Whistle Blower Policy

1.1 The Corporation believes in the conduct of its affairs in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behavior.

1.2 The Corporation is committed to developing a culture where it is safe for all employees to raise concerns about any poor or unacceptable practice and any event of misconduct.

1.3 DPE guidelines issued on Corporate Governance vide OM No.18(8)/2005-GM dated 14th May, 2010 provides to establish a mechanism for employees to report to the management, concern about unethical behaviors, actual or suspected fraud, or violation of the company's General guidelines on conduct or ethics policy. This mechanism could also provide for adequate safeguards against victimization of employees who avail of the mechanism and also provide for direct access to the Chairman of the Audit Committee in exceptional cases.

1.4 The purpose of this policy is to provide a framework to promote responsible and secure whistle blowing. It protects employees wishing to raise a concern about serious irregularities within the Corporation.

1.5 The policy neither releases employees 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.

2.1 This Policy is for the Employees as defined hereinafter.

2.2 The Policy has been drawn up so that Employees can be confident about raising a concern. The areas of concern covered by this Policy are summarized in paragraph 5.

3.1 'Disciplinary Action' means any action that can be taken on the completion of/ during the investigation proceedings including but not limiting to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.

3.2 'Corporation' means 'National Handloom Development Corporation Ltd.'

3.3 'Employee' means all permanent employees of the Corporation.

3.4 'Protected Disclosure' means a concern raised by a written communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.

3.5 'Subject' means a person against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.

3.6 'Whistle Blower' is someone who makes a Protected Disclosure under this Policy.

3.7 'Whistle Officer' or 'Committee' means an officer or Committee of persons who is nominated/appointed to conduct detailed investigation.

3.8 'Compliance Officer' means Company Secretary of the corporation.

3.9 'Ombudsperson' will be the Managing Director for the purpose of receiving all complaints under this Policy and ensuring appropriate action.

6.1 While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action.

6.2 Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention.

6.3 Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious shall be subject to disciplinary action, up to and including termination of employment, in accordance with corporation's rules, policies and procedures.

7.1 Employees can make Protected Disclosure to Ombudsperson, as soon as possible but not later than 30 consecutive days after becoming aware of the same.

7.2 Whistle Blower must put his/ her name to allegations. Concerns expressed anonymously WILL NOT BE investigated.

7.3 If initial enquiries by the Ombudsperson indicate that the concern has no basis, or it is not a matter of investigation under this Policy, it may be dismissed at this stage and the decision is documented.

7.4 Where initial enquiries indicate that further investigation is necessary, this will be carried through either by the Ombudsperson alone, or by a Whistle Officer/ Committee nominated by the Ombudsperson for this purpose.

7.5 Ombudsperson/ Whistle Officer/ Committee shall have right to call for any information/document and examination of any employee of the Corporation or other person(s), as they may deem appropriate for the purpose of conducting investigation under this policy.

7.6 Name of the Whistle Blower shall not be disclosed to the Whistle Officer/ Committee.

8.1 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 corporation, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle Blower.

8.2 The identity of the Whistle Blower shall be kept confidential.

8.3 Any other Employee assisting in the said investigation or furnishing evidence shall also be protected to the same extent as the Whistle Blower.