Whistle Blower Policy

  • Preamble

    Sun TV Network Limited (the Company) believes in highest ethical behaviour, transparency, professionalism and accurate compliance with all laws. In accordance with SEBI Listing Obligations and Disclosure Requirements (LODR) Regulations, the Company hereby formulate a vigil mechanism/whistle blower policy for Directors and Employees to report genuine concerns about actual or suspected violations of applicable laws and regulations and the Code of Conduct.

    Scope of the Policy

    This Vigil Mechanism and Whistle-blower Policy (the “Policy”) elaborates the guidelines and the procedure to be followed when making a disclosure.

    This Policy applies to all Employees, regardless of their position and their location.

    Any violation reported through this policy, if proved, will be met with strict disciplinary action.

    The employees are required to familiarize themselves with this Policy, and seek advice from the Head of the Department if any questions arise.

    Terms and Definitions

    “Audit Committee” means the committee constituted by the Board of Directors of the Company in accordance with Section 177 of the Companies Act 2013, which has responsibility for supervising the development and implementation of this Policy.

    “Code of Conduct” means the Code of Business Conduct and Ethics.

    “Employee” means any employee or director of the Company.

    “Protected Disclosure” means the disclosure of a Reportable Matter in accordance with this Policy.

    “Reportable Matter” means a genuine concern about actual or suspected:

    i. fraudulent practices, such as improperly tampering with the books and records of the Company, or theft of company property;

    ii. corruption, including bribery and money laundering;

    iii. actual or suspected violation of any law or regulation or code of conduct

    It should be noted that complaints concerning personal grievances, such as professional development issues or Employee compensation, are not Reportable Matters for purposes of this Policy.

    “Whistle-blower” means any Employee who makes a Protected Disclosure under this Policy.

    Responsibility to Report

    Protected Disclosures are to be made whenever an employee becomes aware of a Reportable Matter.

    The Protected Disclosure should be made promptly upon the Employee becoming aware of the Reportable Matter.

    Reportable Matters should be made pursuant to the reporting mechanism described herein below. The role of a Whistle-blower is limited to making a Protected Disclosure. A Whistleblower should not engage in investigations concerning a Reportable Matter that is the subject of a Protected Disclosure. Neither should a Whistle-blower become involved in determining the appropriate corrective action that might follow from the submission of a Protected Disclosure.

    Reporting

    The Whistle Blower should submit the Protected Disclosures referred to above to the Managing Director.

    Moreover, in exceptional cases, Whistle Blower have a right to make Protected Disclosures directly to the Chairman of the Audit Committee.

    To enable the proper investigation of any Reportable Matter, a Protected Disclosure should include as much information as possible concerning the Reportable Matter. To the extent possible, the following information should be provided:

    the nature of the Reportable Matter (for example, if the Reportable Matter concerns an alleged violation of the Code of Conduct, please refer to the provision of the Code of Conduct that is alleged to have been violated);

    the names of the Employees to which the Reportable Matter relates (for example, please provide the name of the business unit that is alleged to have violated the Code of Conduct);

    the relevant factual background concerning the Reportable Matter (for example, if the Reportable Matter concerns a violation of the Code of Conduct, please include information about the circumstances and timing of the violation); and

    to enable further investigation of Reportable Matters, Whistle-blowers are strongly encouraged to provide their name and contact details whenever they make a Protected Disclosure under this Policy.

    All Protected Disclosures are taken seriously and will be promptly scrutinized and investigated by the Company in accordance with the Guidance on Responding to Protected Disclosures

    Protection Of Whistle-Blowers:

    If a Whistle-blower does provide his or her name when making a Protected Disclosure, the Company will treat the identity of the Whistle-blower and the fact that a Protected Disclosure has been made will be kept confidential, except as otherwise required by law and to the extent possible while allowing an investigation to proceed.

    A Whistle-blower may make a Protected Disclosure without fear of retaliation or intimidation. The Company prohibits its Employees from engaging in retaliation or intimidation that is directed against a Whistle-blower.

    Employees who engage in retaliation or intimidation in violation of this Policy will be subject to disciplinary action, which may include dismissal from employment.

    If a Whistle-blower has been found to have made a deliberately false Protected Disclosure that Whistle-blower may be subject to disciplinary action, which may include dismissal.