1. Preamble:

Purvaja Fincap Private Limited (hereinafter referred to as “the Company”) is committed to maintaining the highest standards of ethical conduct, transparency, and accountability in its business operations. In line with this commitment, the Company has established a Vigil Mechanism and Whistleblower Policy to encourage its employees and stakeholders to report genuine concerns about unethical behaviour, malpractices, or any other wrongdoing within the organization.

2. Objective:

The primary objective of this policy is to provide a framework for employees and other stakeholders to report concerns or grievances about any unethical, illegal, or questionable activities within the Company, without fear of retaliation.

3. Applicability:

This policy is applicable to all employees, directors, contractors, vendors, customers, and any other stakeholders associated with Purvaja Fincap Private Limited.

4. Definitions:

Whistleblower: Any individual who raises a concern about wrongdoing within the Company.

Vigil Officer: A designated senior executive responsible for overseeing the implementation and administration of this policy.

Protected Disclosure: Any communication made in good faith, that discloses or demonstrates information that may evidence unethical or improper activity.

5. Reporting Mechanism:

Employees and stakeholders are encouraged to report concerns through the following channels: a. Directly to the Vigil Officer via email at [VigilOfficer@purvajafincap.com]. b. Through the Company’s dedicated hotline for whistleblower complaints. c. In writing, addressed to the Vigil Officer or any member of the Board of Directors.

6. Confidentiality:

The Company is committed to maintaining the confidentiality of the whistleblower’s identity to the extent possible. However, anonymity cannot be guaranteed if the disclosure is made openly or if the circumstances require investigation by law enforcement agencies.

7. Non-Retaliation:

The Company prohibits any form of retaliation, discrimination, or adverse employment action against individuals who, in good faith, report concerns or participate in an investigation.

8. Investigation Process:

The Vigil Officer will promptly acknowledge receipt of the complaint and initiate an impartial and confidential investigation.

The investigation will be conducted in accordance with applicable laws and regulations.

The findings will be reported to the Audit Committee and appropriate remedial actions will be taken.

9. Protection Against False Allegations:

Individuals making malicious or false allegations may be subject to disciplinary action, including termination of employment or legal action.

10. Review and Amendment:

The Company will periodically review and update this policy to ensure its effectiveness and compliance with regulatory requirements.

11. Contact Information:

Vigil Officer: Mr Ajith Krishan

Email: ajith@purvajafin.com