Whistleblower Policy

Whistleblower Policy

Ojeev Foundation

Effective Date: 12 May 2026
Last Updated: 27 June 2026

Whistleblower Policy

1. Introduction

Ojeev Foundation ("the Foundation", "we", "our", or "us") is committed to conducting all its charitable, social, environmental, educational, healthcare, heritage preservation, and community development activities with the highest standards of integrity, transparency, accountability, and ethical governance.

As a Section 8 Company established under the laws of India, Ojeev Foundation believes that every employee, volunteer, donor, trustee, consultant, intern, vendor, partner, beneficiary, and stakeholder has the right and responsibility to report any genuine concern regarding unethical, illegal, fraudulent, or improper conduct without fear of retaliation.

This Whistleblower Policy establishes a secure and confidential mechanism for reporting concerns while ensuring that individuals who raise genuine concerns in good faith are protected from harassment, discrimination, intimidation, or any form of victimization.

2. Purpose

The objectives of this policy are to:

• Promote a culture of honesty and ethical conduct.
• Encourage early reporting of suspected wrongdoing.
• Protect individuals who report concerns in good faith.
• Prevent fraud, corruption, abuse, and misconduct.
• Ensure compliance with applicable laws of India.
• Strengthen accountability within the Foundation.
• Safeguard charitable assets and donor contributions.
• Protect beneficiaries and vulnerable communities.
• Maintain public trust in Ojeev Foundation.

3. Scope

This policy applies to all individuals associated with Ojeev Foundation, including but not limited to:

• Board of Directors
• Trustees
• Advisory Members
• Employees
• Volunteers
• Interns
• Consultants
• Contractors
• Vendors
• Suppliers
• Service Providers
• Donors
• CSR Partners
• Beneficiaries
• Community Members
• Government Liaison Officers
• Any individual interacting with the Foundation

4. Guiding Principles

Ojeev Foundation is committed to the following principles:

• Integrity
• Transparency
• Accountability
• Confidentiality
• Fair Investigation
• Protection Against Retaliation
• Ethical Decision-Making
• Respect for Human Rights
• Legal Compliance
• Responsible Governance

5. Reportable Concerns

A whistleblower may report any genuine concern involving misconduct or suspected wrongdoing, including but not limited to:

Financial Misconduct

• Fraud
• Theft
• Embezzlement
• Misappropriation of donations
• Unauthorized financial transactions
• False accounting
• Fake invoices
• Manipulation of financial records
• Misuse of grants
• Diversion of project funds

Corruption

• Bribery
• Kickbacks
• Illegal commissions
• Abuse of authority
• Influence peddling
• Conflict of interest
• Nepotism
• Favoritism

Legal Violations

• Violation of Indian laws
• Regulatory non-compliance
• Tax violations
• CSR misuse
• Violation of company policies
• Data privacy violations
• Intellectual property infringement

Ethical Misconduct

• Harassment
• Workplace bullying
• Discrimination
• Abuse of beneficiaries
• Exploitation
• Child abuse
• Sexual harassment
• Human rights violations

Operational Misconduct

• Misuse of Foundation property
• Unauthorized use of funds
• Forgery
• Falsification of reports
• Manipulation of donor information
• Destruction of records
• Concealment of evidence

Environmental Misconduct

• Illegal waste disposal
• Environmental damage
• Violation of sustainability commitments

Heritage & Temple Projects

• Misuse of restoration funds
• Illegal sale of historical artifacts
• Damage to protected heritage structures
• Misrepresentation of restoration work
• Unauthorized alteration of cultural sites

Digital Misconduct

• Unauthorized access to systems
• Cybersecurity violations
• Theft of confidential information
• Data breaches
• Misuse of donor databases
• Identity theft

6. Good Faith Reporting

Individuals are encouraged to report concerns honestly and responsibly.

A report should be based on:

• Reasonable belief
• Genuine concern
• Available facts
• Honest observations

A whistleblower is not required to prove misconduct before making a report.

7. Anonymous Reporting

Reports may be submitted anonymously.

However, anonymous reports may be more difficult to investigate if insufficient information is provided.

Whistleblowers are encouraged to include:

• Dates
• Locations
• Persons involved
• Supporting documents
• Emails
• Photographs
• Transaction details
• Witnesses

8. Confidentiality

Ojeev Foundation will maintain the confidentiality of whistleblowers to the maximum extent possible.

Identity shall only be disclosed:

• When legally required.
• When necessary for investigation.
• With the whistleblower's consent.
• Pursuant to a court or government order.

All investigations shall be conducted discreetly.

9. Protection Against Retaliation

Ojeev Foundation strictly prohibits retaliation against any person who reports concerns in good faith.

Retaliation includes:

• Dismissal
• Suspension
• Demotion
• Salary reduction
• Harassment
• Threats
• Intimidation
• Bullying
• Discrimination
• Negative performance reviews
• Blacklisting
• Social exclusion

Any individual engaging in retaliation may face disciplinary action, including termination of employment or engagement.

10. False or Malicious Complaints

While good faith reporting is encouraged, knowingly making false, malicious, or misleading allegations is prohibited.

Such conduct may result in:

• Disciplinary action
• Termination
• Legal proceedings
• Recovery of damages where applicable

This provision does not apply to reports made honestly that ultimately prove to be unsubstantiated.

11. Reporting Channels

Concerns may be reported through the following channels:

Email

info@ojeev.org

Postal Address

Ojeev Foundation
B3, Basement, A44, Sector 2
Noida, Uttar Pradesh – 201301
India

Whistleblowers should include as much relevant information as possible to facilitate a fair and timely investigation.

12. Investigation Process

Upon receiving a complaint:

Step 1

Acknowledgement of the complaint, where possible.

Step 2

Preliminary assessment.

Step 3

Appointment of an appropriate investigation team or authorized committee.

Step 4

Collection of evidence.

Step 5

Interviews with relevant individuals.

Step 6

Review of financial, operational, or technical records.

Step 7

Preparation of findings.

Step 8

Corrective and preventive actions, where necessary.

13. Investigation Standards

Investigations shall be:

• Fair
• Independent
• Objective
• Confidential
• Timely
• Evidence-based
• Free from conflicts of interest

14. Corrective Actions

Depending on the findings, Ojeev Foundation may:

• Issue warnings
• Suspend individuals
• Terminate employment or contracts
• Recover financial losses
• Report matters to law enforcement
• Notify regulatory authorities
• Improve internal controls
• Revise organizational policies
• Strengthen governance mechanisms

15. Responsibilities

Management

Management shall:

• Promote ethical conduct.
• Support whistleblowers.
• Ensure fair investigations.
• Maintain confidentiality.
• Implement corrective measures.

Employees and Volunteers

Every individual associated with the Foundation shall:

• Report suspected misconduct.
• Cooperate with investigations.
• Maintain confidentiality.
• Avoid retaliation.

16. Record Retention

Whistleblower reports and investigation records shall be securely maintained for a reasonable period in accordance with applicable laws and organizational record-retention practices.

17. Privacy

Personal information collected during investigations shall be handled in accordance with the Foundation's Privacy Policy and applicable Indian data protection laws.

Information shall only be used for legitimate investigative and legal purposes.

18. Compliance with Law

This policy shall be interpreted in accordance with:

• Applicable laws of India
• Companies Act, 2013 (where relevant)
• Section 8 Company governance requirements
• Anti-corruption and anti-fraud laws
• Data protection and privacy obligations
• Other applicable regulatory requirements

19. Policy Review

This policy may be reviewed and updated periodically to reflect changes in law, governance practices, or the operational requirements of Ojeev Foundation.

The latest version will be published on the Foundation's official website.

20. Contact Information

Ojeev Foundation

Website
www.ojeev.org

Email
info@ojeev.org

Phone
+91 9220143121

Address
B3, Basement, A44, Sector 2
Noida, Uttar Pradesh – 201301
India

21. Acceptance

By engaging with Ojeev Foundation as an employee, volunteer, trustee, consultant, vendor, donor, beneficiary, or partner, you acknowledge that you have read, understood, and agree to comply with this Whistleblower Policy.

Ojeev Foundation remains committed to fostering an environment where ethical conduct, accountability, transparency, and responsible governance guide every aspect of its mission to serve society.