#POL-IN-308: Whistleblower and Grievance Policy

#1. Statement, and the honest position on why it exists

Edsol Edtech Pvt. Ltd. operates a vigil mechanism. It is not required to by the Companies Act, 2013; section 177(9) applies to listed companies and to certain classes of company that Edsol Edtech Pvt. Ltd. does not fall within. It exists because the Company writes software that hospitals run their operations on, and the cheapest possible way to learn that something is wrong is from the person who noticed it.

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#2. What to report

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#3. How to report

3.1 No form is required. A sentence is enough. There is no obligation to have evidence, to be certain, or to have exhausted anything first.

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#4. What happens, and when

4.1 The person complained about does not investigate the complaint, and does not choose the investigator.

4.2 Where a report reveals something a hospital needs to know, the hospital is told: under NTC-GL-002 where it is a security or data matter, and by the Founder directly otherwise. POL-IN-305 Section 2.5. The existence of an internal investigation is not a reason to delay a notification to a customer, and never a reason to miss the four-hour commitment in DIS-GL-016.

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#5. Protection

5.1 No retaliation. No person suffers any detriment for making a report in good faith: no change to duties, appraisal, remuneration, project allocation or standing. Retaliation is gross misconduct under POL-GL-322 and is treated as more serious than the matter originally reported.

5.2 Good faith, not correctness. A report that turns out to be mistaken is protected. A report is unprotected only where it was knowingly false, and that requires a finding on inquiry with reasons recorded.

5.3 Reporting your own error is protected and is treated more leniently than the same error discovered by somebody else. This is stated because it changes behaviour: a person who has just made a production mistake at two in the morning decides in the next sixty seconds whether to tell anybody, and the whole cost of the incident turns on that decision.

5.4 Confidentiality. The reporter's identity is known to the smallest number of people necessary and is not disclosed to the person reported about unless the reporter agrees or the law requires it. Where identity must be disclosed, the reporter is told first.

5.5 No contractual gag. No employment contract, settlement, separation agreement or non-disclosure agreement made by Edsol Edtech Pvt. Ltd. prevents a person from reporting under this Policy, from reporting to a statutory authority, or from giving evidence. Any such term is void to that extent: POL-IN-302 clause 6.3.

5.6 Access to a regulator is not conditional on internal reporting. A person may go straight to CERT-In, the Data Protection Board, a labour authority or the police, at any time, without telling Edsol Edtech Pvt. Ltd. first.

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#6. Records

Every report, its assessment, its investigation, its outcome and the date of each step are recorded in a register held by the Founder with restricted access, retained for Hr whistleblower retention years years. Aggregate numbers (reports received, upheld, pending) are published annually. No identifying detail is published, and no case is discussed with a customer or a prospect.

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#7. Ordinary grievances

A grievance about pay, hours, leave, workload, a manager, a decision or a working condition, anything that is not in Section 2, is raised with the person's manager first, then with the Founder, then in writing to info@pensievelabs.org. The timelines in Section 4 apply. A grievance from a person with a disability, or about accessibility, may be raised with the Liaison Officer named in POL-IN-307 Section 2, who is the grievance redressal officer for matters under the Rights of Persons with Disabilities Act, 2016.

Grievances from outside the Company (from a hospital, a Data Principal or a member of the public) are handled under POL-GL-066, which carries the statutory clocks. This Policy is internal.

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