Vigil Mechanism Policy
Hero Realty Private Limited (hereafter referred to as “HRPL” or “Company” in this document) believes in promoting a fair, transparent, ethical and professional work environment. While the HRPL code of conduct defines the expectations from employees in terms of their integrity and professional conduct, the vigil mechanism defines the mechanism for reporting deviations from the standards defined in the code.
The Vigil mechanism is implemented not only as a safeguard to unethical practices. This mechanism is intended to provide mechanism for reporting genuine concerns or grievance and ensure that deviations from the Company’s Business Conduct Manual and Values are dealt with in a fair and unbiased manner as provided in Section 177 (9) and (10) of the Companies Act, 2013 and the Companies Rules, 2014. The mechanism is also intended to cover the Whistleblower Mechanism aspect.
Definitions of some of the key terms used in this mechanism are given below:
To ensure effective implementation of vigil mechanism, the company shall:
All employees, directors, vendors, suppliers, contractors and consultants, including auditors and advocates who are associated with HRPL can raise concerns regarding malpractices and events which may negatively impact the company.
All matters not covered under this mechanism can be reported directly to your one over manager or your Human Resources contact.
The whistleblowers are expected to speak up and bring forward the concerns or complaints about issues listed under Section IV “Coverage of the vigil mechanism”. The Ethics Helpline is established for this purpose and the reporting channels which can be made available to the whistleblower are covered in Appendix A.
The reporting channels are managed by an independent third party. Complainants will be provided a reference number for their complaint that can be used to provide any additional information or seek feedback or updates on actions taken by the company.
The Ethics Helpline will prepare the report based on the information provided by the whistleblower and will share the incident report with the Ethics Committee in next 2 business days. In case any member of the Ethics Committee is the subject of the complaint or have perceived conflict of interest, the incident report would be sent to the remaining members of the Ethics Committee.
Any member of the Ethics Committee, or any Board Committee formed to investigate any complaint who may have a perceived conflict will recuse themselves from further discussions or meetings on the subject.
Complainants may also directly report concerns to any of the Ethics Committee members as stated under this policy.
Directors may report their concerns or complaints to Audit Committee directly. In addition, under exceptional circumstances where a complainant wants to complain directly to the Chairman of the Audit Committee, he or she may do so at the email address provided on Appendix A to this document. For any complaints made to the Chairman directly, it is mandatory for the complainant to disclose their identity and provide their contact information. The Chairman of the Audit Committee may choose to discuss the matter with the complainant prior to initiating any review or investigation.
HRPL expects individuals involved in the review or investigation to maintain complete confidentiality. Disciplinary action may be initiated against anyone found not complying with the below:
The Company holds the right to amend or modify the policy. Any amendment or modification of the policy would be done by an appropriate authority as mandated in law. The updated Vigil mechanism would be shared with the employees, suppliers and vendors thereafter.
|S. No.||Reporting Channel||Contact Information||Availability|
|1.||Phone||011-47467000||7 AM to 11 PM on weekdays|
|2.||Info.firstname.lastname@example.org||24 hours a day|
|1.||Fax||011-47467070||24 hours a day|
|4.||Post||264, Okhla Industrial Estate, Phase-III, New Delhi-110020||24 hours a day|
The current Ethics Committee of Hero Realty Private Limited described in the Ethics committee company’s section of the Vigil mechanism would be as follows: The incident reports will be shared with: