Our company has adopted this Whistle Blower Policy in line with the objective of strengthening the governance mechanism and to report to the management instances of unethical behaviour, actual or suspected misconduct or fraud. This policy will also meet the requirement of the Companies Act, 2013.
The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees and Directors who have concerns about suspected misconduct or fraud to come forward and express these concerns without fear of punishment or unfair treatment.
This Policy aims to provide an avenue for employees and Directors to raise concerns of any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, improper misconduct, unethical behaviour etc
The Policy shall extend to whole of the Company. The Policy shall be available on the Company's website at http://www.gmmco.in/
Employees and Directors of the Company are eligible to make protected disclosures under this Policy The Whistle Blower's role is to report or raise any concerns which the individual believes is an internal malpractice or wrongdoing which could affect the business or reputation of the Company. Any allegation which falls within the scope of the concerns identified below will be seriously considered and investigated.
These concerns would include but are not restricted to:-
All suspected concerns/violations are to be reported to Mr. Shahid Ashraf, Senior Vice President – HR & Training (Designated Authority) for investigation.
The Contact details are:
Contact no: 044 – 22676201 / 8056042827
Email : whistleblowing@gmmcoindia.com
Mailing Address : Mr. Shahid Ashraf, Senior Vice President – HR & Training, GMMCO Limited, No. 6, GST Road, St. Thomas Mount Alandur, Chennai – 600 016, Tamil Nadu, India.
Protected Disclosures should preferably be reported in writing so as to ensure a clear understanding of the issues raised and should either be typed or written in a legible handwriting in English, Hindi or in the regional language of the place of employment of the Whistle Blower.
The Protected Disclosure should be forwarded under a covering letter. This shall bear the identity of the Whistle Blower.
In case the Complaint is regarding any exceptional matter or involving members of the Senior Management Team of the Company including the Key Managerial personnel, or concerning financial/accounting matters the Designated Authority shall forward the Protected Disclosure to the Chairman Audit Committee for investigation. All other Protected Disclosures shall be investigated by the Designated Authority.
The protected disclosure should be completely factual. Complete details must be elaborately discussed by the Whistle Blower to enable right and swift action.
If a Protected Disclosure is received by any executive of the Company other than the Designated authority or Audit Committee, the same should be forwarded to the Designated authority or Audit Committee for further appropriate action.
Subject to provisions under the heading "Untrue allegations", no unfair treatment will be meted out to a Whistle Blower by virtue of his/her having reported a concern under this Policy. The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle Blowers.
Protection will be given to Whistle Blowers against any unfair practice like retaliation, threat or intimidation of 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 Whistle Blower's right to continue to perform his duties/ functions including making further Disclosure. The Company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Disclosure.
The Identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. Any Employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.
If a Whistle Blower face any retaliatory action or threat as a result of making a Protected Disclosure he may immediately write to the Chairman of the audit Committee who will recommend appropriate steps to protect the Whistle Blower from such retaliatory action and ensure implementation of such steps for the protection of the Whistle Blower.
This Policy encourages individuals to put their name to any Disclosures they make. Disclosures expressed anonymously are much less credible, but they may be considered at the discretion of the Audit Committee. In exercising this discretion, the factors to be taken into account will include:
In making a Disclosure the individual should exercise due care to ensure the accuracy of the information. If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. If however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them despite the outcome of the investigation, the Audit Committee may recommend action against the individual.
The investigation shall be completed normally within 60days of the receipt of the concern. However in appropriate cases, the Designated Authority or the Audit Committee as the case may be, for reasons to be recorded in writing may take longer time to complete the investigation.
If the investigation is carried out by the Designated Authority, the Designated Authority shall forward its finding to the Audit Committee.
If the investigation by the Designated authority or by the Audit Committee as the case may be leads the Audit Committee to conclude that an improper or unethical act has been committed, the Audit Committee shall recommend to the management/ Board of the Company to take such disciplinary or corrective action.
All Disclosures in writing as well as all documents related to any investigation and the results of the investigation relating thereto shall be retained for a period of 7 years.
This Policy may be amended or modified in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the employees which will be notified to the employees by posting it on the Company's website at http://www.gmmco.in