Objective –

The company is committed to the highest levels of ethics & integrity in the way it conducts business and encourages an open and transparent way of working and dealing with employees, customers and the general public.

Applicability- The policy is applicable to

• All employees of the company
• Employees of contractual nature, agency staff, Temporary workers, Management Trainees, Probation employees and directors
• Any other person having an association with the Company

Coverage of Policy –

• This Policy covers malpractices and events which have taken place/ suspected to take place involving but not limited to Corruption/Fraud, Breach of contract, Negligence causing substantial and specific danger to public health and safety, Manipulation of company data/records, Financial irregularities, including fraud or suspected fraud, Any unlawful act whether criminal/ civil including taking bribes, Unauthorized disclosure of confidential/propriety information, Wastage/misappropriation of company funds/assets, Breach of Policy and procedures or failure to implement or comply with any approved Company’s Policy and procedures, Any other act of an Employee which affects the interest of the Company adversely and has the potential to cause financial or reputational loss to the Company.

Protection of Whistle Blower-

• Any employee who observes or notice any unethical and inappropriate behaviour or alleged misconduct in the company may report it to the Department head or Head of Human Resources. The confidentiality of the whistleblower will be maintained to the maximum extent possible.

Compliance Officer-

• Compliance officer is Chief Executive Officer, of the company.

Whistle Blower Complaints Mechanism –

• The Designated Official shall, on receipt of the complaint, arrange to verify the identity of the Whistle Blower.
• The action taken against each disclosure will be also noted and put up to the Reviewing Authority within 7 days of receipt of Complaint. Only on being satisfied that the disclosure has verifiable information, necessary enquiry and investigation will be conducted with regard to the complaint.
• Investigation should be conducted within three months, or such extended time as agreed from the date of receipt of complaint.
• The Compliance Officer, after due enquiries, pass orders for remedies as per the disciplinary policy.
• The cases reported shall be updated in Executive Committee and Audit Committee.