Exhibit 99.7


                              WHISTLEBLOWER POLICY

                                       OF

                          INFOSYS TECHNOLOGIES LIMITED

 (as adopted by the Audit Committee of the Board of Directors on April 09, 2003)

         As a public company, the integrity of the financial information of
Infosys Technologies Limited (the "Company") is paramount. The Company's
financial information guides the decisions of the Board of Directors of the
Company (the "Board of Directors"), and is relied upon by our stockholders and
the financial markets. For these reasons, the Company must maintain a workplace
where the Company can retain and treat all complaints concerning questionable
accounting, internal accounting controls, or auditing matters (collectively
"Questionable Accounting/Audit Matters"), or the reporting of fraudulent
financial information to our shareholders, the government or the financial
markets. and where employees can raise these concerns free of any
discrimination, retaliation or harassment.

         The Company recognises the value of transparency and accountability in
its administrative and management practices, and therefore also supports the
making of disclosures that reveal Grave Misconduct, i.e., conduct which results
in a violation of law by the Company or in a substantial mismanagement of
company resources and if proven constitutes a criminal offence or reasonable
grounds for dismissal of the person engaging in such conduct.

         Therefore, it is the policy of the Company to encourage employees, when
they reasonably believe that questionable Accounting/Audit matters,, or the
reporting of fraudulent financial information to our shareholders, the
government or the financial markets and/or Grave Misconduct have occurred or are
occurring, to report those concerns to Company management (on an anonymous
basis, if employees so desire) or to raise those concerns by e-mailing the
Company's e-mail id for this purpose, on an anonymous basis, as described below.
All reports will be taken seriously and will be promptly investigated. The
specific action taken in any particular case depends on the nature and gravity
of the conduct or circumstances reported, and the quality of the information
provided. Where Questionable Accounting/Audit Matters have occurred, or
fraudulent financial information has been reported to our shareholders, the
government or the financial markets, or Grave Misconduct has occurred, those
matters will be corrected and, if appropriate, the persons responsible will be
disciplined.

         In addition, the Company is committed to providing a work environment
in which employees, when they reasonably believe that Questionable
Accounting/Audit Matters have occurred, or that fraudulent financial information
has been reported to our shareholders, the government or the financial markets,
or that Grave Misconduct has occurred, can raise those concerns free of
discrimination, retaliation or harassment. Accordingly, the Company strictly
prohibits discrimination, retaliation or harassment of any kind against any
employee who, based


on the employee's reasonable belief that such conduct or practices have occurred
or are occurring, reports that information.

                           REPORTING AND INVESTIGATION

         If you have reason to believe that you have become aware of
Questionable Accounting/Audit Matters, or the reporting of fraudulent financial
information to our shareholders, the government or the financial markets, or of
Grave Misconduct, you must immediately report those facts to your immediate
supervisor or to the Corporate Counsel. You may then be requested to document
your report in writing. You may also report your concerns anonymously by
e-mailing the Company's e-mail id for this purpose at whistleblower@infosys.com
or by sending an anonymous letter to the Corporate Counsel. If you have reason
to believe that both of those individuals are involved in these matters, you
should report those facts to the Audit Committee of the Company's Board of
Directors (the "Audit Committee").

         If you later believe that you have been subject to discrimination,
retaliation or harassment for having made a report under this Policy, you must
immediately report those facts to your immediate supervisor or the Corporate
Counsel. If, for any reason, you do not feel comfortable discussing the matter
with your immediate supervisor or the Corporate Counsel, you should bring the
matter to the attention of the supervisor of your immediate supervisor, and if
you are not comfortable with discussing the matter with any of those
individuals, you should bring the matter to the attention of the Audit
Committee. It is imperative that you bring the matter to the Company's attention
promptly so that any concern of discrimination, retaliation or harassment can be
investigated and addressed promptly and appropriately.

         All complaints under this Policy will be promptly and thoroughly
investigated, and all information disclosed during the course of the
investigation will remain confidential, except as necessary to conduct the
investigation and take any remedial action, in accordance with applicable law.
All employees and supervisors have a duty to cooperate in the investigation of
reports of Questionable Accounting/Audit Matters, or the reporting of fraudulent
financial information, or of Grave Misconduct, or of discrimination, retaliation
or harassment resulting from the reporting or investigation of such matters. In
addition, an employee shall be subject to disciplinary action, including the
termination of their employment, if the employee fails to cooperate in an
investigation, or deliberately provides false information during an
investigation. If, at the conclusion of its investigation, the Company
determines that a violation of policy has occurred, the Company will take
effective remedial action commensurate with the severity of the offense. This
action may include disciplinary action against the accused party, up to and
including termination. Reasonable and necessary steps will also be taken to
prevent any further violations of policy.

                    DISCRIMINATION, RETALIATION OR HARASSMENT

         The Company strictly prohibits any discrimination, retaliation or
harassment against any person who reports incidents of questionable accounting
or auditing matters, or the reporting of fraudulent financial information, or of
Grave Misconduct, based on the person's reasonable belief that such misconduct
occurred. The Company also strictly prohibits any discrimination,


retaliation or harassment against any person who participates in an
investigation of complaints about questionable accounting or auditing matters,
or of the reporting of fraudulent financial information, or of Grave Misconduct.

         Any complaint that any managers, supervisors, or employees are involved
in discrimination, retaliation or harassment related to the reporting or
investigation of questionable accounting or auditing matters, or the reporting
of fraudulent financial information, or of Grave Misconduct shall be promptly
and thoroughly investigated in accordance with the Company's investigation
procedures. If a complaint of discrimination, retaliation or harassment is
substantiated, appropriate disciplinary action, up to and including discharge,
will be taken.

                                    RETENTION

         All documents related to the reporting, investigation and enforcement
of this policy, as a result of a report of questionable accounting, internal
accounting controls, or auditing matters, or the reporting of fraudulent
financial information to our shareholders, the government or the financial
markets or of Grave Misconduct, or of the discrimination, retaliation or
harassment of an employee that made such a report, shall be kept in accordance
with the Company's record retention policy and applicable law.

                       ADDITIONAL ENFORCEMENT INFORMATION

         In addition to the Company's internal complaint procedure, employees
should also be aware that certain central, federal, local and state law
enforcement agencies are authorized to review questionable accounting or
auditing matters, or potentially fraudulent reports of financial information.
The Company's policies and practices have been developed as a guide to our legal
and ethical responsibilities to achieve and maintain the highest business
standards. Conduct that violates the Company's policies will be viewed as
unacceptable under the terms of employment at the Company. Certain violations of
the Company's policies and practices could even subject the Company and any
individual employees involved to civil and criminal penalties. Before issues or
behavior can rise to that level, employees are encouraged to report Questionable
Accounting/Audit Matters, suspicion of fraudulent financial information, or
Grave Misconduct, or discrimination, retaliation or harassment related to such
reports. Nothing in this Policy is intended to prevent an employee from
reporting information to the appropriate agency when the employee has reasonable
cause to believe that the violation of a central, federal, local or state
statute or regulation has occurred.

                                  MODIFICATION

         The Audit Committee or the Board of Directors of the Company can modify
this Policy unilaterally at any time without notice. Modification may be
necessary, among other reasons, to maintain compliance with local, state,
central and federal regulations and/or accommodate organizational changes within
the Company.

                 [Reminder of the Page Left Intentionally Blank]



         Please sign the acknowledgment form below and return it to Human
Resources. This will let the Company know that you have received the
Whistleblower Policy and are aware of the Company's commitment to a work
environment free of discrimination, retaliation or harassment for reporting of
questionable accounting, internal accounting controls, or auditing matters, or
fraudulent financial information, or Grave Misconduct as well as your
obligations to report such information.

                          ACKNOWLEDGMENT AND AGREEMENT
                       REGARDING THE WHISTLEBLOWER POLICY

         This is to acknowledge that I have received a copy of the Company's
Whistleblower Policy. I understand that, as a public company, the integrity of
the financial information of the Company is paramount. I further understand that
the Company is committed to a work environment free of discrimination,
retaliation or harassment for employees who have raised concerns regarding
questionable accounting, internal accounting controls, or auditing matters, or
reporting of fraudulent financial information, or of Grave Misconduct and that
the Company specifically prohibits discrimination, retaliation or harassment
whenever an employee makes a good faith report regarding such concerns.
Accordingly, I specifically agree that to the extent I have concerns that I
reasonably believe to be related to questionable accounting, accounting
controls, auditing matters, or reporting of fraudulent financial information, or
of Grave Misconduct, or which is otherwise in violation of the Company's
policies, I will immediately report such conduct in accordance with the
Company's Whistleblower Policy.

         I understand and agree that to the extent I do not use the procedures
outlined in the Whistleblower Policy, the Company and its officers and directors
shall have the right to presume and rely on the fact that I have no knowledge or
concern of any such information or conduct.

                                    ____________________________________________
                                    Employee's signature

                                    ____________________________________________
                                    Employee's Name [printed]

                                    ____________________________________________
                                    Date