Whistle-blower Policy
Risk Educators Pvt Ltd (“REPL”) operating under the brand Global Risk Management Institute (“GRMI”) requires its directors, officers, employees, students, faculty, vendors, customers, interns, and volunteers, [as well as all persons who provide REPL with contracted services] to observe high standards of business and personal ethics in the performance of their duties on the Institute’s behalf.
The Institute is committed to protecting individuals from interference when making a “Protected Disclosure” (see definition below) and from retaliation for having made a Protected Disclosure or for having refused to follow an illegal instruction.
The principal objective of this Whistleblower Policy is to encourage and enable Institute representatives, without the fear of retaliation, to raise concerns regarding suspected unethical and/or illegal conduct or practices on a confidential and, if desired, anonymous basis, so that the Institute can address and correct inappropriate conduct and actions.
This policy is not intended to be the method for reporting violations of the Institute’s applicable human resources policies, problems with colleagues, co-workers, or supervisors, all of which should be handled in accordance with the Institute’s Personnel, Student Conduct Policies and the PGDRM Manual & HR Policy. Those policies, found in the Institute Statutes, the Handbook for Administrators, and the Student Handbook, are designed to address individual grievances and personal complaints.
The Institute will exercise its authority to take whatever action may be needed to prevent and correct activities that are found to constitute wrongful conduct.
Definitions
A. Wrongful Conduct Concern (“Concern”)
A violation of Institute policies; a violation of applicable local, Haryana State; or the use of Institute property, resources, or authority for personal gain or other non-Institute-related purposes.
B. Protected Disclosure
Communication about actual or suspected wrongful conduct engaged in by a Institute faculty member, staff member, student worker, volunteer, Staff, Faculty, Customer, vendor or contractor (who is not also the disclosing individual) based on a good faith and reasonable belief that the conduct has both occurred and is wrongful under Institute policies and/or applicable laws. Individuals who are aware of, or have reason to suspect wrongful conduct should report the conduct promptly.
Reporting Concerns
Concerns should be reported either in writing as soon as practicable to any one of the following:
1. President and Academic Council head
Handling Reporting Concerns
The Dean office receiving reports shall report them immediately to the Office of Academic Council, Board of Directors, or Management as applicable which, in consultation with the Office of Legal Counsel, has the responsibility for investigating concerns and issuing reports to the Board Committee on Audit and Risk Management (“Board Committee”).
Investigations
The Office of the Dean and responsible committee will attempt to notify the disclosing individual (when identity is known) to acknowledge receipt of the reported concern. All reports will be promptly investigated, and appropriate corrective action will be taken when warranted by the investigation. The Office shall determine the scope, manner, and parameters of any investigation and report to the Board Committee and appropriate Institute officers.
Reporting Responsibility
It is the responsibility of all Institute representatives to report, in good faith, concerns they may have regarding actual or suspected activities which my be illegal or in violation of the Institute’s policies with respect to, without limitation, fraud, theft, embezzlement, accounting, or auditing irregularities, bribery, kickbacks, and misuse of the Institute’s accounting or auditing irregularities, bribery, kickbacks, and misuse of the Institute’s assets, as well as any violations or suspected violations of high business and personal ethical standards.
No Retaliation
No Institute representative who in good faith reports a concern shall suffer intimidation, harassment, retaliation, discrimination, or adverse employment consequences because of such report. Any employee of the Institute who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including termination of employment.
Acting in Good Faith
Anyone reporting a concern must act in good faith and have reasonable grounds for believing that the information disclosed may indicate a violation of a law, Institute policy and/or ethical standards. Any allegations that prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
Confidentiality
The Institute takes seriously its responsibility to enforce this Policy, and therefore encourages any person reporting a concern to identify him or herself so as to facilitate any resulting investigation. Notwithstanding the foregoing, in reporting a concern, Institute representatives can request that their report be treated in a confidential manner (including that the Institute takes reasonable steps to ensure that the identity of the reporting person remains anonymous).
Concerns will be kept confidential to the extent possible, consistent with the need to conduct a thorough and complete investigation.
Records
The Institute will retain on a strictly confidential basis for a period of seven (7) Years (or otherwise as required under the Institute’s Record Retention and Disposal Policies in effect from time to time) all records relating to any reported Concern and to the investigation and resolution thereof. All such records are confidential to the Institute, and such records will be considered privileged and confidential, subject only to a lawful subpoena or other recognized government authorities.
Distribution
The Institute shall inform and provide a copy of this Policy to all Institute employees, officers, directors, student workers, and all other persons or contractors who provide substantial service to REPL.
