FAQs
Why whistle-blower mechanism is important to us?
India Nippon Electricals Limited and its related entities (‘the Company’) are committed towards conducting its business with highest standards of ethics, honesty, integrity and ethical behaviour. As per the section 177 of the Companies Act 2013, it is mandatory for every listed company to have a whistle-blower mechanism. Though it is not mandatory to engage a third party to receive, examine and report on complaints, we have decided to appoint a dedicated Ethics Helpline, as a best practice.
What is the role of Ethics Helpline managed by KPMG?
Ethics Helpline is an independent, secure and confidential reporting platform to report any unethical conduct. Ethics Helpline will attend to your complaints and will prepare a report based on the information provided by you and will share the incident report with the Ethics Committee in 2 (two) business days. In case any member of the Ethics Committee is found to have perceived conflict of interest, the Ethics Helpline will share the incident report with Chairman of the Audit Committee both physically and electronically at the following address and email ID.
Address:
Mr. K G Raghavan (the present Chairman of the Audit Committee) Srivatsa’ No.51, Kumarakrupa I Cross, Madhavanagar, Bengaluru, Karnataka - 560001
Email ID - chmnac@inel.co.in
What is Ethics Committee?
Ethics Committee means a committee comprising of senior members of the Company to manage the whistle-blower mechanism and to receive complaints from the Ethics Helpline.
What is Audit Committee?
Audit Committee means the Audit & Risk Management Committee of the Company in accordance with Section 177 of the Companies Act 2013 and read with Regulation 22 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
What type of potential incidents can be reported on the Ethics Helpline?
Any allegation which falls under the scope identified below but not limited to, can be reported to the Ethics Helpline:
1. Acceptance of kickbacks
2. Bribery and/or corruption
3. Child labor
4. Claiming of false reimbursement expenses
5. Concurrent employment
6. Conflict of interest
7. Discrimination, victimization or bullying
8. Financial fraud of any nature
9. Harassment of any nature other than Sexual Harassment
10. Inappropriate use of social media
11. Insider trading
12. Leak/suspected leak of Unpublished Price Sensitive Information
13. Misappropriation of Company assets/ resources
14. Misrepresentation of Company’s financial books and records
15. Misuse of authority
16. Sexual harassment
17. Unauthorized use of Company confidential/ proprietary information
18. Unfair trade practices and/ or anti-competitive behavior
19. Violation of any laws or regulations applicable to the Company
20. Violation of human rights
21. Violation of the environment, health and safety guidelines.
22. Violation of Company's Code of Conduct & Business Ethics, Code on Prevention of Insider Trading, Code on Fair Disclosure and other Statutory & internal Policies.
Can I also report directly to the Chairman of Audit Committee?
Yes, in case of serious issues of financial statement misrepresentation, fraud or violations of serious nature that would entail severe penalty or imprisonment to the Company and/or the directors, you may directly make the Protected Disclosure to the Chairman of the Audit Committee, who shall then deal with such Protected Disclosure in a manner as the Chairman of Audit Committee deems appropriate (as detailed in Section 2 of the FAQ).
What is a Protected Disclosure?
Protected Disclosure means a genuine concern that discloses or demonstrates information that may evidence any misconduct or malpractice or other unethical activity. Unethical activity means any unethical behavior or activity that includes, actual or suspected fraud, violation of the Company policies and systems, adversely affects Company’s reputation or brand image, violation of applicable laws, gross or willful negligence causing substantial and specific danger to health, safety and environment in the Company, accounting or financial misreporting, bribery, graft and insider trading, etc.
Is it mandatory to disclose the identity while reporting a Protected Disclosure?
Employees and directors can choose to remain anonymous while reporting the Protected Disclosure and the Company will not make any attempt to discover the identity of the whistle-blower. It would be mandatory for the third-parties to disclose their identity and Protected Disclosure pertaining to sexual harassment without written and self-attested complaint.
What are the disqualifications of Protected Disclosure?
Ethics Committee shall not investigate the Protected Disclosures which would fall under the following categories:
1. Protected Disclosures related to issues which are not covered under the whistle-blower policy (as detailed in Section 5 of the FAQ).
2. Anonymous reporting of Protected Disclosure by third-party or issues related to sexual harassment without written and self-attested Complaint.
3. If the Protected Disclosure does not carry following minimum information:
a. Name, designation and location of the subject(s) involved
b. Detailed description of the incident
c. Location and time or duration of incident
d. Specific evidence or source of evidence
If I don’t feel comfortable making my secure report from my office computer, what are my other options?
We uses the latest encryption and authentication technology, ensuring that your communications on our web site are secure and private. The ‘https’ keyword in the location bar when submitting information ensures that the connection is encrypted.