Whistle Blower Policy

Role of a Whistle Blower / Complainant​

The Whistle Blower/Complainant's role is that of reporting party with reliable information. They are not required to act as investigators nor would determine the appropriate or remedial action. They should also not act nor participate in any investigation activities unle?ss warranted otherwise.

Procedure

1. Every Business/Unit shall formulate a Grievances Redressal Committee ('GRC') comprising of management representatives (Refer : Redressal process of : Operational procedure for ABFL Whistle Blower Policy ) for the following:
   1. To conduct the enquiry in fair and unbiased manner;
   2. To ensure complete fact finding;
   3. To appoint investigating officer(s) / agencies (internal or external) if required;
   4. To maintain strict confidentiality;
   5. To decide on the outcome of the investigation;
   6. To recommend an appropriate course of action and appeal if any;
   7. Such other areas & matter that the Committee may decide upon for the furtherance of its objective;
2. Every ABFL entities/business shall include the Whistle Blower/Grievance Redressal Committee Members in the below format.

   Name	Designation	Contact Details
   Mr. Rakesh Singh	Chief Executive Officer	rakesh.bsingh@adityabirlacapital.com
   Dr. Sujatha Sudheendra	Head - Human Resources & Administration	sujatha.sudheendra@adityabirlacapital.com
   Mr. Manauar Jawed	Head – Retail Risk	Manauar.Jawed@adityabirlacapital.com
   Mr. Udayan Sharma	Head – Emerging Businesses and Wealth	Udayan.Sharma@adityabirlacapital.com
   Whistleblower Generic Email ID for ABFL	ABFL.UVSC@adityabirlacapital.com

3. HR Head shall develop procedures to facilitate the implementation of this policy and shall be the owner of the process.
4. Human Resource function shall implement adequate reporting mechanism for ease and timely reporting.
5. The jurisdiction of the committee is restricted to the violation of code of conduct and/or business ethics alleged to have been committed within one year of the receipt of complaint by the Committee.
6. It shall be the responsibility of the HR Head to create the necessary awareness among all employees' in all cadres and make those concerned/affected known on the company's policies in place.
7. The Committee structure at Unit level shall investigate and recommend action on unethical behaviours, malpractices, wrongful conduct, fraud, violation of the company's policies & Values, violation of law by any employee of ABFL. Any whistle blower/complainant, through written communication, complete with related evidence, can send his/her observation of actual fact(s) to one or more members of the Whistle Blower/Grievance Redressal Committee. The whistle blower/complainant may send the complaint in writing, by an email to the Whistle Blower/Grievance Redressal Committee of the level he / she belongs to, using the standard template (Refer Annexure - 1 The' Template for reporting' below), or log on to the ABC website (http://gportal01/intranet/portal.nsf/LandingForm?openform).

   Example:

   Name	Level	Email address	In writing
   1	Unit	abfl.alert@adityabirla.com	Unit GRC