Approved by CEO | Ver: 001 | DATE: 15.03.2021
SPEAK UP AT HIRA
Whistle Blower Policy
I. Objective
HIRA and its group companies 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/ various stakeholders who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. This policy aims to provide an avenue for employees/ various stakeholders to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements, reports and unethical practices.
II. Applicability
Various stakeholders of the Company are eligible to make Protected Disclosures under this policy. The stakeholders may fall into any of the following broad categories:
- Employee of the Company.
- Employees of other agencies deployed for the Company's activities, whether working from any of the Company's offices or any other location.
- Contractors, vendors, suppliers or agencies (or any of their employees) providing any material or services to the Company.
- Customer of the Company.
- Business partners and joint ventures.
- Any other person/ entity having direct and indirect association with the Company.
A person belonging to any of the above-mentioned categories can avail of the channel provided by this policy for raising an issue covered under this policy.
III. Coverage of the Policy
This policy encourages all the employees/ various stakeholders of the Company as aforesaid to report in good faith any violation of The Hira Group Code of Ethics covering the following:
- Violation of any laws or regulations, policies including but not limited to corruption, bribery, theft, fraud, coercion and willful omission;
- Unethical selection of suppliers & procurement frauds;
- Failure to keep accurate and complete financial records; Manipulation of company data/records;
- Conflict of interest; Abuse of authority; Negligence; Reputation Damage;
- Breach of Company Policy or failure to implement or comply with the approved policy;
- Mismanagement, wastage, misappropriation or unofficial use of company funds/assets/human resources;
- Leaking confidential/proprietary information;
- A substantial and specific danger to public health and safety;
- Unlawful discrimination, abuse or harassment physical & verbal;
- Retaliation;
- Breach of IT Security and data privacy;
- Social Media Misuse;
- Anticompetitive behaviour, such as entering into unlawful agreements with competitors.
IV. Procedure
- In line with Hira Group Code of Ethics policy, all employees are required to act honestly and always with the highest levels of integrity and ethics when conducting business for the Group. They also have the responsibility to report any policy breach, any suspected fraud or any other unethical practices in a timely manner to the appropriate team or the Group Audit Manager.
- In turn, the Management is expected to be alert, recognize risks, be aware of symptoms of unethical practices or corrupt acts, and respond to all reporting and indications of these, whilst ensuring the confidentiality and protection procedures outlined in this policy.
- If for any reason an employee cannot raise a certain qualified concern with regard to a violation or potential violation of The Hira Group Code of Ethics with their line manager or with any other people or functionaries, then they would still be able to raise their concerns
- By e-mail to a dedicated confidential inbox operated by the Compliance Facilitator - [email protected]
- Concerns related to dispute with line manager / job dissatisfaction/ salary and similar kind of matters should be addressed directly to your HR business partner.
V. Protection
- No unfair treatment will be meted out to a Whistle Blower by virtue of his/her having reported a Protected Disclosure under this Policy. The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted. Complete protection will, therefore, be given to Whistle Blower against any unfair practice like retaliation, threat or intimidation/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/her duties/functions including making further protected disclosure. Reasonable out of pocket expenses as per the company policy will be reimbursed on submission of actual receipts and, as per Management discretion, a Whistle Blower will be rewarded for their effort, loyalty and timely escalation of violation of The Hira Group Code of Ethics points.
- In case the Company finds the complaint to be motivated or vexatious, it shall be at the liberty to take appropriate steps.
VI. Investigation
- All complaints/concerns under this policy will be recorded and thoroughly investigated. The Internal Audit may investigate and may at its discretion consider involving any other officer(s) of the Company for the purpose of the investigation.
- Strict confidentiality and objectivity concerning the complainant and the information will be maintained at all stages of the investigation.
VII. Amendment to the Policy
The Board reserves their right to review and amend this policy from time to time.
Approved by CEO | Ver: 001 | DATE: 15.03.2021
