Purpose

The Culture Whistleblowing policy at Uplers  is aimed at aligning the organization with the new culture values, assisting employees to clear any misunderstanding(s) related to it, and conveying the message that our values are the peak priority to the organization.

Scope

This policy is applicable to all the employees of Uplers  with no exception.

Eligibility

All the Employees, & Leaders at all the levels of the organization are eligible to make protected disclosures under the policy. The protected disclosures would be in relation to matters concerning the culture of the company. 

Definition

The terms used in this policy shall have the same meaning and effect, as has been ascribed to each term under the Headings herein set out.

• • Whistleblowing

Whistle blowing is the process whereby an employee of Uplers  raises a concern about a culture misconduct which could either be a risk to the organization’s interests or reputation or discloses information of possible wrongdoing or malpractice in the company’s operations.

• • Whistleblower

A Whistleblower is any of the Uplers  employees who have the knowledge of, and makes a protected disclosure of, any cultural wrongdoing or malpractice within the company’s operations. The whistleblower is protected by Uplers / Mavlers from all reprisal for such a disclosure. 

• • Protected Disclosure 

The purpose of the policy is to encourage employees, who have observed reportable cultural misconduct or wrongdoing, to disclose such wrongdoing in the workplace by providing them protection from victimization or harassment when making disclosures. Such disclosures are known as Protected Disclosures. 

The company through the approval of this policy by its Cultural Committee undertakes that a genuine whistleblower will remain protected for whistle Blowing. 

Reporting Channels 

Mode of Raising Concern

1. Employees can draft a direct mail to a dedicated Cultural Whistleblowing Committee team / To immediate Supervisor or Manager.
2. Employees can also raise concern by filling out the Cultural Whistleblowing form.

General Criteria

1. Minor cultural misconduct / wrongdoing cases reported, could be resolved with specific feedback.
2. For major cultural misconduct / wrongdoing, cases would require deeper interventions and firmer actions from Cultural Committee’s end.
3. Types of issue that should be reported includes but are not limited to, major instances of nonconfirmation / misalignment of the values and / or multiple small instances of value nonconfirmation / misalignment..

Reporting Procedure

1. A detailed description of the incident is to be shared by the employee, it would be reviewed by the culture committee, and they would make the decision within a defined TAT. The reportee would be kept in loop, so the message of importance is conveyed.
2. In case a breach of value is established, the person would undergo counseling via one of the members of the culture committee.
3. A training module for each cultural value and mandatory training within 2 weeks is to be followed by the employee under counseling.
4. A short exam to be taken by the reported employee before giving clearance by culture buddy.

Investigating Criteria

1. The investing process should be transparent and the aim should be to remove subjectivity as much as feasible. 
2. In case the investigation finds the reportee viewpoint was wrong, they would in return go to counseling by an assigned culture buddy to convey their proactiveness is good, but their view was incorrect, and make them aligned with values, so they are still encouraged to report future cases but be more judicious.
3. Investigating procedure by the Culture Whistleblowing Committee may have TAT of 3 weeks from the date of report.

Culture Whistleblowing Committee

Purpose

• Align organization with new culture values 
• Handle matters where there has been grievances related to value breach
• Take corrective action for the instances where the value breach took place

Committee Structure & Selection

• The committee should have min 5 and max 7 members
• The committee members
  • Head of People & Culture (Default)
  • One of CEO/ COO (Volunteer)
  • At least 1 Vice President or above (Volunteer)
  • At least 2 members with title Associate Director or above (Selection) 
  • At least 2 female members (Mandate)
  • The members would be selected based on nomination and subsequently culture evaluation

Confidentiality Criteria

1. Confidentiality of the investigation process and any reports generated during the investigation process to be kept by the Culture Committee, and non-retaliation statements to be released to encourage more employees to take up such initiatives.
2. Committee’s would provide assurance that culture whistleblowers data would be protected, and under no circumstances their identity to be shared beyond the culture counsel and the supporting team.

Ownership, Review & Approval

This Policy is owned and administered by the People and Culture department and must be reviewed and updated (at least every 12 months). Any exceptions in the policy depend on the sole right of the Associate Director- People & Culture only.

Uplers reserves the right to update this policy periodically.