News & Events

Whistle Blower Policy

(A) INTRODUCTION

  • Carrying forward the values of the Peerless Group, PFS is committed to the highest standards of integrity, honesty, fairness and ethics coupled with complete transparency in all its actions.
  • PFS believes in the best corporate governance practices which promote professionalism. Accordingly, with a view to reinforcing its commitment to fairness and integrity of its own and its employees, PFS has put in place this “Whistle Blower Policy with adequate mechanism to address any complaint related to questionable practices, internal controls, auditing matters or reporting of information to the shareholders, the Government Agencies, Regulatory Authorities etc. Such a mechanism will allow the employees to disclose internally of such matters without fear of reprisal, discrimination or adverse employment consequences.
  • Similarly, PFS encourages its customers, vendors and other stakeholders to report to the appropriate authority of management about the instances of unethical behaviour, actual or suspected fraud or serious irregularities within the company.
  • This Whistle Blower Policy neither absolves the employees from their duty of confidentiality in the course of their work nor is it a route for taking up a grievance about a personal situation.
  • This Whistle Blower Policy aims at:
    • Ensuring complete confidentiality and providing adequate protection of the Whistle Blower and the person processing the Protected Disclosure from any victimization, unless proved otherwise.
    • Taking prompt action against person(s) trying to victimize the Whistle Blower and against the person(s) trying to destroy the evidence of the Protected Disclosure or trying to put undue influence or coercion on the Whistle Blower.
    • Providing an opportunity to the subject/person(s) involved to put forth his/their viewpoint.
  • This Whistle Blower Policy may be reviewed annually by the Board of Directors and amendments may be made if deemed fit.


(B) DEFINITIONS

  • “Whistle Blower” means someone who makes a Protected Disclosure under this Policy.
  • “Protected Disclosure” means a concern raised by a written communication made in good faith that discloses or demonstrates information that may reveal/evidence unethical or improper activity.
  • “Subject” means a person against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.
  • “Investigators” means any person(s) authorised, appointed, consulted or approached by the MD & CEO of the Company or the Chairman of the Audit Committee of Directors to conduct an investigation under this Policy.
  • “Action or Disciplinary Action” means any action that can be taken against the employee as per the provisions of the Service Rule and Code of Conduct as laid down in the HR Policy of the company.


(C) COVERAGE OF POLICY

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

  • Abuse of authority.
  • Fraud or suspected fraud or corruption.
  • Manipulation/destruction of company’s records.
  • Breach of contract with criminal intent.
  • Misappropriation/misuse of company’s funds/assets.
  • Theft of confidential/propriety information for passing on the same to competitors.
  • Deliberate violation of law/regulation.


(D) EXCLUSIONS

  • This Whistle Blower Policy should not be used for Employee Grievance Redressal or a route for raising malicious or unfounded allegations against colleagues.
  • While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment, 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.


(E) PROCEDURE

  • Any Employee, vendor, customer or any other stakeholder can make a protected disclosure in writing elaborating the issue in explicit terms either by way of a confidential letter or e-mail addressed to the Chairman, Audit Committee of Directors, as under:
    The Chairman,
    Audit Committee of Directors
    Peerless Financial Services Limited
    Peerless Bhavan,
    3, Esplanade East,
    Kolkata - 700 069
    Email: dchatterji@lbjha.com
  • The Whistle Blower should disclose his/her identity in the covering letter forwarding such protected disclosure.
  • Normally, anonymous protected disclosures are not considered. However, if the disclosure is serious and sensitive in nature, the company may initiate an investigation into the said anonymous disclosure solely at its discretion.
  • If initial enquiries by the Investigators indicate that the issue raised has no basis or it is not a matter to be pursued under this Policy, it may be dismissed at initial stage itself after due documentation.
  • The identity of the Subject and the Whistle Blower shall be kept confidential to the extent possible and as permitted under law of the land. Any other Employee assisting in the investigation shall also be protected to the same extent as that provided to the Whistle Blower and the Subject.
  • Subject will be informed of the allegations at the beginning of a formal investigation and shall be given an opportunity to offer explanations during the investigation process.
  • The Subject is duty bound to co-operate during the investigation process.
  • The investigation shall be conducted in a fair manner as an unbiased fact-finding exercise and without presumption of guilt. A written report of the findings shall be submitted to the appropriate authority. The appropriate authority will be the Chairman of the Audit Committee of Directors.
  • In case the Protected Disclosure is proved, the appropriate authority shall take necessary action as he may think fit and take preventive measures to avoid recurrence of the matter;


(F) PROTECTION

  • PFS shall provide complete protection to the Whistle Blower against any type of internal harassment like intimidation, retaliation or threat of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, discrimination including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his/her duties. In case any Subject or any concerned employee resorting to any type of harassment as mentioned above shall be declared as having committed a breach of the Company’s principles warranting suitable disciplinary action including dismissal from service.
  • PFS shall take sufficient action to minimize difficulties which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus, if the Whistle Blower is required to give evidence in criminal or disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice about the procedure, etc.
  • The identity of the Whistle Blower shall be kept confidential to the extent possible and as permitted under law. Any other Employee assisting in the investigation or furnishing evidence shall also be protected to the same extent as that provided to the Whistle Blower.


REPORTING OF PROTECTED DISCLOSURES

An annual report on the status of investigations and action taken on Protected Disclosures shall be submitted to the Audit Committee of Directors.