy is intended to encourage, facilitate, and enable the raising of genuine concerns. No complainant who reports an incident under this Policy shall suffer any harassment, retaliation, or adverse employment condition because of such reporting.
• Any employee who retaliates against a person reporting a violation will be subject to disciplinary proceedings, which may extend to termination of employment.
• If any complainant is victimized or harassed for reporting any genuine concern, he / she may file an application before the Whistleblower Complaints Committee seeking redressal of the matter. The Whistleblower Complaints Committee shall take appropriate action to attend to the complainant's concern. However, if the complainant feels that his / her concern has not been addressed, he / she may approach the any founder, failing which the Chairman of the Whistleblower Complaints Committee.

Complaints to be made in good faith

• A complainant must act in good faith and have reasonable grounds for forming a belief that his or her complaint constitutes an incident within the purview of this Policy.
• This Policy should not be used as a tool for making false or mala fide allegations.
• Any person who is found to be making baseless, reckless, malicious or deliberately false allegations, shall be subject to disciplinary proceedings, which may extend to termination of employment.