All Protected Disclosures should be reported in writing by the complainant as soon
as possible after the Whistle Blower becomes aware of the same so as to ensure a
clear understanding of the issues raised and should either be typed or written in
a legible handwriting in English.
The Protected Disclosure should be submitted in a closed and secured envelope and
should be super scribed as “Protected disclosure under the Whistle Blower policy”.
Alternatively, the same can also be sent through email with the subject “Protected
disclosure under the Whistle Blower policy”. If the complaint is not super scribed
and closed as mentioned above, it will not be possible for the Audit Committee to
protect the complainant and the protected disclosure will be dealt with as if a
normal disclosure. In order to protect identity of the complainant, the Vigilance
and Ethics Officer will not issue any acknowledgement to the complainants and they
are advised neither to write their name / address on the envelope nor enter into
any further correspondence with the Vigilance and Ethics Officer. The Vigilance
and Ethics Officer shall assure that in case any further clarification is required
he will get in touch with the complainant.
Anonymous / Pseudonymous disclosure shall not be entertained by the Vigilance and
The Protected Disclosure should be forwarded under a covering letter signed by the
complainant. The Vigilance and Ethics Officer / Chairman of the Audit Committee/
MD/ Chairman as the case may be, shall detach the covering letter bearing the identity
of the Whistle Blower and process only the Protected Disclosure.
All Protected Disclosures should be addressed to the Vigilance and Ethics Officer
of the Company or to the Chairman of the Audit Committee/ MD/ Chairman in exceptional
cases. The contact details of the Vigilance and Ethics Officer is as under:-
Protected Disclosure against the Vigilance and Ethics Officer should be addressed
to the Chairman of the Company and the Protected Disclosure against the Chairman/
MD of the Company should be addressed to the Chairman of the Audit Committee. The
contact details of the Chairman, MD and the Chairman of the Audit Committee are
On receipt of the protected disclosure, the Vigilance and Ethics Officer / Chairman/
MD / Chairman of the Audit Committee, as the case may be, shall make a record of
the Protected Disclosure and also ascertain from the complainant whether he was
the person who made the protected disclosure or not. He shall also carry out initial
investigation either himself or by involving any other Officer of the Company or
an outside agency before referring the matter to the Audit Committee of the Company
for further appropriate investigation and needful action.
The record will include:
- Brief facts
- Whether the same Protected Disclosure was raised previously by anyone, and if so,
the outcome thereof;
- Whether the same Protected Disclosure was raised previously on the same subject
- Details of actions taken by Vigilance and Ethics Officer / Chairman/ CEO for processing
- Findings of the Audit Committee
- The recommendations of the Audit Committee/ other action(s).
The Audit Committee, if deems fit, may call for further information or particulars
from the complainant.