RR Policy 0-37 - Whistle Blower Policy

Purpose 

Red Road encourages its employees to report improper activities in the workplace and will protect employees from retaliation for making any such report in good faith. 

1. Employee Rights 

The process is designed to offer protection to the whistle blower (employees and directors) provided that the disclosure made / concern raised / allegations made (“complaint”) by a whistle blower is in good faith and the alleged action or non-action constitutes a genuine and serious breach of what is laid down in Policy 0-11 Code of Conduct.  

The Company affirms that it will not allow any whistle blower to be victimized for making any complaint. Any kind of victimization of the whistle blower brought to the notice of the Board of Directors will be treated as an act warranting disciplinary action. As a Company, Red Road condemns any kind of discrimination, harassment, victimization, or any other unfair employment practice adopted against the whistle blowers. Complete protection will be given to the whistle blowers against any unfair practices like retaliation, threat or intimidation or termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the whistle blower’s right to continue to perform his/her duties/functions in a free and fair manner.  

2. Where to Report 

A whistle blower can make a compliant by emailing to – whistleblowerhotline@redroad.in 

3. Protection from Retaliation 

It is the intent of this policy to encourage employees to report fraudulent or illegal activities and there shall be no retaliation for any reports made pursuant to this policy. Any employee who believes they have been retaliated against for whistle blowing may file a complaint with either the Managing Director or the Board of Director. Any complaint of retaliation will be promptly investigated, and remedial action taken when warranted. This protection from retaliation is not intended to prohibit managers or supervisors from taking action, including disciplinary action, in the ordinary course of business based on valid performance-related factors. 

4. Process 

• Employees can make Protected Disclosure by sending email to whistleblowerhotline@redroad.in as soon as possible but not later than 30 consecutive days after becoming aware of the same. 

• Whistle Blower must put his/her name to allegations. Concerns expressed anonymously WILL NOT BE investigated. Red Road will protect against retaliation of the whistle-blower 

• All Whistle Blower disclosures received through this channel will reach the designated Corporate Ombudsperson who will do the initial investigation. 

• The corporate ombudsperson is primarily responsible for overseeing and managing compliance issues within the organization. The corporate ombudsperson is in charge of ensuring, that the company and its employees are complying with internal policies and procedures.  

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

• Where initial inquiries indicate that further investigation is necessary, this will be carried through either by the Corporate Ombudsperson alone or by a committee nominated by him/her for this purpose, depending on the nature of the complaint.  A minimum 3-member committee consisting of experts will be formed with the right knowledge and objectivity from within the company. Members from this committee shall be assigned to investigate into the matter within 48 working hours of receipt of the whistle blower complaint.  

• The investigation would be conducted in a fair manner, as a neutral fact-finding process and without presumption of guilt. A written report of the findings would be made. 

• Name of the Whistle Blower shall not be disclosed to the committee. 

• The Corporate Ombudsperson/ Committee shall: 

1. Make a detailed written record of the Protected Disclosure. The record will include: 

1. Facts of the matter 

2. Whether the same Protected Disclosure was raised previously by anyone, and if so, the outcome thereof. 

3. Whether any Protected Disclosure was raised previously against the same Subject. 

4. The financial/ otherwise loss which has been incurred / would have been incurred by the Company. 

5. Findings of Ombudsperson/Committee. 

6. The recommendations of the Ombudsperson/Committee on disciplinary/other action/(s). 

2. The committee shall finalise and submit the report to the Ombudsperson within 15 days of being nominated/appointed. 

• On submission of report, the Committee shall discuss the matter with Corporate Ombudsperson who shall either: 

1. In case the protected disclosure is proved, accept the findings of the committee, and take such disciplinary action as he may think fit and take preventive measures to avoid re- occurrence of the matter. 

2. In case the protected disclosure is not proved, extinguish the matter. 

• The Corporate Ombudsperson shall submit a report of all the complaints received during a quarter to the Board of directors in the first Board meeting held in the following quarter or such other Board meeting at the direction of the Board. 

• Retention of Documents: All Complaints received via email or documented along with the results of investigation relating thereto shall be retained by the Company for a minimum period of seven years. 

5. Disqualifications 

• 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. 

• 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. 

• Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious shall be liable to be prosecuted under Company’s Code of Conduct. 

6.  Rewards And Recognition To The Whistle Blower 

Category 1: Appreciation for all deserving cases, for whistleblowing – Certificate/Letter to be released by Ombudsperson team.  

Category 2: INR 5K + certification for all those whistle blowers where it went on to get investigated and resulted in > INR 5 lakhs savings/recoveries  

Category 3: INR 1 L + certification for all those whistle blowers where it went on to get investigated and resulted in > INR 20 lakhs savings/recoveries.