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Whistle Blower Policy

 

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WHISTLEBLOWER POLICY


 

What is Whistle Blowing Policy and Procedure? Whistleblower Meaning and Definition :

As per whistle blower meaning an employee rises complain for any wrongdoing within the organisation. The whistleblower policy in business exists in an organisation to give authority to employees to raise their concern against any breach of code of conduct, misconduct, misbehaviour, illegal activity, sharing of confidential information, patent etc. Wrong doing generally include when an employee has done any criminal offense or an employee has poised danger to health and safety of others, sharing or leakage of any confidential information to others. An employee must genuinely believe that there is wrongdoing in employer business (Whistle blower policy in business) and a company is committed to highest standard of openness, probity and accountability. This policy is meant to guide individuals who have discovered any improper act or wrongdoing. Any matter which is being taken care under harassment, complain, disciplinary action should not be taken under whistle blower policy.

 

Types of Whistle Blower Policy 

There are two types of whistle blower policy, internal and external. Internal when concern is raised within the organisation and external when concern is raised outside of organisation for instance to media etc. but in both the cases It is the employee whistleblower who raise the concern.

 

Who is a whistleblower?

A whistle blower is defined as someone who raises a concern against any of the activity happening in the organisation which is unethical in nature. The activity has been explained in above paragraph. The whistleblower policy example includes any concern raised to prevent the loss to the organisation and to protect the company from any bad image.  Beneath said approach is Whistle blower strategy test. Alongside shriek blower arrangement test It is essential to have a culture in the association which bolsters the informant strategy. Some steps can be taken for promoting a whistleblower culture:

  1. Make a whistle blower policy and announce it.
  2. Stress on communication about bans on retaliation for whistle blowing activities.
  3. Message of incorporation of whistleblower must percolate down from top to bottom i.e. from top management to entry level employees.
  4. There should be commitment of implementing whistle blower
  5. In the event that there is inappropriate act, it must be altogether researched through whistleblower

Having a corporate whistle blower is important from various angles. It generates the environment of trust and integrity within the organisation. However it is foremost responsibility of top management to provide safety and security to the whistleblower. 

 

Some benefits of having a whistleblower in workplace can be explained as:

  1. Make employees vigilant about any wrongdoing
  2. Remove corruption
  3. Make employees more responsible by giving them authority to raise concern
  4. Reduces risk happening
  5. More jobs to internal auditors etc to create a strong mechanism.
  6. With whistleblower policy once can outline consequences of making false accusations about the company.

However it is to be noted that the protection is given to employees in terms of confidentiality and against retaliation. This is to be followed as Confidence is given to employees so that they can share freely any improper act which they come across while working. As per the whistle blower policy, the complaint is made to whistle officer who in turn investigate with the investigation team. Finally, the final call is taken by whistle officer in consultation with audit committee. This is as per whistle blower process. The whistle blower examples should not be confused with grievances as they are dealt separately by HR.

 

   

 

In the whistle blower policy we have tried explaining the objective of the policy, eligibility under the policy, definitions which are used within the policy, reportable matters, and guidelines procedures. What are the responsibilities of whistleblower, whistle officer, investigation team, disclosure and reporting of improper act, protection that is given to the whistle blower, rights of a subject, It also

includes the corporate whistle blower policy and whistle blower process.  Whistle blowing at work includes who is a whistle blower, what are the various steps of investigation, Actions on false allegations, documentation, retention of documents, sharing of reports and documents and process flow of whistleblower.

 

Disclaimer: The content prepared has been created with greatest care.

These policies have been prepared for sample. However for accuracy

and completeness hrhelpboard.com cannot guarantee.

The user is therefore requested to professionally check or

to have professionally checked the suitability of all content for its use.



 

 

  

 

Sample 1. Whistle blower Policy Template

 

 
 
Index
1. Objective
2. Scope
3. Definitions
4. Whistleblower complaint
5. Principle of reporting
6. Protection
7. Areas covered under the policy
8. Whistleblower process
9. Management assurance
10. Corporate ombudsperson
11. Investigation process
12. Roles and responsibilities
13. Confidentiality
14. Retention of documents 

 
1. Objective 
 
a. The objective of whistleblowing policy is to give employees, investors, contractors, vendors, and other stakeholders a platform whereon they can raise their concern against any wrongdoing done by the company.
b. To give necessary safety measure for the protection of employee against any retaliation on account of whistleblowing. 
c. The company is committed for conducting business in an ethical way therefore, it motivates all its employees, vendors, stakeholders and contractors to voice their concern if they come across any behaviour, activity which is suspected to be unethical and dangerous for the company.
d. The  whistleblowing policy  is a crucial policy which gives stakeholders the liberty to raise concern against any suspected illegal activity.
e. It also gives employees of the company a mechanism to report any concern by an authorised channel operated under the audit committee.
 
2. Scope
This policy is applicable to all employees permanent or contractual  of the company. 
 
3. Definitions: 
 
a. Whistle blower definition  may be defined as the person who raises the concern against any wrongdoing unethical or improper practice seen or observed. Whistleblower can be an employee of the company, contractor, vendor or any other stakeholder.
b. Whistleblower committee:  The committee that has been formed to deal with protest raised by the employee or any other stakeholder under whistleblower policy.
c. Chairman:  Chairman may be defined as the person who heads the whistleblower committee. The head can be any chief officer or any person appointed by the board.
d. Complaint:  A complaint is defined as the reporting of any unethical and improper practice or violation to the whistleblower committee by a whistleblower made in good faith would constitute a complaint.
e. Ombudsperson:  It may be defined as the person who does the investigation of the complaint raised by an employee or any other stakeholder of the company.
f. Audit committee:  An audit committee is a committee formed by the board of directors according to the applicable law section 177 of the company's act 2013 and rule 6 and 7  of companies meeting of the board and its power rules 2014 deals with the provision of the audit committee. 
 
4. Policy Guidelines:
     
a. It is the responsibility of all employees of a company to raise their concern against any unethical behaviour or any wrongdoing in the company while following the  Whistleblower procedure .
b. Not reporting any illegal activity despite knowing about it will be considered a breach of ethical behaviour and will be considered an unethical behaviour. 
c. There will not be retaliation against the whistleblower. The various actions under the term retaliation  are suspension from employment, any decrease in salary etc. , any assignment which is of poor quality or any threats given to employee verbally or in writing.
d. The  protection to the whistleblower is provided under 2 areas:
1. Sharing information related to whistleblower confidentiality
2. In case of retaliation. Generally, the identity of whistleblower is kept confidential except for the reason that they are required to be shared as per the demand of investigation or laws.
e. Individuals  who are protected includes:
1. Person who is working alongside the whistleblower.
2. Person who is representing on behalf of  whistleblower as per the whistleblowing  process in investigation or court action.
f. The organisation cannot discriminate against any person regarding the employee salary or other terms or conditions of employment. 
g. The company cannot discriminate against an employee who is helping in the investigation process of any matter related to any public concern.
h. This is not under the provision of this policy to pay any compensation to the employee on his/her participation in the whistleblowing process. 
i. There should not be any denial in compensating an employee for involvement in the smooth processing of whistleblower process or his/her participation in the investigation process.
j. Sharing of information that should be kept secret otherwise.
k. A person is not entitled to any kind of protection until unless the concern raised by the whistleblower is done in good faith.
l. In case an employee raises concern related to any public dealing an employee is supposed to take written permission from the chief executive officer.
m. The whistleblower policy includes breach of the code of conduct or happening of any activity which is not legally permissible in the company.
n. Any kind of fraud, misrepresentation, any kind of theft, abuse of authority, getting hold of confidential Information any kind of discrimination is included under the whistleblower policy.  
 
5. Whistleblower complaint: 
 
A whistleblower complaint may be defined as complaint wherein whistleblower
(person raising the complaint) has observed that an employee , associate etc. have breached or may have breached the ethical code of business conduct, accounting, auditing matters etc. Raising concern against any wrongdoing which has been done or can be done will protect the company's reputation. It is the responsibility of all the employees, vendors, contractors, stakeholder etc. to highlight any wrongdoing as soon as possible. All the complaints must be raised to ombudsperson.
 
6. The Principle of reporting:
 
If an employee of the company observe or see in good faith that there is the violation of the code of conduct or there can be the violation of code of conduct, he /she must immediately inform their superior. An employee who has any doubt that any illegal activity is happening or can happen must inform superior or legal department on the same.
 
7. The Protection is given to a whistle blower:
 
As per the whistleblowing process, the company believes that there must not be any revenge against the employee who has raised the concern for breach of any code of conduct or integrity issue. Such an employee should not be at any drawback for raising a concern. In case there is any retaliation, strict disciplinary action will be taken against the employee found guilty on the same. Such issues can be raised to HR  or ombudsperson
 
8. Areas covered under whistleblower policy
 
The list gives some examples of the area where the breach of the code of conduct is observed. However, there can be reasons beyond the list as well:
a. Any kind of Harassment or discrimination
b. Sharing of confidential information
c. Any breach of privacy
d. Any kind of Fraud or Fraudulent
e. Misrepresentation of  financial data
f. Any kind of illegal activity
g. Corruption
h. Invalid promotion
i. Illegal sales activity
j. Conflict of interest
k. Trading within the company
l. Illegal competitive behaviour
m. Improper use of company assets.
 
9. Whistle  Blower  Process: 
 
The  whistleblower process has been explained in detail in whistle blowing process.  The process is as follows:
 
a. The whistleblower can raise the concern in writing or verbally to the ombudsperson. The written complaint can be sent through an email id and verbally he/she can inform through the telephone. However, even for verbal complain a written draft is prepared by ombudsperson".
b. All complaints which are received by ombudsperson or the audit committee constituted by ombudsperson shall be reviewed to check whether any breach of the code of conduct has happened or not. In case of the review by the audit committee, if any illegal activity has happened committee can recommend that its whistleblowing complaint or not. The ombudsperson or audit committee will respond to the concern within 2 days of receiving the complaint. 
c. The whistleblower may or may not disclose his/her identity.
d. It is up to the whistleblower whether he/she wants to disclose identity or not. Even in case of whistleblower has not revealed the identity , the complaint will be taken with utmost seriousness. However for smooth investigation and to provide more hold on the complaint it is suggested to disclose identity,however the final decision on the same lies with the whistleblower. The identity of whistleblower is kept confidential in all cases. This is to be noted that any false allegations on any employee by other employees, vendor or contractor or any other stakeholder will result in strict disciplinary action. This is as per the rules and regulations framed under the whistleblowing policy in the workplace.
e. Once the investigation is given to the audit committee by the ombudsperson the audit committee will perform the following tasks:
1. Will be in contact with employee, vendor, and stakeholder to get the necessary information to carry out further investigation.
2. Will discuss the steps needed internally for investigation of the complaint.
3. It is advised to keep all information confidential while carrying out the investigation. No information is shared outside either by the whistleblower or by the audit committee. 
4. This secrecy is maintained to protect the uprightness of the whistleblower process and investigation.
5. It is the responsibility of the ombudsperson to share the status and findings of investigation with the board of director. The final report must contain all the details and documentation deemed fit or necessary. 
 
f. The whistleblower in the corporate or company may raise their concern to their manager or head of the department. However, they can also contact the following mentioned persons:
 
a. Human  resource
b. Head of the department
c. Legal department
d. Compliance Head
e. CEO
f. Members of the management committee
 
g. In an urgent  situation, an employee can write directly to the chairman of the audit committee 
h. Any complaint received by HR will be sent to the director of the human resource for their action.
 
10. Management  assurance: 
 
a. The Identity of the whistleblower:  As per the meaning of term whistleblower a person who raises the concern the revelation of identity depends upon the choice of whistleblower.  Also as discussed in the previous paragraph the identity is kept confidential. It is shared only in case it becomes necessary for the investigation purpose or as per the demand of the business.
b. No Retaliation: The company makes sure that there will be no retaliation action against any employee who has raised any concern in good faith.
 
11. Corporate ombudsperson:  
 
The corporate ombudsperson has been given responsibility to deal with the investigation process fort eh concern raised by the employee. He/she is also responsible for the management of compliance issue within the organisation. He/ she is also responsible to check that the audit committee is investigating the case while abiding by the internal policies and procedure. 
 
12. Investigation Process : 
 
Any concern raised by an employee for breach of the ethical code of business will be taken under investigation by the corporate ombudsperson and the audit committee as per the process defined above in the policy. The employee, vendor, stakeholder against whom the concern is raised if found guilty will be dealt with strict disciplinary action.  The process of whistleblowing in business  undergoes the following steps:
 
A. In the first step, the employee/ vendor/ contractor raises the concern to the corporate ombudsperson as soon as possible with all relevant documents and proofs.
B. An audit committee is formed by the corporate ombudsperson carrying minimum 8 persons with expertise in dealing with legal compliance. This committee is formed within the company. The audit committee needs to start their investigation process within 2 days of receipt of the complaint. 
C. The audit committee must start the inquiry and come up with the report within 15 to 45 days from the receipt of the initial complaint.
D. The audit committee must suggest the corrective action which needs to be taken by the immediate reporting manager or head of the department for implementation. In case the employee who is found to be guilty of any illegal wrongdoing will be penalised as prescribed by ombudsperson and will be implemented by HR. 
E. The whistleblower will get to know the status and final findings on the investigation done.  
 
13. Role and Responsibilities :
 
Following  the regulations  guided by the  Whistleblowing in the work  the roles and responsibilities  of employees, stakeholders, ombudsman, audit committee and CEO are explained as follows:
 
a. Employees:
1. The first and foremost task of the employee is to bring into notice of the company in case any illegal activity is done in the company or about to happen in the company. The employee must have proper evidence to raise any concern.
2. To work in collaboration with the audit committee with complete confidentiality.
3. The policy is meant to raise concern which is of serious nature and is actually happening. Any false allegation will result in serious disciplinary action.
4. An  Employee who is whistleblower  if not satisfied with the investigation done by the ombudsperson, he/she can directly approach the chairman of the audit committee.
 
b. Ombudsperson: 
1. To make sure that the whistleblower policy is implemented in the company. 
2. In case the ombudsperson through investigation comes to a conclusion that any illegal act or wrongdoing has been done, the case can be closed by ombudsperson.
3. All the inquiry details must be properly implemented.
4. Appointment of the audit committee to carry out investigation further. 
5. To handover, the report received to the board of directors, CEO and director HR.
6. To share the final findings with the whistleblower, with a gesture of thanks for protecting the company's reputation.
7. To make sure that all safety measures are followed for the protection of the whistleblower.
 
c. Audit Committee
1. To carry on the investigation in a transparent way.
2. To make sure that complete findings have been done by the committee.
3. To make sure each and every information is kept confidential.
4. To finally decide after investigation if any wrongdoing has been done or not, in case it is done then by whom?
5. To ensure an appropriate action being taken against the dismissal and preventive measures.
6. Documentation of complete report.
7. Submission of the final findings and final report to the ombudsperson.
 
d. CEO: 
1. To share the final report with the statutory board.
2. To cooperate fully with the investigation team.
3. Maintain complete confidentiality.
4. To make sure the audit committee and ombudsperson have taken necessary action against the wrongdoers.
5. Be known with the final conclusion of the investigation team.
 
14.   Confidentiality: 
 
  • By following rules and regulations under whistleblowing guidelines for employees all complaints must be kept confidential. It can be highlighted only on a need to know basis. 
  • All the people involved in the process must make sure that they do not share any information outside.
  • Maintain secrecy of entire matter.
  • Must discuss the matter only if being asked to do by management for investigation purpose.
  • Not keep any documentation related to investigation unattended.
  • Also, the whistleblower name can be revealed only if
1. Whistleblower confirms that he/she will be identified and has no issue related to identification.
2. Identification is one of the requirement to carry on the investigation further.
3. According to laws identification is required.
 
15. Retention of  documents: 
 
1. Following the whistleblower policy and procedure,  it is the responsibility of the ombudsperson for the maintenance of documents needed for the complaint received from the whistleblower.
2. All the details related to complaints are maintained for reporting purpose.
3. All the documents are retained for a period of 8 years.
                                                             **********

 

Sample 2 Whistle blower Policy for Employees
 

 
 
Preamble:  There is certain set of behaviour which is to be followed within the organisation. The code of conduct policy explains the ideal behaviour and actions of employees within the organisation. The whistle blower policy gives authority to employees to raise their concern in case they come across any type of improper act or violation of code of conduct which includes Fraud, scam etc. Details on the process and procedure are explained in the whistle blowing policy template below.


In order to maintain higher standard of ethical conduct our organisation provides a broad way to employees to raise their concern against any kind of fraud, scam, and any misrepresentation of data in case they come across any of them without fear or unfair treatment. This is the main objective of whistle blower policy or whistle blowing at work.

Objective: 

  • This policy provides a platform to employees to voice their concern on any improper act. However a certain set of whistle blowing procedure should be followed as per the whistle blowing at workplace.
  • It also encourages employees to share their concern timely and also to ensure there is timely response from the company on the same. 
  • To promote Lawful conduct.

 

 

Scope: The scope of whistle blower policy is to define the actions for raising a concern, and the protection provided to the person raising the concern. The set of whistle blowing procedures to be followed by the corporate whistle blower (Whistle blower definition explained in policy later) as a concern is raised and the responsibilities of different associates. In all cases company reserves the right whether a case requires investigation or not, if required then how it has to be followed as per the whistle blower policy.

 

whistle blower policy

Regular and contractual employees of the company

Eligibility: All employees of an organisation are covered under whistle blower policy template It includes

  1. Vendors
  2.  suppliers or agency
  3. Contractors

Disciplinary actions: It means any action that is being taken against an employee if any kind of improper act like fraud, scam etc. identified during course of investigation. It includes

However it is not limited to warning, suspension. Disciplinary action varies from case to case basis.

Whistle blower definition:  It means a person who raises his/ her voice against any wrong doing within the organisation or outside the organisation. It defines whistle blower.

 

Subject: A person against whom the allegations are made or evidences collected during an investigation.

 

Audit committee: It means a person or group of persons who carry out investigation against the case that is raised by the whistle blower. They are the ones who recommend disciplinary action.

 

Good Faith: It means the right intent with which the unethical or improper act is raised. It will lose its meaning in case some false accusations are made and if in case the alleged practice lacks facts or personal knowledge.

 

Whistle officer: A whistle officer is generally the company secretary.

 

Investigation team:  It may be defined as a team who carry out investigation of protected disclosure.

 

Employee:  Employee means employee working in the company.

 

Protected disclosure:  It is defined as concern raised by written communication made in honest intentions that disclose unethical activity.

 

Chairman: Chairman means the chairman of whistle blower committee.

 

Whistle committee: The committee constituted to deal with Complaints under this Policy.

 

Reportable Matters:

Following are considered under the reportable matters:

1. Breach of contract

2. Misuse of Authority

3. Misrepresentation of company data

4. Negligence towards public health and safety

5. Misrepresentation of financial records

6. Any illegal act

7. Sharing of confidential information

8. Misuse of company assets

9. Non compliance with the company authority.

10. Non compliance with the code of conduct.

11.Disclosing confidential information with outsiders ex. competitors

12.  Unethical practice like bribe given or bribe taken

13. Misuse of company powers

14. Theft of confidential information’s

 

Policy details:  It is the responsibility of all employees to raise the concern in case they come across any unethical practice. Failing to comply with it will be considered as immoral behaviour. What is whistle blowing as already been explained in the whistle blowing template above.

Guideline procedure:

In order to make whistle blower policy a success it is necessary that the company will take care of following:

  1. To make sure that whistle blower do not undergo any unfair treatment and is not exploited
  2. Complete confidentiality of  matter
  3. To take adequate step in case of unfair treatment or exploitation
  4. Take stringent actions, if any evidence related material is destroyed.

 Exclusions:

In case the investigation team reaches a conclusion that the concern raised was false and was made with malicious intentions, in such case strong disciplinary action is taken against the employee raising the concern. However there may be case when any concern is raised which might not need any investigation but it has been raised with honest intentions in such case no action will be raised against the employee.
The complaints raised by a whistle blower (define Whistle blower explained above) should not be confused with grievances. This policy excludes any complain made against superior/ subordinate relationship issues, dissatisfaction in job profile, issues related to favouritism etc. Such issues are not covered under the whistle blower policy. Any external matter like non receipt of payment etc is also excluded from this policy. Day to day operations problems shall be dealt normally under
grievance handling by HR. What is whistle blowing as already been explained so far. Whistle blowing policy meaning is completely different from grievance handling.

 

Raising a concern:

Whenever an employee comes across any improper act it is requested to make the concern in writing in order to assure better understanding of the issues. The report must contain all facts and information and there should not be any assumptions. It is not necessary for the whistleblower to prove the complaint but it is expected that the complain must have facts. The details are mentioned in whistle blowing process.

 

 Responsibilities:

 

 Responsibilities of a whistle blower

  1. To bring to notice any improper practice happening in the organisation which employee whistle blower comes across. However while reporting the matter whistle blower must have evidences against the improper practice. This is as per the whistle blower policy meaning.
  2. There should not be any delay in reporting such matter.
  3. All the rules and regulations as mentioned in the policy must be followed while reporting an improper act. It has been explained in what is whistle blower policy?
  4. A whistle blower must produce genuine evidences against the improper act reported by him/her as explained in define whistle blower.
  5. Any false allegations by whistle blower may attract disciplinary actions. As explained in define whistle blower.
  6. It is must for whistle blower to maintain the confidentiality of the matter till it is completely resolved. This is expected from employee whistle blower.
  7. A whistle blower is supposed to provide evidences which must have a ground for initiation of investigation. However he /she must try getting the evidences which they have access to. Company cannot guarantee any protection in case they try getting it which they do not have access to.

Responsibilities of Investigation team:

  1. The investigation team is supposed to carry out investigation in a very transparent way.
  2. To maintain confidentiality of the information.
  3. To make sure investigation is done thoroughly to find the facts.
  4. Keep all documentation safe and secure.
  5. Recommendation of disciplinary action
  6. Submission of documents evidences to whistle Officer.

  Responsibilities of Whistle officer:

  1. The whistle officer is supposed to maintain the confidentiality of the matter.
  2. To keep all information and evidences safe and secure.
  3. To act as secretary to ombudsperson or arbiter.
  4. To carry out non biased enquiry.
  5. Proposal of disciplinary action, if any.
  6. Preparation of final report.

 

Responsibilities of an audit committee:

  1. To review and approve the whistleblower process.
  2. To analyse cases received under whistle blower policy.
  3. In case similar kind of concern is raised against an employee repeatedly, in such case audit committee can take strong disciplinary action which may even lead to termination.

 

Disciplinary act:

 

       In case it is determined that an improper act has happened, the following actions can be taken:

  1. Any employee found accountable of an improper act will be subject to disciplinary actions, it may even lead to termination of employee.
  2. Policies will be formed to ensure that any such violation can be perceived in an early stage.
  3. In case an employee is trying to destroy any of the evidences, then disciplinary action will be taken against the employee who may even lead to termination.

Disclosure of improper act:

The disclosure of any improper act by the whistle blower may be done while sharing or hiding their names. However in case name is kept hidden the company will decide whether to take up the investigation or not. It will depend on how seriously the improper act has been raised by the whistle blower when identity is hidden.

Reporting of improper act:

       The reporting of improper act will be done either by sending an email or writing a letter to the whistle officer. All the critical information must be provided rightly by the whistleblower.

Format of raising a concern:

While raising a concern it is generally preferred that it should be given in writing. The whistle blower ideally should mention the name and contact details.

 Summary of the improper act, all those employees/ persons involved in improper act, time and place of occurrence of the act.

Protection of whistle blower:

1. The whistle blower is given protection to safeguard him/her from any form of retaliation like reprisal or any kind of exploitation.

2. Neither the whistle blower be transferred nor demoted during course of investigation.

3. Protection is given to whistle blower provided that the disclosure is made with honest intentions.

4. Identity of whistle blower is kept confidential unless the whistle blower has no issues in being identified or identification is needed as per the law.

5. Whistle blower is provided protection from any kind of retaliation.

6. Whistle blower who comes across any kind of retaliation may file a complaint to whistle officer. Strong disciplinary action taken against the person who retaliates.

7. The improper act as raised by whistle blower is true.

8. No false allegations made by whistle blower.

9. No allegations are made for personal interest.

10. Strict disciplinary action will be taken against those who try to exploit the whistle blower.

11. Any other person/ employee supporting the investigation will also be protected like the whistle blower.

Rights of a subject:

  1. It is the right of the subject to be perceived.
  2. It also has the right to be informed of the outcome of investigation.

Method to be followed for raising a concern:

It is generally preferred that the concern must be raised in writing. It can be done by writing an email or in the form of a letter.  Any kind of concern related to senior management should be sent directly to CMD. The CMD will constitute a committee to investigate the improper act related to senior management. However in case of employees other then the senior management, the company secretary will be the whistle officer of the company. However to carry out the investigation HR head is also involve to determine whether

Improper act has happened or not. The process Owner for whistle blower policy is the company secretary.

To carry out the investigation the whistle officer receives the concern through email/letter as preferred by whistle blower. The whistle officer along with company secretary and HR head examine whether concern raised is improper act or not. It is then communicated to the whistle blower. The whistle officer keeps records of the findings and communicates with the whistle blower.

If any improper act has happened the whistle blower along with the whistle committee investigates as per the policy. The whistle committee comprises of HR Head, Internal audit, 1 employee from department where improper act has happened.

Sometimes it might be the possibility that internal investigation does not help and it needs to be audited externally as required by the law. In such case the whistle blower raises the concern to the external authority and wait for the report.

The employee who has committed the improper act is also informed as investigation can’t be progressed without information. Investigation generally happens with interviews and with documents as and when required.

The whistle committee conduct the investigation and submits the report within 60 days of receipt of concern. If it is a criminal offence, Police is informed on the same. The Whistle officer, policy owner and CMD of the company will decide the action to be taken against the employee who has committed improper act on recommendation from whistle blower committee and keep whistle blower informed on the same.

 

Documentation and retention of documents:

The whistle officer will maintain all documentation. It includes all the documents provided by the complainant or any other document as received during investigation. All the documentation must be retained in an orderly fashion. Documentation access is limited to whistle blower, whistle officer, investigation team, HR Head and Audit committee. The document related to any such case shall be retained for minimum 9 years.

Action on False allegation:

Serious action will be taken against employees who knowingly make false allegations under unethical and improper practice. The stringent action against any such employee may even lead to termination.

Process Flow:

                     hrhelpboard -whistle blower -flow chart

                      whistle blower policy -hrhelpboard

 

 

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