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iTechWorks Technology Solutions Private Limited

Whistleblower and Non-Retaliation Statement

Effective 08 September, 2018

Why Do We Have This Statement? We actively encourage Associates to report concerns and ask questions. Specifically, this Statement provides that:

  • Under the oversight of the iTechWorks Audit Committee, iTechWorks maintains a reporting system whereby iTechWorks Associates, as well as third parties (such as competitors, vendors, and consumers) can report suspected legal and ethical concerns, including those related to accounting, internal accounting controls, auditing matters, and corruption;
  • iTechWorks Associates and third parties may report their concerns confidentially and anonymously;
  • Reports of suspected violations of law, the Code, or other iTechWorks policies will be investigated;
  • iTechWorks is committed to protecting anyone that makes a report of a legal or ethical concern from retaliation, retribution, or harassment; investigating each complaint of retaliation; and taking appropriate disciplinary action for retaliation, up to and including termination of employment.

Reporting Suspected Violations of Law or Company Policies The Company provides a number of channels to make reports of actual or potential violations of the Code or of any applicable law. Associates may request guidance about how to comply with applicable law or the Code and report violations through any of the following channels:

  • Any member of the iTechWorks Legal Department

    By email: By using the Contact Us Portal at https://inettechworks.com

    By mail: By using the Address listed at https://inettechworks.com

  • Your local compliance resource
  • iTechWorks Helpline

The iTechWorks Helpline is available by phone or online. Reports may be made anonymously, where local laws allow. However, you are encouraged to identify yourself when making a report, so that additional information can be obtained if needed. Whenever possible and permitted by law, your identity will be kept strictly confidential.

  • To access the Helpline via the internet, go to the Contact Us Portal at https://inettechworks.com and follow the instructions for submitting a query/ report.
  • To make a report by telephone, use the contact number listed at https://inettechworks.com

Use the appropriate access code for your country.

Will the Information I Provide be Kept Confidential?

Associates who report a concern may choose to remain anonymous, although we encourage reporters to provide contact information to assist the Company in investigating reports. iTechWorks will keep reports confidential to the extent consistent with its ability to conduct a full and fair investigation and to comply with its legal obligations.

How are reports handled?

Any manager or other individual who receives a report of a violation or a possible violation should refrain from conducting their own investigation, and promptly forward the report to the Legal Department. iTechWorks will assign an experienced professional to investigate any known or suspected misconduct. Our experts will investigate professionally, and any appropriate corrective action will be taken with management oversight.

Protection Against Retaliation for Reporting Suspected Violations or Cooperating with Investigations iTechWorks does not tolerate retaliation against any individual who submits a good faith report of a violation or possible violation of law, the Code, or other iTechWorks policies. iTechWorks Associates must never intimidate, harass, or take any retaliatory action against a person who makes a report of a potential violation of law, regulation, the Code, other iTechWorks policies, or who cooperates with an investigation of any such report.

“Retaliation” includes, but is not limited to any adverse action taken against a person because he or she:

  • Submitted a report of a violation or suspected violation of the Code, other iTechWorks policies or procedures, or applicable law (including those regarding accounting irregularities);
  • Participated or provided information or otherwise assisted in an investigation of any suspected violation of the Code, other iTechWorks policies or procedures, or applicable law;
  • Provided truthful information to any regulatory or law enforcement agency regarding the commission or possible commission of any federal or state offense, or regarding potential violations of anti- corruption, workplace safety, anti- discrimination, anti-harassment, or other laws.

We Encourage Associates Who Believe They are the Subject of Retaliation to Report Violations Anyone who is the target of retaliation should promptly report it to one of the resources listed in the Code or in this Statement. Examples of prohibited retaliation, retribution, and harassment include:

  • Attempting to intimidate an Associate into withdrawing or altering his/her report;
  • Punishing a person who has made a good faith report by taking adverse action concerning the Associate’s work or shift assignments, salary, evaluation, vacation, and/or other terms of employment;
  • Terminating, demoting, suspending, or disciplining an Associate for making a good faith report;
  • Threatening to do any of the above.

Any Associate who witnesses or knows about any Associate retaliation, retribution, or harassment must make a report through one of the reporting channels set forth above.

iTechWorks Pledges to Appropriately Investigate Any Allegation of Retaliation. iTechWorks shall investigate each complaint of retaliation and, if any such retaliation claim is substantiated, take appropriate disciplinary action, up to and including termination of employment, and implement any appropriate remedial measures.

Who should I contact with questions? Questions regarding this Statement should be directed to the Legal Department or your local compliance resource.