Speak‑Up & Ethics
Reporting Policy
Purpose
Preemptive Technofield Pvt. Ltd. (“the Company”) is committed to conducting its business with the highest standards of integrity, transparency, accountability, and ethical behavior. This Speak‑Up & Ethics Reporting Policy (“Policy”) provides a structured and safe mechanism for employees and stakeholders to report concerns regarding unethical behavior, violations of law, company policies, or professional standards.
The Policy aims to: – Encourage a culture of openness and ethical conduct – Enable early identification and resolution of concerns – Protect individuals who raise concerns in good faith – Ensure compliance with applicable laws, regulations, and corporate governance standards.
Scope
This Policy applies to: – All permanent, temporary, contractual, and trainee employees – Directors and officers of the Company – Consultants, vendors, partners, and service providers – Any stakeholder associated with the Company who becomes aware of unethical or improper conduct.
The Policy covers concerns arising from activities related to the Company’s operations, projects, customers, suppliers, and partners.
What Should Be Reported
Concerns that should be reported under this Policy include, but are not limited to:
Ethical Misconduct
- Fraud, theft, bribery, or corruption
- Conflict of interest or undisclosed personal gain
- Abuse of authority or misuse of company resources
Legal & Regulatory Violations
- Violation of applicable laws or regulations
- Non‑compliance with statutory or contractual obligations
- Data protection or privacy breaches
Workplace Misconduct
- Harassment, discrimination, or bullying
- Unsafe or unhealthy working conditions
- Retaliation against individuals raising concerns
Information Security & IT Ethics
- Unauthorized access to systems or data
- Cybersecurity violations
- Intellectual property misuse
Financial & Reporting Irregularities
- Manipulation of accounts or financial records
- Misrepresentation to auditors, customers, or regulators
Who Can Raise a Concern
Any individual covered under this Policy may raise a concern if they reasonably believe that misconduct has occurred, is occurring, or is likely to occur.
Concerns must be raised in good faith. Deliberately false, malicious, or frivolous allegations may result in disciplinary action.
Speak‑Up Channels
Concerns can be reported through any of the following channels:
Primary Reporting Channels
- Email: ethics@preemptive.in (or designated ethics email)
- Written Communication: Addressed to the Ethics Committee / Compliance Officer
- Direct Reporting: To immediate manager, HR, or Compliance Officer
Anonymous Reporting
- Anonymous reports are permitted and will be investigated to the extent possible
- Individuals are encouraged to provide sufficient information to enable effective investigation
Confidentiality
- All concerns will be handled with strict confidentiality
- The identity of the reporting individual will be protected to the maximum extent possible
- Information will be disclosed only on a “need‑to‑know” basis for investigation and legal compliance
Protection Against Retaliation
Preemptive Technofield Pvt. Ltd. strictly prohibits retaliation against anyone who raises a concern in good faith.
Retaliation includes: – Termination, demotion, or denial of promotion – Harassment, intimidation, or discrimination – Any adverse employment or contractual action.
Any act of retaliation will be treated as a serious violation and may result in disciplinary action, including termination.
Review & Investigation Process
- Acknowledgment: Receipt of the concern will be acknowledged (where identity is known)
- Preliminary Review: Initial assessment to determine scope and credibility
- Investigation: Conducted by the Ethics Committee, Compliance Officer, or external experts
- Documentation: All findings will be documented objectively
- Corrective Action: Appropriate actions will be taken based on findings
Investigations will be conducted fairly, independently, and within reasonable timelines.
Investigation Timelines
- Preliminary review: within 5 working days
- Detailed investigation and reporting: typically within 15–45 working days, depending on complexity
The reporter may be informed of the status and outcome, subject to confidentiality and legal constraints.
Roles & Responsibilities
Ethics Committee / Compliance Officer
- Receive and assess reported concerns
- Ensure fair and timely investigation
- Recommend corrective and preventive actions
- Maintain records and reporting
Management
- Promote ethical culture and awareness
- Support investigations and corrective actions
- Ensure no retaliation occurs
Employees & Stakeholders
- Act ethically and responsibly
- Report concerns promptly
- Cooperate during investigations
Disciplinary Actions
If misconduct is substantiated, the Company may take actions including: – Counseling or warnings – Suspension or termination of employment or contract – Legal action or reporting to authorities, where required.
Record Keeping
All reports, investigations, and outcomes will be securely documented and retained by the Company in accordance with applicable legal and regulatory requirements, for a minimum period of seven (7) years or such longer period as may be prescribed by law.
Awareness & Training
The Company will: – Communicate this Policy to all employees and relevant stakeholders – Provide periodic training and awareness sessions – Display the Policy on internal portals and the Company website, where appropriate.
Policy Review & Amendments
This Policy will be reviewed periodically to ensure effectiveness and compliance with applicable laws and best practices. The Company reserves the right to amend or modify this Policy at any time.
Contact Information
For questions or clarification regarding this Policy, please contact:
Compliance Officer / Ethics Committee
Preemptive Technofield Pvt. Ltd.
E-156, 2nd Floor, Kalkaji
New Delhi – 110019
Commitment Statement
Preemptive Technofield Pvt. Ltd. is committed to maintaining the highest ethical standards and encourages everyone to speak up without fear, ensuring a transparent, responsible, and ethical workplace.
Access to Documentation
