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POLICY |
Whistleblower Policy |
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OBJECTIVE |
To provide
employees, customers and vendors an
avenue to raise concerns, in line
with the commitment of Cholamandalam Investment and Finance Company Limited to
the highest possible standards of
ethical, moral and legal business
conduct and its commitment to open
communication.
To provide necessary safeguards for
protection of employees from
reprisals or victimization, for
whistleblowing in good faith. |
| SCOPE |
All permanent
employees, customers and vendors of
Cholamandalam Investment and Finance Company Limited. |
|
COVERAGE |
Cholamandalam Investment and Finance Company Limited including
Associate Companies and Joint
Ventures. |
MAIN
FEATURES
Improper Practice |
The whistleblowing
policy is intended to cover serious
concerns that could have a large
impact on Cholamandalam Investment and Finance Company Limited, such as actions
(actual or suspected) that:
" May lead to incorrect financial
reporting;
" Are not in line with applicable
company policy;
" Are unlawful or,
" Otherwise amount to serious
improper conduct. |
Complainant
(Whistleblower) |
An
employee/customer/vendor making a
disclosure under this policy is
commonly referred to as a
complainant (whistleblower). The
complainant’s role is as a reporting
party, he/she is not an
investigator. Although the
complainant is not expected to prove
the truth of an allegation, the
complainant needs to demonstrate to
the Ombudsperson, that there are
sufficient grounds for concern. |
|
Safeguards |
Harassment or
Victimisation: Harassment or
victimistion of the complainant will
not be tolerated and could
constitute sufficient grounds for
dismissal of the concerned employee.
Confidentiality: Every effort
will be made to protect the
complainant’s identity, subject to
legal constraints.
Anonymous Allegations:
Complainants must put their names to
allegations as follow-up questions
and investigation may not be
possible unless the source of the
information is identified. Concerns
expressed anonymously WILL NOT BE
usually investigated BUT subject to
the seriousness of the issue raised
the Ombudsperson can initiate an
investigation independently.
Malicious Allegations:
Malicious allegations by employees
may result in disciplinary action. |
|
Ombudsperson |
The Ombudsperson
will be a person, including a
fulltime senior employee, well
respected for his/her integrity,
independence and fairness. S/he
would be authorised by the Statutory
Board of the company for the purpose
of receiving all complaints under
this policy and ensuring appropriate
action. |
|
Reporting |
The whistleblowing
procedure is intended to be used for
serious and sensitive issues.
Serious concerns relating to
financial reporting, unethical or
illegal conduct should be reported
to the Ombudsperson. Annexure
I provides the necessary
contact details. |
|
Investigation |
All complaints
received will be recorded and looked
into. If initial enquiries by the
Ombudsperson indicate that the
concern has no basis, or it is not a
matter to be 4/9 pursued under this
policy, it may be dismissed at this
stage and the decision documented.
Where initial enquiries indicate
that further investigation is
necessary, this will be carried
through either by the Ombudsperson
alone, or by a Committee nominated
by the Ombudsperson for this
purpose. The investigation would be
conducted in a fair manner, as a
neutral factfinding process and
without presumption of guilt. A
written report of the findings would
be made. |
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Investigation Result |
Based on a thorough
examination of the findings, the
committee (or Ombudsperson) would
recommend an appropriate course of
action to the CEO / MD of Cholamandalam Investment and Finance Company Limited.
Where an improper practice is
proved, this would cover suggested
disciplinary action, including
dismissal, if applicable, as well as
preventive measures for the future.
All discussions would be minuted and
the final report prepared. |
|
Investigation Subject |
The investigation
subject is the person / group of
persons who are the focus of the
enquiry / investigation. Their
identity would be kept confidential
to the extent possible. |
|
Reporting by Ombudsperson |
The Ombudsperson
will provide quarterly reports to
the Chairman of the Statutory Board
with a copy to the Group Director
HR. |
|
Communication with Complainant |
The complainant
will receive acknowledgement on
receipt of the concern.
The amount of contact between the
complainant and the body
investigating the concern will
depend on the nature of the issue
and the clarity of information
provided. Further information may be
sought from him/her.
Subject to legal constraints, s/he
will receive information about the
outcome of any investigations. |
| Changes
to Policy |
This policy can be
changed, modified, rescinded or
abrogated at any time by Cholamandalam Investment and Finance Company Limited. |
ACCOUNTABILITIES
Employees / Customers /
Vendors |
- Bring to early attention of
the company any improper
practice they become aware of.
Although they are not required
to provide proof, they must have
sufficient cause for concern
- Avoid anonymity when raising
a concern.
- Co-operate with
investigating authorities,
maintaining full
confidentiality.
- The intent of the policy is
to bring genuine and serious
issues to the fore and it is not
intended for petty complaints.
Malicious allegations by
employees may attract
disciplinary action.
- A complainant has the right
to protection from retaliation.
But this does not extend to
immunity for complicity in the
matters that are the subject of
the allegations and
investigation.
- In exceptional cases, where
the complainant is not satisfied
with the outcome of the
investigation carried out by the
Ombudsperson, s/he can make a
direct appeal to the Chairman of
the Audit Committee of Cholamandalam Investment and Finance Company Limited.
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|
Ombudsperson |
- Ensure that the policy is
being implemented.
- Ascertain prima facie the
credibility of the charge. If
initial enquiry indicates
further investigation is not
required, close the issue.
- Document the initial
enquiry.
- Where further investigation
is indicated carry this through,
appointing a Committee if
necessary.
- Provide quarterly reports to
the CEO of Cholamandalam Investment and Finance Company Limited with a copy
to the Group Director HR.
- Acknowledge receipt of
concern to the complainant,
thanking him/her for initiative
taken in upholding the company’s
business conduct standards.
- Ensure that necessary
safeguards are provided to the
complainant.
|
Ombudsperson /
Committee |
- Conduct the enquiry in a
fair, unbiased manner
- Ensure complete
fact-finding.
- Maintain strict
confidentiality.
- Decide on the outcome of the
investigation, whether an
improper practice has been
committed and if so by whom.
- Recommend an appropriate
course of action - suggested
disciplinary action, including
dismissal, and preventive
measures.
- Minute Committee
deliberations and document the
final report.
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| CEO |
- Table the quarterly reports
from the Ombudsperson with the
Statutory Board.
- Ensure necessary actioning
of recommendations of the
Ombudsperson / Committee.
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|
Investigation Subject |
- Provide full co-operation to
the Investigation team.
- Be informed of the outcome
of the investigation.
- Accept the decision of the
Ombudsperson.
- Maintain strict
confidentiality.
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