The document outlines a risk management and whistleblowing policy for an organization. It defines whistleblowing as raising concerns about danger or illegality that affects others. It notes the Public Interest Disclosure Act of 1999 protects employees who report issues. The policy aims to encourage open communication, address concerns internally, act as a deterrent to malpractice, and protect whistleblowers from reprisal. It applies to employees, contractors, suppliers, and council members. It covers a wide range of issues and legal/ethical concerns. The organization pledges to treat reports confidentially and not tolerate victimization of whistleblowers.

1. RISK MANAGEMENT
AND WHISTLE
BLOWING POLICY
111101111!111111

2. Whistleblowing: Introduction
“Whistleblowing occurs when a worker raises a concern about danger or illegality
that affects others, for example members of the public“
In 1999, the Public Interest Disclosure Act came into force in the UK in response to a
number of high profile disasters and scandals in which, after the event, it was
revealed that employees had been aware of the dangers, but were too scared to
‘blow the whistle’.
Employees may be fearful that raising the alarm will lead to retribution from their
colleagues or indeed their employer who may ‘shoot the messenger’, but a good
organisation should encourage staff to voice their concerns over malpractice and act
against an employee who would try to hinder them doing so. There are a number of
reasons why implementing a whistleblowing policy is beneficial:
•
Having such a policy should enable an organisation to deal with a concern
internally and in an appropriate manner, rather than publicly. Publicity about a
malpractice can severely harm an organisation’s reputation and funding potential
and have a similar impact on other organisations in the same sector.
•
A whistleblowing policy should encourage a climate of open communication
which enables staff to voice concerns at the earliest opportunity and thus averts a
larger issue in future. Also, if the employee’s concerns are misplaced, then this
misunderstanding can be addressed sooner rather than later.
•
Knowing that an organisation has a clear policy on whistleblowing and is serious
about dealing with malpractice should act as a deterrent to those who may be
considering an illegal, improper or unethical practice.
1|Page

3. Who does the Policy apply to?
The policy applies to all employees, (including those designated as casual hours, temporary, agency, authorised
volunteers or work experience), and those contractors working for the Council on Council Premises, for example,
agency staff, builders, drivers. It also covers suppliers and those providing services under a contract with the Council
in their own premises, for example, care homes and childrens centres. The policy also covers Members.This policy
has been discussed with the relevant trade unions and professional organisations and has their support.
The Aims of the Policy
•
To encourage you to feel confident in raising concerns and to question and act upon concerns about
practice.
•
To provide avenues for you to raise concerns in confidence and receive feedback on any action taken.
•
To ensure that you receive a response to your concerns and that you are aware of how to pursue them if
you are not satisfied.
•
To reassure you that you will be protected from possible reprisals or victimisation if you have a reasonable
belief that you have made any disclosure which is in the public interest. .
What Types of Concern are Covered?
•
Conduct which is an offence or a breach of law.
•
Failure to comply with a legal obligation.
•
Disclosures related to miscarriages of justice.
•
Health and safety risks, including risks to the public as well as other employees.
•
Damage to the environment.
•
The unauthorised use of public funds.
•
Possible fraud and corruption.
•
Sexual, physical or other abuse of clients.
•
Other unethical conduct.
•
Actions which are unprofessional, inappropriate or conflict with a general understanding of what is rights and
wrong.
NB. Other procedures are available to employees e.g. the Grievance procedure which relates to complaints about
your own employment. This policy also does not replace other corporate complaints procedures which are for public
use.
Safeguards and Victimisation
The Council recognises that the decision to report a concern can be a difficult one to make. If what you are saying is
true, you should have nothing to fear because you will be doing your duty to your employer and those for whom you
provide a service.
The Council will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate
action to protect you when you raise a concern which is in the public interest.
2|Page

4. Confidentiality
All concerns will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At
the appropriate time, however, you may need to come forward as a witness.
This policy encourages you however to put your name to your concern whenever possible. Please note that:
•
Staff must believe the disclosure of information is in the public interest.
•
Staff must believe it to be substantially true.
•
Staff must not act maliciously or make false allegations.
•
Staff must not seek any personal gain.
The Response of Corporate India :
Corporate India was slow to respond to the nonmandatory requirements of Clause 49 in general, and the
clause relating to the whistle-blower policy in particular. A regulatory recommendation is a law in the
making, and it is heartening to find that an increasing number of companies are now realising the need
to pay heed to these non-mandatory requirements. A peek at some of the corporate governance reports
that form part of the annual reports of companies reveals the status of adoption of this non-mandatory
requirement (refer Table).
Table
Company Name
LIC Housing Finance
Ltd.
Compliance of the non-mandatory requirement of
Annual
Clause 49 of the Listing Agreement on whistle-blower
Report
policy
200910
The Company has whistleblower policy and adheres
to norms relating to the same.
200910
During the year the Company has established a
Whistle Blower Policy with a view to provide a
mechanism for employees to report to the
management concerns about unethical behavior,
fraud, etc. The Policy also provides for adequate
safeguards against victimization of employees who
avail of the mechanism and also provides for direct
access to the chairman of the Audit Committee.
Asian Paints Ltd.
200910
The Board of Directors of the Company at their
meeting held on 25th June, 2009 approved and
adopted the Whistle-Blower Policy of the Company
with an objective to establish a formal mechanism
to provide protection to the employees of the
Company from unethical work practices and
irregularities.
CMI FPE Ltd.
2008-
The Company has not established a formal whistle
blower policy mechanism. However, there is a
The Great Eastern
Shipping Co. Ltd.
3|Page

5. 09
mechanism in place to address unethical conduct, if
any, by employees vis-à-vis the standards stipulated
in the code of conduct and work ethics. Moreover,
no personnel of the Company have been denied any
access to the Audit Committee.
IDFC
200910
Although it is not mandatory the Board of IDFC has
also adopted Whistle Blower Policy.
Divis Lab Ltd.
200809
The Company is in the process of development of
suitable Whistle Blower Policy.
2008
Presently, the Company does not have a Whistle
Blower Policy but has a policy similar to it for the
entire BP Group of Companies worldwide which is
called ‘Open Talk’. No personnel of the Company
has been denied access to the Audit Committee.
Kotak Mahindra Bank
200910
The Bank has adopted the Whistle Blower Policy
pursuant to which employees of the Bank can raise
their concerns relating to the fraud, malpractice or
any other untoward activity or event which is
against the interest of the Bank or society as a
whole.
Ashok Leyland Ltd.
200809
The Company does not have a Whistle Blower
Policy, but has an independent Ombudsman, who is
not an employee of the Company.
Bharat Forge Ltd.
200809
The company has not adopted any non-mandatory
requirements of the Clause 49.
Castrol India Ltd.
4|Page