By using www.khadims.com and/or purchasing its products, you agree categorically to the terms and regulations of KHADIM’s Policy. Any/all changes in the policy will be notified to website users and customers by updating the Policy on the website. It is your responsibility to regularly review this Policy and any subsequent changes.
Your use of our site post changes will not only denote your approval of these changes but will also be binding. In the event you decide to discontinue using our site without taking any action regarding your personal data, your information will remain subject to use under our Policy prior to its change.
KHADIM’s will collect your personal information when provided to us, such as during login as a registered user of www.khadims.com or setting up a user account as well as password, ordering a product, contacting us by e- mail, phone or otherwise, providing details in your account (and there could be multiple, if multiple e-mail addresses have been used by you while buying from us) or during filling up of an entry form for participating in a survey, promotion or contest, whether at any of our retail outlets or online.
Consequent to these activities, you might share with us personal information such as your name, phone number(s), postal and e-mail addresses, credit card details, names of individuals who have received shipped purchases, including their telephone numbers and address, financial information, product interest information and in some cases, your individual preferences and opinions. A record of your product preferences may also be maintained by us.
KHADIM’s website is meant to be used by adults. No personal information from children below 18 years will be knowingly collected by us. Our website should not be used by anyone under 18 nor should they provide us with any personal data.
Your personal information may be used by KHADIM’s for:
- processing your order and answering queries about your order status
- shipping ordered products to you or your associates, relatives or friends
- communication (via post, e-mail or otherwise) and providing personalized services, promotional/special offers and additional information about our services, products, surveys, events and contests
- helping us be more aware of your shopping interests
- conducting performance and marketing research, helping us benchmark our performance, measuring your customer service and assisting us in improving our product offers and your shopping experience
You are free to refuse receiving marketing information or promotional materials under terms mentioned below.
3. Promotional Communications
KHADIM’s will communicate with you only if you want us to. If you do not want us to send you promotional offers, or use your data to improve your shopping experience, kindly inform us via toll-free 1800 274 0501 or email firstname.lastname@example.org. Please provide your full name and the e-mail id used by you at the time of registration or purchase. We may take up to 2 weeks to process your request, during which period, KHADIM’s may continue to send you communications.
4. Changing or Accessing Personal Information
KHADIM’s will ensure the personal data it collects is up-to- date, complete and accurate as is required for the purposes of its use. You have the right to request access to and correction of your personal information. Such requests, complaints or queries regarding this Policy and the privacy practices of KHADIM’s may be made in writing to:
Khadim India Ltd.
Kankaria Estate, 5th Floor
6, Little Russell Street,
Kolkata - 700 071
Your consent to/approval of collection, use and/or disclosure of personal data can be withdrawn anytime by writing to our privacy officer. Your personal data will be retained only so long as it is required for the purposes stated in this Policy or an extended period as needed under laws applicable.
5. Information Sharing with Third Parties
KHADIM’s may share your personal information (collected during your visit and purchase on www.khadims.com, participation in a survey/contest, availing a special offer/promotion or during shopping at our stores) with its Affiliates to let them communicate with you (by post, e-mail or otherwise), offer you promotional materials and additional details about their services, products, contests, and special offers that you may find interesting, or collect and utilize that information for purposes specified in this Policy.
Your personal information is not sold or rented by us to any non-affiliated third party, except when certified by law. Nevertheless, in case all or nearly all of KHADIM’s businesses are sold or in the event of any similar transaction, your personal information may be transferred or disclosed by us to a buyer or prospective buyer, who may accumulate, utilize and reveal such information to access the proposed deal or operate and handle the activities of the acquired business, or for any other reasons specified in this Policy.
Personal information may be transferred by us to non-affiliated third parties to process pursuant to deals that prevent them from utilizing or revealing the personal data for any other purpose except for processing, and enforce security precautions suitable to the sensitivity of the data.
In consideration of the sensitive nature of your personal data and the reasons for their intended use, we have taken appropriate measures to ensure data confidentiality and safety, and their protection against theft or loss, unauthorized access, copying, disclosure, and modification or use. This Policy is binding to all employees and agents of KHADIM’s.
TERMS & CONDITIONS
KHADIM INDIA LTD. (hereinafter referred to as KHADIM’s) owns www.khadims.com and operates it for your personal information and use. Access and browsing of this site implies your unconditional acceptance of the following terms, without qualification or limitation. This website is meant to be used by adults, only. You represent that you possess the legal right and ability to create binding obligations. KHADIM’s reserves the right to cancel orders or refuse service in its sole discretion.
Every effort has been made to provide correct product information, their fair description and accurate display of their colour and appearance. However, we cannot assure that the colour or appearance or any other description of the ordered product will be accurately reflected by your display since the actual colours or appearance may differ owing to difference in picture or monitor quality, or for other such reasons. We do not signify and vouch for the accuracy, completeness or flawlessness of product descriptions, appearance, images or other product details or site content.
If you have any reason for dissatisfaction about the product description after receiving it, you are advised to return it unused and without any harm whatsoever, together with the invoice.
General limits and practices may be established by us, regarding the use of our site and the services provided by us, including restrictions to the number and size of any contents and messages sent, or the length of their stay on our site. We can delete or amend any website material at any time, and we are not accountable for deleting, amending or not storing any contents or materials transmitted to us.
LIMITATION OF LIABILITY
We shall not be responsible for any damage, consequential or incidental, direct or indirect, caused by:
- the inability to use/non-use of products, services or materials of any kind offered.
- the use of this site to your computer or any other software, equipment used by you.
Every effort has been made to keep the website free from viruses or defects. You are responsible for using the correct equipment during website usage, and to safeguard it against anything that is damaging.
KHADIM’s does not claim this website to be error-free, or any content, data, software, information or any other material that can be accessed through this site to be free from viruses, bugs, Trojan horses, worms or similar damaging components. We provide information on this site “as is”, including all faults and devoid of any kind of warranties, whether stated or implied.
TRADEMARKS AND COPYRIGHTS
KHADIM’s owns and provides materials on this site, which include texts, illustrations, images, audio and video clips, and software, all of which is safeguarded by the Copyright Act, the appropriate Intellectual Property Laws and also international treaties. Thus, you are not permitted to copy, republish, reproduce, post, download, transmit, modify or distribute, directly or indirectly, in part or in whole, in any form at all, comprising but not restricted to text, images, photographs, audio or video, layout, designs, etc. The trade name, trademarks, service marks and logos (collectively referred to as “Marks”) of KHADIM’s demonstrated on this site are KHADIM’s registered/unregistered Marks. The service marks, logos and other marks on the site belong to their individual owners and you are prohibited from their use, directly or indirectly. Nothing in this site allows you to use the material or the Marks safeguarded by the Copyright Act (or its equivalent).
Your visit to this site or act of sending e-mails denotes electronic communications with us and your approval to receive such communications from us. We will correspond with you via e-mail or posted notices on this site. You accept that all agreements, disclosures, notices and other communications provided by us electronically to you comply with any legal obligation that such correspondences be in writing.
KHADIM’s may monitor site access and other activities related to it, and intervene if necessary. However, no representation or warranty is made or given by KHADIM’s to that effect. If KHADIM’s ever resolves to do it, you agree to such intervention and surveillance.
HARMFUL MATERIAL / INFORMATION
You are not permitted to introduce through or into this site any harmful material or information. You are also not allowed to include, intentionally or otherwise, any defect or error in information or material which may, be a slander, libel, obscenity or defamation, or foster hatred or trigger a civil liability or criminal offence by any individual or entity.
We provide references and links to other sites only for convenience. KHADIM’s has not assessed and so, does not implicitly or expressly vouch for other websites or any material or information, or their accessibility, with the help of such links. We also do not take liability for other such sites, material or information published thereon, or services or products offered thereon. Unless allowed by KHADIM’s expressly, you shall not indulge in link creation to this site from others.
KHADIM’s does not claim the material or information accessed through or from this site to be uninterrupted or devoid of defects, errors, viruses or other damaging components, or to correct any such problems, if discovered.
RESERVATION OF RIGHTS
KHADIM’s reserves all rights not explicitly allowed in these terms. Nothing covered in these terms shall be interpreted, by estoppel, implication or otherwise, as bestowing any right or license under any trademark, patent, copyright or other such intellectual property rights of KHADIM’s or any other individual or to you.
RESOLUTION OF DISPUTES BY ARBITRATION:
Any claim or disagreement arising from the use of this site, including the scope or applicability of this clause of arbitration shall be raised to and resolved finally by KHADIM’s appointed Sole Arbitrator, excluding courts of law, in compliance with the Indian Arbitration Act, 1996. But, prior to submitting an arbitration claim, a customer service representative at KHADIM’s must be first contacted in order to resolve the disagreement, just as KHADIM’s too must contact you before taking it to arbitration. If the disagreement remains unresolved after 60 days of informing KHADIM’s, you may inform us to appoint an Arbitrator for the purpose and we shall do the needful within 15 days of receiving such intimation. The Arbitration venue shall be Kolkata, the language shall be English and law applicable shall be Indian.
Any award resultant from Arbitration shall be binding on and final for both parties. Such award may be executed or enforced by any court with jurisdiction over the property or person against whom the award is sought to be enforced.
Apart from the terms in this Clause, KHADIM’s may also seek and obtain any interim, provisional or injunctive relief from any court of capable jurisdiction for protecting our trademark or confidential data or any intellectual property right etc.
KHADIM’s controls and operate this site from Kolkata, India, and the applicable Indian laws shall govern any transaction carried out from or on it, without reference to codes of conflict of laws. Items delivered or sold abroad via this site shall be bound by India’s export control regulations and laws.
Cookies are short data strings that enable this site to remember your identity. We use them to determine your search preferences as well as other site preferences, for providing a better experience at the time of your next website visit. Your departure from the site terminates our communication with the cookie. Though it remains on your device, it can be deleted any time by logging in again and re-entering your preferences, in case there are any.
ABSENCE OF WAIVER
KHADIM’s failure to implement any policies of these terms or to react to a breach of these terms by any third party or you shall not waive, in any way, KHADIM’s right to implement subsequently any of the stated terms and conditions or to take action regarding similar breaches.
SEVERABILITY / CHANGES TO TERMS
The terms that apply to this site may be modified, updated or changed from time to time by KHADIM’s and your continued use of our site will denote your acceptance of the modified terms. In case any term is deemed void, invalid or unenforceable, those shall be considered severable but the enforceability and validity of remaining terms shall not be affected by it.
These terms and regulations referred to or incorporated herein denote the full agreement between us, regarding the use of this site and any form of transaction carried out from or on this site, along with its contents. Also, any prior agreement or understanding (whether written, oral or electronic) is superseded by it.
The right to end your access to any or all parts of this site is reserved by KHADIM’s, with or without intimation, at its individual discretion.
The headings mentioned here are used for ease of reference and do not affect the interpretation or construction of the terms and regulations herein.
This security policy divulges the security practices of www.khadims.com and indicates the security measures followed to prevent the alteration, misuse and loss of information under the control of KHADIM INDIA LTD.
Online Data Security
This website takes all necessary online and offline precautions to safeguard sensitive information submitted by YOU, the user.
When you submit confidential information (like credit card details), we encrypt and protect that information with SSL (Secure Sockets Layer) technology, which is the standard Web security measure used particularly during transmission of sensitive data over the Internet. When you visit a secure page, the lock icon present at the foot of web browsers like Microsoft Internet Explorer and Netscape Navigator, gets activated as opposed to being open or unlocked at the time of just “surfing.” A protected connection between a website and your browser denotes that the data sent by you across the connection cannot be easily accessed by anyone.
Furthermore, our servers storing personally identifiable information is kept (hosted) in a safe environment, protected against breach, hacking and virus attack.
Offline Data Security
In addition to using SSL encryption to safeguard your data online, we take every measure to protect your data offline.
Information provided by you is secure in our offices; access to all personally identifiable information is granted to only those employees who require the data to perform an assigned responsibility (such as a customer service representative or a billing clerk). Also, KHADIM INDIA LTD. employees are frequently updated about our privacy and security practices, and notified and reminded regularly of their importance and the necessary steps they can take to ensure the protection of information of our customers.
For further queries regarding the security of our website, please mail us: email@example.com
This site and its contents are meant only for information purposes. Khadim India Ltd. (hereinafter referred to as Khadim’s) cannot be held accountable for any damage or loss (including consequential damage or loss), incurred or suffered, or arising directly or indirectly, owing to information provided on this site.
Though we make every effort to ensure the timeliness, accuracy and relevance of content, we do not accept responsibility for the authenticity or otherwise of any data whatsoever, published on any of the pages on the site.
Constant amendment is made to this facility in order to provide the most accurate and recent available information. Nevertheless, some information may still not be the latest. Viewers are advised to keep this in mind while browsing through published information.
YOU ARE ADVISED TO CHECK DIRECTLY WITH THE COUNCIL IN WRITING OR BY TELEPHONE TO CONFIRM THE AUTHENTICITY OF ALL INFORMATION PUBLISHED ON THIS SITE, PARTICULARLY IF ANY INFORMATION IS TO BE USED FOR LEGAL PURPOSE.
Khadim’s cannot be held accountable for any kind of correspondence, including EMAIL, sent via the Internet from or to this site. The Company is not obliged to read, reply or take any action with regard to such transmissions. If any user contacts the Company with the help of this medium, they do so at their own and not the company’s responsibility.
Nevertheless, all electronic contacts are highly valued by the Council and it will try to offer the most superior form of customer service by giving the same treatment to all other types of contact with the Council.
Copyright and Intellectual Property Rights
This site is protected by Intellectual Property Laws. Copyright 2013 covers all Material stated or contained in the domain www.khadims.com . Unless indicated otherwise explicitly, Khadim’s owns the copyright of all Material under the said domain. Every page on this site (including artwork, content and source code) is copyrighted. Except for the purposes of and subject to the terms proposed in the Copyright Act 1968 along with any other legislation applicable all over the world, or as provided for otherwise in this copyright notice, you are not permitted to reproduce, transmit, publish, store or adapt any part of any Material available on this site by any means or in any form (including recording, photocopying, microcopying, mechanical, electronic, magnetic or optical) without the copyright owner’s written permission in advance.
Enquiries are to be addressed to:
Khadim India Ltd.
5th Floor, Kankaria Estate
6, Little Russell Street
Kolkata – 700 071
Khadim’s permits you to do any of these with Material unless indicated otherwise:
- Take hard copy prints of Material for non-commercial, informational use;
- Store a copy of Material on your local computer in order to view the Material;
- Distribute or reproduce any entire page of the Material, making sure you do not distribute or reproduce less than an entire page, or where there are multiple pages in a document, less than the entire document. This copyright notice should appear entirely in any copy distributed or made, and the Material must be credited appropriately to Khadim’s.
The copyright owner(s) reserve all other rights. Khadim’s logo is safeguarded by laws that govern intellectual property. Neither you nor any other individual should use Khadim’s logo except as part of any approved replication of the Material as stated above. You are not allowed to alter or permit the alteration of Khadim’s logo in any manner.
Khadim’s does not represent or warranty that Material on other sites to which it links does not violate the intellectual property rights of any individual anywhere in the world. Khadim’s does not, and must not be assumed to approve violation of any intellectual property rights pertaining to material on other websites by establishing a link between such materials on other websites and Material.
The following Terms and Conditions are applicable for access to this website:
You agree to use the information present in the Material on this website as well as these pages at your own risk. Periodical changes are made to the Material but technical inaccuracies could be included in it. The information is given and denoted as “AS IS”, and devoid of any kind of warranty.
All warranties, implied or expressed, are disclaimed explicitly by Khadim’s. This includes but is not restricted to the suggested warranties of merchantability or accuracy or quality and fitness for a specific purpose. Khadim’s gives no guarantee to rely on the information present in the Material. No representations or guarantee are given by Khadim’s with regard to the use or the outcome of the use of the Material.
There may be frames, hypertext links or other allusions to other parties along with their internet websites contained in the site. The contents of such sites cannot be controlled by us, and thus no warranty is made about the subject matter, timeliness or accuracy of the material present on those websites. Such references endorse neither those parties nor their services or products. They also do not indicate sponsorship or approval. To the maximum limit allowed by law, Khadim’s and each of its authors disown any liability to any individual, resulting from any action or inability to act by that individual, in browsing, downloading, relying on or using any Material from this online site. Liability is restricted to either the resupply of the Material or the equitable expense of resupplying the Material. No warranty or representation is given that any files procured through or from this site are devoid of computer viruses or any other fault. Such files are given, and you can only use them, on the basis that all responsibility is assumed by the user for any damage, loss or consequence, arising from the use of those files directly or indirectly.
LABOUR COMPLIANCE DETAILS OF KHADIMS INDIA LIMITED
|SL No.||DESCRIPTION||DETAILS OF ESTABLISHMENT|
|1||NAME AND ADDRESS OF THE ESTABLISHMENT||KHADIM INDIA LIMITED, 6 Little Russell Street Kankaria Estate 5TH Floor Kolkata-700071,W.B.|
|2||WEBSITE ADDRESS OF ESTABLISHMENT||www.Khadims.com|
|3||NAME AND ADDRESS OF THE PROPREITOR/PARTNER/DIRECTOR/MANAGING||MR.SIDDHARTHA ROY BURMAN , 6 Little Russell Street 5TH Floor Kankaria Estate,Kolkata- 700071,W.B.|
|4||PHONE/MOBILE NUMBER AND EMAIL ID OF ESTABLISHMENT/PERSON INCHARGE OF CONTRACT WORK||MR. PARTHA MONDOL / 09953329717 / firstname.lastname@example.org / www.khadims.com|
|5||NAME AND ADDRESS OF THE PLACE/SITE WHERE THE CONTRACT WORKERS ARE TO BE EMPLOYED||KHADIM INDIA LIMITED , Khasra 50/6(4-16),7(4-16),8(4-16), Village Alipor New Delhi,PIN-110036|
|6||PHONE/MOBILE NUMBER/EMAIL ID OF PERSON INCHARGE OF THE SITE||MR. PARTHA MONDOL / 09953329717 /email@example.com|
|7||COPY OF POWER OF ATTORNEY/BOARD RESOLUTION AUTHORIZING TO ACT AS P.E||Click For Details|
|8||COPY OF M.O.A/A.O.A/PARTNERSHIP DEED/PROPREITORS ID PROOF||Click For Details|
|9||NATURE OF WORK FOR WHICH CONTRACT WORKMEN EMPLOYED||Loading & Unloading|
|10||FORM "V" ISSUED BY P.E TO EACH CONTRACTOR-RULE 21(2)||Click For Details|
|11||NOTICE OF COMMENCEMENT/COMPLETION OF CONTRACT WORK-RULE 81(3)||Click For Details|
|12||APPLICATION INFORM I-RULE 17(1)||Click For Details|
|13||AGREEMENT WITH EACH CONTRACTOR ALONG WITH RATE & NUMBER OF WORKERS FOR WHICH CONTRACT HAS BEEN GIVEN Click For Details||Click For Details|
|14||LETTER OF EXTENSION OF CONTRACT PERIOD ISSUED TO CONTRACTORS, IN CASE OF RENEWAL OF LICENSE||Click For Details|
|15||AFFIDAVIT BY P.E REGARDING COMPLAINS OF RULE 25(2)(V) AND THAT WAGES TO CONTRACT WORKERS ARE BEING PAID THROUGH ACCOUNT PAYEE/CHEQUES/ECS||Click For Details|
|16||NAME AND DESIGNATION OF THE PERSON AUTHORIZED UNDER RULE||MR. DARPAN BOSE , ASSISTANT MANAGER , ADMIN|
|17||CHALLAN OF REGISTRATION FEES (G.A.R.7)||.....................................................|
|18||REGISTRATION CERTIFICATE NO UNDER CLRA ACT, 1970||Click For Details|
|19||REGISTRATION NO/CERTIFICATE UNDER THE COMPANIES ACT 1956||Click For Details|
|20||REGISTRATION NO UNDER THE DELHI SHOPS & ESTABLISHMENT ACT, 1954||.....................................................|
|21||COPY OF APPLICATION FOR AMENDMENT||Click For Details|
|22||ANNUAL RETURN-RULE 82(2)||Click For Details|
|23||CONTRACTOR DETAILS||Click For Details|
vigil mechanism / whistle blower policy
Section 177 of the Companies Act, 2013, and the Rules made thereunder (‘Act’) and Regulation 4(2)(d)(iv), 22 and 46(2)(e) of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) (“Listing Regulations”) contain detailed provisions on Vigil Mechanism or Whistle Blower Mechanism which needs to be implemented in all Companies governed under the Statutes. Moreover, Khadim India Limited (‘Company’) believes in the conduct of its affairs in a fair and transparent manner by adopting and upholding highest standards of ethics, professionalism, honesty and integrity.
Through this policy, the Company shall enable all employee and / or associate to raise their complaints / concerns / grievances related to any form of misconduct, mismanagement or any kind of violation of laws, rules or regulations in the Company, in a prescribed method, without any fear of victimization and persecution. This Policy shall also ensure the confidentiality of the complainant’s identity, complaints and disclosures as well as the identity of the person against whom the complaint has been raised and investigation is being carried out by the competent authority, following the basic principles of natural justice.
Short Title, Applicability and Commencement
This Policy shall be called as “Khadim India Limited - Vigil Mechanism / Whistle Blower Policy” (‘Policy’).
This Policy shall apply to all the employees (including temporary, outsourced and contractual), stakeholders and associates of the Company.
This Policy shall come into force with effect from April 01, 2019.
“Associate” shall mean business associates of the Company including existing or proposed consultants, service providers, Lessors / Owners of Properties etc.
“Audit Committee” shall mean the Audit Committee of the Board of Directors of the Company constituted / re-constituted in accordance with Section 177 of the Companies Act, 2013.
“Board" shall mean the Board of Directors of the Company.
“Competent Authority”” shall mean the following office bearers of Khadim India Limited:
- Chief Financial Officer and, or
- VP – HR or Head - HR and, or
- Company Secretary & Head - Legal and, or
- Head – Internal Audit and, or
who shall act jointly and severally as the Competent Authority under this Policy.
“Disciplinary Action” shall mean any punitive action (more fully and particularly described in clause 10 of this Policy) that can be taken against the accused, where the Committee finds him / her guilty on completion of / during the investigation proceedings.
“Employee” shall mean every employee including temporary employee, outsourced employee and contractual employee of the Company including Whole-time Directors.
“Whistle Blower” means an Employee or Director who makes a Protected Disclosure / Complaint under this Policy.
Un-published Price Sensitive Information (“UPSI”) shall mean any information, relating to a Company or its securities, directly or indirectly, that is not generally available and which, upon becoming generally available, is likely to materially affect the price of the securities and shall, ordinarily include but not restricted to, information relating to the following:
- Periodical financial results of the Company;
- Intended declaration of dividends (Interim and Final);
- Change in capital structure i.e. Issue of securities, buy - back of securities or any forfeiture of shares or change in market lot of the Company’s shares;
- Mergers, De-mergers, Amalgamation, Acquisitions, De-listing of Securities, Scheme of Arrangement or Takeover, disposals, spin off or selling division of whole or substantially whole of the undertaking and expansion of business and such other transactions;
- Any major expansion plans or execution of new projects or any significant changes in policies, plans or operations of the Company;
- Changes in Key Managerial Personnel;
Words and expressions used and not defined herein but defined in Companies Act 2013, Securities Contracts (Regulation) Act 1956, SEBI Act, 1992, and Rules / Regulations framed therein, and the Listing Regulations shall have the meaning respectively assigned to them in those provisions.
Scope of the Policy
In line with the provisions under Regulation 22 of the Listing Regulations, this policy has been designed for directors and employees to report genuine concerns. The policy shall also provide for adequate safeguards against victimization of director(s) or employee(s) or any other person who avail the mechanism and provide for direct access to the chairperson of the audit committee in appropriate or exceptional cases.
This Policy encourages all the Whistle Blowers to report any kind of misuse of Company’s properties, mismanagement or misconduct prevailing / executed in the Company or any kind of violation of laws, rules and regulations, which the Whistle Blower in good faith, believes, evidences any of the following:
Breach of Company’s Code of Conduct.
Commission of gross misconduct and Business Ethics.
Violation of any law or regulations, policies including but not limited to corruption, bribery, theft, fraud, coercion and willful omission and negligence.
Criminal Offence having ramifications on the Company or its repute.
Rebating of Commission / benefit or conflict of interest.
Mismanagement, gross wastage or misappropriation of Company’s funds / assets.
Manipulation and / or unethical sharing of Company’s data / records.
Misappropriating cash / Company’s assets, leaking confidential or proprietary information.
Unofficial use of Company’s property (tangible and intellectual) / human assets.
Activities violating Company’s policies.
A substantial and specific danger to public health and safety.
An abuse of authority or fraud.
Leak of UPSI
Any other activity (ies) or behaviour or events, whether unethical or improper in nature, which are against the interests of the Company.
Competent Authority under the Policy
The Board shall constitute a Competent Authority under this Policy, comprising of office bearers of the Company to act, jointly and severally to receive Complaint from the Whistle Blower and conduct investigation of the disclosure made by the Whistle Blower.
- The office bearers of the Company who shall act as Competent Authority under this Policy are -
- Chief Financial Officer, and / or
- VP - HR or Head - HR, and / or
- Company Secretary & Head – Legal, and / or
- Head – Internal Audit and / or
It shall not be mandatory to have all the five office bearers who are empowered to act as the Competent Authority under this Policy, to conduct particular proceedings on consultation among each other. Any one or more office bearers can act as Competent Authority to conduct particular proceedings, depending on the seriousness of the Complaint.
- The powers and functions of the Competent Authority shall be:
- To conduct the enquiry / investigation in a fair and unbiased manner;
- To maintain confidentiality of the investigation / enquiry and the parties involved therein;
- To ensure that complete fact finding has taken place with regard to a particular investigation;
- To decide on the outcome of the investigation;
- To recommend penal provisions / disciplinary actions to the Audit Committee of the Company against the accused, if found guilty (subject to final approval by the Chairman & Managing Director);
- To recommend an appropriate course of action and / or disciplinary action against the complainant including his / her accomplices, for false or malicious Complaints / claims under this Policy;
- To receive a Complaint raised by the Whistle Blower, by accessing the email id specifically created for receiving Complaints under this Policy and no other person apart from the Competent Authority shall get access the email id, without express written consent of the Competent Authority; Competent Authority may receive the Complaint in a hand written / typed letter form or in exceptional circumstances in verbal or telephonic form.
- To appoint investigating officer(s) / agencies (internal or external), if required.
Role and Responsibility of Whistle Blower
The Whistle Blower shall report his / her Complaint / Disclosure with reliable information. The Whistle Blower shall co-operate with the Competent Authority under this Policy and extend all necessary support including production of documentary evidences to investigate the Complaints. He / she is neither required to act as investigator nor permitted to determine the appropriate or remedial action on behalf of the Company.
Malicious Whistle Blowing
Whistle Blowers who shall report Complaints which are found to be mala fide, frivolous, baseless, malicious, or reported otherwise than in good faith, the Competent Authority would reserve its right to recommend / pronounce appropriate disciplinary action.
If any Whistle Blower lodge Complaint, which is of malicious in nature, in that case the Competent Authority may bar that Whistle Blower from making Complaint under this Policy for a period the Competent Authority deems fit; Competent Authority may take / recommend appropriate disciplinary action as well.
Disclosure / Complaint
The Whistle Blower may lodge his / her Disclosure / Complaint to the Competent Authority by sending an e-mail with proper information and details to firstname.lastname@example.org or by sending a hand written / typed letter addressed to any of the office bearers who are ex-officio Competent Authority under this Policy or in exceptional circumstances by verbal or telephonic communication.
In case the Disclosure / Complaint made by a verbal or telephonic conversation, the Competent Authority may record the communication in a written or electronic / audio recording form at the earliest, to initiate next course of action.
The Whistle Blower must indicate his / her name, contact details and relationship with the Company in the Complaint. Relevant supporting documents / evidences and a brief background must form an integral part of the written Complaint.
The name and contact details of the Whistle Blower shall not be disclosed by the Competent Authority to anyone except the Chairman of the Audit Committee and / or the Chairman & Managing Director of the Company and / or to the concerned office bearers of the Company who are required to be informed in case of such incident. No unnamed Complaint shall be entertained. If the Complaint relates to a fact / incident, the Whistle Blower must lodge the Complaint within 30 days from the date he / she became aware of such fact / incident.
The Whistle Blower shall exercise caution before lodging a Complaint to ensure that he / she is not doing so under influence of any person and / or any past incidence.
All relevant Disclosures / Complaint reported under this Policy will be recorded and duly investigated. The Competent Authority may at its sole discretion consider the involvement of any other investigator.
If Disclosures / Complaint is made against any of the office bearer who is an ex - officio Competent Authority, such office bearer will be barred to act as Competent Authority in the said proceedings / investigation and shall extend co-operation to the Competent Authority if sought for in such proceedings.
After completion of investigation process, if it is found that an improper / unethical act has been committed, the Competent Authority shall place their findings / recommendations to the Audit Committee of the Company to take such disciplinary / corrective actions as it may deems fit in consultations with the Chairman & Managing Director of the Company.
The Company may take the following punitive actions against the accused, where the Committee finds him / her guilty:
Issue of an official reprimand cum warning letter;
Bar from participating in performance bonus review;
Cessation in increment of remuneration for a particular period as the Competent Authority deems fit;
Termination from employment;
Cancellation of Orders placed as per Purchase / Work Order;
Recovery of monetary loss suffered by the Company;
Legal Suit or / and appropriate legal recourse under civil and criminal laws of the land;
Any other punitive action which the Competent Authority shall deem fit, provided it shall be proportionate to the offence committed by the accused;
During the period of investigation or even after completion of the investigation, the identity of the Whistle Blower and the accused should be confidential. Any disclosure of identity of the accused shall be only to the extent it is necessary considering the progress of investigation process and the legitimate needs of law.
There will not be any retaliation or victimization against the Whistle Blower for disclosing in good faith any genuine concerns or grievances concerning unethical and improper practice or wrongful conduct prevailing in the Company, provided there is no Malice reporting
The Head – Internal Audit shall submit an yearly report to the Audit Committee informing the status of all Complaints received from the Whistle Blowers, Complaints resolved and action taken, Complaints under investigation and number of false Complaints lodged by Whistle Blowers.
The Head of Internal Audit of the Company (ex-officio Competent Authority under this Policy) may also submit his observations on quarterly basis on the proceedings under this Policy before the Audit Committee of the Company.
The complaint may be sent directly to the Chairman of the Audit Committee, as per the details given hereunder:-
Name: Indra Nath Chatterjee
Address: Kankaria Estate, 5th Floor,
6, Little Russell Street,Kolkata- 700071
Any subsequent modification/amendment to the provisions of the Act / Regulations shall automatically apply to this Policy.
Kankaria Estate, 5th Floor, 6, Little Russell Street, Kolkata – 700 071, West Bengal, INDIA
For queries and grievances contact: