The Whistle Blower Policy covers all stakeholders whether employees or not so as to encourage any person to report of any wrong doing by any other stakeholder of the Company to the Whistle Blowing Officer. The policy covers all disclosures and shall include:
REPORTING OF DISCLOSURE
Any stakeholder can make a disclosure to the Whistle Blowing officer by writing in an email to email@example.com or by sending in a letter or hand delivering a letter to The Whistle Blowing Officer, TVS Mobility P Ltd, 58 Eldams Road, Teynampet, Chennai 600018.
There is no specific format of disclosure and this could be made through a simple letter or communication of the facts and background of the case with full details as far as possible with evidences if present.
The disclosure should contain the name of the person and contact number and address of the person making the disclosure.
CONFIDENTIALITY AND PROTECTION FOR WHISTLE BLOWER
The Company will ensure confidentiality of the disclosure and the whistle blower and will ensure the protection of the whistle blower’s identity and also protect from any retaliatory attacks which the Whistle Blower may be subjected to, in case the same is reported to the Company.
Anonymous complaints will be taken cognizance off and a preliminary investigation will be done and if found warranted a full investigation will be undertaken and done and the findings reported to Management. However if there is no sufficient evidence in the preliminary investigation, the disclosure will not be investigated and will be treated as closed. Anonymous disclosures will not be responded specifically thought might be acknowledged sometimes. Acknowledgement of anonymous disclosures does not mean a full investigation will be done.
MALICIOUS INTENT AND FALSE DISCLOSURES
Disclosures made by stakeholders with false or malicious intent about a particular stakeholder will be dealt with strong action by the Company up to and including termination of the relationship or employment if warranted.
REPORTS AND DOCUMENTS
The Whistle blower should fully co-operate for all forms of investigations as deemed fit by the Whistle Blowing Committee (WBC) or Whistle Blowing Officer (WBO) and will need to submit all documents asked for the WBC or WBO.
Retention of documents / investigation reports and findings
The Company will retain all documents, investigation reports and findings of a particular case of disclosure for which action has been taken for a period of 7 years.
The Company may independently pursue any actions to be taken against any individual under other redressal mechanisms and may choose to exclude the complaint from the purview of this policy. Examples of this will include action against a person under the Prevention of Sexual Harassment of Women Policy, Standing orders of the Company or any other independent process.
UMBRAGE UNDER WB POLICY
The stakeholder cannot use the Whistle Blowing Policy as a cover to exclude himself from any process of disciplinary action initiated on him prior or post the disclosure if that is independent of the disclosure made. The Whistle Blower cannot claim immunity or protection under this Policy in such a case.
RIGHTS AND DUTIES OF THE WHISTLE BLOWER
RIGHTS AND DUTIES OF THE WBO, WBC, COMPANY
Sometimes, the disclosures made under this Policy may be complicated and sometimes even leading to ambiguous situations where decisions will need to take to ensure logical progress and conclusion of the case in hand. In such situations, the Company has the full powers to make necessary changes to facilitate the logical facilitation of such investigative procedures and processes to ensure conclusion of the investigation of the disclosures made and all these actions will have deemed to have been taken in good faith by the WBO or WBC as the case may be.
This policy shall be reviewed each year by the Head – HR as part of the normal process of Policy review for adequacies with local legislations and context of the operating business environment and practices and the Policy shall be reissued each year as part of the organization Policy review process. Any suggestion related to this Policy shall be addressed to the Head – HR for review.