ICICI Home Finance Company Ltd (’the Company’) is committed to adopting the highest business, governance, ethical and legal standards. To aid in achieving this objective, the Company has formulated several policies and guidelines that assist its employees in maintaining these high standards. The Company also employs several modes of checks and balances to ensure adherence to its policies.
The purpose of the Whistle Blower Policy (’the Policy’) is to encourage employees to report matters without the risk of subsequent victimisation, discrimination or disadvantage. The Policy applies to all employees working for the Company.
A whistle blowing or reporting mechanism set out in the Policy, invites all employees to act responsibly to uphold the reputation of the Company. The Policy aims to provide a mechanism to ensure that concerns are properly raised, appropriately investigated and addressed. The Company recognises this mechanism as an important enabling factor in administering good governance practices. .
The Policy complies with the requirements of the vigil mechanism as envisaged by the Companies Act, 2013 and the rules framed thereunder.
Nothing in this policy is intended to limit any protections provided to Whistle Blowers by any applicable laws or regulations, or to place any limits on a Whistle Blower’s ability to communicate with government, administrative or law enforcement authorities as provided for by law.
Audit and Risk Management Committee (’the Committee’) constituted by the Board of Directors of the Company.
An employee is every bona fide employee currently in the employment of the Company. For the purpose of this policy, employee includes directors of the ICICI Home Finance Company Ltd
Retaliation is any act, direct or indirect, recommended, threatened or taken against a whistle blower by any person because the whistle blower has made a disclosure pursuant to the Policy. Retaliation includes overt/covert acts of discrimination, reprisal, harassment, vengeance.
A whistle blower means any employee/individual who raises a concern in accordance with this Policy.
Whistle blowing (also referred to as 'complaint' or 'concern') can be described as attracting management's attention to information about potentially illegal and/or unacceptable practices.
Employees can raise concerns/issues, if any, which they have on the following or possibilities/apprehensions of:
· Breach of any law, statute or regulation by the Company
· Issues related to accounting policies and procedures adopted for any area or item
· Acts resulting in financial loss or loss of reputation
· Misuse of office, suspected/actual fraud and criminal offenses
To be considered under the Policy, the complainant (i.e. employee or director making the complaint) is encouraged to provide the following information in his/her complaint: name, contact details, employee number and department. Other than complaints relating to concerns regarding questionable accounting or auditing matters, misuse of office, suspected/actual fraud and criminal offences. The Company shall not entertain any complaint where all such information is not provided, including anonymous/pseudonymous complaints, no further action will be required to be taken and the case will be closed without intimation to the complainant.
Notwithstanding the foregoing, the Head-Internal Audit may decide, in his/her discretion, that anonymous/pseudonymous complaints be considered under the Policy, even when such complaints do not relate to concerns regarding questionable accounting or auditing matters, misuse of office, suspected/actual fraud and criminal offences.
An official designated as Head of Internal Audit of the Company.
Records pertaining to the complaint shall be maintained by the Internal Audit Department. Records shall be maintained as per the existing Record Retention Policy of the Company.
Head –Internal Audit shall lay down an appropriate mechanism to communicate the policy periodically to the employees and for its suitable display on the Company’s website etc.