Cusin Pvt. Ltd. (“the Company” or “Cusin”) is committed to adhere to the highest standards of ethical, moral and legal conduct of its business operations. To maintain these standards, the Company has formulated several policies to assist its employees in achieving and maintaining these standards.
The purpose of the Whistle Blower Policy (“the Policy”) is to provide an avenue for employees to report matters without the risk of subsequent victimization, discrimination or disadvantage. The Policy applies to all employees working for the Company and its subsidiaries.
A whistle-blowing or reporting mechanism as such set out in the Policy, invites all employees to act responsibly to uphold the reputation of the Company and its subsidiaries. The Policy aims to ensure that serious concerns are properly raised and addressed and are recognized as an enabling factor in administering good governance practices.
The Company adopts accounting policies and practices in accordance with the applicable accounting standards to present a true and fair view of its operations and financial position. Selection of accounting practices requires interpretation and exercise of judgement, which may give rise to differing opinions. Employees are free to raise issues, if any, which they may have on the accounting policies and procedures adopted for any area or item and discuss the same.
2.1. Investigation Committee: Investigation Committee (“the Committee”) constituted by the Board of Directors of the Company as per Companies Act.
2.2. Employee: An employee is every bona-fide employee currently in the employment of the Company and/or any of its subsidiaries.
2.3. Subsidiary Company: Subsidiaries as per the last available Published Accounts of the Company are classified as subsidiary companies.
2.4. Retaliation / Victimization: Retaliation is any act, direct or indirect, recommended, threatened or taken against a Whistle Blower by any person because the Whistle Blower has made a disclosure pursuant to the Policy. Retaliation includes overt/covert acts of:
2.5. Whistle Blower: A Whistle Blower means any employee who raises a concern in accordance with this Policy.
2.6. Whistle Blowing 'Concern' or 'Complaint': Whistle blowing (also referred to as 'complaint' or 'concern') can be described as attracting management's attention to information about potentially illegal and/or unacceptable practices. Employees can raise concerns/issues on:
The employee may report concern(s) by visiting the website: https://Cusin.com/.
Upon receiving the concern, an acknowledgment shall be sent to the employee (if email or address is provided), confirming receipt and stating that it will be investigated and reported to the Audit Committee.
If the concern falls outside the Policy’s scope, it will be forwarded to the appropriate department.
The Investigation Committee shall promptly begin an inquiry and report the concern and its status in the next quarterly Audit Committee meeting. The full inquiry should be completed within 90 days, unless more time is needed. Closure status will be tracked and reported.
Once resolved, the concern will be marked as closed, and relevant actions like legal steps or disciplinary action will be taken. Status of open and closed concerns is reported quarterly to the Audit Committee.
Protection is available if the employee:
The Company will protect such employees from sanctions or disadvantages and will act against misuse of the policy.
Concerns related to retaliation must be reported within 3 months. Post this period, it will not be treated under this policy.
Employees may raise complaints anonymously. All cases will be treated confidentially. If necessary, the identity may be disclosed during investigation on a “need to know” basis and with the employee's consent. This will not affect employment terms.
All complaint records will be maintained by the HR Team.
The Company reserves the right to amend this Policy without any reason. The HR Team will ensure communication of the updated Policy periodically.
The Whistle Blower may report his/her concern(s) by visiting:
Complaints submitted through the website are sent to the official email:
Auto-reply message: “Thanks for raising the issue. Your complaint has been submitted successfully in our records. We will get back to you shortly.”