Whistleblower Policy

 Whistleblower Policy for SYNTARION INDIA CONSULTING PRIVATE LIMITED, operating under the brand Moiret. This policy complies with Section 177 of the Companies Act, 2013 and aligns with global governance principles, such as those recommended by SEBI and OECD.

WHISTLEBLOWER POLICY

Effective Date: 09-06-2025
Last Updated: 08-06-2025

1. Purpose

The purpose of this Whistleblower Policy is to provide a safe and confidential mechanism for employees, directors, and stakeholders of SYNTARION INDIA CONSULTING PRIVATE LIMITED ("Company", "we", "us", or "our") to report concerns about unethical behavior, actual or suspected fraud, or violations of the Company’s Code of Conduct or applicable laws.

2. Objective

This policy aims to:

• Encourage employees and other stakeholders to raise serious concerns without fear of retaliation;
• Establish a formal process for receiving, investigating, and resolving reported concerns;
• Promote integrity, accountability, and lawful conduct in all company operations.

3. Applicability

This policy is applicable to:

• All employees (permanent, temporary, contractual);
• Directors, officers, interns, and consultants;
• Vendors, suppliers, customers, and other business partners.

4. Reportable Matters

Whistleblowing may relate to, but is not limited to, the following:

• Financial fraud, embezzlement, or accounting irregularities;
• Insider trading or misuse of confidential information;
• Corruption, bribery, or unethical business practices;
• Harassment or discrimination;
• Violations of environmental, data, or labor laws;
• Gross mismanagement or serious health/safety risks;
• Breach of Company’s Code of Conduct or Ethics Policy.

5. Good Faith Requirement

Whistleblowers must act in good faith, with reasonable belief that the information disclosed indicates misconduct or a violation. Allegations with malafide intent or knowingly false reports will lead to disciplinary action.

6. Protection from Retaliation

The Company strictly prohibits retaliation or victimization of whistleblowers. Any employee or official found retaliating will face disciplinary or legal consequences.

Protection under this policy includes:

• Anonymity (if requested);
• Protection against demotion, suspension, threats, or harassment;
• Assurance that the whistleblower’s identity will be kept confidential to the extent possible.

7. Reporting Mechanism

Concerns can be reported via any of the following:

Email: supports@moiret.com
Subject Line: “Whistleblower Complaint – Confidential”
Grievance/Whistleblower Officer: [Insert Officer’s Name]
Mailing Address:
SYNTARION INDIA CONSULTING PRIVATE LIMITED
2nd Phase Gokula Ext., Kyathsandra, Tumkur City, Tumkur, Karnataka

Anonymous complaints will be accepted but must include sufficient information for proper investigation.

8. Investigation Process

• All reports will be acknowledged within 5 working days;
• A preliminary assessment will be conducted to determine the validity;
• If warranted, a formal internal or third-party investigation will follow;
• Findings and recommended actions will be submitted to senior management or the Audit Committee;
• The whistleblower may be informed of the outcome, subject to confidentiality constraints.

9. Recordkeeping and Confidentiality

• Records of complaints, investigation findings, and resolution steps will be securely maintained;
• All documents will be retained for a minimum of 8 years or longer where legally required;
• Confidentiality of the whistleblower and accused shall be respected at all times.

10. Roles and Responsibilities

• Whistleblower Officer / Compliance Officer: Oversees policy implementation and report handling;
• Audit Committee (if constituted): Receives and reviews significant complaints;
• HR Department: Assists with disciplinary action and ensures non-retaliation.

11. False Allegations

Deliberate false reporting, made with malice or for personal gain, is a violation of this policy and will result in strict action, including possible termination or legal prosecution.

12. Policy Communication

This policy will be:

• Shared with all employees upon joining;
• Published on the Company’s internal platform and/or website;
• Reviewed annually for legal and operational updates.