Whistler Blower Policy - Neuron Energy Pvt. Ltd.
1. Introduction:
Neuron Energy Private Limited (“the Company”) is committed to conducting its business with integrity and in compliance with all applicable laws and regulations. The Company values transparency and ethical behaviour and encourages employees, stakeholders, and other associated parties to report any unethical or unlawful behaviour.
2. Applicability:
This Whistleblower Policy (“the Policy”) establishes a framework for reporting concerns and ensures that whistleblowers are protected against retaliation. This Policy is applicable to the Company and all its subsidiary companies (collectively referred to as “the Neuron Energy Group”).
3. Objective:
The primary objectives of this Policy are:
a. To provide a mechanism for reporting concerns about unethical, illegal, or improper practices, including but not limited to:
• Fraudulent activities
• Non-compliance
• Corruption or bribery
• Misuse of Company resources
• Breach of confidentiality
b. To ensure confidentiality, protect whistleblowers, and prevent retaliation.
c. To promote adherence to applicable laws, rules, and regulations.
4. Scope:
This Policy is applicable to:
1. All employees (permanent, contractual, or temporary) of Neuron Energy.
2. Directors, officers, and stakeholders of Neuron Energy.
3. External stakeholders such as vendors, clients, and consultants associated with Neuron Energy.
5. Definition:
a. Whistleblower: A person or an entity making a disclosure of any unethical activity that they have observed. Whistleblowers could be Employees, contractors, contractor’s employees, clients, vendors, internal or external auditors, law enforcement/regulatory agencies or other third parties, or anyone who makes a Disclosure/reporting under this Policy.
b. Concern: Any act, omission, or behavior that:
• Violates laws, regulations, or internal policies.
• Endangers the environment, public health, or safety.
• Is fraudulent or corrupt in nature.
c. Investigator: A person or Whistle Blower committee / Board of Directors authorized by the Company to investigate the reported concerns.
d. Disciplinary Action: means any action that can be taken on the completion of /during the investigation proceedings including but not limited to a warning, imposition of fine, suspension from official duties or any such action as is deemed to be fit considering the gravity of the matter.
e. Complaint: It means a concern raised by a written communication by an Employee for any grievance that is personal in nature to the complainant and does not affect others.
6. Reporting Mechanism:
a. Concerns may be reported through any of the following channels:
• Email:
Send details to the mentioned email ID: manjula@neuronenergy.in
• Written Complaint:
Address a sealed envelope marked “Private & Confidential – Whistle Blower Complaint” to:
Chairperson, Whistle Blower Committee/Board of Directors.
505, Sai Heritage, Tilak Road, Ghatkopar (E)
• Anonymous Reporting:
Anonymous complaints will be reviewed based on the credibility of the information provided.
b. All complaints must include:
• A clear description of the concern or violation.
• Date, location, and parties involved.
• Any evidence, if available.
c. Anonymous reporting is permitted; however, whistleblowers are encouraged to disclose their identity
to facilitate a more thorough investigation.
7. Investigation Process:
a. Acknowledgment: The Company will acknowledge receipt of the concern within 7 working days.
b. Preliminary Review: A designated Investigator or Whistle Blower committee/Board of Directors will conduct a preliminary review to determine the validity of the concern.
c. Full Investigation: If warranted, a detailed investigation will be conducted.
d. Resolution: Based on findings, appropriate corrective and disciplinary actions will be taken.
e. Feedback: Whistleblowers will be informed of the outcome, subject to confidentiality constraints.
8. Protection Against Retaliation:
a. Neuron Energy strictly prohibits any form of retaliation, discrimination, or harassment against whistleblowers.
b. Any individual found retaliating against a whistleblower will face disciplinary action, including termination of employment.
c. Whistleblowers who believe they have faced retaliation may report directly to Chairperson of Audit committee/Board of Directors if formulated or Board of Directors.
9. Confidentiality
The identity of the whistleblower and details of the reported concern will be kept confidential, except as required by law or to facilitate the investigation process.
10. Accountabilities Of Whistleblowers:
The following are the accountabilities of the Whistleblower(s):
• Bring to early attention of the Company any improper practice they become aware of. Although they are not required to provide proof, they must have sufficient cause for concern. Delay in reporting may lead to loss of evidence and also financial loss for the Company;
• Avoid anonymity when raising a concern;
• Follow the procedures prescribed in this Policy for reporting or making a Disclosure;
• The intent of the Policy is to bring genuine and serious issues to the fore and it is not intended for petty disclosures. Malicious allegations by Employees may attract Disciplinary Action;
• A Whistleblower has the right to protection from retaliation. But this does not extend to immunity for involvement in the matters that are the subject of the allegations and investigation; and
• Maintain confidentiality of the subject matter of the Protected Disclosure and the identity of the persons involved in the alleged malpractice. It may forewarn the Subject and important evidence is likely to be destroyed.
11. Responsibilities
a. Audit Committee: The Audit Committee of the Company (if formulated) shall oversee the implementation of this Policy and review whistleblower concerns periodically. In absence of Audit Committee, Board of Directors shall oversee the implementation.
b. Board of Director: The Board of Directors of the Company shall ensure adherence to this Policy.
12. Review and Amendments
This Policy will be reviewed periodically by the Board of Directors in consultation with Compliance department and amended as necessary to ensure compliance with applicable laws and regulations.
13. Communication
The Policy shall be communicated to all employees and stakeholders through internal channels and made available on the Company’s website.