Jaro Finance

[Formerly known as Nambiar Finance and Leasing Pvt Ltd]

Whistle Blower Policy

jaro finance believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behaviour.

It is therefore decided to establish a mechanism called ‘Whistle Blower Policy’ for employees to report to the management instances of unethical behaviour, actual or suspected, as well as fraud or violation of any good management policies. Accordingly, this Whistle Blower Policy (“the Policy”) has been formulated with a view to provide a mechanism for employees of the Company to approach the Ethics Counsellor. The Chief Operating Officer of the Organization will act as the Ethics Counsellor.

Every employee of the Organization shall promptly report to the management any actual or possible violation of the law or an event that could affect the business or reputation of the Organization as soon as he / she become aware of it. Such report will be treated as “Protected Disclosure”.

“Protected Disclosure” means any communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.

All Protected Disclosures will be kept strictly confidential & appropriate care will be taken to keep the identity of the Whistle Blower confidential.

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. 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 Ethics Counsellor. Protected Disclosure will be appropriately dealt with by the Ethics Counsellor, as the case may be. All the Employees of the Organization are eligible to make Protected Disclosures under the Policy. The Protected Disclosures may be in relation to matters concerning the Organization.

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. 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 appropriate disciplinary action.

Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide or malicious or Whistle Blowers who make 3 or more Protected Disclosures, which have been subsequently found to be frivolous, baseless or reported otherwise than in good faith, will be disqualified from reporting further Protected Disclosures under this Policy.

All Protected Disclosures concerning financial/accounting matters as well as those concerning any employee, including employee at the highest level of the Organisation should be addressed to the Ethics Counsellor. However, any Protected Disclosure against COO may be made to the Chairman of Board.

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. Alternatively, Protected Disclosures can also be reported orally.

Protected Disclosures should be factual & 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 & extent of the concern.

An employee may bring to the notice of the Management, undesirable or unethical acts, suspected or actual frauds without disclosing his/ her identity. The Management may at is discretion decide to investigate the information or otherwise. In such cases the employee concerned cannot claim protection under this Policy. However, when the Whistle Blower discloses his/her identity in the covering letter forwarding such Protected Disclosure, he will be entitled to protection under this Policy.

All Protected Disclosures reported under this Policy will be thoroughly investigated by the Ethics Counsellor.

The Ethics Counsellor may at his discretion, consider involving any Investigators for the purpose of investigation.

The identity of the subject and the Whistle Blower will be kept confidential to the extent possible given the legitimate needs of law and the investigation. Any other Employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.

Subjects will normally be informed of the allegations at the outset of a formal investigation and will be given opportunities for providing their inputs during the investigation.

No unfair treatment will be meted out to a Whistle Blower by virtue of his/her having reported a Protected Disclosure under this Policy.

The Organization, 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 orintimidation of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his duties/functions including making further Protected Disclosure.

The investigation shall be completed normally within 45 days of the receipt of the Protected Disclosure.

The Organization reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever.