Whistle Blower Policy 254t6f

BY: Priyanka Amin (PG-10-62) Pranjali Patki (PG-10-98) Kalyani Gadre (PG-10-71)

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Anyone who makes a good faith effort to disclose information about  

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Disclosure may be oral or written The alleged misconduct may be 

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―Improper activities‖ or alleged dishonest or illegal activities Significant threats to public health and safety

a violation of a law, rule, regulation and/or a direct threat to public interest, such as fraud, health/safety violations, and corruption.

Whistle-blowers may make their allegations internally (for example, to other people within the organization) or externally (to regulators, law enforcement agencies, to the media or to groups concerned with the issues).

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Actions that violate ―any law or regulation,‖ including but not limited to:  

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Corruption Bribery Theft or misuse of property Fraud Coercion Willful omission

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Economic waste; Gross misconduct, gross incompetence, or gross inefficiency Not limited to misuse of money. Also applies to: Sexual harassment  Scientific misconduct  Improper use of authority 

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Fraud prevention Better governance To protect the whistle blower Encourage timely, safe, and honest reporting of alleged wrongs Ensure consistent and timely institutional response

If someone on your staff comes to you with an allegation: Ask questions. Get as much detail as you can from the whistleblower  Encourage the whistleblower to make a written report  If whistleblower won’t put it in writing, you should document your conversation in detail 

If your whistleblower wants to be anonymous: Advise him/her that confidentiality will be maintained to the extent possible,  But within 

 Limitations of law and policy  Need to conduct a competent investigation

If you think the alleged act—if true— might be an improper governmental activity: 

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Consult with and/or report it to  Your supervisor,  Appropriate manager (HR, Audit, etc.), or

If you suspect a crime has been committed, notify the police!

You should ―exercise appropriate judgment‖ in deciding whether to refer to a higher level of management  Try to balance your need to manage with the Organization's need to know

You must refer to the manager if alleged act: 

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Results from an internal control or policy deficiency likely to exist elsewhere Is likely to receive media attention Involves potentially large amounts of money Involves possible crimes Involves a significant threat to health and safety Is significant or sensitive for other reasons

You are a supervisor, not an investigator! 

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OK to perform oversight, analysis, review, etc., within the normal scope of your job, but Do not launch your own investigation

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Listing Agreement- Clause 49 – ―Corporate Governance‖ Non- Mandatory Requirements- Annexure I DWhistle Blower’s Policy

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A Mechanism for employees to report about unethical behavior Provision for adequate safeguards against victimization of employees Direct access to Chairman of the Audit Committee Communication about the existence of the mechanism

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In 2003, the Law Commission of India recommended the adoption of the Public Interest Disclosure (Protection of Informers Act, 2002) In August 2010, the Public Interest Disclosure and Protection of Persons Making the Disclosures Bill, 2010 was introduced into the Parliament of India, Lok Sabha. LIC housing finance Ltd. Kotak Mahindra Bank, Asian Paints have adopted the Policy – Annual Report 2008-09 Ashok Leyland has an independent Ombudsman, who is not an employee of the Company.

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Definition: An Office provided for by the Constitution or by action of the Legislature or Parliament and headed by an independent, high-level public official Responsible to the Legislature or Parliament Receives complaints from aggrieved persons against Government agencies, officials and employees Acts on one’s own motion Power to investigate, recommend corrective action, and issue reports

• A person who acts as a trusted intermediary between an organization, and internal employees, while representing not only but mostly the broad scope of constituent interests • An organizational ombudsman can • provide options to whistleblowers or employees with ethics concerns, • provide mediation for conflicts, • track problem areas, and • make recommendations for changes to policies or procedures in of orderly systems change. • An important function is to pick up "new disruptive issues" that require the organization to review and possibly improve its policies, procedures and/or structures.

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Adopted by the audit committee of BOD on April 9th, 2003 Recognizes the value of transparency and ability in its istrative and management practices. Encourages employees, to report fraudulent financial information or grave misconduct to the Company’s management or to raise those concerns by sending e-mail to [email protected] Specific action taken depends on the nature and gravity of the conduct or circumstances reported, and the quality of the information provided

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Report those facts to your immediate supervisor or to the corporate counsel. document your report in writing All complaints under this policy will be promptly and thoroughly investigated all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation

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strictly prohibits any discrimination, retaliation or harassment against  

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person who reports incidents person who participates in an investigation of complaints

If a complaint of discrimination, retaliation or harassment is substantiated, appropriate disciplinary action, up to and including discharge, will be taken.

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All documents related to the reporting, investigation and enforcement of this policy, as a result of a report of such matters, shall be kept in accordance with the Company’s record retention policy and applicable law.

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In addition to the Company’s internal complaint procedure, employees should also be aware that certain federal and state law enforcement agencies are authorized to review questionable ing or auditing matters, or potentially fraudulent reports of financial information Conduct that violates the Company’s policies will be viewed as unacceptable under the of employment at the Company

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The audit committee or BOD of the Company can modify this Policy unilaterally at any time without notice. Modification are necessary, to maintain compliance with State and Federal regulations and / or accommodate organizational changes within the Company.

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Sherron Watkins Vice President, Enron In August 2001 she wrote a letter to Kenneth Lay warning of ing irregularities that could pose a threat to the company Kenneth Lay was the company founder Former Chief Executive was Jeffery Skilling

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She has never been charged with insider trading, allegedly said that Lay knew Enron was in financial turmoil when he claimed publicly that the company was strong in the fall of 2001. The government contends Skilling also lied about the company’s financial condition before he resigned.

―I am incredibly nervous that we will implode in a wave of ing scandals. My eight years of Enron work history will be worth nothing on my résumé, the business world will consider the past successes as nothing but an elaborate ing hoax‖ In 2001, Enron was once the nation’s seventhlargest company and it sought bankruptcy protection by year’s end !!!

Thank You