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Vigil Mechanism Policy

This Policy is pursuant to the mandate prescribed by Section 177 of the Companies Act, which mandates

  • Every listed company
  • Companies which accepts deposits from the public and
  • Companies that have borrowed from banks/financial institutions more than INR 50 Crores

to establish a Vigil Mechanism for the directors and employees to report genuine concerns or grievances about unethical behaviour, actual or suspected fraud or violation of the company’s Code of Conduct.

EarlySalary Services Private Limited (formerly known as Ashish Securities Private Limited) Pvt Ltd (the “Company”) has adopted a Code of Conduct (“the Code”), which lays down the principles and standards that should govern the actions of the Company and its employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the Company. Such a vigil mechanism shall provide for adequate safeguards against victimization of directors and employees who avail of such mechanism and make provisions for direct access to the Mr. Ashish Sohan Goyal the Director of the Company in exceptional cases.


This policy applies to all the employees of EarlySalary Services Private Limited (formerly known as Ashish Securities Private Limited)


  • To provide a mechanism to employees to report genuine concerns about any unethical, improper practices or any wrongful conduct they observe in the Company.
  • The Vigil Mechanism aims to provide a channel to the Directors and employees to report genuine concerns about unethical behaviour, actual or suspected fraud or violation of policy.
  • The mechanism provides for adequate safeguards against victimization of directors and employees.


This Policy intends to cover serious concerns that could have grave impact on the operations and performance of the business of the Company and malpractices and events which have taken place/suspected to have taken place involving:

  • Breach of business integrity and ethics
  • Breach of terms and conditions of employment and rules thereof
  • Intentional financial irregularities, including fraud, or suspected fraud
  • Violation of any law or regulations, policies including but not limited to corruption, bribery, theft, fraud, coercion and wilful omission.
  • Gross or wilful Negligence causing substantial and specific danger to health, safety and environment
  • Manipulation of company data/records
  • Pilferage of confidential/propriety information
  • Gross wastage/misappropriation of Company funds/assets

The above list is merely illustrative and should not be considered as exhaustive.

The policy is however not a route for taking up a grievance about a personal situation.


  • “Protected Disclosure” means any communication made in good faith discloses or demonstrates information that may evidence unethical or improper activity.
  • "Whistle Blower” means an employee and/or director making a Protected Disclosure under this policy.
  • “Vigilance Officer” is a person nominated/appointed to receive Protected Disclosures from Whistle Blower, maintaining records thereof, placing the same before the Board of Directors of the Company for its disposal and informing the Whistle Blower the result thereof.


All Directors and Employees of the Company are eligible to make Protected Disclosures under the Policy in relation to matters concerning the Company.


  • Any Whistle Blower may report on any unethical or wrongful practices or conduct they have observed in the Company. All Protected Disclosures should be reported in writing by the Whistle Blower as soon as possible.
  • The Whistle Blower’s role is that of a reporting party with reliable information. They are not required or expected to act as investigators or finders of facts nor would they determine the appropriate corrective or remedial action that may be warranted in a given case.
  • It will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment or victimisation.
  • Appropriate care will be taken to keep the identity of the Whistle Blower confidential.
  • Protected Disclosure should preferably be reported, in writing, so as to ensure a clear understanding of the issues raised and should either be typed or written in a legible handwriting in English, Hindi or in the regional language of the place of employment of the Whistle Blower.
  • All Protected Disclosures should be addressed to the Vigilance Officer.
  • However, any abuse of this protection will warrant disciplinary action:
  • Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be malafide or malicious or frivolous, baseless or reported otherwise than in good faith, will be subject to disciplinary/other action.
  • The contact details of the Vigilance Officer are as under: -
  • Name : Ashish Sohan Goyal

    Designation : Whole-Time Director

    Email: grievance@fibe.in

    Address : Unit No. 404, The Chambers, Viman Nagar, Pune - 411014

  • The Board of Directors of the Company shall oversee the implementation of this policy.
  • Any Director of the Company or other officer having any conflict of interest with the matter shall disclose his / her concern/interest forthwith and shall not deal with the matter / investigation process.