Whistle Blower Policy

Purpose:

OIT believes in the conduct of its operations in a fair and transparent manner by adopting the 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 that 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, the 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 the 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.
• Whistle blowing ‘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.
• Audit Committee: The Committee is already set up to investigate matters being covered under the Policy and shall review the functioning of the vigil mechanism.

Applicability

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

• Breach of any law, statute, or regulation by the Company.
• Issues related to accounting policies and procedures adopted for any area or item
• Misuse or suspected misuse of office, actual fraud
• Leakage of Unpublished Price Sensitive Information (UPSI) resulting in financial loss or reputation.
• 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 Audit 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 Audit Committee set up 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 head of Human Resources or any other person/official authorized by the Audit Committee.

Dissemination of information about the Policy

The policy is disclosed on the Website of the Trust. Queries/clarifications under the Policy would be handled by the Head of Human Resources.