WHISTLE BLOWER POLICY
A) Objective
The principles of Trust through Transparency and Accountability are at the core of vidharbhalaxmi’s (hereinafter known as “the Company‟) existence. To ensure strict compliance with ethical and legal standards across the company, the present policy has been created.
The objectives of this Policy are:
B) Scope
This policy defines and lays down the process for raising a “complaint”, the safeguards in place for the person raising a complaint, the roles and responsibilities of all stake holders and also sets the timelines for all processes to be followed. In all instances, the Company retains the prerogative to determine when circumstances warrant an investigation and, in conformity with this policy and applicable laws and regulations, the appropriate investigative process to be employed.
Complaints related to any only unethical business conduct or illegal acts will be dealt by Whistleblower policy. Any complaints related to HR issues or issues related to sexual harassment will be forwarded to the Internal / POSH Committee. This policy covers all employees, third party vendors, consultants, and customers throughout the world, operating out of any location of the Company.
C) Definitions
Whistle-blower: A person or entity making a disclosure of any unethical activity that they have observed which includes violation of any law or code of conduct or any company policy. Whistle-blowers could be contractors, contractor’s employees, clients, vendors, internal or external auditors, law enforcement /regulatory agencies or other third parties.
Complaint: The reporting of any such unethical activity or violation to the Ethics Committee by a whistle-blower as defined above made in good faith would constitute a complaint.
Ombudsperson: Any agency / individual / department appointed to independently carry out an initial investigation of the complaints lodged by employees, vendors, customers or consultants of Vidharbhalaxmi Micro Services.
D) Policy Details
It is the duty of all employees to notify the company if they observe, or learn of, any unethical business conduct or illegal acts. Failure to promptly raise a known or suspected violation is considered an unethical behavior. Please refer the Company’s Code of Conduct for the standards of ethical behavior and personal conduct.
E) Reporting a Complaint
Reports of allegations of suspected unethical activities are encouraged to be made in writing/mail so as to assure a clear understanding of the issues. Such reports should be factual rather than speculative and must contain as much specific information as possible to allow for proper assessment of the nature, extent and urgency of preliminary investigative procedures. The Whistle-blower need not prove the concern but must demonstrate sufficient grounds for raising the concern. The disclosure can also be made anonymously, but it will be the decision of the Ethics Committee to further act upon on an anonymous complaint or not depending upon the disclosure so made.
F) Reporting Process
The complaint can be made in any of the following methods:
Written Complaint: A written complaint can be sent to the Company Secretary or Chief Executive Officer of the Company.
E-mail: vishalk@vidharbhalxmifs.com.com which will be managed by the Chief Executive Officer, Chief Operating Officer and the Company Secretary of the Company.
Disqualification
In case of it is found that the complaint has been made with malafide intentions and is a false accusation or is an abuse of process, and then appropriate action against the person making the disclosure will be taken. Having said that, the Company clearly understands that some disclosures may not result in any investigation or action at a later stage even though they are made in good faith. In such circumstances, no action would be initiated against the submitter of information. It is also clarified that this process should not be used as a grievance redressal mechanism.
Procedure of Investigation
All complaints received by the Ethics committee will be categorized in two broad categories:
Complaints against Senior Top Management Officers hereinafter referred as “C” Level officers. Complaints against others.
The Ombudsperson Function will carry out preliminary investigation of complaints received against employees other than “C” level officers and based on the findings of preliminary investigation report to Top management which shall decide upon further investigation and the next steps.
The complaints against “C” level officers will be dealt with by CEO’s Office.
Remedies and Discipline
If the company determines that a compliance or ethical violation has occurred, it will take the following actions as deemed fit to correct it:
Any person found guilty of violation of the Company’s Code of Conduct will be subject to disciplinary action up to and including termination of employment. Appropriate procedures, policies and controls will be established in all departments to ensure early detection of similar violation.
During the investigation period or at any time thereafter, if any employee is found to be (a) retaliating against the complainant, (b) coaching witnesses or (c) tampering with evidence, then it would lead to severe disciplinary action including termination of employment.
Investigating Officer:
To receive complaints and provide acknowledgment to the complainant. To maintain tracker for complaints raised along with action taken report. To forward complaints received against “C” level officers to CEO’s Office Carry out an initial investigation based on preliminary evaluation of complaint and the quality of information / evidence provided for complaints involving other than “C” Level officers. To present update on cases investigated and action taken report to Top-management every 15 days.
G) Whistle-blower
The Whistle-blower provides the complaint, which is the initial information related to a reasonable belief that an unethical activity has occurred. The motivation of a Whistle-blower is irrelevant to the consideration of the validity of the allegation.
Whistle-blower (including anonymous Whistle-blower) must provide all factual corroborating evidence, as is available/possible, to enable commencement of an investigation, material which demonstrates sufficient grounds for concern. However, the Whistle-blower shall refrain from obtaining evidence for which they do not have a right of access and no protection would be guaranteed to the Whistle-blower for having obtained information illegally.
The Whistle-blowers will not be immune to disciplinary action if he is found guilty of or is a party to the allegations.
Whistle-blower Protection
The Company will ensure to protect whistle-blowers against retaliation, as described below:
The Company prohibits retaliation against a whistle-blower with the intent or effect of adversely affecting the terms or conditions of employment (including but not limited to, threats of physical harm, loss of job, punitive work assignments, or impact on salary or wages). Whistle-blowers who believe that they have been retaliated against may file a written complaint with the Whistle-blower Committee (Management team and HR Head). A proven complaint of retaliation shall result in a proper remedy for the person harmed and severe disciplinary action including termination of employment against the retaliating person. This protection from retaliation is not intended to prohibit managers or supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.
Annexure 1: Illustrative List of Malpractices and EventsThis Policy can be amended, modified, or withdrawn at the company’s discretion. This policy shall be effective from the date of approval. Any deviation to this policy requires approval from CEO, in his absence the COO.
GRIEVANCE HANDLING POLICY
A. Background and Objective
The timely and effective handling of consumer Complaints/Concerns is fundamental to vidharbhalaxmi’ vidharnhalaxmi micro services foundation principles of Responsible Finance and its commitment to treat consumers fairly. We at vidharnhalaxmi micro services foundation are committed to promptly responding to and resolving customers’ Complaints/Concerns and driving appropriate adjustments to business practices to improve customer service and enhance risk management.
The objective of the policy is to ensure that:
All customers are treated fairly and without bias at all times. All issues raised by customers are dealt with courtesy and resolved on time.
Customers are made completely aware of their rights so that they can opt for alternative remedies if they are not fully satisfied with our response or resolution to their complaint.
B. Definition of a Complaint / Concern
Complaint/ Concern means an oral or written communication (including an electronic communication) that expresses dissatisfaction with a Vidharbhalaxmi product, service of employee or a third party service provider acting on Vidharbhalaxmi’ behalf.
C. Channels available for customers to report grievance
if a customer has a problem or wishes to register a complaint, they can reach us at any of the following access channel. Phone, Through Email, Interaction at Branch, Through Letter
D. Grievance redressal mechanism
1. Registration of Complaints
The Company enables customers to register a Complaint through multiple channels as mentioned above in Section C.
2. Acknowledgement & Receipt
Complaints/Concerns will be acknowledged upon receipt to the customer; acknowledgement will occur verbally, in writing, or electronically, depending on the channel received.
3. Resolution of Grievances
The Customer Care Team is responsible for resolution of complaint/ grievance to the customer’s satisfaction. Every attempt is made to offer the customer suitable and appropriate alternate solutions wherever possible. However, if the customer continues to remain dissatisfied with the resolution, he/ she/ it can escalate the issue through the grievance redressal mechanism as referred above.
4. Time frame
Suitable timelines have been set for every complaint depending upon the investigations which would be involved in resolving the same. Company will ensure that final decision is communicated to the complainant within 30days from the date of receipt of the complaint by the Company.
E. Complaint Lodgment and Escalation:
1st level: Branch Level Customer Service
Vidharbhalaxmi Micro has constituted Branch level Customer Service headed by Branch head. All complaints / grievances of customers should be addressed to the branch manager / officer in charge If not satisfied with the reply / action taken by them within 7 days, customers can escalate the matter to second level
2nd level: Head Office level
Please contact Customer Service by explaining the details of the issue concerned, write to
Head – Customer Care
Vidharbhalaxmi Micro Services Foundation.
Contact No: +91 9922224907 / +91 7058124907, Email id: vidharbhalaxmi2024@gmail.com / vishalk@vidharbhalaxmifs.com
3rd level: Grievance Redressal officer at Corporate Office
In case the complaint is not resolved within 10 days, please contact:
Mrs. JYOTI V. KANHIRE
Grievance Redressal Officer
Vidharbhalaxmi Micro Services Founadation.
2ND Floor No. S 201, GAJANAN APARTMENT III, M CROP (V.M.V.), BEHIND OM CELIBRATION LAWN
RAHATGAON RING ROAD, AMRAVATHI MAHARASHTA 444604
Contact No: 7058124907 / 9922224907, Email id: Jyoti@vidharbhalaxmifs.com / Jyotik@vidharbhalaxmifs.com
F. Reserve Bank of India –
As per the Reserve Bank of India Integrated Ombudsman Scheme, 2021, a customer can file his complaint before the Banking Ombudsman if the reply is not received from the bank within a period of 30 days after the bank/FI Concerned has received his representation, or the bank rejects the complaint, or the complainant is not satisfied with the reply given to him by the bank.
In line with the above Scheme, in case customers have not heard from us for 30 days or customers are not satisfied with the resolution provided by any of the above channels or individuals appointed by Vidharbhalaxmi Micro services foundation, please feel free to contact the Banking Ombudsman, a statutory body appointed by the Reserve Bank of India to look into the provision of satisfactory service by banks. Customer can refer the same through http://www.rbi.org.in.
Escalation to RBI -Ombudsman Scheme, 2021.
In case the complaint is not resolved within 30 days, please contact The Reserve Bank – Integrated Ombudsman Scheme, 2021: Complaints can be filed online on complaint lodging portal of the Ombudsman at https://cms.rbi.org.in Complaints can also be filed through the dedicated e-mail to CRPC@rbi.org.in or sent in physical mode to.
The ‘Centralised Receipt and Processing Centre’ Reserve Bank of India,
Officer-In-Charge / DNBS Nodal Officer, Department of Non-Banking Supervision,
Reserve Bank of India, Mumbai Regional Office, 3rd Floor,
Opp. Mumbai Central Railway Station,
Byculla, Mumbai – 400008
Additionally, a Contact Centre with a toll-free number – 14448 (9:30 am to 5:15 pm) – is also being operationalized in Hindi, English and in eight regional languages to begin with and will be expanded to cover other Indian languages in due course.The Contact Centre will provide information/clarifications regarding the alternate grievance redress mechanism of RBI and to guide complainants in filing of a complaint.
A copy of the Scheme is available on the RBI website and on the CMS portal (https://cms.rbi.org.in).