VALUES AND WHISTLE BLOWER POLICY – MORE RETAIL
LIMITED
MRL
Issue No: 02
Revision No: 1
Date of Release: 01st Sep 2019
Whistle Blower Policy | MRL
Values and Whistle Blower Policy
Prepared By: Head HR
Issue No.:01 Revision No.: 01
First Released on: Approved by: CHRO
Document No.: MRL
th
20 May 2019
REVISION HISTORY
Iss/ Description of
Author Effective Date
Rev Change
00/01 First Issue Head – HR 1st Jan 2020
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
Table of Contents
1. Purpose of this policy ......................................................................................................... 4
2. Scope .................................................................................................................................. 5
3. Definitions and acronyms ................................................................................................... 6
4. Flow Charts ......................................................................................................................... 6
5. Protection of whistle blower .............................................................................................. 7
6. Reporting in good faith ....................................................................................................... 7
7. List of exclusions ................................................................................................................. 7
8. Dealing with anonymity ...................................................................................................... 8
9. Confidentiality .................................................................................................................... 8
10. Procedure for raising a complaint .................................................................................. 8
11. Procedure for handling a complaint is as given below: ................................................ 11
12. Appeal by aggrieved person :……………………………………..............................................13
13. Reporting Mechanism ................................................................................................... 13
14. Important Templates .................................................................................................... 13
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
The MRL Leadership Principles & Values of Customer Obsession, Frugality, Growing Talent,
Grit, Collaboration and Integrity are the foundation for all actions and decisions we take. They
set standards for the organization and for employee conduct.
To ensure that there is a common minimum standard of professional behavior, MRL has
articulated the Policy on Code of Conduct / Redressal Process. This policy lists down broadly
the identifiable and non-negotiable set of actions/behavior applicable to all employees across
the company. It provides direction and limits. It explains how to report violations/ potential
violations of the MRL Code of Conduct and the process of Redressal.
1. Purpose of this policy
The purpose of this policy is to articulate the company’s point of view on whistleblowing, the
process, and the procedure to strengthen whistleblowing mechanism at MRL.
This policy:
Provides a platform and mechanism for the Employees and Directors to voice genuine
concerns or grievances about unprofessional conduct without fear of reprisal
It provides an environment that promotes responsible and protected whistle blowing.
It reminds Employees and Directors about their duty to report any suspected violation
of any law that applies to the company and any suspected violation of the MRL Code
of Conduct.
Above all, it is a dynamic source of information about what may be going wrong at
various levels within the company and which will help the company in realigning
various processes and take corrective actions as part of good governance practice.
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
2. Scope
This policy is applicable to all employees, irrespective of their level, across all stores, offices,
DCs, RPCs, CCs and all other establishments.
This document provides guidelines for the operationalization of whistle blower / value
standards committee, through a robust process of dealing with violations of code or conduct
/ values, and outlines steps for employees to report any incident of violation. Every employee
will be given a fair trial according to the ‘principle of natural justice.’
The principle of natural justice includes three key features
1. The right to be heard by an unbiased tribunal
2. The right to have notice of charges of misconduct
3. The right to be heard in answer to that charge
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
3. Definitions and acronyms
3.1. “Employee” - For the purpose of this policy, the term “employee” means any person
on the rolls of MRL including offices DCs, RPCs, CCs , stores and all other
establishments. This will include employees who fall in the managerial, supervisory
or workmen cadre.
3.2. “Whistle Blower” - Any Employee or Director who discloses or demonstrates an
evidence of an unethical activity or any conduct that may constitute breach of the
Group’s/Group Company’s Code of Conduct or Group Values. This whistleblower has
come to the decision to make a disclosure or express a genuine concern
/grievance/allegations, after a lot of thought.
3.3 “Values Standard Committee”- A Committee formed under this policy to investigate
complaints of violation of code of conduct / values referred to it and takes
appropriate disciplinary action
3.4 “Whistle blower officer”- For the purpose of this policy, the Company Secretary (or
in his absence, the Legal Head) of the relevant Unit/Business would act as the
Secretary of the relevant Values Standard Committee and is also known as a Whistle
Blower officer.
4. Flow Charts
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
5. Protection of whistle blower
The process is designed to offer protection to the whistleblower (employees and directors)
provided that the disclosure made / concern raised / allegations made (“complaint”) by a
whistleblower is in good faith and the alleged action or non-action constitutes a genuine and
serious breach of what is laid down in the Group Values or MRL’s Code of Conduct , policy.
The company affirms that it will not allow any whistleblower to be victimized for making any
complaint. Any kind of victimization of the whistleblower brought to the notice of the Value
Standards Committee will be treated as an act warranting disciplinary action and will be
treated so.
As a company, we condemn any kind of discrimination, harassment, victimization or any other
unfair employment practice adopted against the whistleblowers. Complete protection will be
given to the whistleblowers against any unfair practices like retaliation, threat or intimidation
or termination/suspension of service, disciplinary action, transfer, demotion, refusal of
promotion, or the like including any direct or indirect use of authority to obstruct the
whistleblower’s right to continue to perform his/her duties/functions in a free and fair
manner.
6. Reporting in good faith
Every Whistle Blower is expected to read and understand this policy and abide by it. It is
recommended that any individual who wishes to report, do so after gathering adequate
facts/data to substantiate the complaint and not complain merely on hearsay or rumor. This
also means that no action should be taken against the whistleblower, if the complaint was
made in good faith, but no misconduct was confirmed on subsequent investigation.
However, if a complaint, after an investigation proves to be frivolous, malicious or made with
an ulterior intent, the Value Standards Committee shall take appropriate disciplinary or legal
action against the concerned whistleblower.
7. List of exclusions
The following types of complaints will ordinarily not be considered and taken up:
1. Complaints that are Illegible , if handwritten
2. Complaints that are vague , with pseudonyms
3. Complaints that are trivial or frivolous in nature
4. Matters which are pending before a court of Law, State, National Human Rights
Commission, Tribunal or any other judiciary or sub judiciary body
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
5. Any matter that is very old from the date on which the act constituting violation is
alleged to have been committed
6. Issue raised, relates to service matters or personal grievance
The Whistle Blowers are encouraged to make complaints that have an impact on company’s
Brand & reputation, cases of financial irregularities, or People related issues of bias, partiality,
and discrimination of any kind, abuse, victimization or harassment.
8. Dealing with anonymity
A whistleblower may choose to keep his/her identity anonymous. In such cases, the
complaint should be accompanied with strong evidence and data.
9. Confidentiality
The Value Standards Committee will treat all complaints in a confidential and sensitive
manner. In specific cases where the criticality and necessity of disclosing the identity of the
whistleblower is important , it may be disclosed, on a ‘need-to-know-basis’, during the
investigation process and only with the prior approval of the whistleblower.
10. Procedure for raising a complaint
A whistleblower can make a compliant in multiple ways:
1. Can write to the relevant Value Standards Committee. The information about name of
members and list of Value Standards Committee (VSC) at various levels, their e-mail id are
available as below:-
Business Level Value Standards Committee
Business Name Role Email ID
Mr. Sumit Narang Chairman
Mr. Mohit Kampani Secretary
MRL Mr. Sashi Gumma Member MRL-mum.whistleblower@moreretail.in
Mr. Girdhar Chitlangia Member
Mr. Ganesh Subramanian Member
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
2. Unit Level Complaints committee
Unit level complaints committee is constituted at various regional level. The unit level
complaints committee will receive and investigate the complaints raised by employees in the
respective regions and stores. The members of Unit Level Value Standard Committees are as
per the table below.
Units Name Role Group Email -id
Deepak Gupta Chairman
Subhash Chander Member
Chandan Kalia Secretary
North Anuj Jain Member Uvsc.north@moreretail.in
Mayur Saxena Member
Tanushree Ajwani Member
Loknath Prahladka Member
Ajay Thakur Chairman
Arnab Seth Secretary
Pravin Gupta Member Uvsc.east@moreretail.in
East
Arnab Bhattacharya Member
Pranab Adhikary Member
Sunil Tripathi Member
Jogendra Shah Chairman
Anish Mathew Secretary
Gopalkrishna M Member Uvsc.west@moreretail.in
West
Vikas Sanas Member
Sachin Mule Member
Kushal Garg Member
K S Dinesh Chairman
Satish Sharma Secretary
Revathi S. Member
TG Kavitha Member Uvsc.tg@moreretail.in
M S Prasad Member
Shiva Rallabandi Member
Hrishikesh Kashyap Member
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
PVD Prasad Chairman
Srinivas Bh. Secretary
Madhu Rayicharla Member
AP Uvsc.ap@moreretail.in
Venkat Narshimhan Member
Pradeep Maji Member
Shyam Pai Member
Appa Rao Chairman
A Raja Member
Phani Madhav Member
TN Laxmi Kumar Member Uvsc.tn@moreretail.in
Anuradha Member
Haribabu Y Secretary
Anita Chandran Member
Predeep Sanker Chairman
Harikrishnan MN Secretary
KE Ranjith Chandran Member Uvsc.ke@moreretail.in
Madhukumar R Member
Nirmal Pillai Member
Atif Rasheed Chairman
Krishnan T S Secretary
Gaurav Mehta Member
Jagananth PSK Member
KN Uvsc.kn@moreretail.in
Kritika Surya Member
Jamir Shah Member
Mohan Kumar Member
Manoj Pawle Member
A whistle blower can send a complaint to the ethics hotline by calling on a toll free number
1800 2000 226, or write to moreconnect@ethicshelpline.co.in, or write to P. O. Box No 71,
DLF Phase 1, Qutub Enclave, Gurgaon -122002, Haryana, India
3. By writing to the Chief Human Resource Officer or Company Secretary, as these officials
are duty bound to share the complaint with the Ethics Hotline.
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
11. Procedure for handling a complaint is as given below:
1. A whistle blower identifies non-adherence of Group Values or MRLs’ Code of Conduct
by any employee or a segment of the organization, will compile information that
supports the case.
2. The whistle blower sends the complaint to the Value Standards Committee or ethics
hotline ,depending on:
The level at which the violation is perceived to be happening, or
The seniority of the individual/s involved
His perception of getting justice from an appropriate body.
3. Upon receipt of information, the secretary of the relevant Values Standard Committee
will first do a preliminary investigation to check whether the complaint seems to be
genuine and falls under the purview of whistle blower policy. If complaint is sent with
malicious intent, then the committee will take appropriate disciplinary action against
the whistle blower.
4. If complaint does not fall under the purview of whistle blower policy, then same would
be redirected to the right forum. For eg – If complaint is related to sexual harassment,
same will be forwarded to the internal Complaints Committee and would be dealt as
defined under. – Policy to Prevent Sexual Harassment at the Workplace If complaint is
related to a personal grievance, e.g. appraisal rating, promotion etc, it will be
forwarded to the Chief Human Resource Officer.
5. Once established that the case needs investigation, the secretary of the Value
Standards Committee after discussion with the committee shall appoint a team to
investigate the case, with utmost confidentiality. The investigative team can be a pool
of internal people specially trained to investigate or can be an external agency
specialized to investigate such cases.
6. Under no circumstances, the secretary, investigation team and the committee would
reveal / disclose the identity of the “accused‟ to anyone else (including the immediate
manager) – other than all those who are required to know about the case.
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
7. The investigation team should work towards ensuring that the investigation is
completed by following the laws of the land and principles of natural justice within 3
weeks of the complaint being reported. If the investigation cannot be completed
within 3 weeks, then the committee needs to have very valid and strong reasons for
the same.
8. Once the investigation is completed, the secretary will submit the report of
investigation to the committee and the committee will then decide on the quantum
of punishment to be given. While deciding on this, the committee will consider the
following:
o Severity of the misconduct
o Impact on the Organization (Reputation, Financial / Non – Financial)
o Past record of the employee
o Past precedence of treating similar violations (a summary of the same will be
kept with Organization Effectiveness portfolio at Group Human Resources)
9. The punishment shall constitute a minimum of written warning and may lead to
withdrawal of last increment, demotion, withholding promotion, dismissal from
service and/ or even prosecution in a court of law.
10. Once the report is received, the committee will put its recommendation and forward
it to the respective Management team. The team will consider the recommendation
and decide on appropriate action within 15 days of receiving the recommendation.
11. While implementing the recommendation, the management will ensure that the
name of the whistle blower and the person accused is kept confidential at all times.
12. If the charges framed on the accused are found to be false after investigation, it is very
essential to demonstrate that the employee’s dignity is respected. Hence, the Business
Head / Unit Head should thank the employee personally for having cooperated in the
process. A formal closure letter has to be sent informing that the charges have not
been proved during the investigation process and hence he / she are fully exonerated
of all the charges.
12. Appeal by aggrieved person:
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
a. The employee has the option to appeal to the next higher level committee. If
he / she appeals, the decision of this committee will be final and binding.
b. If the employee chooses to appeal against the order, he / she has to submit a
request in writing to the next higher level of committee i.e. Group Value
Standards Committee within 7 days of receiving the order. If the request is not
received within 7 days, the next higher level committee i has the option to reject the
appeal.
c. Based on the request for appeal, the committee will decide whether to
reinvestigate/ re-look at the quantum of punishment. However, the next higher
level committee will close the case within 21 days of receiving the appeal.
d. The victim employee has the option of seeking his/her own transfer if the case
is found to be valid and serious.
e. If the whistle blower or the person accused feels unsatisfied with the outcome of
his/her complaint to the Regional level /Business Level committee as the case
may be, he/she may appeal to the Group Complaints Committee. This
committee after hearing the appeal shall review the case and present their
recommendations to the appropriate Management Team. The decision of the
Group Level Management Team will be final and binding on all parties
concerned.
13. Reporting Mechanism
An Annual and Quarterly report will be prepared by the Business Value Standards Committee
of which copies will be placed before the Audit Committee of the relevant Group Company
and Organization Effectiveness portfolio at Group Human Resources.
14. Important Templates
Annexure 1 – Template for reporting violations
Annexure 1 – Template for Reporting Violation
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
To: Value Standards Committee <at Business or Zonal level>: ____________________
Please select the applicable incident type(s) from the list below that best describes the issue(s)
you are reporting. Please note that multiple issues can be selected
1. Misappropriation of company assets or resources
2. Conflict of interest
3. Inappropriate sharing of confidential information
4. Financial fraud of any nature
5. Violation of gifts and entertainment policy
6. Non-adherence to safety guidelines
7. Inaccurate financial reporting
8. Bribery & Corruption
9. Insider trading
10. Other forms of Harassment – Victimization, Bullying, Discrimination etc.
11. Social Media Usage
12. Misuse of authority
13. Environment, health and safety
14. Concurrent employment
15. Others ___________________________________________________
Please provide name, designation and department of the person(s) involved?
Name Department Designation
Individual 1
Individual 2
Individual 3
Individual 4
When did the incident occur? (Please provide tentative date if you do not know the exact date)
________________________________________________
Please confirm the location of the incident
________________________________________________
How did you find out about this incident?
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy | MRL
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
How long has this been occurring for?
Less than a month
1-6 months
6-12 months
Greater than 12 months
Please provide a detailed description of the incident. To enable your company to act on your
complaint, you are requested to provide specific information where possible including names,
location, date, time etc. Please note that this field is limited to 5,000 characters.
_________________________________________________________________________________
_________________________________________________________________________________
________________________________________________________________________________
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This policy is confidential and should not be circulated beyond current MRL employees. MRL reserves
unconditional right to amend, abrogate, modify and / or rescind any of the provisions of this policy at any time .
Whistle Blower Policy| MRL –
Do you have any evidence in support of your allegations?
Yes
No
Is anyone else aware of this incident?
Yes
No
Is there any additional information that would facilitate the investigation of this matter?
Yes
No
Have you reported this incident to anyone in the company?
Yes
No
Date: __________________________
Location: ___________________________
Name of the Person reporting (optional): ___________________________
Contact Information (incl email optional): ___________________________
The complaint should be either reported on Values Microsite on Poornata to the relevant Values Standard Committee
at Unit, Business or Group level or can be shared to ethics hotline at either verbally over a phone or through email.
The details of the Values Standard Committee is available on Values microsite on Poornata and Onstream.
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