We at Digital Connexion believe that best practice governance, controls and compliance are essential for maximizing shareholder value. In order to achieve this, we must act with integrity and honesty in everything we do thereby helping customers to have confidence when entrusting their business to the Company. We are therefore committed to high moral and ethical standards in all our business activities. As employees and representatives of Digital Connexion, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
The objective of this policy is:
This Whistle Blower Policy applies to all directors, officers, and employees across the organization.
Every employee is responsible for reporting any conduct within the Company that the employee reasonably believes might:
If an employee is aware of a violation and does not report it, he/she may be held equally culpable as the guilty party and may face disciplinary action leading to termination.
A person or entity making a protected disclosure is commonly referred to as a whistleblower. Whistleblowers may be employees, applicants for employment, vendors, contractors or the general public. The whistleblower’s role is a reporting party. They are not investigators or finders of fact, nor do they determine the appropriate corrective or remedial action that may be warranted.
In the first instance, an employee should speak to their reporting manager about their concerns and explain the reason for their concerns. A meeting with the employee’s reporting Manager to discuss the concern more fully should normally be held within 48 hours, although this will depend upon the seriousness of the concern.
Any employee who is uncomfortable making a report to his or her direct Reporting Manager or supervisor should raise their concerns with either
No Employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequences. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower policy is intended to encourage and enable employees and others to raise serious concerns within Company rather than seeking resolution outside the company.
Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
All records relating to any accounting allegation, Legal allegation, report of a retaliatory act or the investigation of any such Report shall be retained for a period of five years.
As a Digital Connexion employee, you are responsible for reporting actual or suspected violations of the CoC and for seeking clarification and guidance on ethics, compliance, and legal issues. All Employees, Directors, members, or other stakeholders associated with the Company may report an actual or suspected ethical violation, or seek guidance, through the following Ethicsline reporting channels:
|- India Toll-Free: 1800-102-6969
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Please provide Access Code: BAMDLR
|BAM DLR, C/o Integrity Matters, Unit 1211, CENTRUM, Plot No C-3, S.G. Barve Road, Wagle Estate, Thane West – 400604, Maharashtra, India
Ethicsline is operated by an independent external third-party specialist service provider “Integrity Matters”. Employees who contact Ethicsline will be assigned a unique report key that they may use to check on the status of reports and inquiries. When using the Ethicsline you will have a choice to remain anonymous. It is vitally important for you to keep your report number in a safe place so you can follow up on your concern or question. The report number, if lost, cannot be retrieved. We may have follow-up questions about your concern, and you can assist with the investigation by calling or logging back into the web reporting site to provide additional details. We request you to provide as much information as possible. Without all of the facts and complete information, it may be difficult for us to get to the bottom of your concerns or questions.