1. Introduction and Objectives
SSB CENTRAL HOSPITAL & RESEARCH CENTRE LIMITED (hereinafter referred to as the Company) is committed to upholding the highest standards of integrity, transparency, and ethical conduct. To ensure that the Company’s values are maintained, a Vigil Mechanism, also known as the Whistle Blower Policy, has been established.
The primary objective of this policy is to provide a formal channel for all Directors and employees to report genuine and serious concerns about unethical behavior, fraud, or violation of the Company’s code of conduct without fear of reprisal.
- Encourage a culture of transparency and accountability
- Provide a clear process for reporting misconduct
- Safeguard the identity and protect the person making a protected disclosure from victimization
- Ensure disclosures are investigated fairly, impartially, and in a timely manner
2. Applicability
This policy applies to all Directors and employees of SSB CENTRAL HOSPITAL & RESEARCH CENTRE LIMITED.
3. Definitions
- Audit Committee: The committee constituted by the Board of Directors in accordance with Section 177 of the Companies Act, 2013.
- Protected Disclosure: A written communication made in good faith by a whistle blower disclosing an improper activity.
- Improper Activity: Any activity violating the Company’s code of conduct, including fraud, financial irregularities, misuse of authority, violation of laws, negligence affecting public safety, misappropriation of assets, or other unethical conduct.
- Whistle Blower: A Director or employee who makes a protected disclosure.
- Subject: A person against whom a protected disclosure is made.
4. Scope of the Policy
This policy is an extension of the Company’s Code of Conduct. It is not intended for personal grievances, which should be addressed through HR channels. The policy covers serious and genuine concerns that may significantly impact the Company.
5. Procedure for Making a Protected Disclosure
5.1 Reporting Channel
- Disclosures must be made in writing and addressed to the Chairman of the Audit Committee.
- They may be sent via email or sealed envelope marked “Confidential – Vigil Mechanism Disclosure”.
5.2 Contents of the Disclosure
- Disclosures must be factual and include sufficient details for investigation.
- Information such as nature of activity, persons involved, date, time, and location should be provided if known.
- The identity of the whistle blower must be stated. Anonymous disclosures will not be entertained.
5.3 Role of the Whistle Blower
- The whistle blower’s role is limited to reporting concerns.
- They are not expected to conduct investigations.
- They must cooperate fully during the investigation process.
6. Safeguards against Victimization
- The Company will protect whistle blowers from unfair treatment or retaliation.
- No adverse action shall be taken against a whistle blower acting in good faith.
- Cases of victimization may be reported to the Chairman of the Audit Committee.
- Protection does not apply to malicious or knowingly false disclosures.
7. Confidentiality and Anonymity
- The identity of the whistle blower shall be kept confidential as far as possible.
- Investigations will protect identities while ensuring fairness to the subject.
8. Investigation Process
- Receipt of disclosure shall be acknowledged within a reasonable time.
- The Audit Committee will assess whether the matter falls within policy scope.
- Investigations may be conducted internally or through external agencies.
- The subject will be given an opportunity to be heard.
- Findings and recommendations shall be submitted to the Board.
- The whistle blower shall be informed of the outcome, subject to confidentiality.
9. Retention of Documents
All records related to disclosures and investigations shall be retained for a minimum of five years or as required by law.
10. Amendment of the Policy
The Board of Directors may amend or modify this policy from time to time.