1. PREAMBLE:

• Whistle blowing, in its simplest form, involves reporting of wrongdoing within our Bank either to internal or external parties. Disclosures of such information in the public interest by the staff / public has gained acceptance by banks for ensuring better governance standards and transparency. Instances of fraudulent activities by staff/ members may result in substantial financial loss, loss of goodwill or even penal action against the officials of the Bank.
• Our Central Government had passed a Resolution in April 2004 authorizing the Central Vigilance Commission (CVC) as the Designated Agency to receive written complaints or disclosure on any allegation of corruption or of misuse of office and recommend appropriate action.
• The jurisdiction of the CVC is restricted to staff of the Central Government and other authorities, corporations, companies etc owned or controlled by it.
• Our Bank has, decided to draw up a Whistle-Blower Policy, keeping in line with our traditions of good governance and transparency.

2. OBJECTIVE

• To provide staff, depositors, borrowers, members etc an avenue to raise concerns of corruption, misuse of office, criminal offences, suspected/actual fraud, failure to comply with existing rules and regulations such as the Banking Regulation Act,1949 (AACS) and actions resulting in financial loss, operational risks, loss of reputation etc detrimental to the depositors/ Bank/ members/public interests.
• A Whistle-Blower Policy and its effective enforcement has the potential not only to significantly reduce fraudulent activity but also to send a signal to both internal and external constituencies that the Bank exercises good corporate Governance.
• The objective of this Policy is also to provide necessary safeguards for the protection of the staff from reprisal or victimization for whistle blowing in good faith.

3. VALIDITY OF THE POLICY

• The present Policy will be effective from date of approval by Board till the next policy is revised and ratified by Board.

4. SCOPE AND COVERAGE

• Under the Policy all staff of the Bank, depositors/ borrowers / shareholders / public having sufficient grounds for concern can lodge the complaints. The complainant would be referred to as the “Whistle Blower”.
• These complaints can pertain to the acts of omission and commission by any of the staff of any of the Branches/Departments/Head/Admin Office.
• In the case of our Bank, the reporting of the complaint will be to an internal agency, at least for the present. This person will be the called the Ombudsperson.

5. MAIN FEATURES OF THE POLICY

The Policy is intended to cover the following serious and sensitive concerns :

• • Acts that are unethical/ immoral/ illegal
  • Actions that would amount to serious improper conduct.
  • Actions that may lead to / has lead to financial frauds/incorrect and misleading financial reporting.
  • Actions that are in contravention of the various policies/rules framed by RBI the regulators & the Bank from time to time.
  • The Ombudsperson will be a senior level officer with proven track record and well respected for his/her integrity, independence and fairness. The General Manager will be the Ombudsperson for the present and he will receive all the complaints under this Policy and ensure appropriate action.
  • Concerns expressed anonymously/pseudonymously will not be usually entertained. However, if the matter is of a very serious nature, the Ombudsperson may initiate an investigation independently.
  • The complainant should give his/her name and address either in the complaint itself or in a covering letter. In the case of an employee making such a complaint, details such as name, designation, department, and place of posting should be furnished. Follow-up questions and investigation may not be possible unless the source of the information is identified.
  • The text of the complaint should be carefully drafted so as not to give any details or clue to the complainant’s identity. The details of the complaint should be specific and verifiable.
  • The complaint should be sent in writing with sealed/closed envelope marked as “CONFIDENTIAL”
  • The envelope should be addressed to The Ombuds person, The Amreli Jilla Madhyastha Sahakari Bank Ltd., “Bhojalram Bhavan”, Rajmahel Road, Amreli-365601.
  • The complainant will receive an acknowledgement on receipt of the complaint.
• All complaints received will be recorded and looked into. If the initial enquiries by the Ombuds person indicate that the concern has no basis, or it is not a matter to be pursued under this Policy, it may be dismissed at the initial stage itself and the decision documented.
• If there appears to be some truth in the complaint, an independent investigation will be ordered by the Chairman / Board.
• The investigation will be carried out either by the Ombudsperson alone or by a Committee nominated by the Chairman / Board. The investigation would be conducted in a fair manner, as a neutral fact-finding process and without presumption of guilt.
• The frequency of contact between the complainant and the body investigating the matter will depend on the nature of the issue and the clarity of information provided. Further information may also be sought from him / her.
• Based on a thorough examination of the findings, the Ombudsperson / the Committee will prepare a report of the findings which would also recommend an appropriate course of action to the Chairman / Board.
• All discussions in the matter will be minuted and the final report prepared.
• Appropriate action will be initiated against the employee, wherever warranted.
• Appropriate administrative steps will be taken for redressing the loss, if any, caused to the Bank, as a result of the corrupt act or misuse of office, or any other offence covered by the Policy.
• Criminal proceedings, if warranted by the facts and circumstances of the case, will be initiated.
• Corrective measures to prevent recurrence of such events in future will be taken.
• Subject to legal constraints the complainant will receive information about the outcome of any investigation.

6. SAFE GUARDS

(i) CONFIDENTIALITY & PROTECTION TO WHISTLE BLOWER :

The Bank will protect the confidentiality of the complainants and their names / identity will not be disclosed except as statutorily required under law. No adverse penal action shall be taken or recommended against an employee in retaliation to his disclosure in good faith of any unethical and improper practices or alleged wrongful conduct. It will be ensured that the Whistle Blower is not victimized for making the disclosure. In case of victimization in such cases, serious view will be taken including departmental action on such persons victimizing the Whistle Blower. Identity of the Whistle Blower will not be disclosed to the Investigating Official. If any person is aggrieved by any action on the ground that he is being victimized due to the fact that he had filed a complaint or disclosure, he may file an application before the Board of Directors in the matter, where in the Board of Directors may give suitable directions to the concerned person or the authority.

(ii) HARASSMENT OR VICTIMISATION

• Harassment or victimization of the complainant will not be tolerated and could constitute sufficient grounds for dismissal of the staff found guilty of such behaviour.

(iii) DISQUALIFICATIONS FROM PROTECTION

i.    Protection under the Policy would not mean protection from departmental actionarisingoutoffalseorbogusdisclosuremadewithmalafideintention or complaints made to settle personal grievance. ii.   Whistle Blowers, who make any disclosures, which have been subsequently found to be malafide or frivolous or malicious shall be liable to be prosecuted and appropriate disciplinary action will be taken against them under Service Rules/ bipartite settlements only when it is established that the Complaint has been made with intention of malice.

7. REPORTING

• The Ombuds person will provide quarterly reports on the number of complaints received and the status of each of them to the Chairman of the Board.

8. CHANGES TO THE POLICY

• This Policy can be reviewed, modified, changedat any time by the Board.

9. RESPONSIBILITY AND ACCOUNTABILITY:

10. PROCESS FLOW CHART