This Whistle Blower Policy seeks to provide an avenue to directors and employees of the Company and other persons dealing with the Company to report without fear any instance of actual or suspected violation, wrongdoings or any unethical or improper practice which may adversely impact the image and / or the financials of the Company, through an appropriate forum, and to communicate the existence of this mechanism, within the organization and to outsiders. This will help persons who have major concerns over any wrongdoing within the Company to report unlawful activities, accounting irregularities, etc. The objective is to maintain a redressal system which can process all such complaints /concerns and provide a resolution.
It is not possible to give an exhaustive list of all the activities intended to be covered, broadly speaking, the following acts are to be covered:
Forgery or alteration of documents
Unauthorised alteration or manipulation of computer files
Financial and accounting irregularities including mismanagement and misreporting
Criminal offence (eg. fraud, physical violence or theft) committed / likely to be committed
A Whistleblower is any person or entity making a disclosure of fraudulent activity that they have observed. Whistleblowers could be directors, employees, apprentices, trainees,contractors, contractor’s employees, clients, vendors, internal or external auditors, lawenforcement / regulatory agencies or other third parties. A whistleblower, who finds that a director, another employee or an outsider is engaged in conduct which may inappropriately affect the financials or the image of the Company can, without expecting any reward in return blow the whistle i.e. report the matter to the management as per the guidelines given below. Such an employee is known as a ‘WHISTLEBLOWER’ and the act of reporting is known as ‘WHISTLEBLOWING’.
This Whistle Blower Policy comes into force from March 1, 2016.
This Whistle Blower Policy is applicable to all directors and employees of the Company in relation to matters concerning the Company.
The Whistleblower’s role is that of a reporting party with reliable and truthful information and they are not expected to act as investigators or fact finders. They should not act on their own and are likely to participate in any investigation aspect only when required by the ‘Whistleblowing Investigation Committee’.
Whistleblowing Investigation Committee
The Committee will comprise of the Chief of Operations, Head – HR and Chief Financial Officer of the Company.
A perceived wrongdoing or an act for whistle blowing should be addressed to the Whistleblowing Investigation Committee of the Company. Any investigation shall be carried out by the officials of the Company or independent Investigators, as decided by the Committee. The identity of the Whistleblower should be maintained confidential by taking due care.
The matter should be reported at the following address:
Whistleblowing Investigation Committee
C3-C7, SKCL Triton Square, TVK Industrial Estate
Guindy, Chennai 600 032
Email : firstname.lastname@example.org
Any such matter, if received by any executive of the Company other than the Committee should be forwarded to the Committee for further appropriate action and care taken to keep the identity of the Whistleblower confidential.
The matter should preferably be reported in writing with a Cover Letter, to ensure clear understanding of the issues raised and should be either typed or written in legible handwriting, bearing the identity of the Whistleblower only on the cover letter. Anonymous letters will not be considered by the Committee.
The matter reported should be factual and not speculative or in the nature of a conclusion and should contain as much specific information as possible, to allow appropriate assessment of the nature and extent of the concern.
The Investigation will be conducted under the authorization of the Committee by appointing a team of officials / investigators, at its discretion. The officials / investigators shall complete the investigation within 45 (forty five) days or such extended time as may be granted by the Committee. Decision on the report will be taken by the Committee within 30 days of the date of the report.
On completion of the investigation, it would be the responsibility of the Committee to recommend suitable action to the management and also advise the concerned Departmental Head, where applicable, to take suitable corrective measures to avoid recurrence of such matters and take suitable disciplinary action against the alleged person.
All matters considered by the Committee with the decisions taken, shall be reported to the Chief Executive.
Protection of Whistleblower
Employees should feel free to report matters of wrongdoing to the Committee without fear of any repercussion on themselves. The management assures maintaining anonymity of the Whistleblower at all times. The management also affirms that the Whistleblower shall be protected from unfair termination and any other unfair prejudicial employment practices, which the Whistleblower may face from any quarters within the Company due to the act of whistle blowing.
Any other employee assisting in the said investigation shall also be protected to the same extent as the Whistleblower.
If at any time, whistleblower perceives or apprehends that he is being unfairly victimized or harassed due to his act of whistle blowing, he shall have the right to approach the Whistleblowing Investigation Committee who will review the Whistleblower’s complaint and take appropriate action, as applicable, to ensure that the Whistleblower is not so subjected to any unfair or prejudicial employment practices on account of his alleged victimization.
Retention of documents
All such matters reported by the Whistleblower under this Policy along with results of investigation relating thereto shall be retained by the Company for a minimum period of 7 (seven) years.
Communication of Policy
The Policy shall be uploaded on the website of the Company and the intranet of the Company
The Company reserves the right to amend or modify this Policy in whole or part, in accordance with any regulatory amendment or notification or otherwise, at any time without assigning any reason whatsoever. Any such amended Policy will be communicated to all the stakeholders concerned from time to time.
In case of repeated frivolous complaints being filed by any person, the Committee may take suitable action against such person, including reprimand.