Purpose and Scope

Globose Technology Solutions Private Limited (GTSPL) is committed to conducting its business legally and ethically. We encourage individuals who are concerned about improper conduct to report such conduct. This policy outlines how you can do that and what we will do when we receive such reports.

This policy applies globally to all GTSPL's subsidiaries, businesses, divisions, and offices. It also applies across all jurisdictions where we operate. If local legislation, regulation, or laws provide a higher level of protection than what is included in this policy, the local legislation will take precedence.

Who is a Reporter?

A reporter is an individual who makes or attempts to make a disclosure of improper conduct. Reporters can be employees, directors, managers, contractors, consultants, suppliers, service providers, auditors, former employees of GTSPL, or family members of any of the above.

Improper Conduct

Improper conduct includes any conduct or an improper state of affairs that is dishonest, fraudulent, corrupt, illegal, in serious breach of internal policy, inconsistent with our corporate values, unethical, improper, unlawfully discriminatory, creates an unsafe work environment, or detrimental to the interests of GTSPL.

Making the Disclosure

As a reporter, you can make a disclosure in any of the following ways:

  • Speak with an officer, director, the company secretary, or a member of the executive team at GTSPL.
  • Speak with GTSPL’s external auditor.
  • Anonymity and Confidentiality

    If you wish to make an anonymous disclosure or restrict your disclosure to only certain people, we will respect that request. You have the right to remain anonymous and do not need to identify yourself at any time during the investigation process.

    The Investigative Process

    Once your disclosure is submitted, it will be reviewed by the General Counsel (or an unimplicated non-executive director of the Board if the disclosure concerns the General Counsel). We may investigate the disclosure internally or use third-parties to investigate any disclosure.

    Retaliation Prohibited

    We prohibit all forms of retaliation against you as a direct result of being a reporter or a witness in an investigation. If you feel that you have been or will be retaliated against, you should escalate this immediately to the General Counsel or SVP of HR.


    If you are a current or former employee, you can access our Employee Assistance Program (EAP) for emotional support. While we may not be able to provide the same level of practical support to non-employee reporters, we will look at ways to provide you support to the extent reasonably possible.

    Reporting to Regulators

    Nothing in this policy is intended to restrict you from disclosing improper conduct, providing information to, or communicating with a government agency, law enforcement body, or a regulator in accordance with any relevant law or regulation in any jurisdiction in which we conduct business.

    Breach of Policy

    Breach of this policy may be regarded as misconduct, which may lead to disciplinary action (including termination of employment or engagement). Any breach of confidentiality of the information provided by a reporter, or of a reporter’s identity, and any retaliation against a reporter, will be taken seriously and if appropriate will be separately investigated.

    Updating the Whistleblowing Policy

    From time to time, and at least annually, we may update this policy. Any changes to this policy will be communicated withall employees and any relevant stakeholders and must be approved by the CEO. Any changes will be reported to the Board as below.

    Reporting to the Board of Directors

    The Board is updated at each Board meeting on the Policy, and any reports, investigations, and results taken under it. Reports or investigations carrying an undue amount of risk will be reported to the Board outside of the monthly updates. The Board at any time can ask about matters arising or pending under the Policy. The Board is responsible and accountable for oversight of the implementation and effectiveness of the Policy.