Whistleblower Policy – Teqtivity – IT Asset Management Software
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Whisteblower Policy

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Updated Date: August 14, 2025
Version: v1.0
Policy Owner: Hiren Hasmukh (CEO) – hiren@teqtivity.com
Review Cadence: Annually
Language: English

1) Introduction

Teqtivity, Inc. is committed to the highest standards of ethics, transparency, and compliance. This policy empowers employees, contractors, and other stakeholders to report illegal, unethical, or harmful behavior without fear of retaliation.

  • Teqtivity provides secure reporting through Deel.
  • Anonymous reporting is enabled in Deel, and reporters receive updates in Deel.
  • This policy is hosted in Deel and linked from our website.

2) Purpose

This policy ensures that reports of improper, unethical, or illegal actions are addressed effectively, securely, and lawfully, and that reporters are protected for good-faith disclosures.

3) Scope

Applies to on-site, remote, and affiliate contributors.

  • Personnel: Employees (full/part-time), managers, directors, executives, contractors, consultants, interns, and shareholders.
  • Company Property: Physical assets and intangible assets (IP, data, confidential information).
  • External Partners: Suppliers, customers, and other third parties associated with Teqtivity.

For general workplace suggestions or non-misconduct feedback, see Speak Up (Section 11).

4) Reportable Conduct (Whistleblowing)

Examples (non-exhaustive):

  • Fraud, theft, embezzlement, corruption, blackmail, bribery, financial malpractice, tax evasion
  • Failure to comply with legal, professional, or regulatory obligations
  • Conduct threatening Teqtivity’s reputation or financial well-being
  • Actions endangering health or safety
  • Environmental damage
  • Providing false information to public officers
  • Miscarriage of justice
  • Unauthorized disclosure of confidential information

Immediate danger: If there is an imminent threat to life or safety, contact local emergency services first, then report via Deel.

5) Reporting Channels

Removed channels: Teqtivity does not accept whistleblowing reports via hotline/phone or postal mail.

  1. Deel Intake (Preferred; anonymous enabled; updates in Deel)
  2. Direct Supervisor
    • If you prefer, you may raise concerns with your supervisor. (Not anonymous; for anonymity, use Deel.)
  3. Human Resources / Whistleblowing Officer
    • Hiren Hasmukh (CEO) – hiren@teqtivity.com
    • Suitable for serious or complex concerns. (Not anonymous; for anonymity, use Deel.)
  4. External Parties (suppliers/customers without Deel)
    • Email: hello@teqtivity.com (Not anonymous. We will instruct external reporters on next steps or refer them to Deel if applicable.)
  5. External Authorities (Exceptional Cases)
    • In extreme cases, you may report to regulators or law enforcement. Consider seeking legal advice before taking this step.

6) Conflict-of-Interest & Recusal

  • If a report implicates or may reasonably appear to implicate the CEO/Policy Owner (or anyone with authority over the investigation), Teqtivity will:
  1. Restrict internal access to the report in Deel to avoid conflicts; and
  2. Appoint an independent external investigator or outside counsel to oversee the matter from intake through resolution.
  • Until an external investigator is appointed, reporters may email hello@teqtivity.com with the subject line “Escalation – CEO Involved” to trigger immediate handling and access restrictions.

7) Investigation Process & SLAs

  1. Acknowledgment: within 2 business days.
  2. Initial Assessment: within 10 business days to determine scope, urgency, and risk.
  3. Assignment: a neutral investigator or team with appropriate expertise is assigned; HR/Legal/Compliance may be involved as needed.
  4. Investigation & Updates: if credible, a full investigation begins. Reporters receive periodic updates in Deel and may be asked for additional information.
  5. Outcome & Actions: Teqtivity will take appropriate action. Where legal/regulatory issues are identified, authorities may be notified. Illegal activity will be referred to the proper authorities with supporting evidence. Non-illegal but concerning conduct may result in training, coaching, corrective action, or disciplinary measures up to and including termination.
  6. Final Reporting: a summary of findings and actions is documented. Whistleblowers are informed of the outcome where possible, consistent with confidentiality, privacy, and legal limits.

8) Protection for Whistleblowers

  • Good-Faith Reporting: Protected from adverse treatment, even if unsubstantiated.
  • Anonymity: Available in Deel.
  • Confidentiality: Identity (if provided) and case details are shared only on a need-to-know basis or where required by law.
  • Privacy & Security: We use industry-standard safeguards to handle reports. See teqtivity.com/security for more information.
  • No Retaliation: Retaliation for good-faith reporting or for participation in an investigation is strictly prohibited and may result in disciplinary action up to and including termination. Examples: termination/demotion, exclusion from projects, isolation or mistreatment, denial of promotions, biased reviews, harassment.
  • To report suspected retaliation, use Deel or contact hiren@teqtivity.com.

9) False Reporting

Protections apply to good-faith reports. Knowingly making false or malicious allegations is a serious offense and may lead to disciplinary action, up to and including termination.

10) Temporary Safeguards for Whistleblowers

While a retaliation complaint is being assessed, Teqtivity’s Compliance function may recommend interim protective measures to the Internal Higher Authority: Hiren Hasmukh (CEO) – such as pausing disputed actions, reassignment, schedule modifications, or special leave—after consulting with the affected individual.

11) Speak Up (Workplace Feedback & Non-Whistleblowing)

Use Speak Up for general workplace feedback or concerns that do not involve suspected wrongdoing as described in Section 4. Examples:

  • Suggestions to improve tools, processes, culture, or communications
  • Team dynamics or non-harassing interpersonal concerns
  • Non-compliance questions or clarifications

How to submit: Email hello@teqtivity.com with the subject line “Speak Up”.

  • Note: Speak Up email is not anonymous. (For anonymity, use Deel under whistleblowing.)
  • You will receive periodic updates via email.

12) Manager Obligations

Managers must immediately escalate any suspected wrongdoing to Deel (preferred) or to hiren@teqtivity.com if Deel access is unavailable. Managers must not investigate on their own or promise outcomes.

13) Data Handling & Retention

  • Retention: Whistleblowing records are retained for 7 years from the date of report (unless a longer period is required by law or for litigation holds).
  • Access Controls: Access to reports is limited to those with a legitimate need to know.
  • Geographies: Teqtivity operates in the USA with outsourced developers in India, Mexico, and the Philippines, and serves customers in the EU. Teqtivity will comply with applicable local requirements; jurisdiction-specific addenda may be issued as needed.

14) Policy Administration

  • Policy Owner: Hiren Hasmukh (CEO) – hiren@teqtivity.com
  • Updated Date: August 14, 2025
  • Review Cadence: Annually
  • Version: v1.0
  • This policy is hosted in Deel and linked from the Teqtivity website.
  • This policy does not create an employment contract or promise of continued employment.

15) Important References

  • Reporting Access: Log in to your Deel account.
  • Security & Privacy Information: teqtivity.com/security