Whistle Blower Policy

Effective Date: 01.12.2025

Background

Handmark (“the Company”) encourages all employees, consultants, contractors, partners, service providers, sellers, users, and any person associated with the Company (“Individuals”) to report, without fear of retaliation, any suspected misconduct or unethical behavior.

This Whistle Blower Policy (“Policy”) establishes a secure and confidential mechanism that enables Individuals to raise genuine concerns about improper conduct or practices that could adversely affect the Company, its employees, or its reputation.

Policy Objectives

The purpose of this Policy is to provide a structured channel for reporting concerns or complaints relating to:

• Violation of the Company’s Code of Conduct
• Breach of integrity or ethical standards
• Misuse or abuse of authority
• Fraud, intentional financial irregularities, or suspected fraud
• Deliberate violation of laws or regulations
• Gross negligence causing harm to health, safety, or the environment
• Manipulation or falsification of Company records or data
• Misappropriation or wastage of Company funds or assets
• Breach of confidentiality or unauthorized disclosure of proprietary information
• Workplace misconduct, including harassment, intimidation, or discrimination
• Any other act adversely impacting an Individual’s rights, safety, dignity, or ability to perform their duties effectively

This Policy does not release Individuals from their confidentiality obligations or permit malicious, false, or unfounded allegations.

Scope

This Policy applies to all employees, consultants, and contractors of Handmark, and covers concerns involving actual or suspected violations of law, breach of contract, misuse of authority, financial malpractice, or other unethical acts detrimental to the Company’s interests.

Definitions

• Code of Conduct: The official code of conduct of the Company.
• Complaint: A written concern raised in good faith that demonstrates information about an unethical or improper activity.
• Whistle Blower: Any Individual who raises a Complaint under this Policy.
• Subject: The person or persons against whom a Complaint is made.
• Whistle Blower Committee: The committee appointed by the Company to receive and investigate Complaints.
• Investigating Officer: The officer nominated by Management to conduct or assist in the investigation.
• Management: The management of the Company responsible for implementation and oversight of this Policy.

Reporting and Submission of Complaints

Complaints should be made in writing, duly signed, and submitted as soon as possible after the occurrence of the event. Anonymous or pseudonymous complaints will not be entertained.

The Complaint may be typed or handwritten (in English or Hindi) and must include:

• Name, designation, location, email ID, contact number, and address of the Whistle Blower
• Description of the concern, including relevant facts, dates, and individuals involved

Complaints should be sent via:

Email: whistleblower@handmark.in

Post:
The CFO
Handmark (Formerly known as Handmark and Swaraaj Ecosystem Private Limited)
Office No. 1201 & 1202, 12th Floor, Colonnade Building,
Above Kalki Showroom, Opp. Iscon BRTS Bus Stop,
Iscon–Ambali Road, Ahmedabad – 380054.

The Whistle Blower Committee will acknowledge receipt and may seek additional information if necessary.

Investigation

All valid Complaints will be recorded and investigated confidentially by the Whistle Blower Committee.

The investigation may include examination of documents, records, and interviews with relevant individuals. All persons are expected to cooperate with the investigation process.

The Subject(s) will normally be informed of the allegations and given an opportunity to respond.

The investigation shall be completed within 30 days of receipt of the Complaint, unless an extension is approved by Management.

Decision and Reporting

The Whistle Blower Committee shall prepare a written report of its findings and recommendations and submit it to Management within 30 days.

Based on the findings, Management shall decide on appropriate action or closure of the case, recording reasons for its decision.

Both the Whistle Blower and the Subject will be informed of the outcome, as appropriate.

Frivolous or malicious Complaints may result in disciplinary action against the Whistle Blower.

All records of Complaints, investigations, and actions taken shall be properly documented and retained.

Confidentiality

• Maintain strict confidentiality of all matters under investigation
• Refrain from discussing or disclosing details outside the official process
• Secure all documents and communications related to the case

Misuse of the Policy

This Policy is intended to address serious concerns and should not be used for personal grievances, routine administrative issues, or interpersonal conflicts that can be resolved through normal HR or management channels.

Misuse or deliberate false reporting under this Policy will result in disciplinary action.

Protection for Whistle Blowers

No Whistle Blower shall suffer retaliation, discrimination, harassment, demotion, or unfair treatment for raising a concern in good faith.

Any form of victimization or retaliation should be immediately reported to the Whistle Blower Committee, which will investigate and recommend corrective action.

The identity of the Whistle Blower shall be kept confidential to the extent possible. Unauthorized disclosure will attract disciplinary measures.

The same level of protection applies to any individual assisting in the investigation.

Communication

This Policy shall be made available on the Company’s official website and internal communication platforms.

Retention of Documents

All Complaints and related investigation reports shall be retained by the compliance department for a minimum period of five (5) years, or longer if required by applicable laws.

Administration and Review

The Whistle Blower Committee, in consultation with Management, shall be responsible for the administration, implementation, and periodic review of this Policy.

The Company reserves the right to amend or update this Policy to ensure continued compliance with legal and governance standards.