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TSS-HR-06 · People & workplace

Whistleblower Policy

How to report illegal, dishonest or dangerous conduct safely, with protection from retaliation.

Version 1.0 · Effective 1 September 2026

Whistleblower Policy

If you see something illegal, dishonest or dangerous happening at TSS, we want to know about it. This policy explains how to report it safely, and promises that you will not be punished for doing so honestly.

Document

Policy number

TSS-HR-06

Version

1.0

Effective from

1 September 2026

Next review

March 2027

Owner

Board of Directors

Approved by

Board of Directors

Applies to

Anyone who works or has worked with TSS: every employee, trainee and intern (including interns under 18), contractors and former employees.

Issued by

Thakur Systems & Structures Private Limited, CIN U62011PN2026PTC254650

Related policies

Code of Conduct and Ethics (TSS-HR-01), Anti-Harassment and Non-Discrimination Policy (TSS-HR-02), Employee Grievance Policy (TSS-HR-09), Incident Response Policy (TSS-IT-05)

1. WHAT YOU CAN REPORT

Anything you honestly and reasonably believe is wrong, for example:

fraud, theft, bribery or corruption;

false accounts, invoices, test results or reports;

breaking the law, including labour, tax, data protection or company law;

misuse of client or personal data, or covering up a data breach;

security problems being deliberately ignored;

danger to anyone’s health or safety;

harassment or discrimination (you can also use the Anti-Harassment and Non-Discrimination Policy);

a Director or manager abusing their position;

anyone being punished for raising a concern;

any attempt to hide any of the above.

Personal complaints about your own pay, workload or working relationships usually belong under the Employee Grievance Policy. If you are not sure which to use, report it anyway and we will make sure it goes to the right place.

2. HOW TO REPORT

Use whichever route you are most comfortable with:

The HR team.

A Director.

The Chairman of the Board of Directors, especially if your concern involves the HR team or a Director.

Report in writing, by email or letter, or ask for a meeting. Say what happened, when, who was involved, and what evidence there is. You do not need proof; a reasonable belief is enough. Do not investigate on your own, and do not collect evidence in ways that break the law or our policies.

Anonymous reports. You can report anonymously, for example by letter. We take anonymous reports seriously, but they are harder to look into because we cannot ask you questions. If you give your name, we will protect it (section 4).

3. WHAT HAPPENS NEXT

We acknowledge your report within two working days, unless it was anonymous.

Someone independent of the matter reviews it and decides how to investigate. Nobody who is the subject of a report will handle it or be told who made it.

We aim to finish the investigation within 30 days, or to tell you why it is taking longer.

We tell you when the investigation is complete, and as much about the outcome as we can without breaching anyone else’s confidentiality or the law.

If wrongdoing is found, we act on it. That may mean fixing a process, taking disciplinary action, or reporting the matter to the authorities where the law requires it.

4. HOW YOU ARE PROTECTED

Confidentiality. Your identity is shared only with the people who need to know it to investigate, and only with your agreement, unless the law requires otherwise.

No retaliation. Nobody will be dismissed, demoted, disciplined, harassed, left out or treated unfairly in any way for reporting a concern in good faith, even if the concern turns out to be mistaken. Retaliation is gross misconduct.

If it happens anyway. If you are treated badly because you reported something, tell the Chairman of the Board of Directors straight away.

If you were involved. If you took part in the wrongdoing yourself, the fact that you reported it will count in your favour.

5. REPORTS MADE IN BAD FAITH

Knowingly making a false report, to harm someone or for personal gain, is misconduct. Being honestly mistaken is not.

6. GOING OUTSIDE TSS

We hope you will raise concerns with us first, so that we can put things right. But nothing in this policy, your Employment Agreement or your Confidentiality and Non-Disclosure Agreement stops you from reporting a possible crime or breach of the law to the police, a regulator or a government authority, or from getting legal advice.

7. RECORDS AND OVERSIGHT

Reports and investigations are recorded confidentially. At least once a year, the Board of Directors reviews a summary of the reports received and what was done about them, without names where confidentiality requires it.