Whistle Blower Policy

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PREFACE

1. Trimurthi Limited conducts its affairs by adopting the highest standards of professionalism, honesty, integrity, and ethical business to ensure the norm for every stakeholder becomes fairness and transparency.

2. To ensure this translates to action, the work culture we have built over the years encourages the company’s directors and employees to flag unethical behaviour along with actual/suspected fraud as well as any violation of the company’s code of conduct and ethics policy.

POLICY

Trimurthi Limited considers whistleblowing to be an ethical act that seeks to highlight gross mistakes and fraudulent activities. As such, our whistleblowing policy creates an atmosphere of security within the company to encourage our employees and directors (as defined hereafter) to speak out in accordance with an established system:

1. This policy creates a framework that promotes responsible and secure whistleblowing — guaranteeing protection for the company’s directors and employees wishing to flag irregularities.

2. However, this policy does not allow employees to renege on their confidentiality agreements nor does it permit itself to be used as a platform for employees to take up personal grievances or act with malafide intentions.

Furthermore, the policy ensures that:

  • Whistleblowers are protected from harassment or any other forms of unfair treatment
  • Every concern raised by a whistleblower is investigated properly with the promise of corrective action to the extent required and deemed fit

DEFINITIONS

  1. “Director” refers to a director appointed to the Board of a Company
  2. “Employee” refers to any employee of the Company (whether in India or abroad) and can be extended to include the company’s directors.
  3. In this parlance, ‘company’ refers to Trimurthi Drugs & Pharmaceuticals Limited
  4. ‘Protected Disclosure’ refers to any and all communication made in good faith that discloses or demonstrates any instance of unethical, illegal, and improper activity or behaviour
  5. Under this policy, ‘whistleblower’ refers to any director or employee making a Protected Disclosure — such as the one defined by this policy
  6. An ‘Audit Committee’ refers to the one constituted by the Board of Directors in accordance with the Companies’ Act of 2013. It is read under Clause 49 of the Listing Agreement for equity listed on the relevant Stock Exchanges.
  7. As such, ‘Disciplinary Action’ refers to any action that can be taken upon the completion of the aforementioned investigation that includes but is not limited to a warning, the imposition of a fine, suspension from official duties, or any other fitting corrective action that is proportionate to the gravity of the matter.
  8. ‘Subject’ refers to a person against or in relation to whom a Protected Disclosure is made or evidence is gathered during the course of an investigation


COVERAGE OF POLICY

Designed to encourage whistleblowers to voice all of their genuine concerns, the policy includes clauses that include but are not limited to:

  1. Abuse of authority
  2. Breach of trust
  3. Breach of confidentiality
  4. Any unlawful act: either criminal (like theft) or a breach of civil law (like slander or libel)
  5. Manipulation of the company’s data/records
  6. Breach of a policy, manual, or code adopted by the company
  7. Financial irregularities — including fraud or suspected fraud
  8. A deliberate violation of the prevailing laws or regulations
  9. Misappropriation of company assets and funds
  10. Any other unethical or improper conduct that is against the company’s spirit


DISQUALIFICATIONS

  1. Any abuse of this protection will warrant disciplinary action
  2. Whistleblowers who make Protected Disclosures that later are found out to be mala fide, frivolous, or malicious will be liable to be prosecuted



REPORTING MECHANISM

All Protected Disclosures must be addressed to the Company Secretary, whose contact details are:



Jyothi ramesh Kankani,
Company Secretary & Compliance Officer,
Trimurthi Limited,
Adress:4-4-231/1/2 ,
ABC,Inder Bagh, Sultan Bazar,
Hyderabad-500095.
Email: info@trimurthilimited.com



1. The disclosure should be made in writing and can be in English, Hindi, or any regional language of the whistleblower’s place of employment. It must be addressed to the Company Secretary and may be submitted by hand, courier, or by post.
2. The disclosure must be made in a sealed envelope that mentions ‘Highly Confidential’ on its face and is addressed to the Company Secretary only. However, exceptional cases or matters of utmost importance make it permissible for it to be addressed to the Chairman of the Audit Committee.
3. The whistleblower must disclose his/her identity in this letter. Concerns expressed anonymously will NOT BE investigated. This is to ensure that only factual information is provided by the whistleblower and that it is exceedingly clear and specific.



INVESTIGATION

  1. All protected disclosures reported under this Policy will be thoroughly investigated by the Company Secretary/Chairman of the Audit Committee or any other person authorized to carry out the same
  2. The decision to conduct an investigation is only a fact-finding exercise and does not prove the veracity of the allegation made
  3. The investigation will be conducted in a fair and transparent manner without the presumption of the involved party’s guilt.
  4. The subject will be informed of the allegations and provided with an avenue to make themselves heard
  5. It becomes the duty of the subject to cooperate to the fullest extent required during the course of the investigation
  6. Subjects have the right to consult with external counsel other than the Company Secretary, whistleblower, and the Audit Committee.
  7. Once the investigation is completed, a final decision will be taken by the Company Secretary in consultation with the Chairman of the Audit Committee after hearing both the parties.
  8. If the accused is ultimately proven guilty, the company will be allowed to take Disciplinary Action as deemed fit along with the preventive measures required to avoid the recurrence of such malpractices



PROTECTION

  1. No unfair treatment will be meted out to the whistleblower for having made a Protected Disclosure under this Policy
  2. The whistleblower’s identity will be kept confidential
  3. Any other employee assisting in the said investigation in any capacity will also be protected to the same extent as the whistleblower



SECRECY/CONFIDENTIALITY

The whistleblower, subject, Compliance Officer, and the Audit Committee along with everyone else involved in the process shall:

a) Maintain complete confidentiality and secrecy about every aspect of the issue

b) Not discuss the matter or any details regarding it at any informal gatherings or meetings

c) Discuss only to the extent required for the purpose of completing the process and the investigation involved

d) Not leave any papers unattended at any time

In the case that the aforementioned people are not complying with the guidelines stipulated above, they will be liable to prosecution on the matter



REPORTING

The Company Secretary must submit a report to the Chairman of the Audit Committee on the most Protected Disclosures, their ensuing investigations along with the results of the investigations undertaken for previously submitted Protected Disclosures



MODIFICATION

The company withholds the right to unilaterally amend this policy at any time without notice. Modification may be necessary to maintain compliance with local, state, central, and federal regulations as well as to accommodate organizational shifts within the company itself along with a host of other reasons.



CONCLUSION

For further queries related to the whistleblowers’ policy of Trimurthi Drugs & Pharmaceuticals, please feel free to reach out to:

Ms. Jyothi Ramesh Kankani
Company Secretary & Compliance Officer
Trimurthi Limited
Adress:4-4-231/1/2 , ABC,Inder Bagh,
Sultan Bazar, Hyderabad-500095.
Email: info@trimurthilimited.com