Last Update: 26/02/2024
Golchha Daga: Whistleblower Policy
Whistleblower Policy Introduction
The firm believes in the conduct of its affairs in a fair and transparent manner by adopting commitments to the highest levels of ethics, professionalism, honesty, and integrity. We understand that this is crucial to our continued success and reputation. It is the responsibility of all personnel, regardless of designation, employment status, function, location, business unit, of the Firm to speak up and report unethical and improper practices or any other wrongful conduct. At the same time, the Firm is committed to developing a culture where it is safe for all personnel who report, in good faith, suspected violations or unacceptable practice and any event of misconduct without adverse consequencesto the individual who so reports. The Firm’s Whistleblower Policy (“Policy”) is an essential element to provide an opportunity to all personnel and the Firm’s business partners to report an incident of any corrupt, illegal, or other undesirable conduct. This Policy describes the reportable conduct, protections available to Whistleblowers and complaint, incidence handling mechanism.
Purpose of this policy
The Policy has been developed considering the professional standards and current leading practices relating to the Whistleblowers’ protection with an aim to foster a speak-up culture amongst the personnel of the Firm. The Designated Committees, including the Ethics and Compliance Committee (the “ECC”) will be set up for assessing and addressing. the concerns reported by Whistleblowers and overseeing policy implementation and effectiveness.
Applicability
This Policy applies to all the all personnel, regardless of designation, employmentstatus, function, location,
and business unit of the Firm.
Whistleblower Policy
Disciplinary Action: Any action that could be taken on the completion of investigation proceedings
including but not limited to a warning, imposition of fine, suspension from official duties, dismissal,
termination or any such action as is deemed to be fit considering the gravity of the matter and circumstances
of the individual.
Ethics and Compliance Committee (ECC): Committee formed to manage and address the Protected
Disclosures and to assist personnel, vendor, external agent, representative, business partner, contact to
report unethical concerns, headed by the Managing cum Executive Partner of the firm.
Personnel
Any individual directly or indirectly in contractual relationship with the Firm regardless of designation,
employment status, function, location, or business unit
Subject: Refers to alleged personnel/individual against whom the Whistleblower has made a Protected Disclosure or
complaint.
Whistleblower: Any current or former personnel, client, vendor, service provider, external agent, representative, affiliate,
business partner, who discloses or demonstrates conclusive and effective evidence of any unethical activity or
any misconduct that may constitute a breach of the Firm’s codes of conduct, policies or legal or regulatory
obligations.
Reportable Disclosure
Reportable Disclosure is anything that has reasonable grounds to suspect any instances of misconduct, or an improper state of affairs or circumstances. A few examples of Reportable Disclosure include but are not limited to:
1) Unethical conduct
2)Abuse of authority.
3) Non compliances with legal or regulatory requirements
4) Independence Issues
5) Non compliances with the codes of conduct, policies, or rules of the Firm.
Complaints RedressalMechanism
The ECC chair shall make a preliminary evaluation and may make a recommendation as follows:
1)further investigation including POSH matters, OR 2) dismissed because of lack of evidence.
The ECC Chair shall decide how each complaint is to be addressed and the composition of relevant investigation team. The ECC shall be responsible for addressing each complaint forwarded to it and how each complaint is to be addressed and the composition of the relevant investigation team. The investigation team may be an internal or external agency; standing committees of the Firm; ad hoc committees of the Firm; specially set up investigation team; or any other appropriate body.
ECC shall assess the gravity of the complaint. If upon the assessment, it is found that the complaint has no basis, is not ofsubstance, or is not a matter to be investigated under this Policy, it may be dismissed at this stage and the decision will be communicated the complainant accordingly.
Subject shall have a duty to co-operate with the ECC and will not compromise self- incrimination protections available under the applicable laws.
Subject has a right to consult with a person or persons of their choice, other than the ECC.
Subject has a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed, or tampered with, and witnesses shall not be influenced, coached, threatened, or intimidated by the Subject.
Unless there are compelling & confidential reasons not to do so, Subject will be informed of the investigation and will be given the opportunity to respond to material findings contained in an investigation report. No allegation of wrongdoing against a Subject shall be considered as maintainable unless there is reasonable evidence in support of the allegation.
Subject has a right to be informed of the outcome of the investigation if allegations are not sustained.
Secrecy/ Confidentiality
The Whistleblower, the Subject, the Administrator and Investigation Team and everyone involved in the
process shall:
1) maintain complete confidentiality/ secrecy of the matter
2) not discuss the matter in any informal/social gatherings/ meetings
3) Discuss only to the extent or with the persons required for the purpose of completing the process and investigations.
4) Do not keep the papers unattended anywhere at any time.
5) keep the relevant electronic mails/files under password protection and adequate security
