Any employee or any other related third party who reasonably observes any misconduct/inappropriate business can report the issue to firstname.lastname@example.org. The whistleblower may use the below whistleblowing format for capturing all relevant information that may be needed for a thorough investigation.
Click here to download the Whistleblowing form.
Once the allegation of malpractice or misconduct is made, it will be registered in a confidential Whistleblowing register.
Protection to Whistleblower
The Company will treat all disclosures with utmost confidence and sensitivity. Every effort will be made by the Company to protect the anonymity of the whistleblower.
Anonymity and Confidentiality
- The Company encourages a whistleblower to identify themselves for the purpose of the investigating team to contact for any further information, details, or clarifications. All information, reports, disclosures provided by a whistleblower will be kept confidential.
- A whistleblower can request anonymity / confidentiality and the Company will take all efforts to protect the identity of the whistleblower during and after the investigation unless otherwise required by law.
Protection Against Reprisals
The Company provides assurance that the whistleblower shall be protected against reprisals or retaliation, and immunity from disciplinary action from the whistleblower’s immediate superior or department/division head or any other person exercising power or authority over the whistleblower in his/her employment, provided that:
- A report is made in good faith and the whistleblower have reasonable grounds and does not provide false or misleading information knowingly, negligently, or recklessly in the report;
- the disclosure is not made with malicious intent or ill will;
- the disclosure is not frivolous or vexatious; and
- the report is not made for personal gain or vendetta.
Investigation and reporting
- Once the allegation of malpractice or misconduct is made, it will be registered in a confidential Whistleblowing register and investigated.
- Depending on the nature of the issue raised by a whistleblower, a confidential and neutral Investigation Officer(s) will be appointed by the Group CEO. The investigation team may include internal reviews/inquiries, reviews made by external auditors, lawyers, or any other external body as per the requirement.
- Once the investigation is complete, the Investigation Officer will present the findings, results of the investigation, recommended action on the alleged, including of the corrective steps to prevent the occurrence of a similar incident.
- Based on the Investigating Officer recommendation, Group CEO may approve of relevant actions. The whistleblower will also be updated of the actions taken if the identity of the whistleblower was disclosed while reporting.
- If the claim of malpractice or misconduct is substantiated, appropriate disciplinary action will be initiated against the responsible individual(s) which may include termination of employment. The Company may even initiate legal proceedings through the local court of law.
- However, if the allegations made were proven it was done with a malicious intent and not in good faith, parties responsible may be subject to disciplinary action.
- A whistleblowing register needs to be maintained and all concerns raised, and the investigation procedures need to be recorded. The proceeding of the investigations and actions thereof will be maintained by the Company Secretary who would be responsible in informing the summary of findings and actions initiated to the Board of Directors on a periodical basis.
- Employees should refer the standard operating procedure for Whistleblowing for the detailed process.
Whistleblowing Process Flowchart