Whistle Blower Policy

Magicrete's Ethical Alert System: Ensuring Transparency and Accountability.

Introduction

This Whistle Blower Policy has been formulated to enable all employees to raise concern against any malpractice such as immoral, unethical conduct, fraud, corruption, potential infractions of the Code of Conduct of the Company, breaches of copyright or patent and alike. This policy also outlines the reporting procedure and investigation mechanism to be followed in case an employee blows the whistle for any wrong-doing in the Company. Employees are given protection in two important areas - confidentiality and against retaliation. It is ensured that Employees can raise concerns regarding any violation or potential violation easily and free of any fear of retaliation, provided they have raised the concern in good faith.

An ombudsperson has been appointed to receive the complaints through email or letters who would investigate the complaints with an investigating team. The final decision would be taken by the Ombudsperson in consultation with the Audit Committee. This Policy would help to draw the Company's attention to unethical, inappropriate or incompetent conduct which has or may have detrimental effects either for the organization or for those affected by its functions.

Background

To create enduring value for all stakeholders and ensure the highest level of honesty, integrity and ethical behavior in all its operations, the Company has formulated this Whistle blower Policy in addition to the existing Code of Conduct that governs the actions of its employees. This Whistle blower Policy aspires to encourage all employees to report suspected or actual occurrence(s) of illegal, unethical or inappropriate events (behaviors or practices) that affect Company's interest /image.

Objective

The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. This policy aims to provide an avenue for employees to raise concerns on any violations of legal or regulatory requirements, incorrect or misrepresentation of any financial statements and reports, etc.

Scope

This policy shall be applicable to all Employees of Magicrete Building Solutions Pvt. Ltd(MPSPL).

Definitions

“Employee”:"Employee" means any person on the rolls including those on deputation, contract, temporary, probationer, apprentice, trainee, part time employees / workers, full time consultants, holding permanent, honorary, ad hoc, voluntary or short term positions.

“Whistle blower”:A Whistle blower is an employee who raises a concern about any wrongdoing, event or information about an actual, suspected or anticipated Reportable Matter. The Whistle blower is not expected to prove the truth of the allegation; but s/he needs to demonstrate sufficient grounds for concern and good faith.

“Reportable Matter”:Reportable Matter includes:

General Malpractice
Abuse of authority
Breach of contract
Negligence causing substantial and specific danger to public health and safety
Manipulation of company data/records
Financial irregularities, including fraud or suspected fraud or Deficiencies in Internal Control and check or deliberate error in preparations of Financial Statements or Misrepresentation of financial reports
Any unlawful act whether Criminal/ Civil
Pilferation of confidential/propriety information
Deliberate violation of law/regulation
Wastage/misappropriation of company funds/assets
Breach of Company Policy or failure to implement or comply with any approved Company Policy
Potential Infractions of the Code of Conduct
Breaches of copyright, patent and disclosure of confidential data/information to competitors/outsiders.