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Hindustan Antibiotics Limited (A Govt. of India Enterprise)
Pimpri , Pune - 411018
Under the Ministry of Chemicals and Fertilizers
CIN No. U24231MH1954PLC009265

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Whistle Blower Policy

POLICY VIGIL MECHANISM / WHISTLE BLOWER POLICY

OBJECTIVE:
To provide employees, suppliers, lenders, service provider and other stakeholders an avenue to raise Complaints, in line with the commitment of Hindustan Antibiotics Limited (HAL) to the highest possible standards of ethical, moral and legal business conduct and its commitment to open communication.

To provide necessary safeguards for the protection of employees from reprisals or victimization, for Whistle Blower in good faith.

SCOPE:
Vigil Mechanism / Whistle Blower Policy shall be applicable only to the employees of HAL.

COVERAGE:
For all matters connected with the business of HAL.

MAIN FEATURES:
The Vigil Mechanism / Whistle Blower Policy is intended to cover serious complaints about actions employee that
could have a large impact on HAL such as : –

• The incidence of unethical behavior towards internal or external stakeholders;
• Actual or suspected fraud, embezzlement, etc;
• Violation of Company’s General guidelines on Conduct;
• Moral turpitude;
• Unlawful conduct.

Complainant (Whistleblower):
An employee of HAL making a disclosure under this policy is commonly referred to as Complainant(Whistleblower). The Complainant’s role is of a reporting party, he /she is not an investigator. Although the complainant is not
expected to provide the proof of the veracity of his allegation, he needs to demonstrate that there are sufficient grounds for complaint.

Safeguards (Harassment or Victimization):
Harassment or Victimization of the Complainant by any employee of the Company will not be tolerated and could constitute sufficient grounds for serious action under Conduct, Discipline and Appeal Rules (CDA) of the Company against such errant employee.

Confidentiality: Every effort will be made within parameters of legal constraints to protect the Complainant’s
identity.

Anonymous Allegations: Complainants must put their names to allegations as follow-up questions and investigation may not be possible unless the source of the information is identified. Complaints expressed anonymously will not be investigated under this policy.

Malicious Allegations: Malicious allegations by the Complainant may result in disciplinary action.

Reporting:
The Complaints may be addressed to the Managing Director of the Company and the exceptional case to the Chairman of the Audit Committee. MD or the Chairman of the Audit Committee shall discuss responsibility of
keeping the identity of the Complainant secret.

The complaint shall be in a sealed envelope which shall be contained in another sealed envelope. It should be addressed to MD or the Chairman of the Audit Committee and shall be superscribed “Complaint under Whistle Blower Policy.”

Investigation:
All Complainants received will be recorded and looked into. If initial enquiries by the Management indicate that the complaint has no basis, or it is not a matter to be pursued under this policy, it may be dismissed at this stage and the decision documented.

Where initial enquiries indicate that further investigation is necessary, this will be carried out under directive either of the Managing Director or the Chairman of the Audit Committee himself, in the manner deemed fit. If required, a Committee may be formed for the purpose. The investigation would be conducted in a fair manner, as a neutral fact-finding process and without the presumption of guilt. A written report of the findings would be made.

Investigation result: Based on thorough examination of the findings of the enquiry conducted, or on the basis of findings of the Committee, the Managing Director or the Chairman of the Audit Committee, would initiate appropriate action. Preventive measures would be taken to prevent re-occurrence of the incident.

Investigation Subject: The investigation subject is the person/group of persons who are the focus of the enquiry/ investigation. Their identity would be kept confidential to the extent possible.

Reporting to Board: Such cases would be periodically reported to the Board of Directors of the Company (HAL).

Communication with Complainant: There will not be any communication with the Complainant.

The amount of contact between the Complainant and the investigators of the complaint will depend on the nature of the issue and the clarity of the information provided. Further information may be sought from him/her, if required.

ACCOUNTABILITIES:

1. While bringing to the attention of the Company, any improper practice they become aware of, the complaint must indicate the sufficient cause for the complaint. The complaint should not be based on conjecture or hearsay.

2. Avoid anonymity when making a complaint.

3. Co-operate with investigating authorities, maintaining full confidentiality, is expected.

4. The intent of the policy is to bring genuine and series issues to the fore and it is not intended for frivolous and malicious complaints. Malicious allegations by employees may attract disciplinary action.

5. A Complainant has the right to protection from retaliation. But this does not extend to immunity for complicity in the matters that are the subject of other allegations and investigations.

6. In exceptional cases, where the Complainant is not satisfied with the outcome of the investigation carried out by the Managing Director or the Committee nominated by him, she/he can make a direct appeal to the Chairman of the Audit Committee of HAL.