WHISTLE BLOWER POLICY
OBJECTIVE & SCOPE OF WHISTLE BLOWER POLICY
It is indeed with great pleasure and pride, we are introducing this Whistle Blower Policy to
Patil Group of Industries.
The company believes in the conduct of the affairs of its constituents in a fair and
transparent manner by adopting highest standard of Quality, professionalism, honesty,
integrity and ethical behaviour.
We are committed to developing a culture where it is safe for all employees, direct and
indirect workers to raise concerns about any poor or unacceptable practice and any event of
misconduct and to ensure 100% compliance on Quality of Product and to create non-
compromised Quality environment.
The Whistle Blower Policy is created to provide all employees, direct and indirect workers,
an avenue to raise concerns, in line with the organization’s commitment to the highest
possible standards of ethical, moral, Quality and legal business conduct and its commitment
to open communication.
The policy neither releases anyone from their duty of confidentiality in the course of their
work, nor is it a route for taking up a grievance about a personal situation.
This policy shall provide necessary safeguards for protection of everyone from reprisals or
victimization, for whistle blowing in good faith. It protects each and every person wishing to
raise a concern about serious irregularities within the company.
This Policy shall be applicable to all group companies of Patil Group.
FEATURES OF WHISTLE BLOWER POLICY
The Whistle blower policy is intended to cover serious concerns that could have a large
impact on the organization, such as actions (actual or suspected) that :
May lead to incorrect financial reporting including fraud or suspected fraud
Are not in line with applicable company policy
Are unlawful or unethical, biased, favoured, imprudent event
Ignorance of Quality Parameters of Production Process
Manipulation of the Quality standard readings
Abuse of authority
Breach of contract/Employee code of conduct or rules
Negligence causing substantial and specific danger to public health and safety
Manipulation of company data/records
Criminal offence
Pilferation of confidential/proprietary information/technical data
Wastage/misappropriation of company funds/assets
LIST OF QUALITY CONCERNS
If the Production is not as per the defined process
If found manipulation in any of the production processes viz.
1. Mould cleaning
2. Tensioning
3. Vibration
4. Steam Curing & Water Curing
Use of bad quality Raw materials (Sand, Cement, Metal, Inserts, etc.)
Manipulating the readings/adjustment of readings
Use of bad quality wire rods
If there is no proper stranding of wires
SR – Heat Treatment Deviation
Compliance of Quality Manual – No short circuiting of QC
PROCESS OF WHISTLE BLOWER POLICY
WHISTLE BLOWER (COMPLAINANT)/OMBUDSPERSON :
An employee making a disclosure under this policy is commonly referred to as a Whistle
Blower (Complainant) and the person receiving the disclosure is referred to as
Ombudsperson.
The ombudsperson may be a Non – Executive Director, or any person including a full time
senior employee or may be an outsider, well respected for his/her integrity, independence
and fairness. He/she would be authorised by the Statutory board of the company for the
purpose of receiving all complaints under this policy and ensuring appropriate action.
The whistle blower’s role is as a reporting party, he/she is not an investigator. Although the
whistle blower is not expected to prove the truth of an allegation, he/she needs to
demonstrate to the Ombudsperson that there are sufficient grounds for concern.
SAFEGUARDS :
1. Harassment or victimisation of the whistle blower will not be tolerated and could
constitute sufficient grounds for dismissal of the concerned employee.
2. Confidentiality shall be strictly maintained and every effort will be made to
protect the whistle blower’s identity.
3. Whistle blower must put their names to allegations as follow-up questions and
investigation may not be possible unless the source of 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.
4. Malicious allegations by employees may result in disciplinary action
The whistle blowing 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. The necessary format for whistle blowing is provided vide
Annexure - I enclosed.
Investigation :
All complaints received under this policy shall 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 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 fact finding process and without presumption of guilt. A written report of the
findings would be made covering the following:
1. Facts of the matter
2. Whether the same protected disclosure was raised previously by anyone, and
if so, the outcome thereof
3. The finance/otherwise loss which has been incurred/would have been
incurred by the Company
Investigation Subject :
The investigation subject is the person/group of persons who are the focus of the
enquiry/investigation. Their identity shall be kept confidential to the extent possible.
Investigation Result :
Based on a thorough examination of the findings, the committee or ombudsperson would
recommend an appropriate course of action to the Executive Chairman of the Company.
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.
The investigation subject is the person/group of persons who are the focus of the
enquiry/investigation. Their identity shall be kept confidential to the extent possible.
The ombudsperson will provide quarterly reports to the Executive Chairman.
Communication with Whistle Blower :
The whistle blower will receive acknowledgement from the ombudsperson on receipt of the
concern.
The amount of contact between the whistle blower and the ombudsperson/investigating
body will depend on the nature of the issue and the clarity of information provided. Further
information may be sought from the whistle blower if necessary. Subject to legal
constraints, the whistle blower 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 the statutory
body of the organization.
Accountabilities of Whistle Blower :
1. 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.
2. Avoid anonymity when raising a concern.
3. Co-operate with investigating authorities, maintaining full confidentiality.
4. The intent of the policy is to bring genuine and serious issues to the forum and it is
not intended for petty complaints. Malicious allegations by employees may attract
disciplinary action.
5. A whistle blower 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.
6. In exceptional cases, where the whistle blower is not satisfied with the outcome of
the investigation carried out by the ombudsperson, he/she can make a direct appeal
to the Executive Chairman.
Accountabilities of Ombudsperson :
1. Ensure that the policy is being implemented
2. Ascertain prima facie – the credibility of the charge. If initial enquiry indicated
further investigation is not required, close the issue
3. Documentation of the initial enquiry
4. Where further investigation is indicated, carry this through, appointing a Committee
if necessary
5. Provide quarterly reports to the Executive Chairman of the group.
6. Acknowledge the receipt of concern to the whistle blower, thanking him/her for
initiative taken in upholding the company’s business conduct standards.
7. Ensure that necessary safeguards are provided to the whistle blower.
Responsibilities of Ombudsperson :
1. Conduct the enquiry in a fair, unbiased manner
2. Ensure complete fact-finding
3. Maintain strict confidentiality
4. Decide on the outcome of the investigation, whether an improper practice has been
committed and if so, by whom
5. Recommend an appropriate course of action, suggest disciplinary action, including
dismissal and preventive measures
6. Minute committee deliberations and document the final report
Investigation Subject :
1. Provide full co-operation to the Investigation team/ombudsperson
2. Be informed of the outcome of the investigation
3. Accept the decision of ombudsperson
4. Maintain strict confidentiality
Rewards :
The Whistle blower shall be suitably rewarded if the concern raised is proved or found to
be correct, depending on the seriousness of the concern.
Special Award :
We, as an Organization is highly focused towards Quality Product and working
continuously towards creating un-compromised quality environment. The action against
ignorance of Quality or manipulation in recording the Quality parameters shall be taken
very seriously. Any concerns raised related to Quality parameters shall be highly
rewarded with a special award.
The process flow of Whistle Blower Policy
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Employee raises a concern
C
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O
Ombudsperson
M
M
Initial Enquiry Concern Dismissed Stop
U
N
Appoint Committee if
I
required/Further investigation
C by ombudsperson
T
Detailed investigation Investigation subject
I
N Decision on action to be Concern disproved Investigation subject
taken exonerated
Concern proved
Disciplinary action
Preventive measures
ANNEXURE – I
(Format for Whistle Blowing)
Date :
From : (Name of the employee & email id to be communicated)
To : Ombudsperson, pgiwhistle@gmail.com & chairman.pgi@gmail.com
Mobile No : 9866789944
9133448181
Investigation subject : (Name of the person focused at)
Brief of the concern
Any evidences : (attach evidences if any)
Note : The whistle blowing shall be submitted atleast within 30 days of the occurrence of
the concern/event (or) before occurrence
