Whistle Blower Policy

A safe mechanism for reporting unethical practices and Code of Conduct violations.

Preface

FriendLoan Technologies Pvt. Ltd. (FTPL) has formulated a Code of Conduct ("the Code"), that lays down the principles and standards that should govern the actions of the Company and their employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the company. Though it is non-mandatory, the Company has decided as a 'good' governance practice to set up a Whistle Blower Policy ("the Policy") with a view to provide a mechanism for employees of the Company to report matters to the management.

Definitions

  • Committee means the Committee constituted by the Board of Directors in accordance with the Companies Act, 2013.
  • Employee means every employee of the Company (whether working in India or abroad), including Directors in the employment of the Company.
  • Code means the Code of Conduct.
  • Investigator(s) mean the person(s) authorized, appointed, consulted, or approached by the Committee and includes the auditors and the police.
  • Protected Disclosure means any communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.
  • Subject means a person against or in relation to whom a Protected Disclosure has been made or evidence gathered during investigation.
  • Whistle Blower means an Employee making a Protected Disclosure under this Policy.

Policy: Scope, Eligibility and Disqualification

Scope

This Policy is an extension of the Code of Conduct. The Whistle Blower's role is that of a reporting party with reliable information. They are not required to act as investigators or finders of facts. Protected Disclosures will be appropriately dealt with by the Committee.

Eligibility

All Employees of the Company are eligible to make Protected Disclosures under the Policy.

Disqualification

  • Protection does not extend to false or bogus allegations made knowingly or with mala fide intention
  • Whistle Blowers making three or more malafide, frivolous, baseless, or malicious disclosures will be disqualified
  • Company reserves right to take appropriate disciplinary action

Policy: Procedure

All Protected Disclosures should be addressed to Mr. Rajesh P, Chief Operating Officer / Grievance Officer.

Email: coo@sampathi.in

  • Disclosures should preferably be in writing (typed or legible handwriting in English, Hindi, or regional language)
  • Should be factual, not speculative, with specific information for proper assessment

Policy: Investigation

  • Committee may involve Investigator(s) at its discretion
  • All disclosures will be thoroughly investigated
  • Decision to investigate is a neutral fact-finding process, not an accusation
  • Subject's identity kept confidential to extent possible
  • Subjects informed of allegations at outset of formal investigation
  • Subjects have duty to cooperate but are not required to admit guilt
  • Subjects may consult persons of their choice and engage counsel at own cost
  • Evidence shall not be withheld, destroyed, or tampered with
  • Subjects given opportunity to respond to material findings
  • No allegation maintainable without good evidence
  • Subjects have right to be informed of outcome
  • Investigation normally completed within 45 days

Policy: Protection

  • No unfair treatment for reporting Protected Disclosures
  • Company condemns discrimination, harassment, victimization
  • Complete protection against: retaliation, threat, termination/suspension, disciplinary action, transfer, demotion, refusal of promotion
  • Company will minimize difficulties for Whistle Blower
  • Identity kept confidential to extent possible and permitted under law

Policy: Investigators, Decision, Reporting and Retention of Documents

Investigators:

  • Derive authority from Audit Committee
  • Must be independent and unbiased
  • Duty of fairness, objectivity, thoroughness, ethical behaviour
  • Investigation launched after preliminary review establishing improper activity

Decisions:

  • If improper act confirmed, Audit Committee recommends disciplinary or corrective action
  • Actions adhere to applicable personnel/staff conduct procedures

Reporting:

  • Investigators submit regular reports to Audit Committee

Retention of Documents:

  • All Protected Disclosures and investigation results retained for minimum 7 years

Contact for Whistle Blower Reports

Name: Mr. Rajesh P
Position: Chief Operating Officer / Grievance Officer
Email: coo@sampathi.in