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1. Purpose:
The Company believes in the conduct of the affairs to be fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behaviour. Accordingly, the Company has adopted the Code of Conduct (“the Code”), which lays down the principles and standards that should govern the actions of the Company and its employees / Vendors. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern. The role of any person in pointing out such violations of the Code cannot be undermined.

The purpose of this Whistle Blower Policy (“the Policy”) is to provide a mechanism including but not limited to employees, customers, and/or third-party intermediaries such as agents and consultants, vendors of the Company to submit confidential and/or anonymous complaints about possible irregularities, governance weaknesses, financial reporting issues or other such matters.

This Policy allows for disclosure by employees, customers and/or third-party intermediaries of such matters internally, without fear of retaliation, discrimination or adverse employment consequences, and also permits the Company to address such disclosures or complaints by taking appropriate action, including but not limited to, disciplining or terminating the employment and/or services of those responsible.

The purpose of this Policy is to provide a framework to promote responsible and secure Whistle Blowing. The Policy neither releases employees, customers and/or third-party intermediaries 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.

2. Definitions
a) “Audit Committee” means the Audit Committee constituted by the Board of Directors of the Company in accordance with Section 177 of the Companies Act, 2013.
b) “Code” means the PMR’s Code of Conduct as in force from time to time.
c) “Company” or PMR means PM Relocations Pvt. Ltd.
d) “Employee” means every employee of the Company, including a Director, Head of each function, employees on probation, and includes an ex-employee of the Company.
e) “Investigator” means those persons authorized, appointed, consulted or approached by the Company to investigate the complaint.
f) “Protected Disclosure” means any good faith communication that discloses or demonstrates an intention to disclose information that may evidence unethical or improper activity in the organisation.
g) “Subject” means, a person who is, the focus of investigative fact finding either by virtue of Protected Disclosure made or evidence gathered during the course of an investigation.
h) “Whistle Blower” means any person making a protected disclosure/Complaint under this Policy including but not limited to Directors, Employees, Agents, Third Party Service Providers and Intermediaries. He/ She is neither an investigator nor a finder of facts, nor does he/ she determine the appropriate corrective or remedial action that may be warranted.
i) “Internal Complaints Committee (ICC)” mean committee formed under Prevention of Sexual Harassment (POSH) by the Company under The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

3. Scope
a) This Policy is an extension of the PMR Code of Conduct. The Whistle Blower’s role is that of a reporting party with reliable information. They are not required or expected to act as investigators or finders of facts, nor would they determine the appropriate corrective or remedial action that may be warranted in a given case.
b) Whistle Blowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the Managing Director or the Investigation Committee.
c) Protected Disclosure will be appropriately dealt with by the Managing Director, as the case may be.

4. Role of Whistle Blower:
The Whistle Blower should, before making a complaint under this policy, reasonably believe in good faith that there exists sufficient reason or ground to make such complaint. However, an employee who becomes aware of the alleged wrongful conduct is encouraged to make a disclosure as soon as possible.

5. Procedure for reporting:
a) Protected Disclosures should preferably be reported in writing so as to ensure a clear understanding of the issues raised and should either be typed or written in a legible handwriting in English, Hindi or in the regional language of the place of employment of the Whistle Blower.
b) Protected Disclosures should be factual and not speculative or in the nature of a conclusion and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern and the urgency of a preliminary investigative procedure.

Complaints under this policy may be made to rajeev[at]pmrelocations(dot)com Or may be sent By Post to:
Rajeev Bhargava (Managing Director)
PM Relocations Private Ltd.,
Plot 370, 1st Floor,
Udyog Vihar, Phase-4,
Gurugram, 122015

Complaints related to Prevention of Sexual Harassment (POSH) may be made by writing at hrsupport[at]pmrelocations(dot)com

6. Investigation Process
a) All complaints received under this Policy will be thoroughly investigated in accordance with the Code of Conduct and Company’s policies. The complaints received under this policy shall be examined within 2 working days from its receipt. The Company shall ensure to:

i. Accept all complaints appearing prima-facie of substance;
ii. Not reject any complaint prima-facie of substance merely for the reason of it being anonymous;
iii. Forward the complaint to the appropriate Investigators.

b) Depending upon the nature of the complaint, investigators from the HR, Legal, PMR etc., will be spearheading the investigation, as the case may be. The Investigators are required to conduct fact-finding and analysis related to cases of alleged improper or unethical activities. Investigators derive their authority and access rights from the Company when acting within the course and scope and they shall have the necessary competency.

a) Technical and other resources may be drawn upon as necessary to augment the investigation. All investigators shall be independent and unbiased both in fact and appearance. Investigators have a duty of fairness, objectivity, thoroughness, ethical behaviour and observance of legal and professional standards. Investigations will be launched only after preliminary consideration that establishes that:

i. The allegation if true, constitutes an improper or unethical activity, and;
ii. Either the allegation is accompanied by information specific enough to be investigated or matters that may be worthy of the management review.

b) All Protected Disclosure reported under this Policy will be thoroughly investigated in accordance with the procedure established.

c) The decision to conduct an investigation is not an accusation and is to be treated as a neutral fact-finding process. The outcome of the investigation may or may not support a conclusion that an improper or unethical act was committed and, if so, by whom. Further, depending upon the facts and circumstances, the Company may at its sole discretion decide on the need to share the report / outcome with the Whistle Blower, as may be appropriate.

d) The investigation shall ordinarily, be completed within 15 to 30 days of the receipt of the disclosures, and the final decision shall be taken basis the Company’s disciplinary grid. Time period between the pendency raised and receipt of requirements shall not be covered under the said clause. However, if the complaint falls under any of the matter which is governed by specific regulation or laws (such as The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, then such complaint shall be adhere to such timelines, as specified therein. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of an investigation pursuant to this policy shall adhere to the applicable Code of Conduct and disciplinary procedures.

e) The final decision on the complaint shall be implemented by the Company basis the investigation findings within 15 days after completion of investigation.

f) The investigation will:
i. subscribe to the principles of fair and natural justice i.e. a person shall not to be a judge in his own case and opportunity of being heard shall be given to the person complained against;
ii. keep records together with supporting evidencing documents; and
iii. be done expeditiously resulting into a report clearly stating findings and recommending the remedial action.

g) The Top management shall be updated on a quarterly basis, of the status of the Whistle Blowing Complaints received by the Company.

h) Escalation process:
An appeal against the decision taken can be made within 15 days to the MD & CEO for this purpose. The MD & CEO shall examine the appeal and grant its decision within 7 days of receipt of such appeal. However, for matters governed by specific regulation or laws, the appeal process & timelines enumerated therein shall be followed.

i) The record of the complaint shall be preserved for 10 years or for a reasonable period in line with Document retention policy of the Company.

7. Role of Subject:
The following principles shall be adhered to, while dealing with any Whistle Blower complaint:
a) Subjects have a duty to co-operate with the Management or any of the investigators during investigation.
b) Subjects have right to consult with a person of their choice, save except the investigators and/ or members of the Audit Committee and/or the Whistle Blower.
c) Subjects have a responsibility not to interfere with the investigation and to adhere to the directives from the investigators in this regard. Evidence shall not be withheld, destroyed or tampered with, and witnesses shall not be influenced, coached, threatened or intimidated in any manner.
d) Subjects will normally be informed of the allegations.

8. Protection:
a) The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted by law.
b) A Whistle Blower will not be at a disadvantage or treated unfairly or discriminated against for the reason of such whistle blow. The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle-blowers. Complete protection will, therefore, be given to Whistle-blowers against any unfair practice like retaliation, threat or intimidation of termination/suspension of service, transfer, demotion etc.
c) Any other person assisting in the investigation arising out of whistle blow will also be protected to the same extent as the Whistle Blower.
d) An employee who retaliates against someone who has reported a violation in good faith is subject to disciplinary action up to and including termination of employment.
e) A Whistle Blower or any other person assisting in the matter arising out of Whistle Blow may report violation of above to the HR Manager of the Company as if it is a complaint under this policy.
f) A whistle-blower is expected to raise only bona-fide complaints.
g) The protection is available provided that:
i. The communication/ disclosure is made in good faith
ii. Whistle blower reasonably believes that information, and any allegations contained in it, are substantially true; and
iii. Whistle blower is not acting for personal gain.

9. Disqualifications:
a) 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.
b) Employee “Whistle Blowers", who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious shall be penalised in accordance with the disciplinary policy and procedure.
c) Protection under this Policy would not mean protection from disciplinary action arising out of false or fake allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention.

10. Legitimate employment action:
An employee against whom an adverse action has been initiated for legitimate reasons or cause under Company policies shall not use this policy as defence. It shall not be a violation of this policy to take adverse action against an employee whose conduct or performance warrants appropriate action.

11. Concerns that can be raised:
The issues that can be addressed under the policy are classified under breach of the policy/ misconduct/ misappropriation/ harassment, etc.

Employees are advised to whistle-blow in respect of the following

a) All unlawful act whether civil or criminal;
b) Breach of or failure to implement or comply with any Company Policy;
c) Manipulation of Company’s data or records;
d) Knowingly breaching any state/ central law, or regulations including in personal capacity;
e) Unprofessional conduct or business practice;
f) Fraudulent or corrupt practices (including the offering or accepting of bribes or otherwise gaining undue advantage from a relationship with the company);
g) Questionable practices that have in any manner circumvented the laid down procedures and policies of the Company;
h) Dangerous practice(s) likely to cause physical harm/ damage to any person/ property;
i) Failure to rectify or take reasonable steps to report a matter likely to give rise to significant and avoidable cost or loss to the Company;
j) Abuse of power or authority for any unauthorized or ulterior purpose;
k) Theft of cash/goods & services
l) Unfair discrimination, coercion, harassment in the course of the employment or provision of services;
m) Any information on theft, data leakage etc. can also be reported.

The list is only illustrative and not exhaustive and shall include other acts pertaining to breach of policy/ misappropriation/harassment, etc.

The Company reserves the right to amend or modify this policy in whole or in parts, at any time without assigning any reason whatsoever.

The Company will ensure that the Whistle Blower Policy is uploaded on the company official website and is adequately communicated amongst the employees. Further, the Company shall ensure that all the vendors and service providers are also adequately informed of the escalation and handling procedures with regard to violation of PMR Code of Conduct and there shall be standard clause in the vendor agreements to this effect.

Note: Policy should not be used in place of the Company grievance procedures or be a route for raising malicious or unfounded allegations against colleagues.

12. Confidentiality
The employee may choose to remain anonymous and raise the concern under this policy. However, the employees are encouraged to disclose their identities while raising concerns under this Policy, this will assist in obtaining additional details or evidence as may be required during the inquiry or faster investigation.

Disclosures or complaints expressed anonymously may just be enquired and ordinarily NOT be investigated.

The identity of the complainant and the process of investigation will be kept confidential and it shall not be disclosed. This would not have any impact on the employee's performance appraisal, assignment of work or other matters related to employment with the Company.

13. Communication & Training
The Company shall adopt various communication and training initiatives on regular basis to create awareness on Whistle Blower Policy and educate on process of reporting of concerns.

14. Ownership and Review of Policy:
(a) This Policy is owned by Managing Director and has the responsibility to implement and ensure compliance to this Policy.
(b) The policy shall be reviewed at least once in three years to keep up to date with the changing requirements.

Updated 21 October 2020

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