RISK MANAGEMENT AND WHISTLE BLOWING POLICY

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Whistleblowing: Introduction
Whistleblowing occurs when a worker raises a concern about danger or illegality that affects others, for example members of the public In 1999, the Public Interest Disclosure Act came into force in the UK in response to a number of high profile disasters and scandals in which, after the event, it was revealed that employees had been aware of the dangers, but were too scared to blow the whistle. Employees may be fearful that raising the alarm will lead to retribution from their colleagues or indeed their employer who may shoot the messenger, but a good organisation should encourage staff to voice their concerns over malpractice and act against an employee who would try to hinder them doing so. There are a number of reasons why implementing a whistleblowing policy is beneficial: Having such a policy should enable an organisation to deal with a concern internally and in an appropriate manner, rather than publicly. Publicity about a malpractice can severely harm an organisations reputation and funding potential and have a similar impact on other organisations in the same sector. A whistleblowing policy should encourage a climate of open communication which enables staff to voice concerns at the earliest opportunity and thus averts a larger issue in future. Also, if the employees concerns are misplaced, then this misunderstanding can be addressed sooner rather than later. Knowing that an organisation has a clear policy on whistleblowing and is serious about dealing with malpractice should act as a deterrent to those who may be considering an illegal, improper or unethical practice.

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Who does the Policy apply to?

The policy applies to all employees, (including those designated as casual hours, temporary, agency, authorised volunteers or work experience), and those contractors working for the Council on Council Premises, for example, agency staff, builders, drivers. It also covers suppliers and those providing services under a contract with the Council in their own premises, for example, care homes and childrens centres. The policy also covers Members.This policy has been discussed with the relevant trade unions and professional organisations and has their support.

The Aims of the Policy

To encourage you to feel confident in raising concerns and to question and act upon concerns about practice. To provide avenues for you to raise concerns in confidence and receive feedback on any action taken. To ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied. To reassure you that you will be protected from possible reprisals or victimisation if you have a reasonable belief that you have made any disclosure which is in the public interest. .

What Types of Concern are Covered?

Conduct which is an offence or a breach of law. Failure to comply with a legal obligation. Disclosures related to miscarriages of justice. Health and safety risks, including risks to the public as well as other employees. Damage to the environment. The unauthorised use of public funds. Possible fraud and corruption. Sexual, physical or other abuse of clients. Other unethical conduct. Actions which are unprofessional, inappropriate or conflict with a general understanding of what is rights and wrong.

NB. Other procedures are available to employees e.g. the Grievance procedure which relates to complaints about your own employment. This policy also does not replace other corporate complaints procedures which are for public use.

Safeguards and Victimisation

The Council recognises that the decision to report a concern can be a difficult one to make. If what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer and those for whom you provide a service. The Council will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate action to protect you when you raise a concern which is in the public interest.

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Confidentiality
All concerns will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At the appropriate time, however, you may need to come forward as a witness. This policy encourages you however to put your name to your concern whenever possible. Please note that:

Staff must believe the disclosure of information is in the public interest. Staff must believe it to be substantially true. Staff must not act maliciously or make false allegations. Staff must not seek any personal gain.

The Response of Corporate India :

Corporate India was slow to respond to the nonmandatory requirements of Clause 49 in general, and the clause relating to the whistle-blower policy in particular. A regulatory recommendation is a law in the making, and it is heartening to find that an increasing number of companies are now realising the need to pay heed to these non-mandatory requirements. A peek at some of the corporate governance reports that form part of the annual reports of companies reveals the status of adoption of this non-mandatory requirement (refer Table). Table Compliance of the non-mandatory requirement of Annual Clause 49 of the Listing Agreement on whistle-blower Report policy 200910 The Company has whistleblower policy and adheres to norms relating to the same. During the year the Company has established a Whistle Blower Policy with a view to provide a mechanism for employees to report to the management concerns about unethical behavior, fraud, etc. The Policy also provides for adequate safeguards against victimization of employees who avail of the mechanism and also provides for direct access to the chairman of the Audit Committee. The Board of Directors of the Company at their meeting held on 25th June, 2009 approved and adopted the Whistle-Blower Policy of the Company with an objective to establish a formal mechanism to provide protection to the employees of the Company from unethical work practices and irregularities. The Company has not established a formal whistle blower policy mechanism. However, there is a

Company Name

LIC Housing Finance Ltd.

The Great Eastern Shipping Co. Ltd.

200910

Asian Paints Ltd.

200910

CMI FPE Ltd.

2008-

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mechanism in place to address unethical conduct, if any, by employees vis--vis the standards stipulated in the code of conduct and work ethics. Moreover, no personnel of the Company have been denied any access to the Audit Committee. Although it is not mandatory the Board of IDFC has also adopted Whistle Blower Policy. The Company is in the process of development of suitable Whistle Blower Policy. Presently, the Company does not have a Whistle Blower Policy but has a policy similar to it for the entire BP Group of Companies worldwide which is called Open Talk. No personnel of the Company has been denied access to the Audit Committee. The Bank has adopted the Whistle Blower Policy pursuant to which employees of the Bank can raise their concerns relating to the fraud, malpractice or any other untoward activity or event which is against the interest of the Bank or society as a whole. The Company does not have a Whistle Blower Policy, but has an independent Ombudsman, who is not an employee of the Company. The company has not adopted any non-mandatory requirements of the Clause 49.

IDFC

200910 200809

Divis Lab Ltd.

Castrol India Ltd.

2008

Kotak Mahindra Bank

200910

Ashok Leyland Ltd.

200809 200809

Bharat Forge Ltd.

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