Whistle Blower Policy

PREAMBLE

The Company is committed to the highest standards of ethics, integrity & professionalism in all the activities & operations that it conducts and has defined systems & procedures in place to root out corruption, malpractices and abuse of authority by the employees/officers in the Company. The Company encourages an open & transparent system of working and dealings between the members of staff/officers, customers and members of general public coming into contact with the Company.
The Government of India passed a resolution on 21st April, 2004 on ‘Public Interest Disclosures & Protection of Informer’ (PIDPI) wherein the Central Vigilance Commission (CVC) has been authorized as “designated Agency” to receive written complaints or disclosure on any allegation of corruption or misuse of office and recommended appropriate action. The jurisdiction of the CVC in this regard is restricted to the employees of the Central Government or of any corporation established by it or under any Central Act, Government Companies, societies or local authorities owned or controlled by the Central Government.
The Company has evolved “Whistle Blower Policy” in line with the proposal in the resolution of Government of India and Central Vigilance Commission adopted norms vide Office Order No.33/5/2004 dated 17.05.2004 (A copy of the detailed notification is also available on the website of the Commission http://www.cvc.ni.in issued in public interest by the Central Vigilance Commission, INA, Satarkata Bhawan, New Delhi).

MODALITY OF OPERATION AT THE COMPANY LEVEL:

As Government Companies is covered under the purview of PIDPI, IPL is required to give publicity to the “Whistle Blower Policy” for its Employees, Officers and general public as laid down by the CVC and this Policy is intended to provide for the same. All concerned are hereby informed that any complaint which is to be made under the “Whistle Blower Policy” should comply with the following aspects”-
The Complainant shall be known as “Whistle Blower” and the policy shall be known as “Whistle Blower Policy”. The confidentiality of whistle blower shall generally be maintained.
In additional to the “The Secretary, Central Vigilance Commission”, the CVO of the Company is also authorized to deal with the complaints received under Whistle Blower Policy. The complainant can lodge the complaint in a closed/secured envelope marked as “Complaint under Whistle Blower Policy” at the following address.

PROCEDURE FOR LODGING COMPLAINT

1. Anonymous/pseudonymous complaints shall not be entertained.
2. The text of the complaint should be carefully drafted so as not to give any details or clue as to his/her identity. However, the details of the complaint should be specific and verifiable.
3. In order to protect identity of the person, no acknowledgment shall be issued and the whistle-blowers are advised not to enter into any further correspondence with the Company in their own interest. The Company assures that, subject to the facts of the case being verifiable, it will take the necessary action as provide under the Government of India Resolution. If any further clarification is required, the Company will get in touch with the complainant.

PROCEDURE FOR LODGING COMPLAINT UNDER WHISTLE BLOWER POLICY:

Any complaint which is to be made under Whistle Blower Policy should comply with the following aspects:-

1. Anonymous/ pseudonymous complaints/ reports shall not be entertained under this scheme.
2. The complaint/report should be sent in a secured manner by way of closed envelope to the Chief Vigilance Officer.
3. The envelope should be addressed to the official as mentioned above and should be superscribed “Complaint under Whistle Blower Policy”. The complainant should only give his/her name and address either in the beginning of the text of the complaint or at the end of it.
4. If the complainant wants that his name should not be disclosed, the text of the complaint should be carefully drafted so as not to give any details or clue as to his/her identity. However, the details of the complaint should be specific and verifiable.
5. If the envelope is not superscribed and closed, it will not be possible to cover the identity of the complainant, thus his protection under the above resolution. Such complaints will be dealt with as per the normal complaint policy of the Company.

OTHER ASPECTS:

1. In order to cover the identity of the complainant (whistle blower), whistle-blower is advised that in case he intends to send reminder, he should follow the same procedure of correspondence as envisaged above.
2. No adverse personnel action shall be taken or recommended against an employee (Whistle Blower) in retaliation to his lodging a complaint under this policy. However, he shall not be protected for his misconduct, which does not relate to the disclosure made as a whistle blower.
3. An employee who knowingly makes false allegations of unethical & improper practices or alleged wrongful conduct shall be subject to disciplinary action and will not be protected under the policy.

Procedure for handling the Complaint

1. All complaints received will be serially entered in a register with full particulars viz. number & date of complaint, date of receipt, brief contents/allegations leveled in the complaint.
2. No acknowledgement of the complaint will be issued to the complainant from the Company
3. Subject to the facts & allegations made in the complaint verifiable, the Company will cause investigation in the matter and will take necessary action.
4. However, if deemed emergent & necessary to verify the contents of the complaint, the Company will get in touch with the complainant at the address/phone/ mobile number/ e-mail ID given in the complaint.
5. Either as a result of discreet enquiry or on the basis of complaint itself without any enquiry, if the CVO is of the opinion that the matter requires to be further investigated, he may invite comments/ response from the concerned employees/ officers of the Company as a part of Investigation.
6. All relevant papers / documents with respect to all the matters raised in the complaint will be obtained, if necessary, by the CVO and investigation in the matter will be commenced immediately.
7. As far as possible, the investigation in the matter will be expeditiously completed.
8. The CVO will follow up the case and advice to the Disciplinary Authority to initiate Disciplinary Action, wherever required.

Protection available to the complainant

1. If the complainant is a members of staff/ officer, he / she should give his / her name and address with pin code number, phone & or mobile number and e-mail, if any, prominently at the beginning or at the end of the complaint or in the covering letter. Further details such as name, designation, name of branch / office / department at which he / she is working, should be clearly mentioned.
2. The Company will ensure that no punitive / administrative action is taken by any concerned authority in the Company against any person on perceived reasons/ suspicion of being ‘whistle Blower’.
3. The identity of the complainant will not be revealed unless the complainant himself has made the details of his complaint either public or disclosed his identity to any other person / authority.
4. The Company shall not take any action or initiate any proceedings to victimize / harass or to intimidate the complainant solely for the reason of his having filed the complaint under the policy.
5. If any person is aggrieved by any action on the ground that he has been victimized or harassed due to filing of complaint or disclosure, he may file any application before the Managing Director seeking redressal of his grievance. The Managing Director will examine the matter and will take such actions as he may deem fit for redressal of the grievance.
6. In case the complainant is any employee/ officer of the Company, the Company shall not take or recommend to take any administrative or disciplinary action against that employee / officer [i.e. whistle blower] in retaliation to his lodging the complaint under the policy and will take all measures / actions to prevent initiation of any adverse administrative/ disciplinary action against the employee/ officer. However, the employee/ officer shall not be protected for his/her misconduct, which does not relate to the disclosures, made as whistle blower.
7. An employee/ officer, who knowingly makes false allegations of unethical & improper practices or knowingly alleges wrongful conduct, shall be subjected to disciplinary action, as appropriate, and will not be protected under the policy.
8. In case the Company finds that the complaint is motivated or vexatious, it shall take action, as appropriate, against the complaint.