Effective Date: With the approval of the Board pursuant to its resolution dated 04.04.2018.
Siddha Real Estate Development Private Limited (the Company) is committed to conducting its business by adopting the highest standards of professional integrity and ethical behavior. The organization has been aiming at develop an open and transparent culture where it is safe for all employees and stakeholders to raise concern about any unacceptable and unethical practices. Including misconduct and provide reassurance that they will be protected from reprisals or victimization for whistle blowing in good faith.
The Company is committed to adopting procedures to receive and address any concern or complaint regarding questionable accounting or auditing matters, internal controls, and disclosure matters, reporting of fraudulent practices, employee misconduct, health, safety, and environmental issues which cannot be resolved through normal management channels.
Pursuant to Section 177 of the Companies Act, 2013, as amended the (“Companies Act”) Rule 7 of the Companies (Meetings of Board and its Powers) Rules, 2014, as amended (the Rules). every listed company or prescribed class or classes of companies as may be prescribed shall establish a vigil mechanism for their directors and employees to report their genuine concerns or grievances.
The vigil mechanism shall provide for adequate safeguards against the victimization of directors, employees or any other persons who use such mechanism and make provision for direct access to the Director nominated to look after the process.
As per the Rules, the companies which are required to constitute an Audit Committee (‘Committee’) shall oversee the vigil mechanism through the Audit committee.
In case of other companies, the Board of directors shall nominate a director to play the role of audit committee for the purpose of vigil mechanism to whom other directors and employees may reports their concerns.
This vigil mechanism ("Policy") aims:
The information on suspected wrongful conduct is information which the aggrieved person in good faith, believes to be an unethical or improper activity under the scope of this Policy ("Wrongful Conduct"). Wrongful Conduct should be factual and not speculative or in nature of an interpretation/conclusion and should contain as much information as possible to allow for proper assessment of the nature and extent of the concern. It includes, without limitation, the Following:
The above list is only illustrative and should not be considered as exhaustive.
Any Whistle Blower who becomes aware of suspected Wrongful Conduct is encouraged to send his/her observations/concrete facts with related evidence without fear of reprisal or retaliation of any Kind. This Policy is not intended to cover career-related or other personal grievances. The aggrieved person's role is limited to reporting only and is not investigators or finders of facts, nor can they determine the appropriate corrective or remedial action that may be warranted.
All such disclosure of Wrongful Conduct should be forwarded emailed under a cover letter to the Managing Director of the Company. The contact details of the Managing Directors are as under.
Mr. Sanjay Jain
Managing Director
Siddha Real Estate Development Private Limited
Siddha Esplanade, 6 Jawaharlal Nehru Road, Kolkata 700013
On receipt of disclosure of any Wrongful Conduct, the Managing Director, as the case may be shall make a record of such disclosure. He/she also carry out initial investigation either himself/herself or by involving any another officer of the company or any outside agency to ascertain its genuineness and veracity. If He/she finds the complaint is found to be genuine, He/she shall make further investigation into the matter. A person against or in relation to whom a disclosure is made or evidence gathered during the course of investigation will have a duty to cooperate with the investigation and would be given an opportunity of being heard. The investigation will be completed within 30 days of receipt of disclosure or such extended time which may be permitted by the Board.
If any investigation leads the managing director to conclude that a wrongful conduct has been committed. He/she shall submit his/her report to the Board of Directors. The Board of Directors may call for further information or particulars from the concerned concerned person and accordingly it shall take such disciplinary or corrective action as may deem fit.
The Managing Director and everybody involved in the process shall maintain confidentiality of all matters (including the identity of the whistle Blower) under this Policy.
While the Policy protects the aggrieved person, it strictly prohibits misuse through frivolous and bogus complaints made with mala fide intentions. Any person making such complaints will be subject to strict disciplinary action.
The Company will retain copies of all complaints, investigation reports, and related documentation. The retention period will be decided by the Managing Director, subject to applicable laws.
The Managing Director will place a report before the Board of Directors on a regular basis, detailing the number of complaints received and their outcomes.
This Policy will be disclosed in the Company's annual report and posted on its website, if required by the Companies Act, 2013, and other regulations.
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