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Whistle-Blower Policy
Issued on: 15/08/2024
Responsible: Directors/General Manager
The Whistle-Blower Policy at Cramlington Precision Forge Ltd. (CPFL) is designed to provide a secure and confidential framework for employees, contractors, suppliers, customers, and other stakeholders to report concerns about unethical behavior, violations of company policies, or illegal activities within CPFL. The Policy ensures that individuals can raise concerns without fear of retaliation, and it commits CPFL to investigating all reported matters thoroughly and impartially.
2. Scope
This Policy applies exclusively to CPFL and extends to all CPFL employees, contractors, suppliers, customers, and any other stakeholders. It covers the reporting of suspected or actual illegal, unethical, or improper conduct, including but not limited to:
Fraud or financial irregularities
Corruption, bribery, or other unlawful acts
'Violations of CPFL's Code of Conduct
Environmental, health, and safety violations
Harassment, discrimination, or other forms of misconduct
Any other illegal or unethical activities
3. Reporting Mechanisms'
CPFL encourages all stakeholders to report any concerns through the following channels:
Email: A secure email address where concerns can be submitted anonymously or with contact details.
Online Portal: A secure, confidential online platform for reporting concerns.
In-Person: Reports can be made directly to the General Manager-HR or another designated officer within CPFL.
4. Confidentiality
CPFL is committed to maintaining the confidentiality of all whistle-blowers. All reports will be handled in a manner that protects the whistle-blower’s identity, except when disclosure is necessary for a thorough investigation or required by law. In such cases, CPFL will inform the whistle-blower before any disclosure is made.
5. Non-Retaliation
CPFL strictly prohibits retaliation against any individual who reports a concern in good faith. Retaliation may include, but is not limited to, dismissal, demotion, harassment, or any form of discrimination. Any employee found to be engaging in retaliatory actions will face disciplinary measures, up to and including termination of employment.
6. Investigation Process
Upon receiving a report, CPFL will:
Acknowledge Receipt: Confirm receipt of the report to the whistle-blower (if contact details are provided).
Initial Assessment: Conduct an initial assessment to determine the validity of the concern and the appropriate course of action.
Investigation: Assign a team to conduct a thorough investigation, ensuring that the process is fair, unbiased, and confidential.
Outcome: Upon conclusion of the investigation, CPFL will take appropriate corrective actions if necessary and inform the whistle-blower of the outcome, where applicable.
Record Keeping: All reports and investigations will be documented and securely stored, ensuring records comply with CPFL’s data retention policies and applicable laws.
Responsible: Directors/General Manager
The Whistle-Blower Policy at Cramlington Precision Forge Ltd. (CPFL) is designed to provide a secure and confidential framework for employees, contractors, suppliers, customers, and other stakeholders to report concerns about unethical behavior, violations of company policies, or illegal activities within CPFL. The Policy ensures that individuals can raise concerns without fear of retaliation, and it commits CPFL to investigating all reported matters thoroughly and impartially.
2. Scope
This Policy applies exclusively to CPFL and extends to all CPFL employees, contractors, suppliers, customers, and any other stakeholders. It covers the reporting of suspected or actual illegal, unethical, or improper conduct, including but not limited to:
Fraud or financial irregularities
Corruption, bribery, or other unlawful acts
'Violations of CPFL's Code of Conduct
Environmental, health, and safety violations
Harassment, discrimination, or other forms of misconduct
Any other illegal or unethical activities
3. Reporting Mechanisms'
CPFL encourages all stakeholders to report any concerns through the following channels:
Email: A secure email address where concerns can be submitted anonymously or with contact details.
Online Portal: A secure, confidential online platform for reporting concerns.
In-Person: Reports can be made directly to the General Manager-HR or another designated officer within CPFL.
4. Confidentiality
CPFL is committed to maintaining the confidentiality of all whistle-blowers. All reports will be handled in a manner that protects the whistle-blower’s identity, except when disclosure is necessary for a thorough investigation or required by law. In such cases, CPFL will inform the whistle-blower before any disclosure is made.
5. Non-Retaliation
CPFL strictly prohibits retaliation against any individual who reports a concern in good faith. Retaliation may include, but is not limited to, dismissal, demotion, harassment, or any form of discrimination. Any employee found to be engaging in retaliatory actions will face disciplinary measures, up to and including termination of employment.
6. Investigation Process
Upon receiving a report, CPFL will:
Acknowledge Receipt: Confirm receipt of the report to the whistle-blower (if contact details are provided).
Initial Assessment: Conduct an initial assessment to determine the validity of the concern and the appropriate course of action.
Investigation: Assign a team to conduct a thorough investigation, ensuring that the process is fair, unbiased, and confidential.
Outcome: Upon conclusion of the investigation, CPFL will take appropriate corrective actions if necessary and inform the whistle-blower of the outcome, where applicable.
Record Keeping: All reports and investigations will be documented and securely stored, ensuring records comply with CPFL’s data retention policies and applicable laws.
7. False Reports
While CPFL encourages all stakeholders to report concerns, it is crucial that these reports are made in good faith. Deliberately making false reports or providing misleading information is a serious offense and may result in disciplinary action, including termination of employment or legal action against the reporting individual.
8. Responsibilities
Compliance Executive Vice-President: Oversees the implementation of this Policy, ensuring all reports are handled appropriately, and that the whistle-blower mechanisms are effective and accessible.
Management: All levels of management are responsible for promoting a culture of openness and accountability and ensuring that employees are aware of this Policy.
Employees: Responsible for reporting any concerns in good faith and cooperating with any investigations arising from a whistle-blower report.
9. Training and Awareness
CPFL will provide training on the Whistle-Blower Policy as part of the company’s broader ethics and compliance program. All employees must complete this training and acknowledge their understanding of the Policy. CPFL will also raise awareness of the whistle-blower mechanisms among other stakeholders through appropriate communication channels.
10. Monitoring and Review
The Compliance Executive Vice-President will monitor the effectiveness of this Policy and the whistle-blower mechanisms, reporting regularly to the Executive Committee. This Policy will be reviewed at least every five years or as necessary to ensure it remains relevant and effective.
11. Consequence Management
Non-compliance with this Policy, including retaliation against a whistle-blower or failure to report a known concern, may result in disciplinary action as outlined in CPFL’s Consequence Management Policy.
12. Final Provisions
In the event of any conflict between this 'Policy and CPFL's Bylaws, the Bylaws shall prevail, and this Policy will be amended accordingly. This Policy is effective upon approval by the Board of Directors.
13. Approvals
Description: General Manager
Drafting: HR
Approval: General Manager (CPFL-15/08/2024)
This Whistle-Blower Policy document is specifically tailored for CPFL, ensuring that all stakeholders have a safe and confidential way to report concerns, while protecting the rights and identities of whistle-blowers and maintaining the integrity of CPFL’s operations.
While CPFL encourages all stakeholders to report concerns, it is crucial that these reports are made in good faith. Deliberately making false reports or providing misleading information is a serious offense and may result in disciplinary action, including termination of employment or legal action against the reporting individual.
8. Responsibilities
Compliance Executive Vice-President: Oversees the implementation of this Policy, ensuring all reports are handled appropriately, and that the whistle-blower mechanisms are effective and accessible.
Management: All levels of management are responsible for promoting a culture of openness and accountability and ensuring that employees are aware of this Policy.
Employees: Responsible for reporting any concerns in good faith and cooperating with any investigations arising from a whistle-blower report.
9. Training and Awareness
CPFL will provide training on the Whistle-Blower Policy as part of the company’s broader ethics and compliance program. All employees must complete this training and acknowledge their understanding of the Policy. CPFL will also raise awareness of the whistle-blower mechanisms among other stakeholders through appropriate communication channels.
10. Monitoring and Review
The Compliance Executive Vice-President will monitor the effectiveness of this Policy and the whistle-blower mechanisms, reporting regularly to the Executive Committee. This Policy will be reviewed at least every five years or as necessary to ensure it remains relevant and effective.
11. Consequence Management
Non-compliance with this Policy, including retaliation against a whistle-blower or failure to report a known concern, may result in disciplinary action as outlined in CPFL’s Consequence Management Policy.
12. Final Provisions
In the event of any conflict between this 'Policy and CPFL's Bylaws, the Bylaws shall prevail, and this Policy will be amended accordingly. This Policy is effective upon approval by the Board of Directors.
13. Approvals
Description: General Manager
Drafting: HR
Approval: General Manager (CPFL-15/08/2024)
This Whistle-Blower Policy document is specifically tailored for CPFL, ensuring that all stakeholders have a safe and confidential way to report concerns, while protecting the rights and identities of whistle-blowers and maintaining the integrity of CPFL’s operations.
