Whistleblowing Policy

Last updated: March 31, 2025

1. Introduction

ADAM Consult is committed to maintaining a workplace where all employees and stakeholders can report misconduct, fraud, or violations of the law in good faith without fear of retaliation. This policy aims to encourage openness and transparency in reporting concerns related to illegal or unethical behavior.

2. Scope of the Policy

This policy applies to all employees, contractors, consultants, and other stakeholders associated with ADAM Consult. It outlines the process for reporting concerns related to unethical behavior, violations of the law, fraud, or any other matters of concern in compliance with Indian laws, including the Prevention of Corruption Act, 1988 and the Whistleblower Protection Act, 2011.

While not mandated under Section 177 of the Companies Act, 2013, ADAM Consult adopts this policy voluntarily to promote a transparent and ethical working environment.

3. What Should Be Reported?

The following types of concerns should be reported under this policy:

4. Reporting Mechanisms

Concerns can be reported through the following channels:

Anonymous complaints will be considered if they contain sufficient information to warrant an investigation.

5. Protection Against Retaliation

ADAM Consult strictly prohibits retaliation or discrimination against anyone who reports a concern in good faith. Any individual who engages in retaliatory actions will be subject to disciplinary measures, which may include termination of employment or legal proceedings. Employees or stakeholders who believe they have been subjected to retaliation should report such behavior immediately. Retaliation is treated as a standalone violation under this policy.

6. Confidentiality

All reports made under this policy will be handled with the utmost confidentiality. The identity of the whistleblower will be protected to the extent possible, consistent with the need to investigate the concern appropriately. However, confidentiality cannot be guaranteed in certain situations, such as when disclosure is required by law.

7. Investigation and Response

All complaints will be assessed by the designated Whistle Officer or Ethics Committee, who will determine the appropriate course of action and ensure a fair and unbiased investigation. The investigation process will be fair, transparent, and conducted in compliance with relevant Indian laws. The person who raised the concern will be kept informed of the progress and outcome of the investigation, while maintaining confidentiality regarding involved individuals.

8. Legal Protections Under Indian Law

In India, whistleblowers are protected under the Whistleblower Protection Act, 2011 and other applicable laws, which provide safeguards against retaliation or victimization. Legal protections are also available under the Indian Penal Code (IPC), the Prevention of Corruption Act, and other regulatory frameworks that support ethical disclosures in the public and private sectors.

9. Responsibilities

Employees and stakeholders are expected to raise any concerns or report suspected misconduct or violations in good faith. All individuals should cooperate with investigations and act with integrity in addressing such issues.

10. Policy Review and Updates

This policy will be reviewed periodically to ensure that it remains effective and compliant with applicable laws and regulations. ADAM Consult reserves the right to modify or update the policy as required.

11. Contact Information

For further inquiries or to report a concern, please contact: