Whistle Blower Policy

whistle Blower Policy

Policy Objective

The objective of this policy document is to provide necessary safeguard for protection of all associated stakeholders from reprisals or victimization, for raising concern and reporting malfunctioning, frauds and unethical practices followed within the company. This policy document outlines framework of company’s safe and secure vigil mechanism and encourages its stakeholders to report concerns which will help company to fulfill its commitment to adhere to the highest standards of ethical, moral and legal conduct of business operations.

Policy

Light has secure vigil mechanism as applicable under section 177 subsection (9) and (10) of The Companies Act, 2013.

Light ensures a protected reporting channel for its stakeholders, which enables them to raise concern and report any unehical practices, frauds and breach of its code of conduct.

Light ensures that genuine Whistle Blower will be provided protection from reprisal or victimization.

Procedure

Whistle Blower can make the Protected Disclosure to Chairperson of Ethics Committee or Chairperson of Audit Committee, as the case may be through any of the mentioned channel as soon he become aware of the ongoing mal practice.

Whistle Blower can report through any of the following channel:

a)In the form of Letter with subject “Protected Disclosure under Vigil Mechanism” to be given personally or through postal mail to-

The Chairperson

Ethics Committee

Light Microfinance Pvt. Ltd.

104A, Pinnacle Business Park

Corporate Road, Prahladnagar

Ahmedabad - 380015

b)In the form of E-mail to address whistleblower@lightmicrofinance.com with subject “Protected Disclosure under Vigil Mechanism”.

c)Through Phone to Ethics Committee which will be documented and recorded, on following number: +91-7575002324

d)Whistle Blower can also report orally to any of the member of ethics committee which will be documented and recorded.

In case Protected Disclosure is received by any of the employee other than member of Ethics Committee, it should immediately be forwarded to Ethics Committee and concerned employee should maintain confidentiality of the matter.

Protected Disclosures should preferably be reported in writing so as to ensure a clear understanding of the issues raised.

For all Protected Disclosures which contains names of member/s of Ethics Committee shall be directly reported to Chairperson, Audit Committee in sealed envelope or through email. The Contact information is as follow:

Light microfinance Pvt. Ltd.

104A, Pinnacle Business Park

Corporate Road, Prahladnagar

Ahmedabad – 380015

Email: Compliance@lightmicrofinance.com

The Company encourages and strongly recommends that the Protected Disclosure should contains necessary and relevant details of the fraud or misconduct or suspected fraud or misconduct or any other unfair practice including the name of the employees or any other person who have engaged or who may have engaged, in the opinion of the Whistle Blower, in the misconduct or fraud or any other unfair practice.

Protection

Light ensures that no unfair treatment is meted out to a Whistleblower by virtue of his/her having reported a Protected Disclosure under this Policy.

The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistleblowers.

Complete protection is given to Whistleblower/s against any unfair practice like retaliation, threat or intimidation 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 Whistleblower’s right to continue to perform his/her duties/functions including making further Protected Disclosure.

The Company takes steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus if the Whistleblower is required to give evidence in criminal or disciplinary proceedings, the Company arranges for the Whistleblower to receive advice about the procedure, etc.

Light ensures that the Whistle Blower, if a Business Associate, is protected from any adverse action which may include but is not limited to unfair termination of the contract, unfair withholding the payments due, non-acceptance of the goods or any other unfair act which may arise solely out of the concerned Business Associate.

The identity of the Whistle Blower is kept confidential. Any other Employee assisting in the said investigation or furnishing evidence is also protected to the same extent as the Whistle Blower.

The Whistle Blower has the right to directly approach the chairperson of audit committee in case of violation of above protection guidelines or occurrence of any adverse action against him/her.

Confidentiality

Light maintains confidentiality/secrecy of all complaints registered and only share the details with the specific persons involved in the process unless legally bound to disclose.

The Whistle Blower, the Ethics Committee, the Investigator, the Subject and all other persons involved in the process are required to maintain complete confidentiality/secrecy of the matter.

The identity of the Whistle Blower is kept confidential. In some special case where it is necessary to disclose complainant’s identity, it will be disclosed only after prior approval from the complainant.

Light keeps all documents and records related to case confidential unless legally required to be produced.