Whistle Blower

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To provide a framework to promote responsible and secure whistle blowing to create a fearless environment for the employees to report any instance of unethical behavior, concerns regarding accounting, auditing, internal controls, disclosure practices of the company or suspected fraud or violation of the Company's code of conduct to the Audit Committee.

The company’s wishes to stop serious irregularities within the company, which is against the Code of Conduct & Ethics defined. Through this policy the employees are encourages to raise issues in relations to matters concerning the Company to which the company shall take appropriate action.

“Whistle Blower” is an employee who makes a Protected Disclosure under this policy.

“Protected Disclosure” means a formal charge or an offence raised to a (body/group of people) herein referred as the “Audit Committee” in good faith that discloses or demonstrates information that may evidence unethical or improper activity or activity against the code of conduct of the Company.

“Audit Committee” means a Committee of persons who is/are nominated /appointed by MD and announced to conduct detailed investigation.

The Whistle Blower Policy (‘the policy’) shall be administered by the Audit Committee and HEAD - HR of the Company who will act as Secretary of the Audit Committee.

All Protected Disclosures shall be addressed to the Chairman of the Audit Committee who will be the President or any person appointed by the MD of the Company for investigation.

If a Protected Disclosure is received by any executive of the Company other than Chairman of Audit Committee, the same should be immediately forwarded to the Chairman of the Audit Committee for further appropriate action. Appropriate care must be taken to keep the identity of the Whistle Blower confidential.

Protected Disclosures 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. Alternatively, Protected Disclosures can also be reported orally in person or by phone.

Protected Disclosures received should not be speculative or in the nature of a conclusion, and should contain sufficient details to permit a thorough investigation without need for direct contact with the employee.

The Protected Disclosure shall specifically include:

  • The nature & facts of the compliant
  • The impact/effect either monetary or otherwise on the company
  • The name & address/work location of the Whistle Blower.

However, the Protected Disclosure without name and address of the whistle blower may be investigated at the discretion of the Audit committee.

Each Protected Disclosure will be assigned a unique number for future reference. The Whistle blower may use the number to monitor status & suggested resolution of the Protected Disclosure.

Protected Disclosure will be appropriately dealt with by the Chairman of the Audit Committee.

The chairman of the Audit Committee shall complete the investigation within a maximum of 45 days of the receipt of the Protected Disclosure & submit his report to the management of the company. For investigation, the Audit Committee may appoint such internal committee or external agency as it may deem fit. The decision on the Protected Disclosure will be communicated to the whistle blower by the chairman of the audit committee within 30 days of the submission of the report.

Further, the Audit Committee may call the whistle blower in person to appear before the Committee and explain the matter or give evidence. In case the Protected Disclosure is proved, the Committee shall recommend the management to take necessary Disciplinary Action and advise further to take preventive measures to avoid reoccurrence of similar matter;

In case the Protected Disclosure is not proved the matter would be extinguished

In exceptional cases, the Chairman of Audit Committee may allow the Whistle Blower to make a direct presentation to the Audit Committee without following the above procedure.

Whistle Blowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the Chairman of the Audit Committee or the Investigators.

While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action.

Policy should not be misused or be a route for raising malicious or unfounded allegations against colleagues.

Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention.

To ensure that this Policy is adhered to, and to assure that the concern will be acted upon seriously, the Company will:

  • Do its best to protect whistle blower’s identity when he or she makes a Protected Disclosure.
  • Ensure that the Whistle Blower and/or the person processing the Protected Disclosure is not victimized for doing so.
  • Treat victimization as a serious matter including initiating disciplinary action on such person/(s).
  • Ensure complete confidentiality.
  • Take disciplinary action, if any one destroys or conceals evidence of the Protected Disclosure made/to be made or retaliation in any manner for blowing the whistle under this policy.
  • Provide an opportunity of being heard to the persons involved especially to the subject.

The policy encourages employees to put their names to the Protected Disclosures. Concerns expressed anonymously will be considered at the discretion of the Audit Committee in consultation with Management of the Company. In exercising this discretion, the factors to be taken into account include:

  • The seriousness of the issues raised,
  • The credibility of the Protected Disclosure, and the likelihood of confirming the Protected Disclosure from attributable sources
  • Discuss only to the extent or with the persons required for the purpose of completing the process and investigations

However as a policy, the Whistle Blower, the subject, the Audit Committee and everyone involved in the process shall not discuss the matter in any informal/social gatherings/ meetings If anyone is found not complying with the above, he/ she shall be held liable for such disciplinary action as is considered fit.

  • not keep the papers unattended anywhere at any time
  • keep the electronic mails/files under password