“Whistle Blower” may raise a complaint in writing, email or verbally on the Whistle Blower helpline, as mentioned in Clause 6(e), giving relevant facts and details without any fear. In case the Whistle Blower wants to keep his/her identity confidential, the Whistle Blower may opt to raise the concern anonymously.
A complaint may either be written/typed in a legible handwriting or verbally raised in English, Hindi, French or in the regional language known to the Whistle Blower.
Complaint by any Whistle Blower could be with respect to any of the following:
a) General Malpractice- such as immoral, illegal or unethical conduct, fraud, bribery or corruption, environmental issues, criminal activities, wastage or misappropriation of Company funds or assets, misleading or falsification of financial or other records, accounting or auditing matters, a clear abuse of authority or any other unethical conduct affecting Company’s interest or image.
b) Potential breach or violation of the Code of Conduct
c) Breach of Copyright, patent, trademarks and disclosures of confidential data or information to competitors or outsiders.
d) Misconduct - Includes a whole variety of issues and some are listed below. However, this is not a comprehensive list but is intended to illustrate the type of issues which may be raised under this policy:
i. Questionable accounting practices
ii. Misconduct with other employees or vulnerable adults (e.g. through physical, sexual, psychological or financial abuse, exploitation.)
iii. Abuse of power (e.g. Bullying or harassment)
iv. Any other unethical or improper conduct.
e) Whistle Blower shall report concerns or complaints of violation or potential violation (with full details and evidence, if any) to the Ombudsperson by using any of the following communication channels
i. Email to: Ombudsperson@jubl.com;
ii. Logging/ accessing the web portal www.cwiportal.com, and clicking on the ‘Lodge Report’ button; and/or
iii. Post, in a sealed envelope, to the following mail box: Post Box No. 4374, The Ombudsperson - Jubilant Bhartia Group, New Delhi.
iv. Toll Free Number: 18601234525 (Availability: Monday to Friday from 0930 -1730 hrs)
f) In appropriate or exceptional cases only, an employee or Director may also directly report concerns or complaints of violation or potential violation to the Chairperson of the Audit Committee, by post, in a sealed envelope, addressed to: Post Box No. 4374, The Chairperson of the Audit Committee, of the Company. All Complaints so received shall be forwarded to the Ombudsperson for investigation.
g) The Whistle Blower has the option of sending anonymous complaints if for any reason he/she wishes to be unidentified. However, for any action to be initiated on such anonymous complaints, it needs to be detailed in description, provide documentary evidence & the basis of making the assertion therein.