Whistle Blower Policy

  1. The complainant may alternatively report the incident to his / her functional head or manager who will then report it (in writing) to the relevant GRC or Group Value Committee.
    If the breach of Code of Conduct or Values is at:
    1. Any level below the function Head level, the same should be reported to the respective Unit level Whistle Blower/Grievance Redressal Committee (UGRC).
    2. At Functional Head level, the employee should write to the Business level Whistle Blower/Grievance Redressal Committee (BGRC)
    3. At Unit Head Level and above, the same should be reported to the Group Value Committee (GRC).
    4. In cases where complaint is against any member of the Business Committee the same should be reported to the Group Value Committee (GRC)
    5. In case where complaint is against any member of the Unit Committee the same should be reported to the Business level Whistle Blower/Grievance Redressal Committee (BGRC)
  2. In case of urgent matters, the whistle blower/complainant may communicate verbally (through phone or in person) but he/she must put the case in writing at the first available opportunity.
  3. The reporting should be factual and not speculative and should, to the extent possible, contain the following, in order to allow proper assessment of the nature and extent of the matter:
    1. The alleged event, matter or issue that is the subject of the Complaint;
    2. The name(s) of the person(s) involved;
    3. If the Complaint involves a specific event or events, the approximate time and location of each event; and
    4. Any additional information, documentation or other evidence available to support the complaint. The prescribed format as per Annexure 1 "Template for Reporting Violation" shall be used for reporting.
  4. For the purpose of providing protection to the whistle blower/complainant, he/she should disclose his/her identity.
  5. Anonymous reporting shall not be entertained as it is usually impractical to investigate a complaint which has been made anonymously. However the whistle blower / complainant may seek the advice of the Committee and based on the advice sought, formally record the complaint as per Annexure 1 of this policy.
  6. If a protected disclosure is received by any executive of the Company other than the CEO or any other Management Representative, the same should be forwarded to the respective Whistle Blower/Grievance Redressal Committee.
  7. The following types of complaints would ordinarily not be entertained:
    1. Illegible, if handwritten;
    2. Vague, anonymous or pseudonymous;
    3. Trivial or frivolous in nature;
    4. The matters which are pending before a Court of Law, State or National Human Rights Commission or any other Commission, Tribunal or any other judiciary or sub-judiciary body;
    5. Any matter, after the expiry of one year from the date on which the act constituting violation of human rights is alleged to have been committed;
    6. Allegation, which is not against the interests of ABC Entities employee as stated above;
    7. Issue raised relates to civil dispute, such property rights, contractual obligations, etc;
    8. Issue raised relates to service matters;
  8. Upon receipt of the complaint the Whistle Blower / Grievance Redressal Committee members, after proper scrutiny, shall investigate as per the "Whistle Blower / Grievance Redressal Committee Charter".
  9. The members shall ascertain the authenticity and correctness of the complaint and shall recommend necessary corrective measures/disposal as follows:-
    1. Closing the complaint, if wrongful conduct remains largely unsubstantiated; and if the case is false and malicious in intent, the whistle blower / complainant would be held guilty of misconduct and appropriate action shall be taken. However, the Committee shall distinguish between mistaken reporting and malicious intent of the employee.
    2. If charges are substantiated, or the complaint is found correct on investigation, suitable action will be suggested; and If the employee is not satisfied with the investigation he may appeal to the next level Whistle Blower / Grievance Redressal Committee.
    3. Lessons identified/learnt shall be used for strengthening the policies and procedures.
  10. The Whistle Blower / Grievance Redressal Committee based on the decisions/recommendations, shall take appropriate action immediately within a stipulated timeframe of Three weeks.
  11. Head Human Resource shall escalate unresolved matters to the next level depending on the nature of complaint (viz. values, sexual harassment) beyond its associated resolution timeframe.
  12. The Committee shall submit periodic report in prescribed Format (Refer: Annexure- 3 of Operational procedure for ABC Whistle Blower Policy) to the Audit Committee of the Board of Directors on the issues reported to it, from time to time for its review & perusal.
  13. The Audit Committee of the Board of Directors shall oversee the vigil mechanism through the Committee and if any of the members of the Committee have a conflict of interest in a given case, they should recuse themselves and the others on the Committee would deal with the matter on hand.
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