Whistle Blower Policy

Purpose:

OIT believes in the conduct of its operations in a fair and transparent manner by adopting highest standards of professionalism, integrity, honesty and ethical behavior. Toward this end, OIT’s Whistle Blower Policy provides a platform for its’ Directors, Employees, Clients, Customers and Other Stakeholders to raise genuine concerns and grievances by internally disclosing information which they believe show serious malpractice, impropriety, abuse or wrongdoing within the Company, or in the dealings of the Company with other persons or constitutes a violation of OIT’s Code of Business Conduct and Ethics Policy without fear of reprisal or victimization.

Policy Objectives:

• The policy shall create an environment free of unfair practices and, unethical conduct. It supplements the OIT Code of Conduct and encourages employees to report matters of unethical behavior without fear of reprisal or victimization
• It shall provide a platform to voice concerns in a responsible and effective manner.
• It shall provide a platform to disclose information, confidentially and without fear of reprisal or victimization, where there is reason to believe that there has been serious malpractice, fraud, impropriety, abuse, or wrongdoing within the Company.
• Shall ensure that no one is disadvantaged as a result of raising concerns
• The policy supports Whistle Blowers and does not in any way intend to limit any protections provided to Whistle Blowers by any applicable laws or regulations, or to place any limits on a Whistle Blower’s ability to communicate with government, administrative, or law enforcement authorities, as provided for by law.
• Shall increase the efficacy of the internal disclosure systems by enabling the Disclosure of information independently of line management for employees

Definitions:

Unless otherwise specified in this Policy, the following terms shall bear the meanings respectively assigned to them herein.

• Employee: An employee is every bona fide employee currently in the employment of the Company. For the purpose of this Policy, employee includes directors of the Company.
• Chief Compliance Officer: Chief Compliance Officer is the Officer of the Company appointed by the Board of Directors in order to ensure compliance with the regulatory framework set by IRDAI.
• Retaliation/Victimization: Any direct/indirect act taken against Whistle-Blower because of him making a disclosure pursuant of the OIT Whistle Blower Policy. Retaliation includes, but is not restricted to:
• Any form of discrimination
• Reprisal
• Harassment covering Mental or Physical
• Vengeance

• Whistle Blower: Any Employee of the firm who has raised concern in accordance with this Policy.
• Whistleblowing ‘Concern’ or ‘Complaint’ (also referred to as ‘complaint’ or ‘concern’) any complaint made for attracting management’s attention to information about potentially illegal and/or unacceptable practices that the individual is aware of or witnessed.
• Disciplinary Committee: Committeeset up to investigate matters being covered under the Policy. The Key Management Team (KMT) of OIT act as the Disciplinary Committee of the Company. The CEO of the Company may at his discretion re-constitute the Committee at any point of time with any Officer(s) of the Company as deemed appropriate

Applicability

• Illustrative Acts of wrongdoings: Any possibilities / apprehensions of the following types can be reported as per the guidelines set by the Policy:

3.1. Breach of any law, statute or regulation by the Company.
3.2. Issues related to accounting policies and procedures adopted for any area or item
3.3. Misuse or suspected misuse of office, actual fraud
3.4. Leakage of Unpublished Price Sensitive Information (UPSI) resulting in financial loss or reputation.
3.5. Any form of Criminal offence

To be considered under the Policy, the complainant (i.e., employee or director making the complaint) is encouraged to provide the following information in his/her complaint which will be kept confidential:

• name,
• contact details,
• employee number and department.

Without this information provided by the complainant the complaint will be considered anonymous, and the Disciplinary Committee would dismiss it and not proceed with the inquiry.

Remedial/Disciplinary Action

Appropriate remedial action can be taken up after investigation of the concern/complaint made by Employee. This stands true in case of the complaint/concern found valid and true. Corrective disciplinary action, as deemed appropriate by the Disciplinary Committee set up for the purpose will be taken.

Confidentiality and Anonymity

Strict confidentiality shall be maintained about the identity of the complainant, both during and post investigation. It would not be revealed unless required by the law.

Record Keeping

Records pertaining to the complaint shall be maintained by the Disciplinary Committee.

Dissemination of information about the Policy

Policy is disclosed on Website/Annual Report. Queries/clarifications under the Policy would be handled by the Chief Compliance Officer, or Head of Human Resources.