1. INTRODUCTION

LOTS Wholesale Solutions (brand of CP Wholesale India Private Limited) (“Company”) has put in place complaint-making and whistle-blowing communication channels, covering complaint filing, verification, and summary of findings, together with protection of the informants or complainants and any related parties. The purpose is to handle complaints, comments, or suggestions from stakeholders affected or potentially affected by the Company’s business conduct or by the conduct of the Company personnel, resulting from law-breaking or violation of the code of conduct as well as any alleged acts of corruption. The scope of complaint and whistle-blowing are any breaches of as well as acts of non-compliance with the applicable laws or official regulations, and the principles of corporate governance together with the Company’s Code of Conduct and rules and regulations, and alleged acts of corruption – all of which have the primary objective of acquiring personal gains or various benefits for others in an unlawful manner; such as acts of fraudulence or embezzlement.

2. WHO CAN COMPLAIN?

Any person, including without limitation the customer, supplier and any other business associate of the Company, who is effected by the conduct of the business of the Company resulting in breach of any law, rule or regulation, Company’s code of conduct and / or corruption, may raise the complaint in accordance with the procedure mentioned in this policy.

The complainant may choose to keep its identity confidential and raise the complaint anonymously, however, it is encouraged that the complainant discloses its identity for more effective disposal of the complaint.

3. GUIDELINES

“Whistle blowing” is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include following (the list is not exhaustive):

Criminal activity
Danger to health and safety or damage to the environment
Failure to comply with any legal or professional obligation or regulatory requirements
Financial fraud or mismanagement
Negligence
Breach of Company’s policies and procedures
Conduct likely to damage Company’s reputation
Unauthorized disclosure of confidential information
Suspected wrongdoing / danger at work
Acts of corruption
Deliberate concealment of any of the above matters

4. PRINCIPLES

Any matter raised under this policy will be investigated as per procedure defined in clause 5 below, in confidence. The Company will proceed as deemed appropriate or forward the report to the responsible person or involved party, through taking into consideration the independence in pursuing the incident based on the facts, issues or complaint received.

The above principle is to ensure that the investigation process is carried out in a comprehensive, correct and equitable manner for all involved parties with full transparency, as well as to be able to monitor any associated progress so as to be sure that the complaint has been dealt with in an appropriate and fully effective manner.

5. PROCESS OF RAISING COMPLAINTS

The complainant may raise the complaint by writing at the following email id: lots.cgoffice@cpwi.in , or by sending a written complaint at the following address: 7th & 8th floor, We Work BlueOne Square, 246, Phase IV, Udyog Vihar, Gurugram, HR 122016

Whistle blowing channels shall mean and include chairman of the board/ chief executive officer/ head of the internal audit of the Company.

The complainant may also raise the relevant complaint at the Company’s portal: Link

6. PROCESS OF COMPLAINT RESOLUTION

After the receipt of the complaint, the Company shall proceed to investigate the matter against the accused person. This step will include forwarding the complaint to the accused and asking the accused for clarification / its stance in the matter.

After hearing the accused and the complainant (if applicable and / or deemed necessary by the Company), the Company shall decide upon the resolution of the matter.

If, following the investigation, a violation has been established, appropriate action shall be taken against the Company’s personnel guilty of misconduct. This may include disciplinary action (up to and including summary dismissal) and where appropriate, the relevant legal authorities may also be involved.

7. CONFIDENTIALITY OBLIGATIONS OF THE COMPANY

Subject to the terms of this policy, the Company assures that the identity of the anonymous complainant shall be kept confidential at all times, unless the complainant itself decides to disclose its identity for the purpose of investigation of the case.

The personnel of the Company who receive the complaint are required to maintain total confidentiality of the incident as well as not disclose any such facts to any irrelevant party unless specifically required to do so by law. If any relevant information is intentionally disclosed/leaked to others, then the Company will take disciplinary action in accordance with the Company’s rules and regulations.

8. FALSE COMPLAINT

If the reported information / complaint is proved to be false due to deliberate distortion of facts and / or false accusation, the complainant would be deemed to have violated the Company’s code of conduct, for which appropriate action shall be taken against the false complainant in the manner deemed fit by the Company.

Complaint Form