Ramaiah Capital Private Limited (RCPL) believes that it is important to prevent corruption, misuse of office property/powers, suspected actual frauds, acts resulting in Financial Loss Operational Risk, Loss of reputation, etc. These are activities which are detrimental to customer’s interest / public interest. It is important to provide an appropriate forum to provide the various stakeholders to fearlessly and openly inform about any of the above-mentioned activity.

 The Whistle-blower policy has been introduced for this purpose. This policy will encourage the stakeholders to bring any issue relating to violation of ethical, regulatory norms, rules and regulations etc. to RCPL’s notice without any fear of retaliation, discrimination or harassment.

 

Objective

 The purpose of this policy is to provide an avenue for the stakeholders to raise concerns and also provide the necessary safeguards for protecting the individuals who come forward from reprisals or victimisation, for whistleblowing in good faith.

 

Eligibility

All stakeholders of RCPL are eligible to raise an issue under the provisions of the policy. The stakeholders of RCPL are Employees (Including Trainees), Consultants, Vendors, Customers and any other individual who is associated with RCPL.

 

The Team

RCPL will constitute a team of two members comprising of the Head of Human Resources and the CEO to receive all the reports/ complaints made under this policy. 

This team will be responsible for receiving all complaints under this policy, maintaining confidentiality and ensuring appropriate action. The team is empowered to appoint an enquiry committee (as may be required) to conduct investigation and enquiries as part of their fact finding process. The members in this committee must exhibit fairness, objectivity, thoroughness, ethical behaviour and must observe high standards of professionalism. The team can also involve investigators at its discretion for the purpose of investigation and as part of fact finding.

 

Lodging of Complaints

The whistle blower shall lodge the complaint in writing or through electronic means by marking the communication as confidential to the Head of HR or the CEO in a sealed cover marked confidential.

In case the compliant is against the HR Head or the CEO the complaint shall be made directly to the Managing Director.

 

Whistel Blower enquiry team (WBET) shall

· Ensure effective implementation of this policy

· Ascertain the credibility of the issue/concern raised

· Document the investigation, related enquiries and further proceedings

 · Ensure that necessary safeguards are provided to the complainant

 · Maintain strict confidentiality

· Ensure complete fact-finding and conduct enquiry in a fair and unbiased manner (discretely wherever possible)

 · Decide on the course of investigation and recommend an appropriate course of action

 · Document the proceedings and minute all the deliberations and store them confidentially

 · Take periodical back-ups of such records to prevent loss of information

 

Alleged Person

· Must cooperate with the investigation process and the WBET

· Should not interfere with the enquiry process and further proceedings

· Have a right to know the outcome of the investigation and also has a right to appeal

 

Investigation

In order to protect the identity of the complainant WBET will not issue any written acknowledgement of receipt of the complaint. Subject to verification of facts, WBET will take the necessary action and if required, will get in touch with the complainant to obtain more information

 

Safeguards

If any individual raises a concern under this policy, WBET will ensure that the individual is not at risk of retaliation or reprisal and will also make every effort possible to protect the identity of the complainant.

 

Disqualifications

Safeguards under this policy would not entail any protection from any disciplinary action to be taken for false allegations (where it is proved that the false complaint was made with an intention).

 

Decision

If the investigation confirms the complainant’s concern, WBET shall recommend to the management to take such disciplinary action and preventive/corrective action as deemed fit.

 

Communication

The policy will be communicated to all its stakeholders and a copy of this policy can be obtained from RCPL on demand by any stakeholder. Employees are communicated about this policy during the induction and handed over an excerpt of this policy any amendments in the policy will be shared via email. Constant reminders on the policy will be sent to all the employees via email.