S-ILF’s Whistle Blower Policy

The Foundation believes in the conduct of its constituents in a fair and transparent manner by adopting the highest standards of professionalism, honesty, integrity and ethical behaviour.

The Foundation is committed to developing a culture where it is safe for all employees to raise concerns about any poor or unacceptable practise and any event of misconduct.

The Guiding Principles:

  • Ensure that the Whistle Blower and/or the person processing the Protected Disclosure is not victimized for doing so;
  • Treat victimization as a serious matter including initiating disciplinary action on such person/(s);
  • Ensure complete confidentiality.
  • Take disciplinary action, if any one destroys or conceals evidence of the protected disclosure made/to be made;
  • Provide an opportunity of being heard to the persons involved especially to the subject.

Process for raising concern:

  • Employees can make a protected disclosure to Chief Executive Officer, as soon as possible but not later than 30 consecutive days after becoming aware of the same.
  • Whistle Blower must put his/her name to allegations. Concerns expressed anonymously WILL NOT BE investigated.
  • Where initial inquiries indicate that further investigation is necessary, this will be carried through either by the Chief Executive Officer alone or Whistle Blower. The investigation would be conducted in a fair manner, as a neutral fact-finding process and without a presumption of guilt. A written report of the findings would be made.
  • The Whistle Blower shall finalize and submit the report to the Management within 15 days of being nominated/appointed unless more time is required under exceptional circumstances.
  • On submission of the report, the Whistle Blower shall discuss the matter with Management.

Reporting:

A quarterly report with the number of complaints received under the Policy and their outcome shall be placed before the Management Board.

Coverage of Policy:

The Policy covers malpractices and events which have taken place/ suspected to take place involving:

  1. Abuse of authority/Power Harassment
  2. Breach of contract
  3. Manipulation of Foundation data/records
  4. Financial irregularities, including fraud, or suspected fraud
  5. Criminal offense
  6. Perforation of confidential/propriety information
  7. Deliberate violation of law/regulation
  8. Wastage/misappropriation of Foundation funds/assets
  9. Breach of employee Code of Conduct/Ethics Policy or Rules
  10. Any other unethical, biased, favoured, imprudent event

Protection:

The Foundation, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practise being adopted against Whistle Blower. Complete protection will, therefore, be given to Whistle Blower against any unfair practice like retaliation, threat or intimidation of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, discrimination, any type of harassment, biased behaviour or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his duties/functions including making further Protected Disclosure.