NATIONAL HANDLOOM DEVELOPMENT CORPORATION LIMITED
WHISTLE BLOWER POLICY
1. Preface
1.1 The Corporation believes in the conduct of its affairs in a fair and transparent
manner by adopting highest standards of professionalism, honesty, integrity and ethical behavior.
1.2 The Corporation is committed to developing a culture where it is safe for all
employees to rai concerns about any poor or unacceptable practice and any event of misconduct.
1.3 DPE guidelines issued on Corporate Governance vide OM No.18(8)/2005-GM
什么学舌dated 14th May, 2010 provides to establish a mechanism for employees to report to the management, concern about unethical behaviors, actual or suspected fraud, or violation of the company’s General guidelines on conduct or ethics policy. This mechanism could also provide for adequate safeguards against victimization of employees who avail of the mechanism and also provide for direct access to the Chairman of the Audit Committee in exceptional cas.
1.4 The purpo of this policy is to provide a framework to promote responsible and
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cure whistle blowing. It protects employees wishing to rai a concern about rious irregularities within the Corporation.
1.5 The policy neither releas employees from their duty of confidentiality in the
cour of their work, nor is it a route for taking up a grievance about a personal situation.
2. Policy
2.1 This Policy is for the Employees as defined hereinafter.
2.2 The Policy has been drawn up so that Employees can be confident about
raising a concern. The areas of concern covered by this Policy are summarized in paragraph 5.
3. Definitions
3.1 ‘Disciplinary Action’ means any action that can be taken on the completion of/
during the investigation proceedings including but not limiting to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.
3.2 ‘Corporation’ means ‘National Handloom Development Corporation Ltd.’
3.3 ‘Employee’ means all permanent employees of the Corporation.
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3.4 ‘Protected Disclosure’ means a concern raid by a written communication
made in good faith that disclos or demonstrates information that may evidence unethical or improper activity.
3.5 ‘Subject’ means a person against or in relation to whom a Protected Disclosure
is made or evidence gathered during the cour of an investigation.
3.6 ‘Whistle Blower’ is someone who makes a Protected Disclosure under this
Policy.
3.7 ‘Whistle Officer’ or ‘Committee’ means an officer or Committee of persons who
is nominated/appointed to conduct detailed investigation.
3.8 ‘Compliance Officer’ means Company Secretary of the corporation.
3.9 ‘Ombudsperson’ will be the Managing Director for the purpo of receiving all
complaints under this Policy and ensuring appropriate action.
4. The Guiding Principles
4.1 To ensure that this Policy is adhered to, and to assure that the concern will be
acted upon riously, the corporation will:
4.1.1 Ensure that the Whistle Blower and/or the person processing the Protected
Disclosure is not victimized for doing so;
4.1.2 Treat victimization as a rious matter including initiating disciplinary action on
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such person/(s);
4.1.3 Ensure complete confidentiality.
4.1.4 Not attempt to conceal evidence of the Protected Disclosure;
4.1.5 Take disciplinary action, if any one destroys or conceals evidence of the
Protected Disclosure made/ to be made;
4.1.6 Provide an opportunity of being heard to the persons involved, especially to the
Subject;
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5. Coverage of Policy
5.1 The Policy covers malpractices and events which have taken place/ suspected少女壁纸
to take place involving:
1.) Abu of authority
2.) Breach of contract
3.) Negligence causing substantial and specific danger to public health and
safety
4.) Manipulation of company data/ records
5.) Financial irregularities, including fraud, or suspected fraud
6.) Criminal offence
7.) Pilferage of confidential/ propriety information
8.) Deliberate violation of law/ regulation
9.) Wastage/ misappropriation of company funds/ asts
10.) Breach of employee Code of Conduct or Rules
11.) Any other unethical, biad, favoured, imprudent event
5.2 Policy should not be ud in place of the corporation’s grievance procedures
including but not limited to compensation, increment, promotion, job location, job profile, immunities, leaves and training or other privileges or be a route for raising malicious or unfounded allegations against colleagues/ niors.
6. Disqualifications
6.1 While it will be ensured that genuine Whistle Blowers are accorded complete
protection from any kind of unfair treatment as herein t out, any abu of this protection will warrant disciplinary action.
6.2 Protection under this Policy would not mean protection from disciplinary action
arising out of fal or bogus allegations made by a Whistle Blower knowing it to be fal or bogus or with a mala fide intention.
6.3 Whistle Blowers, who make any Protected Disclosures, which have been
subquently found to be mala fide, frivolous or malicious shall be subject to disciplinary action, up to and including termination of employment, in accordance with corporation’s rules, policies and procedures. Further, this policy may not be ud as a defen by an employee against whom an adver personnel action has been taken independent of any disclosure of information by him and for legitimate reasons or cau under corporation’s rules and policies.
7. Manner in which concern can be raid:
7.1 Employees can make Protected Disclosure to Ombudsperson, as soon as
possible but not later than 30 concutive days after becoming aware of the same.
7.2 Whistle Blower must put his/ her name to allegations. Concerns expresd
anonymously WILL NOT BE investigated.
7.3 If initial enquiries by the Ombudsperson indicate that the concern has no basis,
or it is not a matter of investigation under this Policy, it may be dismisd at this stage and the decision is documented.
7.4 Where initial enquiries indicate that further investigation is necessary, this will
be carried through either by the Ombudsperson alone, or by a Whistle Officer/ Committee nominated by the Ombudsperson for this purpo. The investigation would be conducted in a fair manner, as a neutral fact-finding process and without presumption of guilt. A written report of the findings would be made.
7.5 Ombudsperson/ Whistle Officer/ Committee shall have right to call for any
information/document and examination of any employee of the Corporation or other person(s), as they may deem appropriate for the purpo of conducting investigation under this policy.
7.6 Name of the Whistle Blower shall not be disclod to the Whistle Officer/
Committee.
7.7 The Ombudsperson/ Whistle Officer/ Committee shall:
i) Make a detailed written record of the Protected Disclosure. The record will
include:
a) Facts of the matter
b) Whether the same Protected Disclosure was raid previously by
anyone, and if so, the outcome thereof;
c) Whether any Protected Disclosure was raid previously against the
same Subject;
d) The financial/ otherwi loss which has been incurred/ would have
been incurred by the Company.
e) F indings of Ombudsperson/ Whistle Officer/ Committee;
f) The recommendations of the Ombudsperson/ Whistle Officer/
Committee on disciplinary/ other action/(s).
ii) The Whistle Officer/ Committee shall finalize and submit the report to the Ombudsperson within 15 days of being nominated/ appointed.
7.8 On submission of report, the Whistle Officer/ Committee shall discuss the
matter with Ombudsperson who shall either:
i) In ca the Protected Disclosure is proved, accept the findings of the
Whistle Officer/ Committee and take such Disciplinary Action as he may就开头的成语
think fit and take preventive measures to avoid reoccurrence of the matter;
ii) In ca the Protected Disclosure is not proved, extinguish the matter;
Or
iii) Depending upon the riousness of the matter, Ombudsperson may refer the matter to the Audit Committee of Directors with propod disciplinary
action/ counter measures. In ca the Audit Committee thinks that the
matter is too rious, it can further place the matter before the Board with
its recommendations. The Board may decide the matter as it deems fit.
7.9 In exceptional cas, where the Whistle Blower is not satisfied with the
outcome of the investigation and the decision, s/he can make a direct appeal to the Chairman of the Audit Committee.
8. Protection
三重一大事项决策制度8.1 No unfair treatment will be meted out to a Whistle Blower by virtue of his/her
having reported a Protected Disclosure under this Policy. The corporation, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle Blower.
Complete protection will, therefore, be given to Whistle Blower against any unfair practice like retaliation, threat or intimidation of termination/suspension of rvice, disciplinary action, demotion, refusal of promotion, discrimination, any type of harassment, biad behavior or the like including any direct or indirect u of authority to obstruct the Whistle Blower’s right to continue to perform his duties/functions including making further Protected Disclosure.
8.2 The identity of the Whistle Blower shall be kept confidential.
8.3 Any other Employee assisting in the said investigation or furnishing evidence
shall also be protected to the same extent as the Whistle Blower.
9. Secrecy/ Confidentiality
The Whistle Blower, the Subject, the Whistle Officer and every one involved in the process shall:
a) maintain complete confidentiality/ crecy of the matter
b) not discuss the matter in any informal/ social gatherings/ meetings
