Corporate Social Responsibility Policy
In accordance with the requirements spelt out in Section 135 of the Companies Act,2013 (the Act?) and „the Companies (Corporate Social Responsibility Policy) Rules,
2014 (CSR Rules) by the Ministry of Corporate Affairs, the Company's Corporate Social Responsibility (CSR) Policy is enunciated.
Our CSR Policy:
For our Company, reaching out to underserved communities is part of our DNA. Our policy will be to focus on Livelihood, Health care, Education and Infrastructure so as to bring measurable improvement in quality of life of unprivileged community.
Our vision is - “to enable sustainable and inclusive development of the community. In doing so, build a better, sustainable way of life for the weaker section of society and raise the country’s Human Development Index.
Implementation process: Identification of projects
All projects are identified in a participatory manner, in consultation with the community, literally programmes sitting with them and gauging their basic needs.
We recourse to the participatory rural appraisal mapping process. Subsequently, based on a consensus and in discussion with the village panchayats, and other influential, projects are prioritized.Arising from this, the focus areas that have emerged are Education, Health care, Sustainable livelihood, Infrastructure development, espousing social causes including the activities specified in the Schedule VII of the Act, from time to time. All of our community projects/programmes are carried out under the aegis of Arthanari Loom Centre (Textile) Private Limited.
In Education, our endeavour is to spark the desire for learning and knowledge at every stage through • Formal schools • Balwadis for elementary education • Quality primary education • Public School • Girl child education • Adult education programmes. Teacher’s Salary • Financial support to schools/college • Infrastructural development to education institute.
In Health care our goal is to render quality health care facilities to people living in the villages and elsewhere through our Hospitals. • Primary health care centers • Old Age Home projects • Health Help Desk for District Hospital • Support of medical equipment to hospitals • Immunization programmes with a thrust on polio and malaria eradication • Patient’s attended meal scheme • Preventive health through awareness programmes • Conducting Medical Camps.
In Sustainable Livelihood our programmes aim at providing livelihood in a locally appropriate and environmentally sustainable manner through • Security Academy • Formation of Self Help Groups for women empowerment • Creating Entrepreneurs • Vocational training • Partnership with Industrial Training Institutes • Agriculture development and better farmer focus and cultivation of Kitchen garden•
In Infrastructure Development we endeavour to set up essential services that form the foundation of sustainable development through • Basic infrastructure facilities • Housing facilities • Safe drinking water • Sanitation & hygiene • Renewable sources of energy.
To bring about Social Change, we advocate and support • Dowry less marriage • Widow Remarriage • Awareness programmes on anti-social issues • De-addiction campaigns and programmes • Espousing basic moral values.
The Company would prioritize and undertake the activities as specified in Schedule VII of the Act, from time to time for long-term sustainable development of the society.
Organizational mechanism responsibilities
Arthanari Loom Centre (Textile) Private Limited provides the vision under the leadership of its Directors. The CSR Committee of Directors at the Board level comprises of:
Sri A.Alagarasan - Chairman
Smt A Pushpa, Member
Sri A Aadhithya Member
A robust implementation structure and a team of professionals is in place at the Company’s units.
Collaborative partnerships are formed with the Government, the District authorities, the village panchayats, NGOs and other like-minded stakeholders. This helps widen the Company’s CSR reach and leverage upon the collective expertise, wisdom and experience that these partnerships bring to the table.
The Company also engages with well-established and recognized programs and national platforms, given their commitment to inclusive growth.
A specific budget is allocated for CSR activities. This budget is project driven.
Information dissemination
The Company’s engagement in this domain would be disseminated on its website, Annual Reports and in-house journals etc.
Management Commitment
Our Board of Directors, our Management and all of our employees subscribe to the philosophy of compassionate care. We believe and act on an ethos of generosity and compassion, characterized by a willingness to build a society that works for everyone. This is the cornerstone of our CSR policy.
CODE OF CONDUCT AND ETHICS FOR DIRECTORS AND SENIOR MANAGEMENT
INTRODUCTION AND APPLICABILITY
This Code shall be applicable to each Director and member of the Senior Management of Arthanari Loom Centre (Textile) Private Limited
“Board” means the Board of Directors of the Company.
“Company” means Arthanari Loom Centre (Textile) Private Limited, a private limited company incorporated under the laws of India and whose registered office is at 78,Sabapathy Street, Kalarampatty, Erumapalayam, Salem - 636 015.
“Code” means this code of conduct and ethics applicable to each Director and Senior Management, as amended from time to time.
“Director” means each member of the Board of Directors of the Company, as may be appointed from time to time.
“Senior Management” mean employees of the Company, other than Directors, that are members of its core management team and includes all executive committee members of the Company, functional heads of the Company and such other employees of the Company as may be designated as members of the Senior Management for the purpose of this Code by the Chairman or Managing Directors of the Company from time to time.
The Code shall have immediate effect.
(a) To set standards of ethical conduct and ensure these standards are upheld in day-to-day activities.
(b) To set standards of corporate governance by complying with all applicable laws, rules and regulations and all applicable policies and procedures adopted by the Company and to fulfil the responsibilities to stakeholders.
(c) To set and implement high standards of transparency, integrity, accountability and corporate social responsibility in all dealings.
Each Director and each member of Senior Management will always act in the best interests of the Company and in accordance with the authority conferred on him or her and shall, without prejudice to the foregoing, always act in accordance with this Code.
The Code seeks to set standards for, and regulate, the subjects described below.
Prudent Conduct and Behaviour
PRUDENT CONDUCT AND BEHAVIOUR
business prudently and in accordance with all applicable laws, rules and regulations and with the highest standards of corporate governance and business ethics both in letter and spirit. The Company is committed to being a good corporate citizen.
To uphold the reputation and values of the Company, the Directors and members of Senior Management must always abide by the policies and procedures that govern the conduct of the Company’s business.
Each Director and each member of Senior Management will always act to uphold the Code.
The Chairman of the Company will act as facilitators and will be available to the Directors and members of Senior Management to answer questions and to help them comply with the Code.
TRANSPERANCY,HONESTY AND INTEGRITY
Each Director and member of Senior Management will always act with the utmost care, skill and diligence and in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct, while working on the Company's premises, at Company sponsored business and social events, or at any other place where the Directors and Senior Management represent the Company. They shall at all times exercise their powers for the purposes they were conferred and for the benefit and prosperity of the Company and discharge their fiduciary duties in a fair and impartial manner.
In carrying out their duties and responsibilities, each Director and member of Senior Management shall endeavor to deal fairly and honestly with shareholders, creditors, lenders, customers, suppliers, employees and competitors.
The Directors and Senior Management shall make their best efforts to contribute to an environment that encourages teamwork, builds confidence and empowers people through personal and professional growth. They shall attempt to build teams that grow together, complement each other and share their knowledge and skills with each other.
The Directors and Senior Management of the Company must avoid situations involving actual or potential conflicts of interest. They shall not engage in any business, relationship or activity, which may lead to a conflict of interest with the Company or affect their ability to perform their duties and responsibilities objectively and effectively.
A conflict of interest may arise where, directly or indirectly, and without limitation:
(a) an independent judgment of the Company’s interest cannot be exercised;
(b) an employee accepts any personal benefits or gifts or entertainment beyond what is considered to be customary in the industry in which the Company operates either by himself or herself or through his family as a result of his position in the Company from any person or company with which the Company has business dealings;
(c) an employee engages in any business activity that detracts from such employee’s ability to devote appropriate time and attention to his or her responsibilities to the Company;
(d) an employee has a significant interest in any supplier, customer or competitor of the Company;
(e) an employee of the Company is also an employee of any supplier, customer, business associate or competitor of the Company; and
(f) an employee is directly or indirectly concerned or interested in a contract or arrangement or proposed contract or arrangement entered into or to be entered into by or on behalf of the Company.
Prior written approval from the Board (with the relevant Director being disqualified from voting and excluded from the quorum) is required if any of the above arises or is anticipated to arise.
COMPLIANCES WITH LAWS AND REGULATIONS
In carrying out their duties and responsibilities, the Directors and Senior Management shall comply with all applicable laws, rules and regulations.
If any Director or member of Senior Management knows of, or suspects, a violation of any applicable laws, rules or regulations or this Code, he or she must immediately report such violation to the Board or any designated person thereof. Such person should as far as possible provide the details of suspected violations with all known particulars relating to the issue. The Company recognizes that resolving such problems or concerns will advance the overall interests of the Company and will help to safeguard the Company’s assets, financial integrity and reputation.
The Directors and Senior Management shall take all necessary steps to ensure that no reprisal, threat, retribution or retaliation is made, or carried out, against any person who has in good faith reported a violation or a suspected violation of law or against any person who is assisting in any investigation or process in relation to such a violation.
The Company will take appropriate action against any Director and members of Senior Management whose actions are found to violate the Code or any other policy of the Company, after giving him or her a reasonable opportunity of being heard. Where laws, rules or regulations have been violated, the Company will cooperate fully with the appropriate authorities and regulators.
FINANCIAL REPORT KEEPING AND REPORTING
Strict compliance with accounting principles is critical to ensure that all financial transactions are properly identified, analysed and recorded. The Directors and Senior Management shall make reasonable efforts to ensure that all business records and reports are accurate, complete and reliable.
No Director or member of Senior Management should serve on the board of directors of, or become a member of the senior management of, or have a significant influence over the management or policies of, a competitor of the Company.
The Directors and Senior Management shall maintain the confidentiality of information entrusted to them, including that of any customer, supplier or business associates of the Company to which the Company has a duty to maintain confidentiality, except when disclosure is authorised. The use of confidential information for his or her own advantage or profit is also prohibited. These obligations apply not only during the course of their employment with the Company but also for a period of one year following the termination of their employment with the Company.
The Directors and Senior Management shall not:
(a) exploit directly or indirectly for their own personal gain, opportunities that are discovered through the use of the Company's property (including intellectual property), information or position, without the specific prior written approval of the Board;
(b) divert directly or indirectly to his or her own advantage any business opportunity that the Company is pursuing or an opportunity that the Company may be pursing in the near future, without the specific prior written approval of the Board; and
(c) compete directly or indirectly with any business of the Company or with any business that the Company is considering, without the specific prior written approval of the Board.
The Directors and Senior Management shall not receive or offer, directly or indirectly, any payments, gifts, donations, hospitality and comparable benefits which are intended or perceived to be intended to influence any business favours, without the specific prior written approval of the Board.
PROTECTION AND COMPANY ASSETS
The Directors and Senior Management shall endeavor to protect the Company’s assets at all times and shall use them for legitimate business purposes only. They shall not use the Company’s assets or manpower or company related information for illegal or unethical purposes or for their personal use unless approved by the Board in writing. Care should be taken to ensure that assets are not misappropriated, loaned to others, or sold or donated without appropriate authorization.
This Code may be amended, modified or varied by the Board as they deem necessary in the interests of the Company and subject to the provisions of applicable laws, regulations or guidelines.
PERIODICAL REVIEW AND COMPLIANCE WITH THE CODE
The Directors and Senior Management shall in the last month of every financial year or whenever this Code is revised, acknowledge the understanding of the Code and execute an undertaking to continue complying with it. New Directors or members of Senior Management shall execute such an undertaking at the time of their induction.
As Approved by the Board of Director at their Meeting unanimously.
As a responsible Corporate Citizen, Arthanari Loom Centre (Textile) Private Limited’s (ALC) Board of Directors monitors continuous compliance with various Legislations applicable to the Company facilitating better Corporate Governance activities which ultimately benefit all the stake holders, namely the customers, employees, investors, community, suppliers, regulators, governments and the Environment.
In pursuance of the provisions of Section 177 of the Companies Act, 2013 inter alia every Listed Company and every Company having a borrowings of Rs.50 Crores or more from Banks and Financial Institutions has to establish a vigil mechanism for the Directors and Employees to report genuine concerns in such manner as prescribed. The Company has adopted a Code of Conduct for Directors and Senior Management Executives (“the Code”), which lays down the principles and standards that should govern the actions of the Company and its employees. Any violation of the Code, would be a matter of serious concern for the Company. Vigil mechanism shall provide for adequate safeguards against victimization of persons who use such mechanism and also make provision for direct access to the Chairperson of the Company in appropriate or exceptional cases. As per the aforesaid provision, the Company have to establish a mechanism called ‘Whistle Blower Policy’ for employees to report to the management instances of unethical behaviour, actual or suspected, fraud etc. Accordingly ALC proposes to establish a Whistle Blower / Vigil Mechanism and to formulate a policy for the same.
This Code shall be applicable to each Director and member of the Senior Management of Arthanari Loom Centre (Textile) Private Limited
This Policy" or "Policies" refers to the "Whistle-Blower Policy.WB means an Employee making a Disclosure under this Policy.
This Policy covers malpractices and events which have taken place / suspected to have taken place, misuse or abuse of authority, fraud or suspected fraud, violation of Company rules, manipulations, negligence causing danger to public health and safety, misappropriation of monies, and other matters or activity on account of which the interest of the Company is affected and formally reported by whistle blowers concerning
its employees
“Alleged wrongful conduct” shall mean violation of law, Infringement of Company’s rules, misappropriation of monies, actual or suspected fraud, substantial and specific danger to public health and safety or abuse of authority”.
“Board” means the Board of Directors of the Company.
“Company or ALC” means the Arthanari Loom Centre (Textile) Private Limited and all its offices.
“Code” means Code of Conduct for Directors and Senior Management Executives adopted by ALC.
“Employee” means all the present employees and whole time Directors of the Company.
“Protected Disclosure” means a concern raised by an employee or group of employees of the Company, through a written communication and made in good faith which discloses or demonstrates information about an unethical or improper activity under the title “SCOPE OF THE POLICY” with respect to the Company. It should be factual and not speculative or in the nature of an interpretation / conclusion and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern.
“Subject” means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.
“Vigilance and Ethics Officer” means an officer appointed to receive protected disclosures from whistle blowers, maintaining records thereof, placing the same before the Chairman of the Board of Directors for its disposal and informing the Whistle Blower the result thereof.
“Whistle Blower” is an employee or group of employees who make a Protected Disclosure under this Policy and also referred in this policy as complainant.
All Directors and Employees of the Company are eligible to make Protected Disclosures under the Policy in relation to matters concerning the Company.
RECEIPT AND DISPOSAL OF PROTECTED DISCLOSURES.
All Protected Disclosures should be reported in writing by the complainant as soon as possible after the Whistle Blower becomes aware of the same so as to ensure a clear understanding of the issues raised and should either be typed or written in a legible handwriting in English or Tamil.
The Protected Disclosure should be submitted in a closed and secured envelope and should be super scribed as “Protected disclosure under the Whistle Blower policy”. Alternatively, the same can also be sent through email with the subject. If the complaint is not super scribed and closed as mentioned above, it will not be possible for the Audit Committee to protect the complainant and the protected disclosure will be dealt with as if a normal disclosure. In order to protect identity of the complainant, the Vigilance and Ethics Officer will not issue any acknowledgement to the complainants and they are advised neither to write their name / address on the envelope nor enter into any further correspondence with the Vigilance and Ethics Officer. The Vigilance and Ethics Officer shall assure that in case any further clarification is required he will get in touch with the complainant.
Anonymous / Pseudonymous disclosure shall not be entertained by the Vigilance and Ethics Officer.
The Protected Disclosure should be forwarded under a covering letter signed by the
complainant. The Vigilance and Ethics Officer / Chairman of the Board of Directors/ CEO as the case may be, shall detach the covering letter bearing the identity of the Whistle Blower and process only the Protected Disclosure.
All Protected Disclosures should be addressed to the Vigilance and Ethics Officer of the Company or to the Chairman of the Audit Board of Directors / CEO in exceptional cases. The contact details of the Vigilance and Ethics Officer is as under:-
Name and Address -
Shri A Alagarasan
78, Sabapathy Street, Kalarampatty Erumapalayam
Salem - 636 015
Each Director and member of Senior Management will always act with the utmost care, skill and diligence and in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct, while working on the Company's premises, at Company sponsored business and social events, or at any other place where the Directors and Senior Management represent the Company. They shall at all times exercise their powers for the purposes they were conferred and for the benefit and prosperity of the Company and discharge their fiduciary duties in a fair and impartial manner.
In carrying out their duties and responsibilities, each Director and member of Senior Management shall endeavor to deal fairly and honestly with shareholders, creditors, lenders, customers, suppliers, employees and competitors.
The Directors and Senior Management shall make their best efforts to contribute to an environment that encourages teamwork, builds confidence and empowers people through personal and professional growth. They shall attempt to build teams that grow together, complement each other and share their knowledge and skills with each other.
The Directors and Senior Management of the Company must avoid situations involving actual or potential conflicts of interest. They shall not engage in any business, relationship or activity, which may lead to a conflict of interest with the Company or affect their ability to perform their duties and responsibilities objectively and effectively.
A conflict of interest may arise where, directly or indirectly, and without limitation:
(a) an independent judgment of the Company’s interest cannot be exercised;
(b) an employee accepts any personal benefits or gifts or entertainment beyond what is considered to be customary in the industry in which the Company operates either by himself or herself or through his family as a result of his position in the Company from any person or company with which the Company has business dealings;
(c) an employee engages in any business activity that detracts from such employee’s ability to devote appropriate time and attention to his or her responsibilities to the Company;
(d) an employee has a significant interest in any supplier, customer or competitor of the Company;
(e) an employee of the Company is also an employee of any supplier, customer, business associate or competitor of the Company; and
(f) an employee is directly or indirectly concerned or interested in a contract or arrangement or proposed contract or arrangement entered into or to be entered into by or on behalf of the Company.
Prior written approval from the Board (with the relevant Director being disqualified from voting and excluded from the quorum) is required if any of the above arises or is anticipated to arise.
COMPLIANCES WITH LAWS AND REGULATIONS
In carrying out their duties and responsibilities, the Directors and Senior Management shall comply with all applicable laws, rules and regulations.
If any Director or member of Senior Management knows of, or suspects, a violation of any applicable laws, rules or regulations or this Code, he or she must immediately report such violation to the Board or any designated person thereof. Such person should as far as possible provide the details of suspected violations with all known particulars relating to the issue. The Company recognizes that resolving such problems or concerns will advance the overall interests of the Company and will help to safeguard the Company’s assets, financial integrity and reputation.
The Directors and Senior Management shall take all necessary steps to ensure that no reprisal, threat, retribution or retaliation is made, or carried out, against any person who has in good faith reported a violation or a suspected violation of law or against any person who is assisting in any investigation or process in relation to such a violation.
The Company will take appropriate action against any Director and members of Senior Management whose actions are found to violate the Code or any other policy of the Company, after giving him or her a reasonable opportunity of being heard. Where laws, rules or regulations have been violated, the Company will cooperate fully with the appropriate authorities and regulators.
FINANCIAL REPORT KEEPING AND REPORTING
Strict compliance with accounting principles is critical to ensure that all financial transactions are properly identified, analysed and recorded. The Directors and Senior Management shall make reasonable efforts to ensure that all business records and reports are accurate, complete and reliable.
Protected Disclosure against the Vigilance and Ethics Officer should be addressed to the Chairman of the Company and the Protected Disclosure against the Chairman/CEO of the Company should be addressed to the Deputy Managing Director of the Company.
The contact details of the Chairman, CEO and the Chairman of the Board of Directors
are as under:
and Address of Chairman - Mr.A.Alagarasan
Email- office@alctex.com
Name and Address of CEO- Mr.A.Alagarasan
Email- office@alctex.com
Name and Address of the Chairman of the Board of Directors – Mr.A.Alagarasan
Email – office@alctex.com
On receipt of the protected disclosure the Vigilance and Ethics Officer / Chairman/ CEO / Chairman of the Board of Directors, as the case may be, shall make a record of the Protected Disclosure and also ascertain from the complainant whether he was the person who made the protected disclosure or not. He shall also carry out initial investigation either himself or by involving any other Officer of the Company or an outside agency before referring the matter to the Board of Directors of the Company for further appropriate investigation and needful action. The record will include:
a)Brief facts;
b) Whether the same Protected Disclosure was raised previously by anyone, and if so, the outcome thereof;
c) Whether the same Protected Disclosure was raised previously on the same subject;
d) Details of actions taken by Vigilance and Ethics Officer / Chairman/ CEO for processing the complaint
e) Findings of the Audit Committee
f) The recommendations of the Board of Directors/ other action(s).
6.8 The Board, if deems fit, may call for further information or particulars from the complainant.
All protected disclosures under this policy will be recorded and thoroughly investigated. The Board may investigate and may at its discretion consider involving any other Officer of the Company and/ or an outside agency for the purpose of investigation.
The decision to conduct an investigation is by itself not an accusation and is to be treated as a neutral fact finding process.
Subject(s) will normally be informed in writing of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation.
Subject(s) shall have a duty to co-operate with the Board or any of the Officers appointed by it in this regard.
Subject(s) have a right to consult with a person or persons of their choice, other than the Vigilance and Ethics Officer / Investigators and/or members of the Board of Directors and/or the Whistle Blower.
Subject(s) have a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed or tampered with and witness shall not be influenced, coached, threatened or intimidated by the subject(s).
Unless there are compelling reasons not to do so, subject(s) will be given the opportunity to respond to material findings contained in the investigation report. No allegation of wrong doing against a subject(s) shall be considered as maintainable unless there is good evidence in support of the allegation.
Subject(s) have a right to be informed of the outcome of the investigations. If allegations are not sustained, the Subject should be consulted as to whether public disclosure of the investigation results would be in the best interest of the Subject and the Company.
The investigation shall be completed normally within 90 days of the receipt of the protected disclosure and is extendable by such period as the Board deems fit.
If an investigation leads the Vigilance and Ethics Officer / Chairman of the Board to conclude that an improper or unethical act has been committed, the Vigilance and Ethics Officer / Chairman of the Board shall recommend to the management of the Company to take such disciplinary or corrective action as he may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures.
The Vigilance and Ethics Officer shall submit a report to the Chairman of the Board on a regular basis about all Protected Disclosures referred to him/her since the last management of the Company to take such disciplinary or corrective action as he may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures. The Vigilance and Ethics Officer shall submit a report to the Chairman of the Board on a regular basis about all Protected Disclosures referred to him/her since the last the right to report the event to the appropriate legal or investigating agency.
A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the subject to the Vigilance and Ethics Officer or the Board shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.
SECRECY / CONFIDENTIALITY
The complainant, Vigilance and Ethics Officer, Members of Board, the Subject and everybody involved in the process shall:
Maintain confidentiality of all matters under this Policy
Discuss only to the extent or with those persons as required under this policy for completing the process of investigations.
Not keep the papers unattended anywhere at any time
Keep the electronic mails / files under password.
to obstruct the Whistle Blower’s right to continue to perform his duties / functions including making further Protected Disclosure. The company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus if the Whistle Blower is required to give evidence in criminal or disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice about the procedure, etc.
A Whistle Blower may report any violation of the above clause to the Chairman of the Board, who shall investigate into the same and recommend suitable action to the management.
The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. The identity of the complainant will not be revealed unless he himself has made either his details public or disclosed his identity to any other office or authority. In the event of the identity of the complainant being disclosed, the Audit Committee is authorized to initiate appropriate action as per extent regulations against the person or agency making such disclosure. The identity of the Whistle Blower, if known, shall remain confidential to those persons directly involved in applying this policy, unless the issue requires investigation by law enforcement agencies, in which case members of the organization are subject to subpoena.
Any other Employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.
Provided however that the complainant before making a complaint has reasonable
belief that an issue exists and he has acted in good faith. Any complaint not made in good faith as assessed as such by the Audit Committee shall be viewed seriously and the complainant shall be subject to disciplinary action as per the Rules / certified standing orders of the Company. This policy does not protect an employee from an adverse action taken independent of his disclosure of unethical and improper practice etc. unrelated to a disclosure made pursuant to this policy.
ACCESS TO CHAIRMAN OF THE BOARD
The Whistle Blower shall have right to access Chairman of the Board directly and he is authorized to prescribe suitable directions in this regard
A whistle Blower policy cannot be effective unless it is properly communicated to employees. Employees shall be informed through by publishing in notice board and the website of the company.
All Protected disclosures in writing or documented along with the results of Investigation relating thereto, shall be retained by the Company for a period of 7 (seven) years or such other period as specified by any other law in force, whichever is more.
ADMINISTRATION AND REVIEW OF THE POLICY
The Chief Executive Officer shall be responsible for the administration, interpretation, application and review of this policy. The Chief Executive Officer also shall be empowered to bring about necessary changes to this Policy, if required at any stage with the concurrence of the Board.
The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or
modification will be binding on the Employees and Directors unless the same is notified
to them in writing.
As Approved by the Board of Director at their Meeting unanimously.