XEBIA PRIVATE LIMITED, WHISTLEBLOWER POLICY
Effective Date of Current Policy: February 12, 2021
Xebia believes in the conduct of affair of its constituents in a fair and transparent manner by adopting
highest standards of professionalism, honesty, integrity, and ethical behaviour. This policy is in line
with the Xebia Code of Conduct which lays down principles and standards that govern actions of all
employees. Any action or potential violation of the Code, or violation of the law would be a matter of
serious concern for Xebia.
This policy will be applicable to all employees or any other person associated with Xebia IT Architects
India Pvt. Ltd. who can make Protected Disclosure under this policy.
The Whistle Blower’s role is of a reporting party with a reliable information about illegal acts,
violation of the Code of Conduct, or unethical acts committed by company officials. Whistle Blowers
are not required or expected to act as an investigator or finders of facts, nor they determine
appropriate corrective or remedial actions that may be warranted in a given case.
Examples of Reportable Conduct include but are not limited to:
2. Whistle Blowers should not act on their own in conducting any investigation activities, nor do they
have right to participate in any investigative activities other than requested by the Core Committee.
3. Protected Disclosure will be appropriately dealt with by the Core Committee, as the case may be.
The Committee for all investigations and decisions under Whistle Blower is as mentioned below:
If an investigation leads the Core Committee or a suitable nominated person to conclude that an
improper and unethical act has been committed. The Core Committee or a suitable nominated
person will recommend to take such disciplinary or corrective action as the Core Committee may
deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject as
result of the finding of an investigation pursuant to this policy shall adhere to the applicable
personnel and disciplinary procedures. The final decision of the Committee will be announced to
the Whistle Blower on the discretion of the committee.
All Protected Disclosures in writing or documented along with the results of the investigation
relating thereto shall be retained by the Company for a minimum period of 5 years.
Xebia reserves its right to amend or modify the policy in whole or in part, at any time without
assigning any reason whatsoever. However, no such amendment or modification will be binding
on employees unless the same is notified to the employee in writing.
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