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Whistle Blower Policy

Policy & its Guiding Principles

This Policy covers all employees including Directors of the company. To ensure that this Policy is adhered to, and to assure that the concern will be acted upon seriously, the Company will:

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.
Not attempt to conceal evidence of the Protected Disclosure;
Take disciplinary action, if any one destroys or conceals evidence of the Protected Disclosure made/to be made;
Provide an opportunity of being heard to the persons involved especially to the Subject;

Coverage of Policy

The Policy covers malpractices and events which have taken place/ suspected to take place involving:

Abuse of authority, Breach of contract, Negligence causing substantial and specific danger to public health and safety, Manipulation of company data/records, Financial irregularities, including fraud, or suspected fraud, Criminal offence, Pilferation of confidential/propriety information, Deliberate violation of law/regulation, Wastage/misappropriation of company funds/assets, Breach of employee Code of Conduct/Ethics Policy or Rules, Any other unethical, biased, favoured, imprudent event

Mechanism under policy should not be used in place of the Company grievance procedures or be a route for raising malicious or unfounded allegations against colleagues.

Disqualifications

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.

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.

Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious shall be liable to be prosecuted under Company’s Code of Conduct.

Manner in which concern can be raised

Employees can make Protected Disclosure to Ombudsperson, as soon as possible but not later than 30 consecutive days after becoming aware of the same.

Whistle Blower must put his/her name to allegations. Concerns expressed anonymously WILL NOT BE investigated.

Name of the Whistle Blower shall not be disclosed to the Whistle Officer/Committee unless required for the purpose of investigation.

The Ombudsperson/Whistle Officer/Committee shall:

Make a detailed written record of the Protected Disclosure. The record will include:

Facts of the matter;
Whether the same Protected Disclosure was raised previously by anyone, and if so, the outcome thereof;
Whether any Protected Disclosure was raised previously against the same Subject;
The financial/ otherwise loss which has been incurred / would have been incurred by the Company.

Findings of Ombudsperson/Whistle Officer/Committee

The recommendations of the Ombudsperson/Whistle Officer/Committee on disciplinary/other action/(s).

The Whistle Officer/Committee shall finalize and submit the report to the Ombudsperson within 15 days of being nominated/appointed, unless more time is required under exceptional circumstances.

In case the Protected Disclosure is proved, accept the findings of the Whistle Officer /Committee and take such Disciplinary Action as he may think fit and take preventive measures to avoid re- occurrence of the matter;

In exceptional cases, where the Whistle Blower is not satisfied with the outcome of the investigation and the decision, s/he can make a direct appeal to the Chairman of the Audit Committee.

Reporting

A quarterly report with number of complaints received under the Policy and their outcome shall be placed before the Audit Committee and the Board.

Designed by 3G Solutions.