The Whistleblower Policy (“Policy”) has been framed for the Stakeholders of the Company to report any violations of code of ethics and conduct, or any wrongdoings in the Company. The Policy provides a framework to promote responsible and secure whistle blowing. It aims to protect stakeholders wishing to raise a concern about any serious irregularities within the Company.

As representatives and being associated with the Company, we are committed to upholding its Code of Ethics and Conduct, acting with unwavering integrity. Corporate misconduct poses a significant risk to the well-being of our organization as a whole. By bravely speaking out against wrongdoing, we can foster a culture of accountability, maintaining a harmonious and thriving work environment. Our actions serve as a catalyst, inspiring others to remain vigilant and promptly report any observed or suspected misconduct. Rest assured, the Company is dedicated to providing the utmost protection to Whistleblowers, ensuring they are shielded from any form of retaliation. However, any misuse of this protection will be met with appropriate disciplinary measures.

All the Stakeholders of the Company may file a Complaint to report any violations of code of ethics and conduct or any wrongdoings in the Company. The term Stakeholders means and includes but not limited to employees, directors vendors, suppliers, lenders, investors, customers, business associates, trainees and others with whom the Company has financial or commercial dealings.

The Whistleblower may submit his/her complaint against any of the following Malpractices and events, which have taken place or suspected to take place:

• 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;
• Criminal offence - theft, bribery, blackmail;
• Pilferage of confidential/propriety information;
• Deliberate violation of law/regulation;
• Wastage / misappropriation / theft of company’s funds / assets;
• Breach of employee Code of Conduct or Rules;
• Any other unethical, biased, favoured, imprudent event.

The above instances are inclusive in nature and not exhaustive.

No, the Whistleblower may submit his/her complaint at any time whenever any of the event as mentioned in question 4 is triggered or suspected to trigger.

Yes, if any stakeholder of the Company including employees, Directors, suppliers, investors or customers come across or feels there is a violation of the code of ethics and conduct, the same can be reported through any of the following modes:

• Physical Letter in a closed and sealed envelope
  
  To,
  Ombudsperson,
  Bharat Forge Limited, Pune Cantonment,
  Mundhwa Pune – 411036
• Drop a written complaint in a closed and sealed envelope in a Letter Box placed at every plant of the Company.
• You can write to whistleblower@bharatforge.com.
• The Stakeholders can also directly report to Chairperson of Audit Committee of the Company subject to specific circumstances as mentioned in question 7.

Following are the exceptional cases, in which the Whistleblower may report any violation to the code of ethics and conduct directly to the Chairperson of Audit Committee of the Company:

• Complaint against the Senior Management;
• To escalate the case which was earlier reported to the Ombudsperson;
• The Complaint is very critical that it needs direct involvement of Audit Committee.

The report can be made via writing e-mail to auditcommittee@bharatforge.com

The Company understands and respects the choice of their Stakeholders of not disclosing their identity and accordingly it has provided an option to Whistleblowers to submit their concerns anonymously. All the reported violation will be heard and addressed appropriately.

However, the Company encourages the Whistleblower to disclose their identity while submitting the protected disclosure so that effective and expeditious investigation can be facilitated.

On receipt of the Complaint, the Company shall initiate the investigation on the basis of the merits of the case and in such manner as detailed in the flow chart enclosed as Annexure. Further, the entire investigation process shall be documented and be completed within 60 days from the receipt of complaint. However, an extension may be granted on the discretion of Ombudsperson depending on the complexity of the case. Click Here for Process Flow

Yes, in case, Whistleblower is not satisfied with the outcome of the investigation and the decision of Investigation Committee, he/she can make direct appeal to the Chairperson of the Audit Committee by writing an e-mail to auditcommittee@bharatforge.com

The Whistleblower should provide the details and documents for supporting his / her Complaint as given in the format enclosed as Annexure. Click Here for Complaint Form

No, the following complaints are not eligible for reporting under the Whistleblower Policy:

• Queries or Complaints received from the Shareholders or Debenture holders relating to his/ her shares or debentures as it is separately dealt by Link Intime India Private Limited, the Registrar and Share Transfer agent of the Company;
• The Complaint regarding instances of leakage of unpublished price sensitive information (UPSI) shall be investigated in accordance with the Code of Conduct for Insider Trading of the Company as framed under the Insider Trading Regulations, 2015;
• Complaints regarding sexual harassment shall be dealt as per the Internal policy framed in accordance with the provisions of the Prevention of Sexual Harassment (POSH) Act, 2013;
• Personal grievances of the employees of the Company.

Where at any stage of investigation, the Complaint is found bogus or frivolous, the Ombudsperson or Investigation Committee may take necessary disciplinary actions against the Whistleblower including levy of fine, termination from the employment, etc.

Yes, any witness assisting in the said investigation or furnishing evidence shall also be protected to the same extent as the Whistleblower.