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Whistle Blower Policy

Procedure for handling a complaint:

  1. A whistle blower identifies non-adherence of the ABC Code of Conduct or the Aditya Birla Group's Code of Conduct by any employee or a segment of the organization, will compile information that supports the case.
  2. The whistle blower sends the complaint to the independent reporting mechanism - Ethics Hotline or to the respective Standards Committee, depending on:
    1. The level at which the violation is perceived to be happening, or
    2. The seniority of the individual/s involved.

    If the breach or misdemeanor is at:
    1. The Unit Head level (Chief Executive Officer, Unit Head etc) and above, the employee will write to the Group level Value Standards Committee (GVSC)
    2. Unit Function Head level, the same will be reported to the respective Business level Value Standards Committee (BWBC)
    3. Any other level, the same will be reported to the respective Unit level Value Standards Committee (UWBC)
  3. A whistle blower can also send the complaint to the Business Head, Unit Head, Chief Human Resource Officer or Company Secretary.
  4. All complaints which are sent directly to the various reporting authorities will necessarily be also reported to the Ethics Hotline. The Ethics hotline will capture all relevant information and send it to relevant Values Standard Committee within 2-3 working days.
  5. Upon receipt of information, the secretary of the relevant Values Standard Committee will first do a preliminary investigation to check whether the complaint seems to be genuine and falls under the purview of the whistle blower policy. If the complaint is sent with malicious intent, then the committee will take appropriate disciplinary action against the whistle blower.
  6. If the complaint does not fall under the purview of whistle blower policy, then the same would be redirected to the right forum. For eg – If complaint is related to sexual harassment, same will be forwarded to the Complaints Committee and would be dealt as per the process prescribed under the Policy to Prevent Sexual Harassment at the Workplace. If a complaint is related to a personal grievance, e.g. appraisal rating, promotion etc, it will be forwarded to the relevant Head HR of the Unit.
  7. Once established that the case needs investigation, the secretary of the relevant Value Standards Committee, in consultation with the committee, shall appoint a team to investigate the case, with utmost confidentiality. The investigative team can be a pool of internal people or can be an external agency specialized in investigating such cases.
  8. Under no circumstances, will the secretary, investigation team and the committee reveal / disclose the identity of the "accused" to anyone else (including the immediate manager) – other than all those who are required to know about the case.
  9. The investigation team should work towards ensuring that the investigation is completed by following the laws of the land and principles of natural justice within 3 weeks of the complaint being reported. If the investigation cannot be completed within 3 weeks, then the committee needs to have very valid and strong reasons for the same.

Actions by Committee

If charges are substantiated, or the complaint is found correct on investigation,suitable action will be suggested. The following punitive actions could be taken against employees, where the committee finds the accused guilty:

  1. Counseling& a Warning letter
  2. Withholding of promotion / increments
  3. Bar from participating in bonus review cycle
  4. Termination
  5. Legal suit

The above are only suggestive and the Committee may decide on the actions to be taken on acase to case basis depending on the gravity of the offence.

If wrongful conduct remains largely unsubstantiated; the committee has the right to close the complaint.

If the case is found to be false and malicious in intent and the whistle blower / complainant has indulged in this knowingly, he/she would be held guilty of misconduct and appropriate action shall be taken. However, the Committee shall distinguish between mistaken reporting and malicious intent of the complainant.

The decision of Whistle Blower Committee will be binding on the parties involved / parties found guilty of the reported mis-conduct.

Reporting process

An Annual and Quarterly report will be prepared by the Business Value Standards Committee of which copies will be placed before the Audit Committee of the relevant Group Company and also shared with the Organization Effectiveness portfolio at Group Human Resources.

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