I. Purpose

Jaffer Group expects abidance of business code of conduct and encourages voluntary reporting of irregularities regarding business ethics, safety, harassment, and other employment-related matters or other possible breaches of compliance. The ‘whistle-blower’ should alert the stakeholders about a person(s) who has done or is doing something wrong.

II. Issues on which Whistle should be Blown 

Following are the issues on the occurrence of which whistle can be blown and any other issues as laid down in the company “Policy of Ethics and Code of Conduct”.

a) Harming Jaffer Group Reputation

• Solicits or accept any advantage as an inducement or reward for doing or intending to commit any act in relation to the Company’s affairs or business.
• Showing or intending to show favours or disfavours to any person in relation to the company’s affairs or business.
• Offers any advantage to anyone as an inducement or reward to get allow them to break company rules.
• Intends to deceive the Company by using any receipt, account or other document which is false or erroneous or defective in any way and which to his knowledge is intended to mislead the Company.
• To mislead or lie to our customers in writing or in discussion, which may tarnish the reputation of the company.
• An employee issuing a fake claim for reimbursement of any type of expenses, whereby either the expenses are inflated.

b) Conflict of Interest

• An employee with purchasing authority forms a class of vendor from which he gets personal favours
• Where an employee (a) is a part owner of the vendor, (b) close family member of the employee works for the vendor, (c) he or she has accepted an offer from the vendor of special discounts for personal purchases.
• An employee uses his or her Company’s resources / assets to market a family member’s or friend’s business.
• Without permission, an employee discloses the proprietary Company information (e.g. forms; procedures; data) in writing an article or a book that personally profits and / or furthers the career of the employee.

c) Dual Employment

Any full-time employee who wishes to seek part-time employment in any other organization or institution must disclose and seek prior approval from Human Resources & Senior Management.

d) Confidential Information

• “Confidential information” is non-public information about the Company would be useful to a competitor. This should never be divulged to anyone outside the company, and also in the company on a ‘need to know’ basis.
• In case a person is found leaking or giving away company’s confidential information to a third party or a competitor, a whistle can be blown against him.

e) Gifts & Bribes

• An employee accepts a gift of an expensive nature from a subordinate employee of the Company, stakeholder of the company, a company vendor or a competitor.
• There is a fine line between an expression of appreciation and bribery, and employees must politely decline all, but very nominal gifts made under circumstances where such a gift is customary and is understood to express only in regard for the recipient in lieu of appreciation for services.
• An employee gives a gift to a customer or a government official, which might be interpreted as consideration for a business or official or personal favour.

f) Sexual Harassment

Jaffer Group prohibits sexual harassment (Policy on Ethics & Code of Conduct’s section Prohibition) of its Employees and applicants for employment by any Employee, non-Employee or applicant. Such conduct may result in whistleblowing.

g) Other Major Whistle Blowing Acts

• Obtaining cash from suppliers or vendors
• Non declaring conflict of interest
• Misusing / forging the invoice for a supplier.
• Using any other employee’s system or email
• Misuse of any other Employee’s ID Card
• Misuse of Employee system password
• Misuse of company’s research material
• Misuse of Company vehicles, stationary and other equipment.
• Misuse of telephone facility
• Fraud or corruption
• Physical, Emotional or Sexual abuse of any employee
• Using abusive language at work
• Misstating facts to third parties
• Compromising the confidentiality of information
• Breaking office decorum
• Consuming alcohol or drugs within office premises
• Carrying unauthorized weapons
• Actively participation or linkages in political parties.

III. Procedure to Blow a Whistle

As soon as any employee becomes reasonably concerned, they may follow the following process:

• Email or write to the Head of Human Resource or Internal Auditor with name and contact details of the whistle-blower. Background and documentary evidence (if available) should also be submitted.
• Head of Human Resource or Internal Auditor will respond back to the initiator for further details and investigate the complaint. The standard turnaround time to complete the investigation process is 30 days.
• Anonymous complaints and complaints made on the basis of personal prejudices shall not be entertained.
• The matter will be forwarded to the Whistle Blowing Committee with the recommendations for final decision. The Whistle Blowing Committee shall comprise of;

a) Chief Executive Officer, Jaffer Brothers (Private) Limited – Chairman
b) Head of Human Resource – Secretary
c) Director Corporate Services. - Member

IV. Protection of Whistleblower

• All concerns raised under this procedure will be treated seriously and a decision made about whether or not an investigation is appropriate. The Human Resources Department will be responsible for keeping the concerned informed about the progress of the investigation and the action that has been taken, although the concerned may not be told about the outcome. In some cases, the investigation may result in disciplinary proceedings.

• The Management of Jaffer Brothers will not tolerate harassment or victimization and will take action to protect the whistleblower if he / she has raised a concern in good faith. Any employee who is found to have victimized or harassed an employee who has raised a concern will face strict disciplinary action.
• The person who blows the whistle shall always remain confidential, maintaining his confidentiality is the duty of the Whistle Blowing Committee. It is not necessary that the line manager has to be involved when it comes to reporting any misconduct.
• Any person who raises a concern under this policy will not be at risk of suffering any form of retaliation.