• Redbox is committed to foster an environment of honest and open communication and discussion, consistent with our values.
    • This policy lays down the process to convey Concerns (as stated in Section 4) in good faith to the management and seek resolution towards the same without fear of Whistle-Blower retaliation.
    • This policy ensures that any violations, wrongdoing or non-compliances are addressed appropriately and promptly.


    • Any changes to this policy shall be tracked and documented for future reference. All changes to the policy shall be performed only after prior approval of the Directors.
    • The Directors shall undertake periodic reviews and update this policy to reflect applicable law(s) and latest notifications released by the regulating authorities from time to time.
    • The Directors shall monitor the effectiveness and review the implementation of the principles outlined in this policy, regularly considering its suitability, adequacy and effectiveness.


    • The principles outlined in this Policy apply to all employees, vendors, sub-contractors, customers, and business partners worldwide.
    • In countries where there are more stringent applicable laws, regulations or industry codes, Redbox requires compliance with the most restrictive requirement. The principles set out in this Policy shall stand superseded in those specific countries.
    • This policy covers reporting of any violation, wrongdoing or non-compliance, including without limitation, those relating to the Code of Conduct, policies and standard procedures of Redbox.
    • This policy does not cover the following indicative but not exhaustive aspects:
      • Compensation related issues like quantum of increments, bonus payouts, etc.
      • Queries relating to deduction of tax from salary, etc.
      • Inappropriate administration services e.g. quality of food, malfunctioning of phones, etc.
      • Malfunctioning of information technology assets like laptop, printers, etc.
      • Queries relating to job openings, internal transfers, etc.
      • Recommendations to enhance operational efficiencies and strategy related decisions.


    • Our Whistle Blower Policy is the first and often the best way to provide a platform to address any concern. It is essential that our employees speak up promptly regarding the concern, so that it can be addressed in a timely manner. Redbox will strive to maintain confidentiality to the greatest extent possible and discussion of the concern should be limited to only those individuals with a “need to know.”
    • Employees with management responsibilities play an essential role in the implementation of the principles outlined in this policy. It is the responsibility of these leaders to:
      • Make employees aware of the principles outlined in this policy and Redbox’s commitment to it;
      • Create an environment in which all employees can, without fear of retaliation, raise what they believe, to be honest issues to any level of leadership.
      • Report all the concerns to the Directors promptly.
    • No party, including the subject(s) of a Whistle Blower investigation, may interfere with the investigation. Any attempts to withhold, destroy, damage or tamper with evidence, or attempts to influence/coerce/threaten/entice a party participating in the investigation process, shall warrant a disciplinary action that may even include termination of employment of an employee or termination of association with a party. Furthermore, Redbox shall ensure that any employee assisting in the said investigation is protected to the same extent as a Whistle Blower.
    • All parties must cooperate with the investigation process, without compromising their self-incrimination privileges under applicable laws. Furthermore, investigations must be treated as a fact-finding discovery procedure and not as an accusation in itself. It is possible that the outcome of the investigation may conclude that an individual did not commit an act in violation of the Redbox Code of Conduct or any of Redbox’s policies.


You can convey your concerns through either of the following channels:


    • If the Whistle Blower chooses to express his / her concern, he/she may disclose his/her identity. The Whistle Blower must disclose:
      • Employees or group of employees against whom he/she has a concern; and
      • The nature of the concern
    • The Directors shall assess the basis and merit of the concern. An investigation would be launched only if the concern(s) raised entails unethical or improper conduct in violation of the Redbox Code of Conduct or any of Redbox’s policies and procedures.
    • The Directors may communicate the results of the investigation to the Whistle Blower after completion of the same. The Directors may keep Whistle Blower informed about the development(s) of the investigation.
    • Depending on the nature of concern (s) or complaint(s), the respective Business Heads should extend their co-operation to Directors whenever required.
    • The Directors shall maintain complete confidentiality of Whistle Blower and protect him/her from retaliation during the investigation and after that.


    • Whistle Blower retaliation is an action in response to a protected disclosure of information and includes activities that could adversely affect the Whistle Blower.
    • Retaliation against any Whistle Blower who raises a concern or reports misconduct is strictly prohibited. In case of any reprisals against raising a concern in good faith, you should immediately contact the Directors.
    • If any individual, regardless of his or her role in Redbox, retaliates against a Whistle Blower, Redbox will take appropriate action – even if it later turns out that the Whistle Blower was mistaken in reporting the matter.


    • If at any time, it is revealed that the concern was raised with malicious intent, then the person reporting it will be subjected to disciplinary action, that may even include termination of employment of an employee or termination of association with a party.


What will happen if, upon investigation, the concern reported proves to be false?

    • If the concern raised by the person is in good faith and with a belief of it being accurate, but the investigation proves it to be wrong, Redbox shall take no action against the person.
    • However, if it is proved that the concern was raised with malicious intent, then the person reporting it shall be subject to disciplinary action.

Is there any time limit for reporting of the concern?

    • There is no time limit for reporting the concern. However, the concerns should be reported at the earliest, preferably immediately after the occurrence.

Will an employee reporting a concern be protected?

    • Yes, the employee reporting any concern shall be protected at all the times during his / her tenure with Redbox against any retaliation.

Can the Whistle Blower approach the Directors to seek information on development pertinent to concern reported by him/her?

    • Yes, the Whistle Blower at any point in time after reporting his/her concern can approach the Directors to seek information on developments or investigation related to concern reported by him/her.