Floor, Gayways House Pee Pee Compound Ranchi Jharkhand 834001, India
Telephone No.: +91- 9304955502 ; E-mail: email@example.com
WHISTLE BLOWER POLICY
1.1 The Company
believes in the conduct of the affairs of its constituents in a fair and
transparent manner by adopting highest
standards of professionalism, honesty, integrity and ethical behaviour.
1.2 Towards this end,
the Company has adopted the Vedant Asset Limited Code of Business Conduct and
Ethics called “Code of Conduct”, which lays down the principles and standards
that should govern the actions of the Company and its employees. Any actual or
potential violation of the Code, howsoever insignificant or perceived as such,
would be a matter of serious concern for the Company.
1.3 Accordingly, this
Whistle Blower Policy (“the Policy”) has been formulated with a view to provide
a mechanism for employees of the Company to approach the Audit Committee of the
Company and protected disclosure to the management instances of unethical behaviour,
actual or suspected fraud or violation of the Code of Conduct.
1.4 The Policy provides
a framework to promote responsible and secure whistle blowing. It protects the
Whistle Blower wishing to raise a concern
about serious irregularities within the Company.
1.5 The Policy neither
releases Whistle Blowers from their duty of confidentiality in the course of
their work, nor is it to be misused
to surface a grievance about a personnel
is applicable to all Directors, Employees and other persons dealing
with the Company.
2.2 The Protected
Disclosure may be areas of concern in respect of the Company
covered by this Policy and summarized in paragraph 5.
3.1 “Disciplinary Action”
means any action that can be taken
on the completion of / during the investigation
proceedings, including but not limited to, a warning, recovery of financial
losses incurred by the Company, suspension/ dismissal from the services of the
Company or any such action as is deemed to be fit considering the gravity of
3.2 “Employee” means
every employee of the Company including the Directors in the whole time
employment of the Company.
Disclosure” means a concern raised by a written communication made in good
faith that discloses or demonstrates information that may evidence unethical or
improper activity (as described more particularly in Clause 5) with respect to
the Company. Protected Disclosures should be factual and not speculative or in
the nature of an interpretations/conclusion, and should contain as much
specific information as possible to allow for proper assessment of the nature
and extent of the concern and the urgency of a preliminary investigative
3.4 “Subject” means a
person against or in relation to whom a Protected Disclosure is made or
evidence gathered during the course of an investigation.
3.5 “Whistle Blower”
means an Employee who makes a Protected Disclosure under this Policy.
THE GUIDING PRINCIPLES
as a policy, condemns any kind of discrimination, harassment, victimization or any other
unfair employment practice
being adopted against
Whistle Blower. The Company will:
Ensure that the Whistle Blower and/or the person
processing the Protected Disclosure is/are not victimized for doing so;
Treat victimization of Whistle Blower as a serious matter
including initiating Disciplinary Action against person(s) causing or allowing
victimization of Whistle Blower;
complete confidentiality of identity of Whistle Blower;
Ø Not attempt to conceal evidence
of the Protected Disclosure;
Take Disciplinary Action for event covered under this
Policy (as mentioned in Clause 5) or upon victimizing Whistle Blower or any
person processing the Protected Disclosure or if any one destroys or conceals evidence
of the Protected Disclosure made/to
an opportunity of being heard to the persons involved
especially to the Subject.
COVERAGE OF POLICY
5.1The Policy covers
malpractices and events
which have taken place/ suspected
to take place involving:
Ø An abuse of authority;
Ø Breach of employment contract;
Ø Manipulation of company data/records;
Ø Financial or compliance irregularities,
including fraud, or suspected fraud;
Ø Criminal offence having repercussions on
the company or its reputation;