Section 37.04 Anonymous Tip-offs
Where an employee is apprehensive about providing his/her name, despite the strictly confidential treatment of such information, tip-offs – especially regarding gross violations and possible criminal activity shall be filed anonymously.
Section 37.05 Tip-offs regarding Accounting and Auditing
Audit Committee shall be responsible to deal with hints that only have to do with accounting and auditing. Tip-offs shall be sent to the following mailing address:
Via mail:
Via email form:
Via telephone:
Via Fax:
Section 37.06 Treatment of Complaints
1. Upon receipt of a concern or complaint, COO shall (i) determine the nature of the concern or complaint (ii) acknowledge receipt of the concern or complaint to the submitter within ten (10) working days, when such complaint has been lodged on a confidential basis and (iii) shall act accordingly i.e if the concern or complaint actually pertains to Accounting Matters shall refer the matter to Audit Committee and all other concerns or complaints shall be referred to the Senior Management Committee.
2. Initial inquiries shall be made to determine whether an investigation is appropriate, and the form that it shall take. Some concerns may be resolved by agreed action without the need for investigation.
3. The Audit Committee may enlist employees of the Organization and/or outside legal, accounting or other advisors, as the Audit Committee determines to be appropriate, to conduct any investigation of complaints relating to Accounting Matters.
4. The amount of contact between the complainant and the team conducting the investigation shall depend on the nature of the issue and the clarity of information provided. Further information may be sought from the complainant.
5. In conducting any investigation, the Audit Committee/ Senior Management Committee shall use reasonable efforts to protect the confidentiality or anonymity of the complainant, consistent with the need to conduct an adequate review.
6. Prompt and appropriate corrective action shall be taken as warranted in the judgment of the Audit Committee/ Senior Management Committee.
7. When possible and when determined appropriate by the Audit Committee/ Senior Management Committee, notice of any corrective action taken will be reported back to the person who submitted the concern or complaint, if return email or other address is provided by the complainant.
8. Subject to legal constraints, the complainant may also receive information regarding the outcome of the investigation.
Section 37.07 Reporting and Retention of Complaints and Investigation
The COO shall maintain a log of all reported concerns or complaints, tracking their receipt, their investigation, and their resolution and shall prepare a periodic summary report thereof for the Board of Directors.
The COO shall retain, as a part of its records, any such complaints or concerns in the Personal File of an employee.
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