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d) |
Any other
Employee assisting in the said
investigation shall also be
protected to the same extent as the
Whistle Blower. |
Whistle Blower
Protection Committee
The Company has constituted the
Whistle Blower Protection Committee
under the Chairmanship of Dy.
Managing Director (Corporate
Services) as under: |
Mr. A N Singh Dy.
Managing Director (Corp. Services)
Chairman
Mr. D Sengupta VP (Shared Services)
Member
Mr. A D Baijal VP (RM & IM) Member
Mr. Abanindra M. Mishra VP (HRM)
Member
Mrs. Rekha Seal Ethics Counsellor
Convener |
|
In case a
Whistle Blower feels that he/she has
been victimized in employment
related matters because of reporting
about the violation of the Code, he/
she can submit a 'Grievance' to the
Ethics Counsellor, giving specific
details of nature of victimization
allegedly suffered by him/her. All
such grievances will be examined by
the aforesaid committee. The
Committee will meet at regular
intervals and examine the grievances
on their merits. The Committee will
also conduct necessary investigation
of the concern and recommend
appropriate action as the case may
be. |
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While Management
is determined to give appropriate
protection to the genuine Whistle
Blower, the employees at the same
time are advised to refrain from
using this facility for furthering
their own personal interest. If
proved, such cases may be referred
to the Whistle Blower Protection
Committee for disciplinary action. |
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9. |
Investigators |
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a) |
Investigators
are required to conduct a process
towards fact-finding and analysis
related to alleged improper or
unethical activities. Investigators
shall derive their authority and
access rights from the Company/Audit
Committee when acting within the
course and scope of their
investigation. |
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b) |
Technical and other resources may be
drawn upon as necessary to augment
the investigation. All Investigators
shall be independent and unbiased
both in fact and as perceived.
Investigators have a duty of
fairness, objectivity, thoroughness,
ethical behavior, and observance of
legal and professional standards. |
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c) |
Investigations
will be launched only after a
preliminary review, which
establishes that: |
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i. |
the alleged act
constitutes an improper or unethical
activity or conduct, and |
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ii. |
either the
allegation is supported by
information specific enough to be
investigated, or matters that do not
meet this standard may be worthy of
management review, but investigation
should not be undertaken as an
investigation of an improper or
unethical activity. |
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10. |
Decision |
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If an
investigation leads the Ethics
Counsellor/ Audit Committee to
conclude that an improper or
unethical act has been committed,
the Ethics Counsellor/Audit
Committee shall recommend to the
management of the Company to take
such disciplinary or corrective
action as they deem fit. It is
clarified that any disciplinary or
corrective action initiated against
the Subject as a result of the
findings of an investigation
pursuant to this Policy shall adhere
to the applicable personnel or staff
conduct and disciplinary procedures. |
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11. |
Reporting |
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The Ethics
Counsellor shall submit a report on
a quarterly basis to the Audit
Committee regarding total number of
disclosures received in previous
quarter, nature of complaint,
outcome of investigation, actions
recommended by the Ethics Counsellor/Audit
Committee and implementation of the
same. The EC should also report to
the AC the concern raised for
victimization for employment related
matters by the Whistle Blower and
action taken by the Whistle Blower
Protection Committee. |
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Such Reports on
the above shall be reviewed and
recorded by the Audit Committee. |
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12. |
Retention of
documents |
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All Protected
Disclosures in writing or documented
along with the results of
investigation relating thereto shall
be retained by the Company for a
minimum period of seven years. |
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13. |
Amendment |
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The Company
reserves its right to amend or
modify this Policy in whole or in
part, at any time without assigning
any reason whatsoever. However, no
such amendment or modification will
be binding on the Employees unless
the same is notified to the
Employees in writing.
This supersedes our earlier Whistle
Blower Policy (Ref. no. AO/2725/04
dated 11.01.2004) |
