1. Employees and Directors can make Protected Disclosure to Ombudsperson appointed by the Company. If it is
received by any other person the same should be forwarded to the Ombudsperson for further appropriate action.
2. Name of the Whistle Blower need not be disclosed to the Whistle Officer / Committee.
3. The Ombudsperson / Whistle Officer / Committee shall after end of investigation make a detailed written record
of the Protected Disclosure.
4. The Whistle Officer / Committee shall finalize and submit the report to the Ombudsperson within 15 days of
5. On submission of report, the Whistle Officer / Committee shall discuss the matter with Ombudsperson who shall
i) In case the Protected Disclosure is proved, accept the findings of the Whistle Officer/Committee and take
such Disciplinary Action as he may think fit and take preventive measures to avoid reoccurrence of the
ii) In case the Protected Disclosure is not proved, extinguish the matter;or
iii) Depending upon the seriousness of the matter, Ombudsperson may refer the matter to the Committee of
Directors with proposed disciplinary action / counter measures
6. Notwithstanding the above, the Whistle Blower shall have direct access to the Chairman of the Audit Committee
in exceptional cases.
7. Audit Committee can seek the assistance of other departments including the Human Resources Department and
other external consultants in appropriate cases.
8. In case of repeated frivolous complaints being filed by a Whistle Blower, the audit committee may take suitable
action against the concerned Whistle Blower including reprimand