Whistleblower Policy

Purpose and Scope

Lovexa is committed to the highest standards of ethics, integrity, and legal compliance in all our operations. Our Whistleblower Policy provides a safe and confidential channel for individuals to report any concerns about unethical, fraudulent, or illegal activities related to Lovexa. This policy applies to everyone connected with Lovexa – including full-time and part-time employees, contractors, consultants, vendors, partners, and even customers or other external stakeholders who might observe wrongdoing involving Lovexa. We encourage anyone who becomes aware of questionable conduct to speak up without fear.

This policy fulfills the role of a “vigil mechanism” as required under Indian law (such as Section 177 of the Companies Act, 2013 for applicable companies) and is aligned with global best practices for whistleblowing systems. Simply put, if you see something wrong, this policy tells you how to safely report it and guarantees that you will be protected when you do.

Reportable Concerns

A whistleblower report may cover any suspected misconduct, including but not limited to:

• Financial Fraud or Malpractice: For example, falsification of financial records, accounting irregularities, corruption, bribery, embezzlement of funds, or misuse of company assets.
• Legal or Regulatory Violations: This could include insider trading, data privacy breaches, violation of competition laws, environmental non-compliance, or any breach of laws/regulations applicable to Lovexa’s business in any country of operation.
• Ethical Violations: Activities that, while not necessarily illegal, violate Lovexa’s Code of Conduct or core values. For instance, conflicts of interest being concealed, accepting kickbacks from suppliers, or unethical procurement practices.
• Workplace Misconduct: Such as harassment (sexual or otherwise), discrimination, bullying, safety violations, or substance abuse on company premises. (Note: Lovexa has separate detailed policies for harassment and HR grievances, but if normal channels are not effective or if an employee fears retaliation, the whistleblower channel is an appropriate escalation path.)
• Gross Mismanagement or Abuse of Authority: Actions by senior staff that amount to gross mismanagement, abuse of power, or willful neglect of duty that could harm the company’s interests or employees’ well-being.
• Any other behavior that could cause serious reputational harm or financial harm to Lovexa or its stakeholders.

It’s important to note that this channel is not for petty grievances or personal disputes that can be handled through normal managerial or HR channels. It’s meant for significant concerns in the public interest or the company’s integrity. If you’re unsure, err on the side of reporting – our team can route issues to the right department if needed.

Reporting Channels

Lovexa provides multiple channels to report whistleblower complaints. Choose the one you are most comfortable with:

• Dedicated Whistleblower Email: You can send a detailed email to [email protected]. This inbox is monitored by Lovexa’s Ethics & Compliance Officer (or a designated Whistleblower Committee). Access is restricted to protect confidentiality.
• Whistleblower Hotline: We have established a phone hotline at [Phone Number] which is available [24/7 or during business hours] for reporting. You may be prompted to leave a voicemail or speak to an independent operator. You can choose to remain anonymous (see anonymity section below).
• Online Reporting Form: On Lovexa’s intranet (for employees) and website (for external stakeholders), there is a secure Whistleblower Report form. This form does not log your identity unless you choose to provide it. It goes directly to the Ethics & Compliance team.
• Postal Mail: If you prefer, you can mail a written complaint. Address it to “Confidential – Whistleblower Report, Attn: Ethics & Compliance Officer” at our corporate office address (listed on our website). Only authorized personnel will open such mail.

Employees also have the option, where appropriate, to directly approach a trusted manager or the HR department. Managers who receive whistleblower-type complaints are obligated to escalate them to the Whistleblower Committee while protecting the reporter’s identity.
If the concern implicates top management or the usual recipients of whistleblower reports, you may directly address your complaint to the Chairperson of the Audit Committee of Lovexa’s Board of Directors (this is specifically allowed under law for serious cases). The contact details for the Audit Committee Chair (or an external ombudsperson, if appointed) are provided in the internal employee handbook and can be furnished upon request by any employee.

Anonymity and Confidentiality

Lovexa accepts anonymous reports. While we encourage reporters to identify themselves (because direct communication can aid investigation), it is not mandatory. Anonymity might slightly constrain our ability to seek clarification, but we would rather have an anonymous tip than silence about a serious issue. If you choose to remain anonymous, please provide as much detail and evidence as possible, since we won’t be able to reach back out for more information easily.

For those who do identify themselves: your identity will be kept strictly confidential by the Whistleblower Committee. The information will only be shared on a need-to-know basis to investigate and resolve the issue. Typically, this might involve a small investigative team or external experts. We will never reveal the identity of a whistleblower to the implicated individuals or to anyone else beyond the investigative group, unless required by law. Even if the investigation eventually leads to legal proceedings or disciplinary action, we will discuss with you how to handle your identity. In Indian context, law enforcement may need a witness statement for criminal matters – we will support you through that process, but the decision to proceed is yours.

All written reports, emails, and documents related to whistleblower cases are kept secure. They are stored in a manner that maintains confidentiality (for example, encrypted digital files or locked physical files) and access is limited.

Protection Against Retaliation

Lovexa strictly prohibits any form of retaliation against anyone who in good faith reports a concern or assists in an investigation. “Retaliation” includes adverse actions like firing, demotion, harassment, transfer to an undesirable position, pay cut, threats, or blacklisting the individual in the industry. It also includes subtle actions that create a hostile environment for the whistleblower.

If you believe you are facing retaliation for having reported something, report that as well – either through this whistleblower channel or directly to a high-level authority (such as the Audit Committee or even regulatory authorities if needed). Any employee, including managers or senior executives, found to have engaged in retaliation will face serious disciplinary action, up to and including termination of employment. Lovexa is committed to ensuring that speaking up is safe.
To facilitate non-retaliation:

• We often handle investigations discreetly so that the source of information isn’t obvious. (For example, when investigating, we might act on the information in a way that doesn’t point back to a single whistleblower source, when possible.)
• We may, in consultation with the whistleblower, reassign or restructure reporting lines temporarily if needed to protect them during and after an investigation (e.g., if you reported on your direct supervisor, we can arrange that you don’t continue to work under that person during the review).
• Retaliation can be reported even if it occurs much later; our policy of protection isn’t time-limited.

Remember, the intention is to protect good faith reporters. If a subsequent investigation reveals that a report was knowingly false and made with malicious intent, that is not protected and will be treated as a serious disciplinary matter (false accusations can destroy reputations unjustly). However, if you reported something that you believed to be true at the time, you are protected even if the investigation doesn’t substantiate the concern.

Investigation Process

When a whistleblower report is received, the following steps generally occur:

1. Initial Triage: The Ethics & Compliance Officer (or Whistleblower Committee) will log the report and do a preliminary assessment. They will assign a reference number to the case. If the report is incomplete or unclear, and if the reporter’s identity is known, they may reach out for more details. If it’s anonymous, they’ll proceed with what’s provided.
2. Assigning Investigators: Depending on the nature of the complaint, an investigator or investigative team will be appointed. This could be internal (for example, someone from internal audit for a finance issue, or HR for a harassment claim) or external (an independent firm or legal counsel, especially if high-level executives are involved to avoid conflicts of interest). The key criteria for investigators are that they must not have any stake in the outcome and must be skilled in handling such inquiries. In some cases, particularly those involving senior management or potential criminal activity, the Audit Committee of the Board will oversee the investigation directly.
3. Investigation: The investigators will conduct a thorough review. This might include interviews with relevant parties (witnesses, the individuals accused of wrongdoing, etc.), review of documents and emails, access logs, financial audits, or whatever is necessary to get to the facts. They will do so discreetly and fairly. The whistleblower’s input may be sought if more information is needed (assuming they are not anonymous and are open to discussion). Whistleblowers may also be asked to provide any evidence they have or to clarify certain points.
4. Documentation: Throughout the process, careful documentation is maintained. This includes a record of all steps taken, evidence gathered, and interview summaries. This is important for transparency and for any future legal or regulatory scrutiny.
5. Conclusion and Report: Once the investigation is completed, the investigators will compile a report of their findings. The report will detail whether the allegation was substantiated, partially substantiated, or unsubstantiated. It will also provide recommendations for action (if any). For instance, if fraud was confirmed, the recommendation might be to take disciplinary action against the perpetrator, recover losses, and perhaps report to law enforcement. If a policy weakness was identified, the recommendation could include strengthening internal controls or changing procedures.
6. Decision and Action: The Whistleblower Committee or appropriate senior management (or the Board, for very significant cases) will review the investigation report and decide on next steps. Actions can range from internal disciplinary measures (warning, suspension, termination) to legal action (filing a police report, suing for damages) or regulatory self-reporting (informing authorities of a violation). In cases of lesser issues, action might simply be coaching or training or a policy update.
7. Feedback to Whistleblower: If the whistleblower’s identity is known, and they have indicated willingness to be kept informed, we will provide feedback at the conclusion of the investigation. Due to privacy considerations, we might not be able to share every detail (“who said what” or specific HR actions against individuals), but we will indicate the outcome generally (for example, “Your concerns were validated and appropriate action has been taken” or “Our investigation did not find evidence to support the allegation” or “We have taken steps to address the issue you raised”). We find it important to close the loop so that reporters know their voice was heard.
8. Closure and Record-Keeping: The case will be marked closed and records filed securely. We also analyze whistleblower reports annually (in aggregate) to identify any patterns or areas of risk that need systemic improvements.

Good Faith and Fairness

We stress that whistleblowers should report in good faith. This means you genuinely believe the information you are reporting is true and concerning. You do not have to have irrefutable proof – if you have a reasonable basis to suspect a problem, that’s enough to trigger a report. We will handle the evidence gathering.
Lovexa will ensure fairness for all parties. This includes:

• Treating implicated individuals as “innocent until proven otherwise.” Accusations are allegations until the investigation is complete. We will give those accused an opportunity to respond or explain as part of the investigation.
• If an allegation is not substantiated, we will strive to repair any potential damage to wrongly accused persons’ reputations (for example, if someone was unjustly suspected and word got out, we will clarify the misunderstanding internally as appropriate).
• Whistleblowers are not investigators – you are not expected to prove the wrongdoing, just to raise the concern. So even if an allegation turns out incorrect or unprovable, as long as it was made sincerely, the whistleblower is safe and the matter is closed without prejudice.

Communication and Training

Lovexa will periodically train employees about the Whistleblower Policy as part of ethics and compliance training. We want all staff to be aware of how to use this mechanism and to trust it. Posters or Intranet reminders will be placed to ensure the reporting channels are handy.
For external stakeholders (vendors, customers), we publicize the whistleblower contact (like the email hotline) on our website’s policy section, so that anyone dealing with Lovexa knows how to report issues directly to us.

Monitoring and Review

Our Audit Committee (or a designated Compliance Committee) will receive a summary of whistleblower complaints and outcomes at least quarterly, ensuring oversight at the highest level. They will ensure that investigations are handled appropriately and that the policy is effectively implemented.
This Whistleblower Policy itself will be reviewed periodically (at least every two years, or when laws change) and updated as needed. Any changes will be approved by the Board (or appropriate authority) and communicated to stakeholders.

Conclusion

Lovexa believes in fostering a culture where honesty and accountability are paramount. This policy is a reflection of our commitment to transparency and ethical conduct. If you see something wrong, we urge you to come forward – you will be heard, you will be protected, and together we will make Lovexa better.
For any questions about this policy or if you’re unsure whether and how to report, please contact [email protected] (you can even ask hypotheticals or seek advice without revealing details, if you’re trying to understand the process). Rest assured, we stand with those who stand up for what’s right.