1.1 To provide a framework to promote responsible and secure whistle blowing. It protects the Whistle Blower wishing to raise a concern about irregularities within the Company
1.2. Protecting the integrity and reputation of the Way2News requires the active support of all members of the organization, who are required to report incidents of suspected fraud, corruption, collusion and coercion, and other serious infringement of the rules or the policies in force at the firm. Members of staff are also required to cooperate in investigations into such incidents
1.3. The Company is committed to develop a culture where it is safe for all Whistle Blowers to raise concerns about any poor or unacceptable practice and in any event of misconduct
1.4. The policy neither releases Whistle Blowers from their duty of confidentiality in the course of their work, nor is it a route for taking up a grievance about a personal situation
2.1. The policy applies to questionable acts that affect customers, company, or employees, including, but not limited to
2.1.1. Breach of Business Practices and Company's Code of Conduct
2.1.2. Non-Compliance with the Company's internal or external regulations by any employee
2.1.3. Corruption, including bribery and money laundering
2.1.4. Fraudulent practices, such as improperly tampering with books and records of the company, and theft of the property of the company
2.1.5. Manipulation of Company's data, record, or pilferage of confidential information
2.1.6. Any other unethical practices or events
3.1. This Policy is applicable to all employees and includes third parties i.e. contributors, reporters, contractors and consultants, of the Company.
3.2. The Policy has been drawn up so that Whistle Blowers are eligible to make Protected Disclosure.
4.1. Whistle Blower means an employee of the company who makes a Protected Disclosure under this Policy
4.2. Subject means a person against whom or in relation to whom, a protected disclosure is made or evidence gathered during the course of an investigation
4.3. Disciplinary Action means any action that can be taken on the completion of or during the investigation proceedings as stated in the Disciplinary Action Policy
4.4. Protected Disclosure means a concern raised by a written letter/email made in good faith
5. All Protected Disclosures should be addressed to whistleblower@way2news.com. This email address shall be accessed by Company Secretary.
All complaints shall be forwarded to whistleblower@way2news.com
6.1. Whistle Blower can make Protected Disclosure as soon as possible but not later than 30 calendar days after becoming aware or suspect of any fraud or any event of misconduct, irregularities etc, unless there are valid reasons for reporting the matter after the period of 30 calendar days.
6.2. Whistle Blower shall put his/her name, contact number in the complaint. In case the identity of the Whistle Blower cannot be ascertained, the complaint will be treated as anonymous/ pseudonymous.
6.3. Only if the anonymous/ pseudonymous complaint contains verifiable and specific information about misconduct or breach, then that case will be put up for further action
6.4. The Protected Disclosures should be made in writing to ensure a clear understanding of the issues raised
7.1. The Company Secretary shall, on receipt of the complaint, with approval of the COO, arrange for investigation into the matter and ensure that the investigation would be conducted in a fair manner, without any bias
7.2. Investigations will be launched only after a preliminary review, which establishes that:
7.2.1. The alleged act constitutes an improper or unethical activity or conduct,
7.2.2. Allegation is supported by information specific enough to be investigated
7.3. The case may be referred to any internal investigating team or external investigation agency for the purpose of investigation. Necessary care has to be ensured that:
7.3.1. Protected disclosure are shared with investigating team/agency strictly on need to know basis only
7.3.2. Identity of the Whistle Blower is not disclosed/shared
7.4. Investigators shall have timely and unrestricted access to any information/records required for investigation, fact-finding and analysis
7.5. The Company Secretary shall prepare a written report of the findings and outcomes of investigation. The report shall be submitted to the COO.
7.6. If an investigation leads to conclude that an improper or unethical act has been committed, the case shall be referred to the HR head for Disciplinary action.
7.7. The whistle-blower's role is that of a reporting party with reliable information. They are not required or expected to determine the appropriate corrective or remedial action that maybe warranted in a given case
7.8. The Company Secretary shall maintain a record of all Protected Disclosures.
8.1. The identity of the Whistle Blower, who makes the complaint in good faith, will be protected and shall be kept confidential, except as otherwise required by law and to the extent possible while allowing investigation to proceed. In order to enable the Company to maintain the confidentiality/identity of the Whistle Blower, the Whistle Blower should use his/her best endeavors to make the complaint to the Company Secretary only.
8.2. A Whistle Blower may make a Protected Disclosure without fear of retaliation or intimidation. The company prohibits its Employees from engaging in retaliation or intimidation that is directed against a Whistle Blower. Employees who engage in retaliation or intimidation in violation of this Policy will be subject to disciplinary action
8.3. Complete protection will be given to Whistle Blower against any service, disciplinary action, transfer, demotion, refusal of promotion, discrimination, any type of harassment etc.
8.4. Any other employee assisting in the said investigation or furnishing evidence shall also be protected to the same extent as the Whistle Blower
8.5. The Whistle Blower, the Subject and everyone involved in the process shall:
8.5.1. Maintain complete confidentiality/ secrecy of the matter
8.5.2. Not discuss the matter in any informal/ social gatherings/ meetings
8.5.3. Discuss only to the extent or with the persons required for the purpose of completing the process and investigations
8.6. If anyone is found not complying with the above, he/she shall be held liable for such disciplinary action as deemed fit
8.7. Whistle-blowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested
8.8. All reports and records associated with "disclosures" are considered confidential information and access will be restricted to Legal and Human Resources.
9.1. Any employee implicated by reports of irregularities must be notified in good time of the allegations made against them, provided that this notification does not impede the progress of the procedure for establishing the circumstances of the case
9.2. In any event, findings referring to employee specifically by name may not be made upon the completion of the above-mentioned procedure
9.3. After having heard the implicated employee, or after having requested the latter to put his/ her case in writing if, for objective reasons, it is not possible to hear him/ her directly, the HOD- HR, Company Secretary and COO shall decide on remedial actions to be taken
9.4. Since the reporting of irregularities and/or the ensuing procedure will involve dealing with personal data, such data shall be managed in keeping with the principles and rules provided for in the regulations applicable to the Company
The Company reserves the right to amend or rescind, in whole or part, this policy at any time and without notice.