TVS INDUSTRIAL & LOGISTICS PARKS PVT LIMITED

CIN: U45200MH2005PTC154628

Vigil Mechanism

Objective

a) To provide for safe avenues for all Directors and employees to raise concerns when violations take place directly or indirectly, intentionally or otherwise, which would bring disrepute to the strong edifice built by TVS Industrial & Logistics Parks Private Limited (“Company” which expression shall also include its subsidiary companies), on the foundations of high standards of integrity, dedicated customer service, fair business practices, efficient, safe and trusted financial policies, highest levels of compliance with all applicable laws in letter and spirit.

b) To provide necessary safeguards for protection to the directors and employees from victimization for whistle blowing in good faith.

Applicability
This policy shall be applicable to all directors and employees of the Company.

Main features

To be used for reporting any serious actual or suspected frauds, concerns relating to financial matters/ reporting, unethical or illegal conduct or actual or possible violation of code of conduct / ethical standards actions which are not in line with the applicable policies of the Company, actions which would affect the Company’s image or reputation, actions which are in the nature of harassment or actions that would amount to serious improper conduct.

Procedure

1) Whistle Blowers
Directors and Employees making disclosure under this policy is referred to as “Whistle Blower” or “Complainant”. The Whistle Blower has to demonstrate or provide sufficient grounds for his / her concern, but should not make any malicious allegations which would result in disciplinary action.

2) Whom to Report
The Complainant should submit the report raising the concern to the Chairman of the Audit Committee of the Company.

3) When to Report
The Complainant shall raise the issue immediately / promptly but within a reasonable period of the event / action / finding but not later than 45 consecutive days.

4) How to Report
The report should include as much information about the suspected violation. Where possible, it should describe the nature of the suspected violation; the identities of persons involved in the suspected violation; a description of documents that relate to the suspected violation and the time frame during which the suspected violation occurred. The Complainant may be required to give further information.

5) Making a protected disclosure
Any Director/employee covered by this policy and the issue concerning financial/ accounting matters may make a disclosure in writing, duly addressed to the Chairman of the Audit Committee as early as possible, but not later than 45 consecutive days after becoming aware of the issue, through email/letter.

The Complainant must put his / her name to allegations, for timely resolution of the issue and for ensuring that adequate protection is granted to him / her under the policy. No anonymous allegation will be entertained.
The written disclosure must ensure the following:
 disclosure to be typed or written in legibly either in English or Hindi or in
regional language of place of employment.
 clear understanding of the issue is brought out.
 actual facts are explained in the issue, and it is not merely speculative.
 specific information is provided to the maximum extent to allow conduct of
Investigation.
 financial or other impact (if any) to be detailed.
 in case the issue was previously brought out, outcome of the same.

6) Contact Details
Chairman of the Audit Committee, TVS Industrial & Logistics Parks Private Limited,

9th Floor , Iconic Building, Urmi Estate, Ganpatrao Kadam Marg, Opposite Peninsula Business Park, Lower Parel West, Mumbai, Maharashtra 400013.

7) Investigation
All reports under this policy will be investigated promptly by the Chairman of the Audit Committee or any committee formed by the Chairman of the Audit Committee at his discretion.

If, at the conclusion of its investigation, the Company determines that a violation has occurred, the Company will take effective remedial action commensurate with the nature of the offence. Reasonable and necessary steps will also be taken to prevent any further violations.

8) Safeguards against victimization
i) No adverse action shall be taken or recommended against a Complainant in retaliation to his/her blowing the whistle. Harassment / victimization of the Complainant will constitute sufficient ground for dismissal of the concerned director/ employee.
ii) Source of information to the Complainant shall be disclosed to facilitate investigation.
iii) Every effort will be made to protect the Complainant’s identity subject to any legal constraints that may arise from time to time.
iv) This policy will also be reviewed by the Audit Committee based on necessity.