WHISTLE BLOWER POLICY

I. Scope of the Policy

1.1 DLearners is committed to adheringto the highest standards of ethical, moral,and legal conduct of business operations.

1.2 Employees and representatives of the DLearnersmust practice honesty and integrity in fulfilling individual and organizational responsibilities and comply with all applicable laws and regulations.

1.3 DLearners encourages its employees who have concerns about suspected misconduct, to come forward and express these concerns without fear of punishment or unfair treatment.

II. Reporting Responsibility

2.1 This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that DLearnerscan address and correctinappropriate conduct and actions.

2.2 It is the responsibility of all board members, officers, employees,and volunteers to report concerns about suspected violations of any of DLearners’ policies or lawsor regulations that govern DLearners’ operations, orany other laws in force in India.

III. No Retaliation

3.1 It is contrary to the values of DLearnersfor anyone to retaliate against any board member, officer, employee,or volunteer,who in good faith reports a suspected violation of any of DLearners’ policies or applicable law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of DLearners, or any laws in force in India.

3.2 An employee who retaliates against someone who has reported a violation in good faith, may be subjected to disciplinary action, including termination of employment.

IV. Reporting Procedure

4.1 DLearnershas an open-doorpolicy and suggests that employees share their questions, concerns, suggestions,or complaints with their supervisor.

4.2 If the employee is not comfortable speaking with theirsupervisor or theyare not satisfied with theirsupervisor’s response, theyare encouraged to speak with Director. Mr. Arun Fernandez.

4.3 Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the DLearners’ Compliance OfficerMs. Deepika and Mr. Shreenath, who has the responsibility to investigate all reported complaints.

4.4 Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Executive Director or the organization’s Compliance Officer.

V. Compliance Officer

5.1 The DLearners Mr. Shreenathand Ms. Deepika is responsible for ensuring that all complaints about suspected illegal conduct are investigated and resolved.

5.2 The Compliance Officer will advise the Director Mr. Arun Fernandez of all complaints and their resolution.

VI. Acting in Good Faith

6.1 Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.

6.2 Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

VII. Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation

VIII. Handling of Reported Violations

8.1 The DLearners Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation.

8.2 All reports will be promptly investigated,and appropriate corrective action will be taken if warranted by the investigation.

Contact information of Compliance Officer:

Shreenath. D, Founders Desk.

shreenath@dlearners.in

Deepika. S, Human Resource.

deepika@dlearners.in

Policy approved by the Board of Directors on 2018.