Whistle Blower Policy

Developing Good Faith for Employees for Organization

Policy Objective

To provide a framework to employees to report in good faith, in case they observe unethical and improper practices or any other alleged wrongful conduct in the Organization and to protect employees who raise such concerns about serious irregularities within the Organization.

Policy Guidelines

Definition

Protected Disclosure: A concern raised by a written or telephonic communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity

Subject: A person against or about whom a Protected Disclosure is made or evidence gathered during an investigation

Whistle Blower: Someone who makes a Protected Disclosure under this Policy

Ombudsman: An Authorized Person to receive all complaints under this Policy and ensure appropriate action. Complaints will be received through an anonymous email id (ethics@rockman.in) or mobile (+91-9810760235), to which only the Ombudsman will have access. The Executive Director will have the authority to change the Ombudsman from time to time.

Procedure for Disclosure

  • An employee who comes to know or observes himself/herself any unethical & improper practices or alleged wrongful conduct shall disclose the ombudsman in writing through letter or e-mail as soon as possible but not later than 30 consecutive calendar days after becoming aware of the same.
  • All disclosures must be sent to the Ombudsman email id
  • Anonymous disclosures shall not be entertained

Enquiry into the Disclosure

  • The Ombudsman will forward the concern to the ED/ MD.
  • The ED/ MD will designate an individual (preferably from Band 1 & 2 and representative from Plant as well as Corporate Office) for investing the claims.
  • An external agency may also be engaged for investigating claims of a very grave nature, based on the discretion of the ED/MD.
  • If initial enquiries by the designated authority indicate that the concern has no basis, or it is not a matter which requires investigation to be pursued under this Policy, it may be dismissed at this stage and the decision is documented.
  • Where initial enquiries indicate that further investigation is necessary, the designated authority shall have the right to call for any information or document and interrogation of any employee of the group or another person (s) as they may deem appropriate for investigating this policy.
  • No attempts should be made to conceal evidence of the Protected Disclosure. Disciplinary action may be taken, if anyone destroys or conceals evidence of the Protected Disclosure made/ to be made.
  • A report shall be prepared after completion of Investigation and submitted to the ED/MD
    After considering the report, the ED/MD would determine the cause of action and may order for remedies

Disqualification

  • Protection under this Policy shall not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention
  • Whistle-Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious, shall be liable to be prosecuted under Company’s Code of Conduct

Secrecy/Confidentiality

The Whistle Blower, the Subject, everyone involved in the process shall:

  • Maintain complete confidentiality/ secrecy of the matter.
  • Not discuss the matter in any informal/social gatherings/ meetings.
  • Discuss only to the extent or with the persons required for completing the process and investigations.
  • Not keep the papers unattended anywhere at any time
  • Keep the electronic mails/files under password.
  • If anyone is found not complying with the above, S(he) shall be held liable for such disciplinary action as is considered fit.

Protection

  • The designated authority will ensure that no adverse personnel action shall be taken or recommended against an employee in retaliation to his or her disclosure in good faith of any unethical & improper practices or alleged wrongful conduct. This policy protects such employees from unfair termination and unfair prejudicial employment practices.
  • However, this policy does not protect an employee from an adverse action which occurs because of poor job performance or any other misconduct unrelated to a disclosure made under this policy, etc., independent of his disclosure of unethical & improper practices or alleged wrongful conduct
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