Purpose:
This policy outlines Amperehour Solar Technology Private Limited's commitment to conducting business with the highest standards of professionalism, honesty, integrity, and ethical behavior, in line with our Business Code of Practice. We recognize that situations may arise where these standards are not upheld, and any such violation is a serious concern. Employees play a crucial role in promptly reporting such issues. This policy aims to create a secure environment and encourage employees to report practices in good faith without fear of adverse personnel actions from managerial personnel.
Scope:
This policy applies to all business units, affiliates, suppliers, and contractors providing services to Amperehour Solar Technology Private Limited, including employees working in India and abroad, and business partners such as contractors, suppliers, agents, and consultants.
Reporting Coverage:
Complaints Topics mentioned in the following table will be entertained by ethics helpline:
The ethics helpline will entertain complaints concerning harassment and workplace practices/discrimination. Please note that issues related to performance appraisals, salary reviews, variable compensation,
promotions, and other Human Resources matters are outside the scope of this policy and should be addressed through normal organizational channels.
Violation of Code of Conduct
Fraud
Conflict of Interest
Corruption & Bribery
Harassment at Workplace or Discrimination
Before Reporting a Violation:
Before sending a report to ethicshelpline@amperehourenergy.com, please try to answer the following questions: Who, What, Where, Why, When, and How. If possible, provide appropriate contact details to the helpline, as your identity will remain anonymous.
Actions that are, or may reasonably be perceived as, violations of laws or the Amperehour Code of Conduct or Policies, Principles & Guidelines should be reported to your nearest Manager. Managers are expected to treat these matters seriously, maintain full confidentiality for the reporting person, and comply with Company policies and values. If your manager is unresponsive, unwilling to act, or involved in the issue, please report the issue to their manager. If this is not possible for the same reasons, reports/complaints can be communicated directly via email, fax, post, or a web link if available.
How to Report a Violation:
Amperehour manages our ethics helpline to ensure independence for reported matters. The following ethics helpline channels are available through Amperehour Solar Technology Private Limited:
A unique e-mail address is available, which is designed
to ensure the anonymity of the sender of the email
ethicshelpline@amperehourenergy.com
Investigation:
All reports under this policy will be promptly and appropriately investigated. All information disclosed during the investigation will remain confidential, except as necessary to conduct the investigation and take remedial action in accordance with applicable law. Management will complete the investigation within 90 days of receiving the complaint and submit its report to the Audit Committee. The Audit Committee will discuss the report with Company Management, and the Chairperson of the Audit Committee, in consultation with Management and Committee Members, will make the final decision.
Roles, Rights & Responsibilities of a Whistleblower:
Whistleblowers provide initial information based on a reasonable belief that wrongful conduct has occurred. The whistleblower's motivation is irrelevant to the validity of the allegations. However, intentionally filing a false report, whether orally or in writing, is considered an improper activity.
Whistleblowers must refrain from obtaining evidence to which they do not have a right of access, as improper access may be considered an improper activity. Anonymous Whistleblowers must provide sufficient supporting evidence to justify an investigation. An investigation into unspecified wrongdoing or broad allegations will not be undertaken without verifiable evidence. Since investigators cannot interview anonymous whistleblowers, it may be more difficult to evaluate the credibility of allegations, potentially making it less likely for an investigation to be initiated.
Whistleblowers are "reporting parties," not investigators. They should not conduct investigative activities on their own or participate in any investigative activities other than as requested by the investigating authority.
The whistleblower's identity will not be disclosed unless required by law for investigation purposes. Whistleblowers are encouraged to leave their contact details with the helpline provider in case the company requires additional relevant information. In such cases, the helpline provider will contact the whistleblower for information without disclosing their identity to the company. Whistleblowers can also choose to share their details with the company, in which case the company will no longer be obligated to withhold their identity.
A whistleblower's right to protection from retaliation does not grant immunity for any complicity in matters subject to the allegations or ensuing investigation, or any other misconduct or wrongdoing. This policy cannot be used as a defense by an employee against whom adverse personnel action has been taken for legitimate reasons or cause under Company rules and policies. It is not a violation of this policy to take adverse personnel action against an employee whose conduct or performance warrants such action, separate from that employee making a disclosure.
Whistleblowers may request an appearance before the Audit Committee to present their complaint. Such requests should be made directly to the Audit Committee. In appropriate or exceptional circumstances, the Audit Committee may allow the whistleblower to appear directly before them regarding their complaint. In cases of repeated frivolous complaints filed by an employee, the Audit Committee may take suitable action against the employee, including a reprimand.
Whistleblower Protection:
No unfair treatment will be meted out to a whistleblower for reporting a protected disclosure under this policy. The Company condemns any discrimination, harassment, victimization, or other unfair employment practices against Whistleblowers. Amperehour will not dismiss, discharge, demote, suspend, threaten, harass, or in any manner retaliate or discriminate against an employee for making a good-faith complaint, disclosing information related to a complaint as part of an investigation, or otherwise participating in an investigation relating to a complaint. Reprisals are considered a serious violation of this policy, and appropriate action will be taken to avoid further damage to the employee and to discipline those responsible for reprisals. If you have reasonable grounds to fear repercussions from reporting an alleged breach, you can inform the Managing Director of the Company.
The identity of the Whistleblower shall be kept confidential to the extent possible and permitted under law. Any other employee assisting in the investigation will also be protected to the same extent as the whistleblower.
Confidentiality:
All reports will be treated confidentially, and you will be granted complete anonymity if you request it at the time of reporting any violation.
Confidentiality:
Q. What will happen after I submit a report?
A. Your complaint will be documented and shared with the designated point of contact at Amperehour Solar Technology Private Limited, Pune. All complaints will be thoroughly investigated, and appropriate action will be taken based on the decision of the Audit Committee in consultation with Management and Committee members.
Q. How can I be sure that my report will remain anonymous and confidential?
A. Those who wish to remain anonymous can do so by not providing personal information when filing the complaint.
Q. I’m afraid of retaliation if I file a report. Should I be?
A. The whistleblower is protected from retaliatory or adverse personnel action for disclosing certain information, including but not limited to, suspected acts of fraud, corruption, or violations of the company
code of conduct.
Q. What happens if a claim is investigated and found to be untrue?
A. The investigation will stop as soon as the complaint investigator reaches a level of evidence that either validates or proves the claim false. If a claim is unsubstantiated, the report will be closed, and no further
action will be taken.
Q. What happens if a claim is investigated and found to be true?
A. If an investigation substantiates allegations with enough relevant and credible evidence, the investigation report will be presented to Management for necessary action.
Q. What is the turnaround time for the report to be closed?
A. The investigation will be completed within 90 days, and the report will be submitted to Amperehour Management by the Audit Committee.
