INVESTOR INFO

Whistle Blower Policy

Arihant Spaces
01
Preface

ARIHANT FOUNDATIONS & HOUSING LIMITED believes in the conduct of its affairs and that of its constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behaviour. Towards this end, ARIHANT FOUNDATIONS & HOUSING LIMITED has formulated the personnel policies that should govern the actions of ARIHANT F0UNDATI0NS & HOUSING LIMITED, its constituents and their employees. Any actual or potential violation ofthe policy, howsoever insignificant or perceived as such, would be a matter of serious concern for the company. The role of the employees in pointing out such violations of the policy cannot be undermined.

Reporting Concerns

Every employee of the company shall promptly report to the management any actual or possible violation of the employment rules or an event he becomes aware of that could affect the business or reputation of his or the company. “clause 49 of the Listing Agreement between listed companies and the Stock Exchanges has been recently amended which, inter alia, provides for a mandatory requirement for all listed companies to establish a mechanism called ‘whistle Blower Policy’for employees to report to the management instances of unethical behaviour, actual or suspected, fraud or violation of the employment rules, working of the Company or ethics policy. Accordingly, this Whistle Blower Policy [“the Policy”] has been formulated with a view to provide a mechanism for employees of the Company to approach the Audit Committee of the Company.

02
Definitions
The definitions of some of the key terms used in this Policy are given below.

Audit Committee” means the Audit Committee constituted by the Board of Directors of the Company in accordance with Section 177 of the Companies Act, 2013 and read with Clause 49 of the Listing Agreement with the Stock Exchanges.

Employee” means every employee of the Company including the Directors in the employment of the Company.

Investigators” mean those persons authorised, appointed, consulted or approached by Audit Committee and include the auditors of the Company and the police.

Protected Disclosure” means any communication made in good faith that discloses or demonstrates information that mayevidence unethical or improper activity.

Subject” means a person against or in relation to whom a Protected Disclosure has been made or evidence gathered during the course of an investigation.

03
Scope

The Whistle Blower’s role is that of a reporting party with reliable information. They are not required or expected to act as investigators or finders of  facts, nor would they determine the appropriate corrective or remedial action that may be warranted in a given case. Whistle Blowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as may be requested by the Audit Committee or the Investigators.

04
Eligibility

All Employees of the Company are eligible to make Protected Disclosures under the Policy. The Protected Disclosures may be in relation to matters concerning the Company.

05
Disqualifications

While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action. Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention. Whistle Blowers, who make three or more Protected Disclosures, which have been subsequently found to be mala fide, frivolous, baseless, malicious, or reported otherwise than in good faith, will be disqualified from reporting further Protected Disclosures under this Policy. In respect of such Whistle Blowers, the Company/ Audit Committee would reserve its right to take/recommend appropriate disciplinary action.

06
Procedure

All Protected Dis clos u res s hould be addressed to the Chairman of the Audit Committee of the Company. The contact details of the Chairman of the Audit Committee arc as under:

The Chairman
Audit Committee
ARIHANT FOUNDATIONS & HOUSING LIMITED
No. 3, Ganapathy Colony, 3rd lane, off. Cenotaph road, Teynampet, Chennai 600 018

Protected Disclosures should preferably be reported in writing so as to ensure a clear understanding of the iss ue s raised and should either be typed or writte n in a legible handwriting in English, Hind i or in the regional la nguage of the place of e mploy me nt of the Whistle Blo we r. The Protected Disclosure should be forwarded under a cove ring letter which shall bear the identity of the Whistle Blow e r. The Chairman of the Audit Committee shall detach the covering letter and discuss the Protected Disclosure with Members of the Audit Committee and if deemed fit. forward the Protected Disclosure for investigation.

Protected Disclosures should be factual and not speculative or in the nature of a conclusion, and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern and the urgency of a preliminary investigative procedure. The Whistle Blower must disclose his/her identity in the covering letter forwarding such Protected Disclosure. Anonymous disclosures will not be entertained by the Audit Committee as it would not be possible for it to interview the Whistle Blowers.

07
Investigation

All Protected Disclosures reported under this Policy will be thoroughly investigated by the Audit Committee. The Audit Committee may at its discretion, consider involving any lnvestigators for the purpose of investigation. The decision to conduct an investigatron taken by the Audit Committee is by itself not an accusation and is to be treated as a neutral fact-finding process. The outcome of the investigation may not support the conclusion of the Whistle Blower that an improper or unethical act was committed. The identity ofa Subject will be kept confidential to the extent possible save for the legitimate needs of law and the investigation.

Subjects will normally be informed of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation.

Subjects shall have a duty to co-operate with the Audit Committee or any of the Investigators during investigation to the extent that such co-operation sought does not merely require them to admit guilt.

Subjects have a right to consult with a person or persons of their choice, other than the lnvestigators and/or members of the Audit Committee and/or the Whistle Blower.

Subjects shall be free at any time to engage counsel at their own cost to represent them in the investigation proceedings.Whistle Blower Policy

Subjects have a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed or tampered with, and witnesses shall not be influenced, coached, threatened or intimidated by the Subjects.

Unless there are compelling reasons not to do so, Subjects will be given the opportunity to respond to material findings contained in an investigation report.

No allegation of wrongdoing against a Subject shall be considered as maintainable unless there is good evidence in support of the allegation.

Subjects have a right to be informed of the outcome of the investigation. If allegations are not sustained, the Subject should be consulted as to whether public disclosure of the investigation results would be in the best interest of the Subject and the Company.

The investigation shall be completed normally within 45 days of the receipt of the Protected Disclosure.

08
Protection

No unfair treatment will be meted out to a Whistle Blower by virtue of his/her having reported a Protected Disclosure under this Policy. ARIHANT FOUNDATIONS & HOUSING LIMITED, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle BIowers. Complete protection will, therefore, be given to Whistle Blowers 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 Whistle Blower’s right to continue to perform his or her duties/functions including making further Protected Disclosure. The Company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus, if the Whistle Blower is required to give evidence in criminal or disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice about the procedure, etc.

The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. Whistle Blowers are cautioned that their identity may become known for reasons outside the control of the Audit Committee [e.g. during investigations carried out bY Investigators].

Any other Employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.

09
Investigators

lnvestigators are required to conduct a process towards fact-finding and analysis. Investigators shall derive their authority and access rights from the Audit committee when acting within the course and scope of their investigation. Technical and other resources may be drawn upon as necessary to augment the investigation. All lnvestigators shall be independent and unbiased both in fact and as perceived. Investigators have a duty of fairness, objectivity, thoroughness, ethical behavior, and observance of legal and professional standards’

Investigations will be launched only after a preliminary review by the Chairman of the Audit Committee or the Ethics Counsellor, as the case may be, which establishes that:

i. the alleged act constitutes an improper or unethical activity or conduct, and

ii. the allegation is supported by information specific enough to be investigated or in cases where the allegation is not supported by specific information, it is felt that the concerned matter is worthy of management review. Provided that such investigation should not be undertaken as an investigation of an improper or unethical activity or conduct.

10
Decision

lf an investigation leads the Audit Committee to conclude that an improper or unethical act has been committed, the Audit Committee shall direct the management of the Company to take such disciplinary or corrective action as the Audit Committee deems fit. It is clarified that any disciplinary or corrective action initiated against the subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures’.

11
Reporting

The Audit committee shall submit a report to the management on a regular basis about all Protected Disclosures referred to it since the last report together with the results of investigations, if any.

12
Retention of Documents

All Protected Disclosures in writing or documented along with the results of investigation relating there to shall be retained by the Company for a minimum period of seven years.

13
Amendment

The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever.  However, no such  amendment or modification  will  be  binding on  the Employees unless the same is notified to the Employees in writing. The above shall form part of the present employment and other personnel policies of the Company.

Arihant - Memorable Spaces

CIN : L70101TN1992PLC022299

Regd. Office :
271 Poonomollee High Rood, “Ankur Manor” 1st Floor, off. McNichols Road, Kilpauk, Chcnnai – 600 010.
Tel : 014 28363266

Corporate Office :
#3 (Old No.25) Ganapathy Colony, 3rd Lane, Off Cenotaph Road, Teynampet, Chennai – 600 018
Tel : 044 4224 4444  / Fax: 044 4224 4440 | Email : info@arihants.co.in | Web : arihantspace.com