A whistle blower is a person who exposes any wrong doing in the office such as scam, fraud, leakage, hidden information or activity, which is illegal.

2.  What is whistle blowing?
 Who is a whistle blower?
 Is every complain related to whistle blowing?
 Types of whistle blowing?
 Culture that promotes whistle blowing
 Why an employee hesitates to be a whistle blower?
 What all is covered under whistle blowing?
 Whistle blowing process.
 Who all can be contacted for whistle blowing
complaint?
 Roles and responsibilities

3.  Whistle Blowing: When a former or existing employee
voice their concern against any wrongdoing happening in
the workplace within organisation is known as "whistle
blowing" .
 Whistle blower: The employee who shares the concern is
known as "Whistleblower”.

4. Complaint
a complaint is related
to an employee on an
individual basis.
It can be anything in
the form of grievances
like something which is
affecting the employee
personally like rude
behaviour by the boss
Whistle
Blowing
Complaint
Whistle blowing is
raising a concern which
might affect the
employer or any third
party.
Not always related to
an individual basis

5. Internal External
Personal/Impersonal Government/Corporate
Open whistle
blowing

6. Open door
culture
Right Training
Involvement of
all stakeholders

7. Need to Act
Commitment
Communication and
Proper investigation

8. Resistance from
Senior
management
Employee union
resistance
Employee Fear
of Retaliation
Cultural
Obstacle

9.  Any kind of Harassment or discrimination
 Sharing of confidential information
 Any breach of privacy
 Any kind of Fraud or Fraudulent
 Misrepresentation of financial data
 Any kind of illegal activity
 Corruption
 Invalid promotion
 Illegal sales activity
 Conflict of interest
 Trading within the company
 Illegal competitive behaviour
 Improper use of company assets.

10. It is up to the whistleblower whether he/she wants to disclose identity or not. Even in case of
whistleblower has not revealed the identity , the complaint will be taken with utmost
seriousness.
However for smooth investigation and to provide more
hold on the complaint it is suggested to disclose
identity,
however the final decision on the same lies with the
whistleblower. The identity of whistleblower is kept
confidential in all cases.
All complaints which are received by ombudsperson or the audit committee constituted by
ombudsperson shall be reviewed to check whether any breach of the code of conduct has
happened or not
In case of the review by the audit committee, if any
illegal activity has happened committee can
recommend that its whistle blowing complaint or not
The ombudsperson or audit committee will respond to
the concern within 2 days of receiving the complaint
The whistleblower can raise the concern in writing or verbally to the ombudsperson
The written complaint can be sent through an email id
and verbally he/she can inform through the telephone
even for verbal complain a written draft is prepared
by "ombudsperson"

11. It is advised to keep all information confidential while carrying
out the investigation. No information is shared outside either
by the whistleblower or by the audit committee
This secrecy is maintained to protect the
uprightness of the whistleblower process and
investigation.
It is the responsibility of the ombudsperson to
share the status and findings of investigation with
the board of director. The final report must
contain all the details and documentation
deemed fit or necessary.
Once the investigation is given to the audit committee by the
ombudsperson the audit committee will perform the following
tasks.
Will be in contact with employee, vendor, and
stakeholder to get the necessary information to
carry out further investigation.
Will discuss the steps needed internally for
investigation of the complaint.

12.  Human resource
 Head of the department
 Legal department
 Compliance Head
 CEO
 Members of the management committee
 In an urgent situation, an employee can write
directly to the chairman of the audit committee
 Any complaint received by HR will be sent to the
director of the human resource for their action.

13. Employee
The first and
foremost task of the
employee is to bring
into notice of the
company in case any
illegal activity is done
in the company or
about to happen in
the company. The
employee must have
proper evidence to
raise any concern.
To work in
collaboration with the
audit committee with
complete
confidentiality.
The policy is meant to
raise concern which is
of serious nature and
is actually happening.
Any false allegation
will result in serious
disciplinary action.

14. To make sure that the
whistleblower policy is
implemented in the
company.
In case the ombudsperson
through investigation comes to a
conclusion that any illegal act or
wrongdoing has been done, the
case can be closed by
ombudsperson.
All the inquiry details must
be properly implemented
To share the final findings with
the whistleblower, with a
gesture of thanks for protecting
the company's reputation
To handover, the report received
to the board of directors, CEO
and director HR.

15. To carry on the
investigation in a
transparent way
To make sure that
complete findings have
been done by the
committee.
To make sure each and
every information is
kept confidential
To finally decide after
investigation if any
wrongdoing has been
done or not, in case it
is done then by whom?
To ensure an
appropriate action
being taken against the
dismissal and
preventive measures.
Documentation of
complete report.

16. To share the final report with the statutory board
To cooperate fully with the
investigation team
To make sure the audit committee
and ombudsperson have taken
necessary action against the
wrongdoers.
Be known with
the final
conclusion of
the
investigation
team
Maintain
complete
confidentiality