1. Purpose and Scope:
Savex Technologies Private Limited (“Savex” or the “Company”) is committed to conducting its business honestly, lawfully and ethically. This Policy provides a simple and confidential mechanism for reporting serious wrongdoing connected with the Company.
This Policy applies across India to all Savex offices, branches, warehouses, depots and other establishments, and to Company-related work performed remotely, during business travel or at customer, vendor or other business locations.
It may be used by directors, employees, trainees, interns, contract or agency personnel, consultants, vendors, suppliers, service providers, channel partners and other persons having a business relationship with Savex.
2. Matters that may be Reported:
A concern may be reported where there is a reasonable belief of actual or suspected serious misconduct, including:
❖ fraud, bribery, corruption, kickbacks or financial irregularity;
❖ theft, pilferage, falsification of records or misuse of Company money, inventory, property, systems or data;
❖ material violation of law, Company policy, internal controls or the Code of Conduct;
❖ conflict of interest, abuse of authority or misuse of position;
❖ serious health, safety or environmental violation;
❖ cybersecurity incident, unauthorised system access, personal data breach or misuse of confidential information;
❖ serious harassment, discrimination or unethical workplace conduct not required to be dealt with under another statutory process;
❖ retaliation against a person for raising or assisting with a genuine concern; or
❖ concealment, destruction of evidence or obstruction of an audit or investigation.
3. Matters handled under another process:
Routine employment grievances relating to salary, appraisal, attendance, leave, transfer, promotion, workload or similar service matters should ordinarily be raised with Human Resources or through the applicable grievance process. A complaint of sexual harassment shall be referred to the competent Internal Committee and handled under the Company’s POSH Policy and applicable law. Customer service, warranty and ordinary commercial disputes will be handled through the relevant business process unless they disclose fraud or serious
misconduct.
4. How to Report:
A concern may be reported by email to legal@savex.in or by a written complaint marked “Confidential Whistleblower Disclosure” and addressed to the Legal Department at the Company’s registered office.
The report should, as far as possible, state what happened, when and where it occurred, the persons involved and include any supporting documents or information available. A person is not required to prove the allegation before reporting it.
Anonymous reports may be examined where they contain sufficient specific information. Where a complaint concerns the Head of Legal or a member of senior management, it may be sent directly to the Managing Director or any Director authorised by the Company for this purpose.
5. Review and Investigation:
The Legal Department or another person authorised by the Company will make a preliminary assessment and determine whether the matter should be investigated, referred to as another internal process or closed for lack of sufficient information.
Any investigation will be conducted fairly, confidentially and without avoidable delay. A person who has a conflict of interest shall not participate. The person against whom an allegation is made will be given a reasonable opportunity to respond before an adverse conclusion is reached, unless immediate protective action is legally or operationally necessary.
The Company may seek assistance from Human Resources, Finance, Internal Audit, Information Security, external advisers or other appropriate persons. Depending on the findings, the Company may take disciplinary, corrective, contractual, civil, criminal or regulatory action in accordance with applicable law and Company procedures.
The reporting person may be informed that the matter has been reviewed or closed, but the Company is not required to disclose confidential investigation material, personal employment information or the details of disciplinary action.
6. Protection Against Retaliation:
No person shall be threatened, harassed, discriminated against, dismissed, demoted, transferred adversely, denied a legitimate benefit or otherwise victimised for making or assisting with a report in good faith.
Any suspected retaliation should be reported immediately to legal@savex.in or to the Managing Director. Retaliation will be treated as misconduct and may result in appropriate action.
Protection under this Policy does not prevent the Company from taking legitimate action for a person’s own misconduct, poor performance or other reasons unrelated to the report, provided such action is not retaliatory.
7. Confidentiality and Data Protection:
The identity of the reporting person, the person complained against, witnesses and investigation records will be kept confidential and shared only with persons who need the information for assessment, investigation, corrective action or legal compliance.
Absolute anonymity cannot be guaranteed where disclosure is required by law, necessary for a fair investigation or needed to protect persons or Company assets. Personal data and records under this Policy will be handled securely and in accordance with applicable privacy and information-security requirements.
8. False or Malicious Complaints:
No action will be taken merely because a report is not proved or is based on incomplete information. However, a person who knowingly makes a false or malicious complaint deliberately fabricates evidence or misuses the mechanism may face appropriate action after being given a fair opportunity to respond.
9 Records and Reporting to Authorities:
Reports and related records will ordinarily be retained securely for five years from closure, or for a longer period where required by law, litigation, audit, investigation or regulatory requirement. Records will be accessed only by authorised persons and securely disposed of when no longer required.
The Company may report suspected criminal conduct, fraud, corruption, data breach or other legal violation to the police, regulator or other competent authority where required or considered appropriate.
10. Administration and Review:
The Legal Department is responsible for administering this Policy and may issue practical procedures or reporting formats consistent with it. The Policy will be reviewed annually or earlier where required by a material change in law or business operations.
The Company may amend this Policy at any time. If any provision conflicts with mandatory law, the applicable law will prevail, and the remaining provisions will continue to apply.
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Document owner
Legal Department
Effective date
April 01, 2026
Policy version
2.0
Review cycle
Annually, and earlier
required due to any change in applicable law, regulatory direction.
Preamble
The Company believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behavior. Section 177(9) of the Companies Act, 2013 read with Rule 7 of the Companies (Meetings of Board and its Powers) Rules, 2014 provides that the Unlisted Companies which has accepted deposits from Public or the Companies which have borrowed money from banks and Public financial institutions in excess of rupees fifty crores shall establish a vigil mechanism for directors and employees to report their genuine concerns or grievances.
Purpose
The purpose of the policy is to provide adequate safeguards against victimization of Directors and employees who avail of the vigil mechanism and to provide direct access to the Chairman of Board / the Chairman of Audit Committee (as and when Audit Committee is established/ formed) to oversee the vigil mechanism in appropriate or exceptional cases.
Definitions
Company means SAVEX Technologies Pvt.Ltd.
Director means Director appointed to the Board of the Company.
Audit Committee means Audit Committee constituted by the Board of Directors.
Employee means every employee of the Company, including the Directors in the employment of the Company.
Whistle Blower means an employee making a protected disclosure under this policy.
Scope
The Policy covers disclosure of any unethical and improper or malpractices and events which have taken place/ suspected to take place involving:
- Financial irregularities and frauds
- Breach of Business Integrity and Ethics
- Manipulation of Company’s figures/data or statements
- Actual / suspected Fraud and corruption
- Abuse of Authority or dominant position
- Wastage or misappropriation of Company’s money or asset(s).
- Breach of terms and conditions of employment and rules thereof
- Deliberate violation of any laws/regulations
- Gross or Willful Negligence causing substantial and specific danger to health, safety and environment
- Pilferation of confidential/propriety information
- Unethical / Immoral Behavior
- Any other dishonest or unethical act causing substantial damage to the Company or its assets.
Every such disclosure can be termed as “Protected Disclosures”.
Procedure
All Protected Disclosures should be reported in writing by the complainant as soon as possible after the Whistle Blower becomes aware of the same and should either be typed or written in a legible handwriting in English. All Protected Disclosures should be addressed to the Chairman of the Board or Chairman of the Audit Committee of the vigil mechanism.
Decision And Reporting
If an investigation leads to a conclusion that an improper or unethical act has been committed, the Committee formed for the purpose, if any / Audit Committee shall recommend to the Board of Directors of the Company and if the investigation is carried by the Board of Director, they shall decide to take such disciplinary or corrective action as it may deem fit. Any disciplinary or corrective action initiated against the subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures. Board of Directors of the Company will be regularly updated on the progress of the matter in case of any events reported under this mechanism until the same is disposed off. A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the subject to the vigilance officer shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.
Protection
No unfair treatment will be meted out to a Whistle Blower by virtue of his/ her having reported a Protected Disclosure under this policy. Adequate safeguards against victimization of complainants shall be provided. The Company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. In exceptional or appropriate cases, Whistle Blower can directly approach to the Chairman of the Board. The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. Any other employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.
Retention Of Documents
All Protected Disclosures in writing or documented along with the results of investigation relating thereto which has been proved shall be retained by the Company for a minimum period of five years. Other Protected Disclosures may be destroyed at the end of the financial year.
Amendment
The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. The Board of Directors / Audit Committee will also review the Policy and suggest amendments to make it responsive and relevant to the changing times. However, no such amendment or modification or establishment will be binding on the Employees unless the same is notified to the Employees in writing or updated on the website of the Company.
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