The Bank has adopted the Code of Conduct and Ethics Policy, which lays down the principles and standards that should govern the actions of the Bank and its employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the Bank. The role of employees in pointing out such violations of the Code cannot be undermined. Accordingly, this Whistle blower Policy (“the Policy”) has been formulated with a view to provide a mechanism for employees of the Bank to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.
The Bank is committed to adhere to the highest standards of ethical, moral, and legal conduct of business operations. To maintain these standards, the Bank encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. This policy aims to provide an avenue for employees to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.
The Whistle blower policy intends to cover serious concerns that could have grave impact on the operations and performance of the business of the Bank. The policy neither releases employees from their duty of confidentiality in the course of their work, nor is it a route for taking up a grievance about a personal situation.
Various stakeholders of the Bank are eligible to make Protected Disclosures under the Policy. These stakeholders may fall into any of the following broad categories:
A person belonging to any of the above-mentioned categories can avail of the channel provided by this Policy for raising an issue covered under this Policy.
The Policy covers malpractices and events which have taken place/suspected to take place involving:
Policy should not be used in place of the Bank grievance procedures or be a route for raising malicious or unfounded allegations against colleagues.
To ensure that this Policy is adhered to, and to assure that the concern will be acted upon seriously, the Bank will:
Whistle blowers must put their names to allegations as follow-up questions and investigation may not be possible unless the source of the information is identified. Disclosures expressed anonymously will ordinarily NOT be investigated.
Protection to Whistle blower
Accountabilities – Whistle blowers
Accountabilities – Whistle Officer and Whistle Committee
Rights of A Subject
Management Action on False Disclosures
An employee who knowingly makes false allegations of unethical & improper practices or alleged wrongful conduct shall be subject to disciplinary action, up to and including termination of employment, in accordance with Bank rules, policies and procedures. Further this policy may not be used as a defense by an employee against whom an adverse personnel action has been taken independent of any disclosure made by him and for legitimate reasons or cause under Bank rules and policies.
Procedure for Reporting & Dealing with Disclosures
For more details, refer to the procedure for reporting & dealing with disclosures given in Annexure A.
Access to Reports and Documents
All reports and records associated with ‘Disclosures’ are considered confidential information and access will be restricted to the Whistle blower, the Whistle Committee and Whistle Officer. ‘Disclosures and any resulting investigations, reports or resulting actions will generally not be disclosed to the public except as required by any legal requirements or regulations or by any corporate policy in place at that time.
Retention of Documents
All Protected Disclosures in writing or documented along with the results of investigation relating there to shall be retained by the Bank’s Record Retention and Maintenance Policy.
A quarterly status report on the total number of complaints received during the period, with summary of the findings of the Whistle Committee and the corrective actions taken will be sent to the CEO of the Bank.
The Bank is entitled to amend, suspend, or rescind this policy at any time. Whilst, the Bank has made best efforts to define detailed procedures for implementation of this policy, there may be occasions when certain matters are not addressed or there may be ambiguity in the procedures. Such difficulties or ambiguities will be resolved in line with the broad intent of the policy. The Bank may also establish further rules and procedures, from time to time, to give effect to the intent of this policy and further the objectiveof good corporate governance.
Amendment of Policy
Any amendments to this policy will be approved by the Nomination and Remuneration Committee (NRC) ofthe Board of Directors of the Bank.
For any deviation in policy & exceptional approvals can be considered on basis of recommendation by skip level & approval from CEO.
A Procedure for Reporting & Dealing with Disclosures
How should a Disclosure be made and to whom?
A Disclosure should be made in writing. Letters can be submitted by hand-delivery, courier or by postaddressed to the Whistle Officer appointed by the Bank. Emails should be sent to the email id: email@example.com
Is there any specific format for submitting the Disclosure?
While there is no specific format for submitting a Disclosure, the following details MUST be mentioned:
What will happen after the Disclosure is submitted?
What should I do if I face any retaliatory action or threats of retaliatory action as a result of making a Disclosure?
If you face any retaliatory action or threats of retaliatory action as a result of making a Disclosure, please inform the Whistle Officer in writing immediately. He/ She will take cognizance of each, and every such complaint/feedback received and investigate the same accordingly and may also recommend appropriate steps to protect you from exposure to such retaliatory action and ensure implementation of such steps for your protection.
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