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WHISTLE BLOWER POLICY

 INTRODUCTION

At Raspn Shipping Services Pvt. Ltd. ("Raspn"), we are committed to maintaining the highest standards of ethics, integrity, and compliance with all applicable laws and regulations. We recognize that our employees, partners, and stakeholders are crucial to upholding these standards, and we encourage them to report any concerns about suspected serious violations of laws, Raspn policies, or ethical standards. This Whistleblower Policy is designed to provide a safe and confidential mechanism for reporting such concerns, ensuring that they are addressed promptly and appropriately.

PURPOSE

​The purpose of this Whistleblower Policy is to:

  • Encourage employees, contractors, suppliers, partners, and other stakeholders to report suspected violations of laws, regulations, or Raspn's policies.

  • Protect whistleblowers from retaliation or discrimination as a result of their good-faith reporting.

  • Foster a culture of openness, accountability, and transparency within Raspn.

  • Provide a clear and confidential process for reporting and addressing such concerns.

  • ​Ensure that all reports are thoroughly investigated, and appropriate corrective actions are taken.

SCOPE

This policy applies to all employees, contractors, suppliers, partners, and any other stakeholders associated with Raspn. It covers all areas of potential concern, including but not limited to:

  • Competition law violations

  • IT security breaches

  • Data privacy (including  Digital Personal Data Protection Act 2023)

  • Threats to health, safety, and the environment

  • Theft, embezzlement, or misappropriation of assets

  • Accounting manipulation or financial fraud

  • Corruption, bribery, or other unethical business practices

  • Violations of foreign trade controls

  • Human rights and labor rights violations

  • Workplace harassment, including sexual harassment

  • Retaliation or discrimination against employees

POLICY STATEMENT

Raspn is committed to maintaining an ethical work environment where employees and stakeholders can raise concerns about potential violations without fear of retaliation. We take all reports of misconduct seriously and will investigate them thoroughly and impartially. This policy is designed to ensure that anyone who reports a concern in good faith is protected from retaliation or any adverse consequences.

REPORTING CONCERNS

What to Report

You should report any concerns or suspicions related to:

  1. Competition Law: Any activities that could be considered anti-competitive, such as price-fixing, market division, bid-rigging, or abuse of market power.

  2. IT Security: Breaches of Raspn’s IT security policies, unauthorized access to systems, data breaches, or any activities that compromise the security of RASPN’s IT infrastructure.

  3. Data Privacy (GDPR): Violations of data protection laws, including the General Data Protection Regulation (GDPR), unauthorized access to personal data, or mishandling of personal information.

  4. Health, Safety, and Environment: Any actions or conditions that pose a threat to the health, safety, or environment, including non-compliance with safety regulations, unsafe working conditions, or environmental damage.

  5. Theft and Embezzlement: Misappropriation of company assets, fraudulent activities, or any form of theft, whether involving financial assets, intellectual property, or physical goods.

  6. Accounting Manipulation and Financial Fraud: Any activities that involve manipulating financial statements, fraudulent accounting practices, or other financial misconduct.

  7. Corruption: Acts of bribery, kickbacks, or other forms of corruption that involve RASPN or its stakeholders.

  8. Foreign Trade Controls: Violations of export controls, sanctions, or other regulations governing international trade.

  9. Human Rights and Labor Rights: Any violations of human rights or labor rights, including forced labor, child labor, discrimination, or unfair treatment of workers.

  10. Workplace and Sexual Harassment: Any form of harassment, including sexual harassment, bullying, or other abusive behavior in the workplace.

  11. Retaliation or Discrimination: Any actions taken against an individual in retaliation for reporting a concern or for participating in an investigation related to this policy.

How to Report

Raspn provides multiple channels for reporting concerns. You can report a concern using any of the following methods:

  1. Internal Reporting: Employees and stakeholders are encouraged to report concerns to their immediate supervisor or manager. If this is not possible or if the concern involves the supervisor or manager, you may report the issue directly to the HR department or the designated Whistleblower Officer.

  2. Whistleblower Email Reporting: Raspn has established a confidential whistleblower communication channel that is available 24/7 and will be reverted within 12 hours. Reports can be made anonymously if preferred. The hotline email is reportit@raspnshipping.co.in.

Confidentiality and Anonymity

Raspn is committed to protecting the confidentiality of whistleblowers. All reports will be treated with the highest level of confidentiality, and the identity of the whistleblower will be protected to the fullest extent possible. Whistleblowers may choose to report anonymously, although providing contact information may facilitate a more thorough investigation.

PROTECTION AGAINST RETAILATION

No Retaliation Policy

Raspn strictly prohibits any form of retaliation against individuals who report concerns in good faith. Retaliation includes any adverse action taken against an individual as a result of their reporting, such as termination, demotion, harassment, or any other form of discrimination. Any employee found to have engaged in retaliatory behavior will be subject to disciplinary action, up to and including termination.

Reporting Retaliation

If you believe you have been subjected to retaliation as a result of reporting a concern or participating in an investigation, you should report this immediately to the Whistleblower Officer or the HR department. Raspn will investigate all claims of retaliation and take appropriate corrective action.

INVESTIGATION PROCESS

Initial Review

Once a concern is reported, the Whistleblower Officer will conduct an initial review to determine the validity of the report and whether it falls within the scope of this policy. If the concern is deemed credible, a formal investigation will be initiated.

Investigation

The investigation will be conducted by a designated investigation team, which may include members of the HR department, legal counsel, and other relevant departments. The investigation will be thorough, impartial, and conducted in a timely manner. The investigation team will gather all relevant evidence, including documents, witness statements, and any other pertinent information.

Communication with Whistleblower

If the whistleblower has provided contact information, they will be kept informed of the progress of the investigation. The whistleblower will be informed of the outcome of the investigation, to the extent that it is appropriate and permissible under the law.

Conclusion of Investigation

Upon conclusion of the investigation, a report will be prepared summarizing the findings and any recommended corrective actions. The report will be reviewed by senior management, and appropriate actions will be taken based on the findings. If the investigation reveals misconduct or a violation of Raspn’s policies, disciplinary action will be taken against the responsible parties.

CORRECTIVE ACTIONS

Disciplinary Actions

Upon conclusion of the investigation, a report will be prepared summarizing the findings and any recommended corrective actions. The report will be reviewed by senior management, and appropriate actions will be taken based on the findings. If the investigation reveals misconduct or a violation of Raspn’s policies, disciplinary action will be taken against the responsible parties.

Systemic Issues

If the investigation reveals systemic issues or weaknesses in Raspn’s policies or procedures, corrective actions will be implemented to address these issues. This may include revising policies, enhancing training programs, or implementing additional controls to prevent future violations.

WHISTLEBLOWER RESPONSIBILITIES

Good Faith Reporting

Whistleblowers are expected to report concerns in good faith. This means that the whistleblower has a reasonable belief that the information they are reporting is true and that it indicates a potential violation of laws, regulations, or Raspn’s policies. Reporting in bad faith, such as knowingly making false accusations, is a serious violation of this policy and may result in disciplinary action.

Cooperation with Investigations

​Whistleblowers and other employees are expected to cooperate fully with investigations. This includes providing all relevant information and documentation, participating in interviews, and assisting the investigation team as needed. Failure to cooperate with an investigation may result in disciplinary action.

TRAINING AND AWARENESS

Employee Training

Raspn is committed to ensuring that all employees are aware of this Whistleblower Policy and understand their rights and responsibilities under it. Regular training sessions will be conducted to educate employees about the policy, how to report concerns, and the protections available to whistleblowers. Training will also cover the importance of ethical conduct and compliance with laws and regulations.

Ongoing Awareness

In addition to formal training, Raspn will promote ongoing awareness of the Whistleblower Policy through internal communications, posters, and other materials. Employees will be reminded of the importance of ethical behavior and the role they play in maintaining Raspn’s high standards of integrity.

TRAINING AND AWARENESS

Policy Review

​This Whistleblower Policy will be reviewed regularly to ensure that it remains effective and up to date with current laws and best practices. Any changes to the policy will be communicated to all employees and stakeholders.

Monitoring

Raspn will monitor the effectiveness of the Whistleblower Policy by tracking the number of reports received, the outcomes of investigations, and any corrective actions taken. This data will be used to assess the overall effectiveness of the policy and to identify areas for improvement.

CONCLUSION

Raspn Shipping Services Pvt. Ltd. is committed to maintaining a culture of integrity, transparency, and accountability. The Whistleblower Policy is a key component of this commitment, providing a safe and confidential mechanism for reporting concerns about potential violations of laws, regulations, or Raspn’s internal policies. We encourage all employees and stakeholders to report any concerns they may have, knowing that they will be protected from retaliation and that their concerns will be addressed appropriately. By working together to uphold our standards of ethics and integrity, we can continue to build a strong and reputable organization that operates in full compliance with the law.

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