Whistleblower
Policy

This Whistleblower Policy ("Policy") establishes TopHawks' framework for the protected disclosure of misconduct, illegal activity, unethical behaviour, or violations of company policy. It reflects our commitment to the highest standards of integrity, accountability, and transparency.

This Policy supplements — and does not replace — any rights and protections available to individuals under applicable law, including statutory whistleblower protection legislation in India and other jurisdictions where TopHawks operates.

This Policy extends its protections to every person who interacts with TopHawks in any capacity, including:

• Employees — full-time, part-time, probationary, and fixed-term
• Contractors & Consultants — engaged directly or through agencies
• Interns & Trainees
• Community Members & Registered Users of the TopHawks platform
• Business Partners & Vendors — and their employees
• Former employees reporting matters that arose during their tenure
• Anonymous individuals — anonymous reports are fully accepted

A "Protected Disclosure" under this Policy means any good-faith report of actual or suspected:

Every good-faith reporter is unconditionally entitled to the following protections, effective from the moment a report is submitted:

Retaliation against a whistleblower is one of the most serious violations recognised under this Policy. It will be treated as a standalone disciplinary matter, independent of the outcome of the original investigation.

Supervisors and managers are specifically accountable for ensuring no retaliation occurs within their teams. Failure to prevent or report known retaliation is itself a disciplinary offence that can result in dismissal.

TopHawks provides multiple reporting channels to ensure every individual can disclose concerns in the way they feel safest. All channels are monitored 24 hours a day, 7 days a week.

All reports are handled by trained investigators who are independent of the subject of the complaint. Our process is designed to be thorough, fair, and time-bound.

Confidentiality is not merely a best-effort commitment at TopHawks — it is operationally enforced through access controls, need-to-know restrictions, and mandatory training for all investigators.

• Reports and investigation files are stored in an encrypted, access-controlled system separate from HR records.
• Access is restricted to the lead investigator, the Ethics & Compliance Officer, and — where legally required — the Board Audit Committee.
• Line managers and colleagues of the reporter are not informed that a report has been made unless strictly necessary for the investigation.
• The identity of the subject of the complaint is protected until findings are substantiated and action is warranted.
• All investigation participants are required to sign confidentiality undertakings before being interviewed.
• Records are retained for a minimum of 7 years in accordance with applicable regulatory requirements, after which they are securely destroyed.

This Policy is built on the presumption of good faith. The vast majority of reporters act honestly, and we will always err on the side of taking reports seriously rather than dismissing them.

However, knowingly making a false report — one that the reporter knew to be untrue at the time of filing, with intent to harm another individual — is itself a breach of TopHawks' Code of Conduct and may result in disciplinary action up to and including termination.

TopHawks strongly encourages individuals to use internal reporting channels first, as this gives us the opportunity to address concerns quickly and directly. However, we fully recognise and respect individuals' legal rights to report concerns to external authorities.

Reporters who disclose concerns to external regulators, law enforcement, or — in the public interest — to the media retain their protections under this Policy provided that:

• The disclosure relates to a matter covered by this Policy;
• The reporter reasonably believed the information to be true at the time of disclosure; and
• The disclosure was not made solely for personal gain.

Relevant external channels in India include the Securities and Exchange Board of India (SEBI), the Serious Fraud Investigation Office (SFIO), the Central Vigilance Commission (CVC), and the National Human Rights Commission (NHRC).

This Policy is designed to be compliant with, and in many areas exceed the requirements of, the following legislative frameworks:

• The Whistle Blowers Protection Act, 2014 (India) — provides a framework for receiving and investigating disclosures of corruption or wilful misuse of power by public servants; TopHawks adopts equivalent standards for its private sector context.
• The Companies Act, 2013 — Section 177 requires listed companies to establish a vigil mechanism for directors and employees to report genuine concerns, with direct access to the Audit Committee for appropriate cases.
• SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 — Regulation 22 mandates listed entities to establish a vigil mechanism with a Whistleblower Policy.
• Digital Personal Data Protection Act, 2023 — governs the processing of personal data during investigations.
• EU Whistleblower Protection Directive (2019/1937) — applicable to TopHawks' European operations and European-resident users and partners.
• UK Public Interest Disclosure Act 1998 (PIDA) — applicable to UK-based operations.