Whistle Blower Policy

whistle-blower-policy

Purpose

The purpose of the Whistle Blower Policy is to devise a procedure by which Employee/s or non-Employee Stakeholders can report to the Company, allegations of known or suspected alleged Improper Activities (as defined hereinafter).

All Employee/s of the Company or non-Employee Stakeholders are encouraged to report either orally or in writing to the Whistle Blower Administrator, evidence/s of activity by the Company, department or Employee/s that may constitute Improper Activities affecting the business or reputation of the Company.

Guidelines

Definition

Fraudulent financial reporting.

Forgery or alteration of documents.

Fraud against the Company’s shareholders.

Pursuit of a benefit or advantage in violation of conflict of interest policy of the Company.

Authorizing or receiving compensation for goods not received or services not rendered.

Misappropriation or misuse of Company resources, such as funds, supplies or other assets.

Violations of laws applicable to the Company.

Disclosure of confidential information.

Authorizing or receiving compensation for hours/days not worked.

Violations of the Company’s Code of Conduct for Directors and Employees or other Code of Conduct framed by the Company, if any.

Non-Employee Stakeholders

The party may be a professional, auditor, expert, vendor, consultant, contractor, contract employee, trainee, ex-employee, skilled/unskilled labour, NGO, semi-government organization or such; and the Company is/was availing of services from such stakeholders.

Whistle Blower

‘Whistle Blower’ means an employee of the Company and includes Non-Employee Stakeholders who informs a manager, supervisor or the Whistle Blower Administrator of the Company and includes the Chairman of the Ethics Committee who works in consultation with the Whistle Blower Administrator, about an activity which that person believes to be fraudulent or dishonest.

PROCESS FOR EMPLOYEES

Reporting Requirement

Employee/s may report information concerning Improper Activities. Such reports may be submitted in a confidential or anonymous manner. Such reports may be made in writing or may be in oral or telephonic conversation also. Such reports should be factual.

Employee/s should provide as much specific information as possible including names, dates, places and events that took place, the Employees’ perception as to why the incident constitutes an Improper Activity.

Obtaining evidence for which they do not have a right of access.

Conducting their own investigation.

Reporting Employee/s who report Improper Activities on an anonymous basis must provide sufficient corroborating evidence to justify an investigation.

Procedure for Reporting Improper Activities

To submit a report involving any known or suspected Improper Activity, an Employee may send an email to the Chairman of the Audit Committee being the Whistle Blower Administrator, with or without disclosing his identity. Employees can send anonymous emails using this link.

Process For Non-Employee Stakeholders

For Online Complaints

E-mail may be sent to the Whistle Blower Administrator on the following e-mail ID:

whistleblower@persistent.com

For Offline Complaints
Ms. Anuja Ramdasi
Head – Internal Audit

Persistent Systems Limited
Bhageerath,
402 Senapati Bapat Road, Pune 411 016
Ph. No.: (020) 6746-2094
e-mail ID: anuja_ramdasi@persistent.com

Protection To Employee/s And Non-Employee Stakeholders

Any Employee or Non-Employee Stakeholder reporting Improper Activities will be protected against threats of retaliation, discharge, or other types of discrimination including compensation or terms and conditions of employment that are directly related to the disclosure of the report.

Any other person assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.

However, Employee/s or Non-Employee Stakeholder who file reports of Improper Activities or provide evidence which they know to be false or without a reasonable belief in the truth and accuracy of such information will not be protected by the above policy statement and may be subject to disciplinary action and legal claims.

You May Be Interested In

Anti-Corruption Policy

Code of Conduct for Prevention of Insider Trading

Code of Conduct for Directors and Employees

Ethics Policy

Vendor Code of Conduct

Anti-Harassment Policy

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