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Whistle Blower Policy
  1. The Complaint should, to the extent possible contain the following:
    1. The alleged event, matter or issue that is the subject of the Complaint:
    2. The name(s) of the person(s) involved;
    3. If the Complaint involves a specific event or events, the approximate time and location of each event; and
    4. Any additional information, documentation or other evidence available to support the Complaint.
    To the extent that it can be provided without compromising the desire for anonymity
  2. The information on suspected wrongful conduct should be such information which the whistleblower in good faith, believes, evidences any of the following:
    1. Violation of any law or regulations, policies including but not limited to corruption, bribery, Theft, fraud, coercion and willful omission.
    2. Rebating of Commission/benefit or conflict of interest.
    3. Procurement frauds.
    4. Mismanagement, Gross wastage or misappropriation of company funds/assets.
    5. Manipulation of Company data/records.
    6. Misappropriating cash/company assets; leaking confidential or proprietary information.
    7. Unofficial use of Company's property/human assets.
    8. Activities violating Company policies(including Code of Conduct policy)
    9. A substantial and specific danger to public health and safety.
    10. An abuse of authority or fraud
    11. An act of discrimination or sexual harassment.
    The above list is illustrative and should not be considered as exhaustive.
  3. The Whistle Blower's role is limited to that of a reporting party with reliable evidence. They are not required or expected to act as investigators or determine the appropriate corrective or remedial action that may be warranted in a given case.
  4. If a protected disclosure is received by any executive of the Company other than the CEO or the ABIBL Grievances and disciplinary committee members, the same should be forwarded to the ABIBL Grievances and disciplinary committee.
The ABIBL Grievances and disciplinary committee members, after proper scrutiny, must investigate as per the ABIBL Grievances and disciplinary committee charter upon receipt of the complaint. The members will ascertain the correctness and trueness of the complaint and shall recommend necessary corrective measures /disposal as follows:-
  1. Closing the complaint if wrongful conduct remains largely unsubstantiated
  2. If the complaint is found correct on investigation, action against concerned persons be suggested.
  3. To overcome system or control weakness, making it more stringent recommending other policies, or procedures.
  4. Management, on the basis of the recommendation of the ABIBL Grievances and disciplinary committee, shall take appropriate action immediately.

Disclosure of wrongful conduct may be made on a confidential basis. Such disclosures will be kept confidential to the extent possible, convenient with the need to conduct an adequate investigation and legal stipulation.
No adverse action shall be taken against an employee or business associate in "knowing retaliation" who makes any good-faith disclosure of suspect or wrongful conduct to the ABIBL Grievances and disciplinary committee.
Not later than 30 days after a current or former employee/business associate is notified or becomes aware of a complaint against him/her, he or she may protest the action by filing a written complaint with the ABIBL Grievances and disciplinary committee if the employee believes the action was based on his or her prior disclosure in good faith, of alleged wrongful conduct.
The policy is approved by the CEO and Board of Directors. The policy may be reviewed internally on annual basis and if changes required, it shall be placed before the CEO and Board of Directors for its Approval.
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