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WHISTLE BLOWER POLICY

1.Purpose

Paracoat Products Limited is committed to upholding the highest standards of integrity, ethics and accountability in all its business dealings. The purpose of this whistleblower policy is to provide a mechanism for employees, contractors, vendors, and other stakeholders to report concerns or suspicions regarding unethical behavior, fraud, illegal activities, or violations of company policies without fear of retaliation.

2.Scope

This policy applies to all employees, contractors, vendors, and other stakeholders and also this policy is equally applicable to Third parties to report a concern related to a potential violation of the Company code of conduct of Paracoat Products Limited.

3.Reporting Mechanism

a. Reporting Channels: Concerns or suspicions may be reported through the following channels:

• Direct supervisor or manager

• Human Resources department

b. Confidentiality: Reports will be handled with the utmost confidentiality to the extent permitted by law. Information disclosed during the reporting process will only be shared with individuals on a need-to-know basis for the purpose of investigation and resolution.

Click this link https://ljforms.office.com/r/QVQvSXJjtz or Scan below QR Code to go to whistle blower form online and you select your language (English/Tamil/Hindi) to fill the form.

4. Protection Against Retaliation

Paracoat Products Limited prohibits retaliation against individuals who report concerns or suspicions in good faith. Retaliation against whistleblowers will not be tolerated and may result in disciplinary action, up to and including termination of employment or legal action.

5. Investigation and Resolution

a. Upon receipt of a report, Paracoat Products Limited will promptly investigate the concerns or suspicions raised. Investigations will be conducted impartially, thoroughly, and with appropriate confidentiality.

b. Where necessary, external resources may be engaged to conduct independent investigations.

c. Following the investigation, appropriate actions will be taken to address any substantiated concerns or suspicions, including disciplinary action, corrective measures, and implementation of preventative controls.

6. Non-Retaliation and Non-Disclosure

Employees are prohibited from retaliating against whistleblowers and from disclosing the identity of individuals who report concerns, except as required by law or as part of the investigation process. 

7. False Reporting

False or malicious reports made with the intent to harm or defame others are strictly prohibited and may result in disciplinary action, up to and including termination of employment. 

8. Specific Areas of Concern

Whistleblowers are encouraged to report concerns related to the following areas, but not limited to:

• Monetary gifts, entertainment, etc., acceptance and borrowing

• Special favors for companies, equity participation, concurrent employment

• Solicitation and unfair demands ) 

• Theft, embezzlement of public funds, and misappropriation

• Stealing of company's material such as RM, Parts, Tools, Instruments, Stationery, Trolleys, Bins, scrap etc. 

• Leakage of internal information 

• Scolding/screaming, Disobeying Coworkers & Superiors, harassing, threatening of consequences etc. which can lead to Lack of job security and morale.

• Document manipulation and fraudulent reporting

• Anti-competitive behavior: monopoly, collusion, abuse of dominance, abuse of authority (bullying}, etc.

• Intentionally Damaging Parts, machinery, Furniture, Tools, instruments etc.

• Other cases (violations of ethical regulations} 

9. Compliance and Oversight

The Compliance Officer or designated individual is responsible for overseeing compliance with this policy and ensuring that appropriate measures are in place to protect whistleblowers and investigate reports in a timely and effective manner. 

10. Acknowledgment

All employees, contractors, vendors, and other stakeholders are required to acknowledge receipt and understanding of this whistleblower policyk3nnually or as part of their onboarding process.