Policy Origination Date: April 1, 2025
Last Reviewed: April 1, 2026
Next Review: April 1, 2027
DataToBiz Private Limited (“DataToBiz,” “we,” “us,” or “our”) is committed to conducting business with integrity. This Whistleblower Policy and Vigil Mechanism gives employees and third parties a confidential channel to raise concerns about misconduct or non-compliance, and sets out how DataToBiz reviews those concerns and protects the people who raise them in good faith.
| Document title | Whistleblower Policy and Vigil Mechanism |
|---|---|
| Founder | DataToBiz Leadership Team – Ankush Sharma (Co-Founder & CEO) and Parindsheel Singh Dhillon (Co-founder & COO) |
| Applies to | All DataToBiz employees and third parties, including contractors, consultants, and suppliers |
| Classification | Public – published at www.datatobiz.com |
| Version | 1.0 |
| Policy origination date | April 1, 2025 |
| Last reviewed | April 1, 2026 |
| Next review | April 1, 2027 |
| Version | Details | Effective Date |
|---|---|---|
| 1.0 | First release | April 1, 2025 |
DataToBiz believes in conducting business with integrity and in compliance with the laws, rules, and regulations applicable in the jurisdictions where we operate. This Whistleblower Policy and Vigil Mechanism (the “Policy”) gives employees and third parties a way to raise concerns about suspected misconduct or non-compliance, confidentially or anonymously, and prohibits retaliation against anyone who, in good faith, makes a report or assists in reviewing one. Where local law sets a higher standard than this Policy, local law takes precedence. This Policy should be read alongside DataToBiz’s Anti-Bribery & Anti-Corruption Policy and Human Rights & Modern Slavery Statement.
This Policy covers malpractice, impropriety, abuse, or wrongdoing connected to DataToBiz. Illustrative examples — this list is not exhaustive — include:
Complaints of sexual harassment are handled through DataToBiz’s Internal Committee (IC) under the POSH Act, 2013, as described in our Human Rights & Modern Slavery Statement, rather than through this Policy. A Whistleblower’s role is to report reliable information in good faith — not to investigate the matter themselves or determine the outcome.
Every DataToBiz employee and third party is eligible to raise a Reportable Matter concerning DataToBiz under this Policy.
Genuine Whistleblowers are given complete protection under this Policy. That protection does not extend to allegations a Whistleblower knew, or should reasonably have known, to be false or made in bad faith — misuse of this Policy in that way may itself lead to disciplinary action.
DataToBiz uses two review structures depending on who a Reportable Matter concerns.
Any Review Panel member with a conflict of interest in a given matter must recuse themselves; the remaining members proceed with the review.
Opening an investigation is not, by itself, an accusation — it is a neutral fact-finding process, and its outcome may or may not support the Whistleblower’s concern. The relevant Review Panel may engage outside auditors, counsel, or other experts, at DataToBiz’s expense, where specialist assistance is needed. A Subject’s identity is kept confidential to the extent the law and the investigation allow; a Subject has the right to be heard, to be informed of the outcome, and to engage counsel at their own cost, and has a duty to cooperate with the investigation and not to interfere with evidence or witnesses.
If the relevant Review Panel concludes that improper or unethical conduct occurred, it directs DataToBiz’s leadership to take disciplinary or corrective action, following DataToBiz’s ordinary personnel and disciplinary procedures. The Review Panel’s decision on a Reportable Matter is final.
No one at DataToBiz will retaliate, or tolerate retaliation by any person or group, against a Whistleblower who makes a Reportable Matter in good faith or who assists a Review Panel’s investigation. DataToBiz will not enforce any confidentiality agreement in a way that would prevent someone from reporting a suspected violation of law to a government authority.
A Reportable Matter and the identity of the Whistleblower are shared only with those directly involved in reviewing it. Unless required by law or necessary to fully investigate a matter, DataToBiz will not disclose the identity of a Whistleblower who asks for confidentiality, and will not attempt to identify a Whistleblower who has reported anonymously.
Protection under this Policy does not extend to a Whistleblower who knowingly makes a false or malicious report. Such conduct may itself result in disciplinary action, consistent with Section 5.
DataToBiz will make employees aware of this Policy as part of onboarding, and will communicate it on an ongoing basis by publishing it on the DataToBiz website and sharing it directly with employees and relevant third parties.
DataToBiz will retain a Reportable Matter and the documents generated during its review or investigation for as long as required by applicable law or reasonably necessary for DataToBiz’s records.
DataToBiz’s leadership team may amend or update this Policy at any time. This Policy is reviewed at least annually, or sooner if DataToBiz’s operating footprint changes materially.
This Policy was approved by DataToBiz’s leadership on behalf of DataToBiz Private Limited.
Ankush Sharma
Co-Founder & Chief Executive Officer, DataToBiz Private Limited | Date: April 1, 2026
Parindsheel Singh Dhillon
Co-Founder, DataToBiz Private Limited | Date: April 1, 2026
