The New India Assurance Company Limited

Whistle Blower Policy

1. PREAMBLE:

The Company believes in conducting its business in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behavior. As such the company endeavors to work against corruption in all its forms including demand and acceptance of Illegal gratification and abuse of official position with a view to obtain pecuniary advantage for self or any other person.

The management of the Company is also empowered to initiate investigations on its own and act on complaints received from public/employees, with regard to violation of company’s rules and procedures in the conduct of business.

Any actual or potential violation of the Company’s rules, regulations and policy governing the conduct of business is a matter of serious concern for the Company. The Company is therefore committed to developing a culture where it is safe for employees to raise concerns about instances if any, where such rules, regulations and policy are not being followed in furtherance of business.

The Objective of this policy is build and strengthen a culture of transparency and trust in the organization and to provide employees with a framework/procedure for responsible and secure reporting of improper activities (whistle blowing) and to protect employees wishing to raise a concern about improper activity/serious irregularities within the Company. The policy does not absolve employees from their duty of confidentiality in the course of their work. It is also not a route for taking up personal grievance.

2. DEFINITIONS:

Company means The New India Assurance Company Limited – UK Branch

Disciplinary Action means any action that can be taken on the completion of/during the investigation proceedings including but not limiting to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.

Designated / Competent Authority is the Chief Executive / Deputy Chief Executive

Employee means every permanent employee of the Company.

Improper Activity means any activity by an employee of the Company that is undertaken in performance of his or her official duty, whether or not that act is within the scope of his or her employment and that is in violation of any law or the rules of conduct applicable to the employee, including but not limited to abuse of authority, breach of contract, manipulation of company data, pilferage or confidential/proprietary information, criminal offence, corruption, bribery, theft, conversion or misuse of the company’s property fraudulent claim, fraud or willful omission to perform the duty, or that is economically wasteful or involving gross misconduct, incompetence or gross inefficiency and any other unethical biased, favored, or impudent act.

Activities which have no nexus to the working of the Company and are purely of personal nature are specifically excluded from the definition of improper activity.

Protected Disclosure means any communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.

Service Rules means the Conduct, Discipline and Appeal rules in case of Management Employees and the applicable Standing Orders in case of employees other than Management employees.

Subject means an employee against or in relation to whom a Protected Disclosure has been made or evidence gathered during the course of an investigation.

Whistle Blower means an Employee making a Protected Disclosure under this policy.

3. ELIGIBILITY:

All employees of the Company are eligible to make Protected Disclosure.

4. PROCEDURE FOR MAKING COMPLAINT UNDER ‘WHISTLE BLOWER POLICY’.

The Complaint should be in a closed/secured envelope addressed to the Chief Executive / Deputy Chief Executive – UK Branch, super scribed “Complaint under Whistle Blower Policy – To be opened by Addressee Only” and should be sent directly to him/her,

If the envelope is not super scribed and not closed, it will not be possible for the authority to protect the identity of the complainant and the complainant will be dealt with as per the normal complaint handling policy. The Complainant should give his/her name and address, telephone number, email id, in the beginning or end of the complaint or in an attached letter.

All such envelopes will be opened by the Designated / Competent Authority.

While considering the complaints the Designated / Competent Authority would take no action on complaints relating to administrative matters like recruitment, promotion, transfers and other related issues. However, in case of serious complaints of irregularities in these matters, the same shall be investigated.

  1. Anonymous/Pseudonymous complaints will not be entertained.
  2. Protected Disclosures should be carefully drafted, factual, specific and verifiable.
  3. The investigation will be conducted by the Designated Authority.

After conducting the investigation, if existence of improper activity is revealed, the Chief Executive / Deputy Chief Executive shall recommend appropriate action which shall inter alia include following:

  1. Appropriate proceedings against the concerned Employee/s.
  2. Recommend to appropriate authority for initiation of criminal proceedings in suitable cases, if warranted, by facts and circumstances of the case.
  3. Recommend corrective measures to prevent recurrence of such events in future.

5. DISQUALIFICATIONS:

While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action.

Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a whistle blower knowing it to be false or bogus or with a mala fide intention.

Whistle Blowers, who make two or more Protected Disclosures, which have been subsequently found to be mala fide, frivolous, baseless, malicious or reported otherwise than in good faith, will be disqualified from reporting further Protected Disclosures under this Policy.

In respect of such Whistle Blowers, the management would reserve its right to take/recommend appropriate disciplinary action.

6. GUIDING PRINCIPLES

  • Protected Disclosures are acted upon in a time bound manner.
  • Complete confidentiality of the Whistle Blower is maintained.
  • The Whistle Blower and/or the person(s) processing the Protected Disclosure are not subjected to victimization.
  • Evidence of the Protected Disclosure is not concealed and appropriate action including disciplinary action is taken in case of attempts to conceal or destroy Evidence.
  • Subject of the Protected Disclosure i.e. person against or in relation to whom a protected disclosure has been made, is provided an opportunity of being heard.

7. REPORTING AND REVIEW:

The Designated /Competent Authority shall maintain a regular register about all Protected Disclosures referred to him/her and the results of investigations.

8. PUBLICATION:

The policy will be posted on the Company’s website and the copy of the policy shall be displayed by all branches/offices of the Company at a place inside the Company’s premises, where customers/general public frequent.

9. DATE OF COMMENCEMENT OF THE POLICY:

The policy shall come into force from October 2019.

10. OPERATION:

This policy shall be in force till such time it is repealed.

How to raise your concerns

You can download our Whistle Blower Disclosure form below.

Download Whistle Blower Disclosure form hereadobepdf

 

Post: (Please place this form in a sealed envelope to the Chief Executive/ Deputy Chief Executive – UK Branch) 

The New India Assurance Company Limited, 36 Leadenhall Street, London, EC3A 1AT, United Kingdom