Whistle Blower Policy
Aptus Finance India Private Limited (the Company) believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behavior. Towards this end, the Company has adopted the “Code of Conduct”, which lays down the principles and standards that should govern the actions of the Company and its employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the Company. The role of the employees in pointing out such violations of the Code cannot be undermined. There is a provision under the Code requiring employees to report violations, which states:
Any Employee or Director should disclose or demonstrate an evidence of an unethical activity or any conduct that may constitute breach of the Code of Conduct or the Values of the Company. This whistleblower has come to the decision to make a disclosure or express a genuine concern/grievance/allegation, after a lot of thought.
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 Values and/ or the Code of Conduct of the Company.
Aptus Finance India Private Limited 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 Management and will be treated as an act warranting disciplinary action and will be treated-so.
The Company condemns any kind of discrimination, harassment, victimization or any other unfair employment practice adopted against whistleblowers. Complete protection will be given to whistleblowers against any unfair practices like retaliation, threat or intimidation, 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.
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 based 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 Management shall take appropriate disciplinary or legal action against the concerned whistleblower.
Scope of Reporting
This policy encourages all Whistle Blowers to report any kind of misuse of company’s properties, or mismanagement or wrongful conduct prevailing/executed in the company, which the whistleblower in good faith, believes, evidences any of the following:
Action by Audit Committee/Director
If charges are substantiated, or the complaint is found correct on investigation, suitable action will be suggested. The following punitive actions could be taken against employees, where the committee finds the accused guilty:
The above are only suggestive and the Committee / Managing Director may decide on the actions to be taken on a case to case basis depending on the gravity of the offence. If wrongful conduct remains largely unsubstantiated; the committee has the right to close the complaint.
If the case is found to be false and malicious in intent and the whistle blower / complainant has indulged in this knowingly, he/she would be held guilty of misconduct and appropriate action shall be taken. However, the Committee shall distinguish between mistaken reporting and malicious intent of the complainant.
The decision of Audit Committee / Director will be binding on the parties involved / parties found guilty of the reported mis-conduct.