Whistle Blower Policy

  • Background

    Section 177 (9) of the Companies Act, 2013 and Clause 49 of the Listing Agreement requires every company to establish a vigil mechanism. Accordingly, Sun TV Network Limited (the Company), which believes in highest ethical behavior, transparency, professionalism and accurate compliance with all laws, formulates the ‘Whistle Blower Policy’ to enable Directors and Employees to report concerns about unethical behaviour, actual or suspected fraud or violation of the Company’s code of conduct.

    The Policy

    1. This policy shall be applicable to all permanent employees and directors of the Company.

    2. A permanent employee or a Director of the Company (hereinafter referred to as Complainant or Whistle Blower) can make a complaint on any of the following incidents;

    a) Any serious actual or suspected frauds

    b) Illegal or unethical conduct

    c) Actual or suspected violation of any law or regulation or code of conduct

    d) Dissemination of confidential or proprietary information of the Company.

    3. The Whistle Blower has to demonstrate or provide sufficient grounds for his /her concern but should not make any malicious allegations which would result in disciplinary action.

    4. This policy must not be used as a tool for raising malicious or unfounded allegations against people in authority and /or colleagues in general.

    5. The Audit Committee of the Company shall be responsible for effectively implementing and overseeing this policy.

    6. The Whistle Blower should submit the complaint on matters referred to above to the Managing Director.

    7. The complaint shall be in writing and must include as much information about the suspected violation. Anonymous complaint will not be entertained.

    8. If the complaint is against the Managing Director, it can be made to the Chairman of the Audit Committee of the Company. Directors when they blow the whistle they should send the complaint to the Chairman of the Audit Committee.

    9. The Whistle Blower shall raise the issue within a reasonable time but not later than two months.

    10. All complaints will be investigated promptly by the Managing Director or by any Committee formed by him in this regard. Based on a through examination of the findings, the Managing Director or the Committee formed in this regard shall submit the Report to the Chairman Audit Committee.

    11. All employees have a duty to cooperate in the investigation.

    12. If, at the conclusion of the said investigation, the Company determines that a violation has occurred, the Company will take effective remedial action commensurate with the nature of the offense. Reasonable and necessary steps will also be taken to prevent any further violations.

    13. No adverse action shall be taken or recommended against a Whistle Blower in retaliation to his blowing the whistle.

    14. Source of information to the Whistle Blower shall be disclosed to facilitate investigation.

    15. Every effort will be made to protect the Whistle Blower’s identity subject to any legal constraints that may arise from time to time.