WHISTLE BLOWER
POLICY
As part of the Corporate Governance measures, TVS Vehicle Mobility Solution has its own Code of Conduct and Standing Orders for its employees to ensure appropriate corporate behavior in all facets of its operations. TVS also has robust practices relating to facilitation of disclosures on all matters relating to its operations by encouraging employees or any other stakeholder to report of any wrong doing related to the Company’s operations to the Management or any other senior leadership team members. Such reporting’s have always been taken cognizance of and investigated if it was warranted basis the merit of such disclosures by the HR team and reports of such investigations placed and apprised to the Management of the Company.
To further strengthen this process and structure this through a formal process and to disseminate the same to all employees and other stakeholders, this Whistle Blower Policy is being brought into effect.
01
OBJECTIVE
To facilitate stakeholders to disclose in good faith without fear or favour any wrong doing by any person related to the Company’s operations which might cause damage to goodwill, reputation or any other loss
- To protect the Whistle blower from acts of retaliation and preserve the confidentiality so as to create and nurture an ambience for sustained disclosures.
- To outline the process of disclosures and other matters relating to the process of governance to bring in clarity and uniform understanding amongst all stakeholders.
02
DEFINITIONS
Company means TVS Vehicle Mobility Solution Private Limited.
- Management means the Board of Directors of the Company.
- Whistle blower means any stakeholder who reports about any wrong doing with respect to any of the Company’s operations.
- WBO means Whistle Blowing Officer, in this case means Head – HR and Operations, Group Head – HR & OC.
- WBC means Whistle Blowing Committee, means a Committee normally comprising of the WBO, Head – Employee Relations, the CFO, the Company Secretary, the CEO or any other body or person(s) which shall be constituted by the Management depending on the nature of the case. This shall be facilitated the WBO.
- Policy means the Whistle Blower policy.
- Stakeholder(s) means any person who has an interest and relationship with Company operations.
- Disciplinary Action means a consequential action post the investigation and findings of the report made by the WBC or WBO.
- Officer, Whistle Blowing officer, Committee means a person or the body of people constituted to investigate a disclosure.
- Senior leadership of the Company means all persons who are in the rank of Assistant Vice President and above.
- MD means Managing Director of the Company
- JMD means Joint Managing Director of the Company.
- Disclosure means any reporting or submissions made by any stakeholder to the Whistle Blower officer or the Committee.
- Whistle Blowing Officer means an Officer who has been nominated by the Company to review and investigate disclosures made under this policy and to report the findings of investigations to the Management.
03
SCOPE OF THIS POLICY
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:
- Any good will and reputation loss
- Any financial loss
- Any loss caused due to willful negligence or sabotage
- Any action causing loss or damage to Environment, Health and Safety of the Society, Individual or the Company.
- Any breach of any rules, regulations or any Policy of the Company
- Any breach or violation of the Code of Conduct or Standing orders.
- Any disclosures made to the MD or JMD or any other senior leadership directly shall also be included in the ambit of the Whistle Blowing Policy and shall be investigated as per the Policy.
04
WHISTLE BLOWING – PROCESS AND PROCEDURES
REPORTING OF DISCLOSURE
Any stakeholder can make a disclosure to the Whistle Blowing officer by writing in an email to whistleblowing@test-wp.innoblitz.in or by sending in a letter or hand delivering a letter to The Whistle Blowing Officer, TVS Vehicle Mobility Solution Private Limited, 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 DISCLOSURES
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.
INDEPENDENT PROCESS
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.
05
RIGHTS AND DUTIES OF THE WHISTLE BLOWER AND THE COMPANY
RIGHTS AND DUTIES OF THE WHISTLE BLOWER
- To be assured of confidentiality and protection of disclosure made in good faith.
- To submit disclosures in writing with as much of evidences as possible.
- To co-operate in all investigations and not to turn hostile.
- To also maintain confidentiality about the process of investigation and matters connected or related to the case at hand.
- RIGHTS AND DUTIES OF THE WBO, WBC, COMPANY
- To acknowledge in writing to a disclosure made to the WBO or WBC within 7 days of the receipt of the same.
- To ensure a fair investigation is undertaken upon receipt of the Complaint.
- To submit findings of the investigation within 60 days of the Complaint to the Management.
- To have all powers to investigate or cause to investigate a complaint and to summon any person connected to or related to the case.
- To have all powers to seek help of any stakeholder in the investigation process.
06
COMPANY’S POWERS
disclosures made under this Policy
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.
07
REVIEW
This policy shall be reviewed each year by the Head – HR
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.
