Whistleblower Policy

1. PURPOSE

This Whistleblower Policy provides a mechanism for employees, contractors, and partners to raise genuine concerns about misconduct, fraud, illegal activity, or breaches of Individual ( Sujeet Uttam Hankare ) policy — safely and confidentially.

2. SCOPE

This policy applies to all employees, contractors, partners, vendors, and third parties associated with Sujeet Uttam Hankare.

3. WHAT CAN BE REPORTED

• Financial fraud, misappropriation, or falsification of records
• Bribery, corruption, or kickbacks
• Misuse of the device locking platform for illegal purposes
• Data breaches or misuse of customer/partner data
• Violation of RBI, NBFC, or consumer protection regulations
• Workplace harassment, including sexual harassment
• Any other serious breach of law or Individual policy

4. HOW TO REPORT

• Email: info@myemilocker.com (marked "Confidential – Whistleblower")
• Anonymous reporting: Reports may be submitted anonymously; however, anonymous reports may limit our ability to investigate fully
• Reports can also be submitted in writing to the Compliance Officer at our registered office

5. INVESTIGATION PROCESS

• Acknowledgement within 5 business days of receipt
• Investigation completed within 60 days (extendable for complex cases)
• Reporter kept informed of progress where identity is known
• Findings shared with the Board / Audit Committee as appropriate

6. PROTECTION AGAINST RETALIATION

Any person who raises a concern in good faith under this policy is protected from retaliation, discrimination, or adverse employment action. Retaliation is a serious violation and will result in disciplinary action up to and including termination.

7. CONFIDENTIALITY

The identity of the whistleblower will be kept confidential to the fullest extent possible, consistent with the need to conduct a proper investigation.

8. GOOD FAITH REQUIREMENT

This policy is intended for genuine concerns. Malicious or frivolous reports made in bad faith may result in disciplinary action against the reporter.

9. CONTACT