Whistle Blower Policy

Clicktech Retail Private Limited

CIN: U52500WB2021PTC250343
Registered Office: 18 Rabindra Sarani, Poddar Court, Gate No. 2, Ground Floor, Kolkata, West Bengal – 700001
Corporate Office: Prestige Sterling Square, Level 3, B Block, Next to Airlines Hotel, Shanthala Nagar, Ashok Nagar, Bengaluru – 560001, India
Email: legal@clicktechretail.com
Website: www.clicktechretail.com

Introduction

Clicktech Retail Private Limited (hereinafter referred to as the “Company”) believes in conducting its affairs in a fair, transparent, and ethical manner, guided by the highest standards of professionalism, honesty, and integrity.

All employees are expected to adhere to the Company’s Code of Business Conduct and Ethics and conduct themselves in an ethical and responsible manner at all times.

Employees and stakeholders are required to report any unethical behavior, fraud, or violations of the Code of Conduct that could impact the Company’s operations, performance, or reputation.

This policy ensures a transparent and secure mechanism for reporting such concerns and encourages individuals to speak up without fear of retaliation.

Terms and References

Whistleblower: Any employee (permanent or contractual), customer, vendor, or service provider who makes a Protected Disclosure.
Protected Disclosure: Any communication made in good faith that discloses or demonstrates information evidencing unethical or improper activity.
Reportable Matter: A genuine concern that may include, but is not limited to:
- Fraudulent practices or financial impropriety.
- Misuse or theft of Company assets, data, or funds.
- Corruption, bribery, or money laundering.
- Breach of Code of Conduct or employment terms.
- Violation of Company policies.
- Misappropriation or wastage of Company funds.
- Unauthorized disclosure of confidential or proprietary information.
- Harassment (including sexual harassment).
- Acceptance or offering of gifts or favors beyond Company policy limits.

Confidentiality

The Company shall make every effort to keep a Whistleblower’s identity confidential.

The Whistleblower will be informed if disclosure of their identity becomes necessary for investigation purposes.

To maintain the integrity of the process, the Whistleblower must also keep the matter confidential and avoid discussing it with others.

Reporting Mechanism

Whistleblowers should report any Reportable Matter promptly to enable early detection and corrective action.

The Company strictly prohibits retaliation against any individual who reports a concern in good faith.

Reporting Channels:

Email: clicktech@ethics-line.com
India International Toll-Free: 0008001004382
Alternate Contact: +91 11 71279005 / 0008001008277
Online: www.tip-offs.com

A Protected Disclosure should include:

Details of the suspected violation.
Names of persons involved.
Supporting evidence (documents, dates, etc.).
Time frame of occurrence.

The Company encourages detailed and fact-based reporting to facilitate effective investigation.

Investigation

Upon receiving a Protected Disclosure, the Board of Directors will appoint a Whistle Blower Committee, consisting of:

Group Legal Head
Group Head of HR
Two other members as nominated by the Board

If any member is implicated in the complaint, alternate members shall be appointed.

The Committee will:

Conduct a fair and confidential inquiry.
Provide an opportunity for all parties to present their views.
Submit a report of findings and recommendations to the Board.

The Board will take appropriate action, including disciplinary or legal measures if violations are confirmed.

Providing false information or failing to cooperate during investigation may result in disciplinary action.

No Retaliation

The Company ensures zero tolerance for retaliation.

No one shall take adverse action against a Whistleblower for reporting a suspected violation or assisting in an investigation.

Any act of retaliation will result in strict disciplinary action, including termination or legal proceedings.

Document Retention

All Protected Disclosures and investigation reports will be retained by the Company for a minimum period of eight (8) years.

Disqualifications

While genuine Whistleblowers are protected, false or malicious allegations are subject to disciplinary action.

The protection under this Policy is not extended to individuals who abuse the reporting process.

Amendment to the Policy

The Company reserves the right to amend or modify this Policy at any time to ensure compliance with applicable laws and organizational requirements.

Clicktech Retail Private Limited