Whistle Blower Policy  



The Company has  a  code  of  conduct  for  the  Board  of  Directors and  Senior  Executives of the



Section 177 of the Companies Act, 2013 and Clause 49 of the Listing Agreement entered into with

the BSE Limited requires that the company shall establish a vigil mechanism for directors and

employees to report concerns about unethical behaviour, actual or suspected fraud or violation of

the company’s code of conduct or ethics policy.  This mechanism should also provide for adequate

safeguards against victimization of Directors / Employees who avail of the mechanism and also

provide for direct access to the Chairman of the Audit Committee in exceptional cases.


Accordingly,  the  Whistle  Blower  Policy  (“the  Policy”)  has  been  formulated  with  a  view  to  

provide    a mechanism    for    the Directors / Employees    of    the    Company    to    approach    the  

designated persons /Chairman  of  the  Audit Committee of the Company to, inter alia, report to the

management instances of unethical behaviour, actual or suspected, fraud or violation of the

Company’s code of conduct or policy.



To provide   Directors / Employees, customers to raise concerns to the highest possible standards of ethical, moral and legal business conduct and its commitment to open communication and to provide necessary safeguards for protection of associates from victimization, for whistle blowing.



All Directors/ Employees, customers,  of the Company.

Main Features of the Policy

The whistle blowing policy is intended to cover serious concerns that could have a large/material

impact on the Company such as (i) suspected action, (ii) incorrect financial reporting , (iii) actions

which are not in line with the Company’s policy, (iv) unlawful actions, (v) fraud  and (vi) any other

actions which are not legal and will have an impact on the performance and image of the Company.



Directors/ Employees, customers, suppliers, shareholders of the Company (“Complainant/

Whistleblower”).  The complainant needs to demonstrate to the Company, that there are sufficient

grounds for concern.



1. Harassment or victimization of the complainant will not be tolerated.

2. Confidentiality

Every effort will be made to protect the complainant’s identity, subject to legal constraints.


3. Anonymous Allegations

Complainants need t o mention their names to allegations. Normally anonymous complaints will not be investigated. However the same will be investigated subject to seriousness of the issue raised.  


4. Malicious Allegations

After the investigation, if it is found that it was a malicious allegation by the complainant, the

same will result into disciplinary action.


Investigating Authority

The Investigation authority will be a person or group of persons of the Company constituted for the

investigation the complaints.


The Company could also appoint an outside agency for investigation of the matter.


The whistle blowing procedure is intended to be used for serious and sensitive issues. Serious concerns relating to financial reporting, unethical or illegal conduct should be reported to the

Investigating Authority.  


The Complaints can be reported to the following persons in writing:




Email Id

Mr. Durga Peasad Sharna



Mr. Anil Arora








All complaints received will be recorded. If initial enquiries by the Investigating Authority reveal that the Complaint has no basis, it may be dismissed at this stage. Where initial enquiries indicate that further investigation is necessary, this will be carried through Investigating Authority or it may engage an outside agency for the said purpose. The investigation would be conducted in a fair manner. The principles of natural justice and equity will be followed. A written report of the findings will be made.  After the investigation if the Complaint is proved, disciplinary action including dismissal will be considered.


If the complaint is false or malicious, suitable action like fine or dismissal will be considered.

The Report the Complaints received, outcome of the investigation will be given to the Managing

Director of the Company






  The complaint received from the complainant will be acknowledged.   If additional information is

required, the Investigation Agency will contact the complainant to get additional information.  The

outcome of the investigation will be communicated to the complainant.



This policy can be changed, modified, rescinded or abrogated at any time by the Company.


Responsibilities of Complainants


To bring early attention of the company any improper practice they become aware of. Co‐operate

with investigating authorities, maintaining full confidentiality. A complainant has the right to protection from retaliation.  


If the Complainant is not satisfied with the outcome of the investigation, the complainant can take

up the matter with the Chairman of the Audit Committee


Role of Investigation Authority

Role shall include:

Ensure that the policy is being implemented.   Ascertain prima facie the credibility of the charge. If

initial enquiry indicates further investigation is not required, close the issue. Document the initial

enquiry.    Provide quarterly reports to the Managing Director of the Company. Acknowledge receipt of concern to the complainant. Ensure that necessary safeguards are provided to the complainant.    Conduct the enquiry in a fair, unbiased manner. Ensure complete fact‐finding. Maintain strict confidentiality. Decide on the outcome of the investigation.    Recommend an appropriate course of action including dismissal, and preventive measures.  Minute Committee deliberations and document the final report.

Role of Managing Director                                                                                                                                                  

   The Managing Director shall place before the Board quarterly reports of the Investigating Agency

and ensure necessary action is taken based on the report of the Investigating Agency.