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.
“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
- 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
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.
PROCESS OF RAISING COMPLAINTS
The complainant may raise the complaint by writing at the following email id: email@example.com , 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
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.
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.