Whistle Blower Policy

BACKGROUND

Section 177(9) of the Companies Act, 2013 requires every company to establish a vigil mechanism. Accordingly, Sun Direct TV Private Limited (hereinafter referred to as “the Company”), which believes in highest ethical behavior, transparency,professionalism and accurate compliance with all laws, formulates the ‘Whistle Blower Policy’ to enable Directors and Employees to report concerns about unethical behavior, actual or suspected fraud or violation of the Company’s code of conduct.

THE POLICY

• This policy shall be applicable to all Permanent Employees and Directors of the Company.
• A permanent employee or a Director of the Company (hereinafter referred to as Complainant or Whistle Blower) can make a complaint on any of the following incidents;
  • Any serious actual or suspected frauds
  • Illegal or unethical conduct
  • Actual or suspected violation of any law or regulation or code of conduct
  • Dissemination of confidential or proprietary information of the Company.
• The Whistle Blower has to demonstrate or provide sufficient grounds for his /her concern but should not make any malicious allegations which would result in disciplinary action.
• This policy must not be used as a tool for raising malicious or unfounded allegations against people in authority and /or colleagues in general.
• The Vigil Mechanism Committee (hereinafter referred to, as “Committee” of the Company shall be responsible for effectively implementing and overseeing this policy.
• The members of the Committee are Mr. RMR Ramesh, Director, Mr. Mohamed Israth, Director and Mr. Y. Anil Kumar, Director.
• The Whistle Blower should submit the complaint on matters referred to above to Mr. RMR Ramesh, Director rmr@sundirect.in.
• The Complaint shall be in writing and must include detailed information about the suspected violation. Anonymous complaint will not be entertained.
• The Whistle Blower shall raise the issue within a reasonable time but not later than two months.
• If the Complaint is not genuine, the Committee shall summarily reject it.
• After the scrutiny, the Committee will investigate all complaints promptly. Based on a through examination of the findings, the Committee shall submit the Report to the Chairman of the Committee.
• The Committee will submit its report to the Board on periodical basis brief summary of Complaints received and status of the Complaints.
• All employees have a duty to cooperate in the investigation.
• At the conclusion of the said investigation, if the Company determines that a violation has occurred, the Company will take effective remedial action commensurate with the nature of the offense. Reasonable and necessary steps will also be taken to prevent any further violations to safeguard the business interests of the Company.
• No adverse action shall be taken or recommended against a Whistle Blower in retaliation to his blowing the whistle.
• Source of information to the Whistle Blower shall be disclosed to facilitate investigation.
• Every effort will be made to keep confidential of the Whistle Blower’s identity subject to any legal constraints that may arise from time to time.