Whistle Blower Policy

Whistle Blower Policy (Vigil Mechanism) – Extract

This is an extract of Whistle Blower Policy dated 1st September 2023 and amended on 13th November 2025. This disclosure is in accordance with Section 177 of the Companies Act, 2013.

The policy provides a mechanism for directors, employees, vendors & other stakeholders to raise genuine concerns about unethical or unprofessional conduct.

This policy is in compliance with Section 177 of the Companies Act, 2013.

This policy is applicable at all India level to all permanent or contractual employees & vendors.

All complaints will be treated in a confidential and sensitive manner.

Identity of Whistle Blower will be disclosed on ‘need-to-know-basis’, subject to approval of Whistle Blower.

1. The WEC consists of CFO, CHRO, COO and Company Secretary.
2. The Whole-time Director, as nominated by the Board shall oversee implementation of vigil mechanism and functioning of WEC.
3. The WEC shall meet as and when required to review and decide upon the complaints.
4. The WEC shall submit its periodic reports to the Whole-time Director.

1. A whistle blower (person who reports an unethical activity or conduct) should register a complaint on number: 9819764352 or by writing to whistleblower@theobroma.in .
2. The complaint will be received by Works Ethics Committee (WEC).
3. The WEC will do preliminary investigation to check the genuineness of complaint.
4. If investigation is required, the WEC shall appoint a team to investigate.
5. The investigation team should complete the investigation and submit the report to WEC.
6. The WEC will then decide and give directions to implement its decision.
7. The decision of WEC shall be final and binding.

Phone: 9819764352

Email: whistleblower@theobroma.in