The Ethics Helpline is a platform to report any violation of our stated Anti Bribery and Corruption Policy and Code of Conduct, or other concern you may have. Any allegation which falls under the scope identified below but not limited to, can be reported to the Ethics Helpline:

1. Acceptance of gifts and entertainment

2. Acceptance of kickbacks

3. Breach of confidentiality of information

4. Bribery of Government officials

5. Commercial corruption

6. Child labour

7. Conflict of interest

8. Discrimination

9. Customer mistreatment

10. Financial fraud of any nature

11. Forced labour

12. Workplace misconduct – Sexual harassment

13. Workplace misconduct – Harassment, bullying, discrimination etc. (other than sexual harassment)

14. Inappropriate use of social media

15. Insider trading – Sharing of unpublished price sensitive information

16. Financial statement fraud

17. Misuse of company assets

18. Misuse of company name or logo

19. Nepotism

20. Non-compliance to applicable laws and regulations

21. Sharing of third-party intellectual property and or data

22. Substance abuse

23. Theft

24. Unfair selection of suppliers

25. Unfair treatment of employees or third parties

26. Violation of health and safety guidelines

27. Retaliation for filing a whistle-blower report

What is a Protected Disclosure?

A Protected Disclosure means any communication made in good faith that discloses or demonstrates information that may evidence unethical behaviour, actual or suspected, fraud or violation of the Code of Conduct or any other unethical or improper activity, abuse of authority by any director or employee, misuse or improper use of accounting policies and procedures resulting in misrepresentation of accounts and financial statements.

What anonymity options do I have while reporting a complaint through Ethics Helpline?

You have three options while reporting a complaint through Ethics Helpline:

1. You may choose to remain anonymous or

2. Share your identity or

3. Share your identity only with KPMG Ethics Helpline and not with the Company.

Is it mandatory to disclose the identity while reporting a Protected Disclosure?

You may choose to remain anonymous or share your identity. While reporting anonymously, you should share the following minimum information for a successful investigation:

It is recommended that you share your contact details as it will help in swift closure of the complaint.

What is the benefit of disclosing my identity to KPMG Ethics Helpline by being anonymous to the Company?

KPMG shall act as an informal, neutral, and impartial third-party service provider. You can disclose your identity with KPMG Ethics Helpline without any fear of victimization or retaliation for a successful investigation of your complaint. In case the Company needs any additional information for your complaint, the Company will reach out to KPMG Ethics Helpline and further they will reach out to you to seek that information.

What information should I include while making a Protected Disclosure?

You should state the facts and should not speculate or draw conclusions. You should provide the Ethics Helpline with as much specific information as possible, so that your allegations can be investigated, such as detailed description of the incident, who was involved, frequency of the issue, evidence, or source of evidence, etc.

If I see a violation, shouldn't I just report it to my manager, security, or human resource officials and let them deal with it?

When you observe some behavior that you believe violates our Code of Conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team. However, we recognize that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with KPMG Ethics Helpline.

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment.

I am concerned that the information provided to the Ethics Helpline will ultimately reveal my identity. How can you assure me that will not happen?

The Ethics Helpline is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the content of the complaint does not reveal your identity by accident. 

Is the telephone toll-free number confidential and anonymous too?

Yes. You will be majorly asked to provide the same information that you would provide through online platforms. Such report has the same security and confidentiality measures applied to them during delivery.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our Company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Our company chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the Company and all its employees and other stakeholders, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So, if you know of any incidents of misconduct or ethical violations, consider it your moral responsibility to yourself and your coworkers to report it.

What happens after a Protected Disclosure is submitted?

The Ethics Helpline will prepare an incident report based on the information, facts and evidence provided by the whistle-blower. The report is shared with the designated contacts within the company for further investigation.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The Ethics Helpline platforms and the report distribution are designed in a way that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the complaint? Or what if the Company has further questions for me concerning my complaint?

When you file a complaint through any channels of Ethics Helpline, you receive a unique case number. You may contact the Ethics Helpline to seek feedback after few days from the date of reporting of incident by quoting the case reference number.

If you have reported the issue through web portal, then you may access through your credentials to add more detail or answer questions posed by a Company representative and add further information that will help resolve open issues.

Are these follow-ups on complaints as secure as the primary complaint?

All correspondences through Ethics Helpline are held in the same strict confidence as the initial complaint, continuing under the umbrella of anonymity.

Isn’t this system just an example of someone watching over me?

The Ethics Helpline concentrates on being a positive aspect of our overall philosophy, and allows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern.

Effective communication is critical in today’s workplace and this is a great platform to enhance that communication. We have carefully chosen the best reporting platform to meet our compliance obligations while maintaining a positive reporting environment.

I hope my server logs are not traced and my identity remains confidential.

Ethics Helpline does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to Ethics Helpline is available. In fact, Ethics Helpline is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the Ethics Helpline’s secure website. Alternatively, you can talk to the Reporting Officers at 18002005478 (toll-free) any time between 7am till 11pm, Monday to Friday, on all business days. You may also write your concerns to crestdigitel@ethicshelpline.in .