Objective

1. The company is committed to adhere to the highest standard of ethical, moral and legal conduct of business operations. To maintain these standards, the company encourages disclosures by its stakeholders who have concerned about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. This policy aims to provide an avenue for stakeholders to raise concerns about violation of law, un ethical practices of gross misconduct by the employees of the company that can lead to financial loss or reputational risk to the organization.

2. The policy does not aim to address issues related to dissatisfaction with appraisal and rewards, company policies, complaints regarding service conditions, improvement suggestions and gender harassment as there are separate prescribed them.

Scope

The policy is applicable to ManiBhavnam Home Finance India Pvt ltd.

=> Permanent and contractual employees of the company

=> Employees of other agencies deployed for the company

=> Contractors, Vendors, Suppliers or Agencies (or any of their employees)

=> Customers of the company

=> Any other person having an association with the company

Guidelines

1. How should a disclosure be made and to whom?
A disclosure should be made in writing through physical letter and e- Mail to ombudsperson as per the given details

Email id:- [email protected]
Email Addressed to Indranath Bose Head of Product, policy & Risk

Mailing Address: N-2, 2^nd Floor South Ext Part 1, New Delhi 110049

2. Is there any specific format for submitting the disclosure?
While there is no specific format for submitting a disclosure, the following details must be mentioned: –

a) Name, Address and contact details of the whistle blower (add employee ID if the whistle-blower an employee)

Anonymous allegation: – Whistle-blower must put their names to allegation as follow up questions and investigations may not be possible unless the source of the information is identified. Disclosures expressed anonymously will ordinarily not be investigated.

b) Brief description of malpractice giving the name of those alleged to have committed or about to commit a malpractice. specific details such as time and place of occurrence are also important.

c) Whistle-blower can request for anonymity and in that case identity of whistle-blower be kept confidential to the extent possible given the legitimate needs of law and the investigation.

3. What will happen after the disclosure is submitted?
a) The ombudsperson shall acknowledge receipt if the disclosure as soon as practical (preferably within 07 days of receipt of a disclosure), where the whistle-blower has provided his/her contact details.

b) The ombudsperson will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the disclosure constitute a mal practice. If the ombudsperson determines that the allegations do not constitute a malpractice, it will record this finding with reasons and communicate the same to the whistle blower.

c) If the Ombudsperson determines that allegations constitute a malpractice; Investigation will be initiated and refer to investigating committee ,if required.

Depending on the disclosure, Ombudsperson may also investigate on its own of delegate as per his/her discretion. If the alleged Malpractice is required by law to be dealt any other mechanism, the Ombudsperson shall refer the disclosure to the appropriate authority under such mandate mechanism and seek a report on the findings from such authority.

d) Whilst it may be difficult for the Ombudsperson to keep the whistle-blower regularly updated on the progress of the investigations, it will keep the whistle blower informed of the result investigations and its recommendations subject to any obligations of confidentially.

e) The Ombudsperson and its discretion may decide not to disclose the name of the whistle blower to investigating committee members in case of sensitive matters.

4. Protection to the whistle blower
If one submits a disclosure under this policy, he/she will not be at risk of suffering any form of reprisal or retaliation. Retaliation includes discrimination, reprisal, harassment or vengeance in any manner. Company’s employee will not be at the risk of losing her/his job or suffer in any other manner like transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the whistle-blower’s right to continue to perform his/her duties/ functions including making further disclosure, as a result of reporting under this policy. The protection is available provided that:

a) The communication/disclosure is made in good faith

b) He/she reasonably believes that information, and any allegation contained in it, are substantially true; and

c) He/she is not acting for personal gain.

Anyone who abuse the procedure (for example by maliciously raising a concern knowing it to be untrue) will be subject to disciplinary action, as will anyone who victimize a colleague by raising a concern through this procedure. If considered appropriate or necessary, suitable legal actions may also be taken against such individuals.

However, no action will take against anyone who makes an allegation in good faith, reasonably believing it to be true, even if the allegation is not subsequently confirmed by the investigation.

Any other employee/ business associate assisting in the said investigation shall also be protected to the same extent as the Whistle-blower. However, a disciplinary action against the Whistle- blower which occurs on account of poor job performance or misconduct by the whistle-blower and which is independent of any disclosure made by the whistle blower, shall not be protected under this policy.

Investigation

=> All the disclosures will be investigated by ombudsperson or committee as decided by him/her

=> In case investigation process leads to another investigation which has not been reported by the whistle-blower, the ombudsperson may expand the scope and timeline to take final decision after final report is submitted.

=> If allegations are against a team member of any of the committee members or in case of conflict of interest in a given case, the members should recuse themselves and the others on the committee would deal with the matter on hand.

Decision

If the investigation leads the ombudsperson to conclude that an improper or un ethical act has been committed, the Ombudsperson will be recommended the disciplinary or corrective action to be taken against the subject to the CEO

Reporting

ManiBhavnam Home Finance India Pvt ltd audit committee will be kept informed about all whistleblowing disclosures & progress in terms of investigation and outcome.

Any investigation beyond 90 days of initial whistle blowing disclosure will be separately presented to ManiBhavnam Home Finance India Pvt Ltd. Audit Committee with reasons.

Company Investigating Committee

Document Retention

All documents related to reporting, investigation and enforcement pursuant to this policy shall be kept in accordance with the company’s record retention policy and applicable law.

Amendment

The company reserves its right to amend or modify this policy in whole or in part, at any time without assigning any reason whatsoever. MBHF audit committee will review, monitor and may amend this policy from time to time.