1.

1 INTRODUCTION

Etymologically the term “ethics” correspond to the Greek word “ethos” which means character,
habit, customs, ways of behaviour, etc. Ethics is also called “moral philosophy”. The word
“moral” comes from Latin word “mores” which signifies customs, character, behaviour, etc.
Thus ethics may be defined as the systematic study of human actions from the point of view of
their rightfulness or wrongfulness, as means for the attainment of the ultimate happiness. It is the
reflective study of what is good or bad in that part of human conduct for which human has some
personal responsibility. In simple words ethics refers to what is good and the way to get it, and 2
what is bad and how to avoid it. It refers to what ought to be done to achieve what is good and
what ought not to be done to avoid what is evil. As a philosophical discipline, ethics is the study
of the values and guidelines by which we live. It also involves the justification of these values
and guidelines. It is not merely following a tradition or custom. Instead it requires analysis and
evaluation of these guidelines in light of universal principles. As moral philosophy, ethics is the
philosophical thinking about morality, moral problems, and moral judgements. Ethics is a
science in as much as it is a set or body of reasoned truths organised in a logical order and having
its specific material and formal objects. It is the science of what human ought to be by reason of
what one is. It is a rational science in so far as its principles are deduced by human’s reason from
the objects that concern the free will. Besides it has for its ulterior end the art by which human
may live uprightly or comfortably to right reason. It is a normative/regulative science in as much
as it regulates and directs human’s life and gives the right orientation to one’s existence. Ethics is
also theoretical and practical. It is theoretical in as much as it provides the fundamental
principles on the basis of which moral judgements are arrived at. It is practical in as much as it is
concerned about an end to be gained, and the means of attaining it. Ethics is sometimes
distinguished from morality. In such cases, ethics is the explicit philosophical reflection on moral
beliefs and practices while morality refers to the first-order beliefs and practices about good and
evil by means of which we guide our behaviour (e.g. music and musicology). However, in most
cases they are referred to as having the same meaning. Ethics is not merely a set of ‘codes’.
Ethics certainly deals with moral codes yet one cannot identify ethics to moral codes. Ethics is
not primarily to restrict one’s behaviour, rather to help one to find what is good and how to get it.
The obligatory character of ethical norms derives from the very purpose of ethical enquiry, i.e. to
discover the most ultimate principles of explanation or the most ultimate reasons why one ought
to do anything.

1.2 SCOPE OF ETHICS

Ethics deals with voluntary actions. We can distinguish between human actions and actions of
human: human actions are those actions that are done by human consciously, deliberately and in
view of an end. Actions of human may not be wilfully, voluntarily, consciously and deliberately
done but all the same they are done by human (e.g. sleeping, walking, etc.). It is the intention
which makes the difference between human action and action of human. In ethics we deal only
with human actions.

1.3 HISTORY OF ETHICS

Ethics is as old as humanity. The first ethical precepts were certainly passed down by word of
mouth by parents and elders, but as societies learned to use the written word, they began to set 3
down their ethical beliefs. These records constitute the first historical evidence of the origins of
ethics. In as much as it is the study of human behaviour, we cannot really trace the history of
ethics. However, as a systematic study of human behaviour, we can point out how ethics evolved
as a discipline. It is not that we have first a straightforward history of moral concepts and then a
separate and secondary history of philosophical comment. To set out to write the history of moral
philosophy involves a careful selection from the past of what falls under the heading of moral
philosophy as we now conceive it. We have to strike a balance between the danger of a dead
antiquarianism, which enjoys the illusion that we can approach the past without preconceptions,
and the other of believing that the whole point of the past was that it should culminate with us.
However, we can observe a gradual development in the ethical thought from the beginning to our
day. In the Western Philosophy, the history of ethics can be traced back to the fifth century B.C
with the appearance of Socrates. As a philosopher among the Greeks his mission was to awaken
his fellow humans to the need for rational criticism of their beliefs and practices. It was the time
when the philosophers began to search for reasons for established modes of conduct. Socrates, in
demanding rational grounds for ethical judgements, brought attention to the problem of tracing
the logical relationship between values and facts and thereby created ethical philosophy. Plato’s
theory of forms could be seen as the first attempt at defending moral realism and offering an
objective ground for moral truths. From the Republic on through the later dialogues and epistles,
Plato constructed a systematic view of nature, God, and human from which one derived one’s
ethical principles. His main goal in his ethical philosophy was to lead the way toward a vision of
the Good. Aristotle differed from Plato in his method of inquiry and his conception of the role of
ethical principles in human affairs. While Plato was the fountainhead of religious and idealistic
ethics, Aristotle engendered the naturalistic tradition. Aristotle’s ethical writings (i.e. Eudemian
Ethics, the Nicomachean Ethics, and the Politics) constitute the first systematic investigation into
the foundations of ethics. Aristotle’s account of the virtues could be seen as one of the first
sustained inquiries in normative ethics. It was a clear mixture of Greco-Roman thought with
Judaism and elements of other Middle Eastern religions. The medieval period was dominated by
the thoughts of Christian philosophers and theologians like Augustine and Thomas Aquinas. The
influence of Christianity dominated the ethical scenario. So much so that during this period
philosophy and religion were nearly indistinguishable. The rise of Christian philosophy produced
a new era of history of ethics. In St. Augustine, the most prominent philosopher of the early
medieval period, ethics became a blend of the pursuit of earthly well-being with preparation of
the soul for eternal salvation. The next towering figure of medieval philosophy is Thomas
Aquinas. He brought about a true reconciliation between Aristotelian science and philosophy
with Augustinian theology. Aquinas greatly succeeded in proving the compatibility of
Aristotelian naturalism with Christian dogma and constructing a unified view of nature, human,
and God. The social and political changes that characterized the end of medieval period and the
rise of modern age of industrial democracy gave rise to a new wave of thinking in the ethical
field. The development of commerce and industry, the discovery of new regions of the world, the
Reformation, the Copernican and Galilean revolutions in science, and the rise of strong secular 4
governments demanded new principles of individual conduct and social organization. Some of
the modern philosophers who contributed to the great changes in ethical thinking were Francis
Bacon, René Descartes, Thomas Hobbes, Gottfried Wilhelm Leibniz, Benedict de Spinoza, John
Locke, David Hume, Immanuel Kant, John Stuart Mill and Friedrich Nietzsche. Further
developments in ethical thinking in the west came with Karl Marx and Sigmund Freud. Here we
are not intending to give a detailed analysis of their contribution to ethics. However, the most
influential ethical thought during this period were the Utilitarianism, dominated by British and
French Philosophy (e.g. Locke, Hume, Bentham, Stuart Mill) and Idealistic ethics in Germany
and Italy (e.g. Kant, Hegel, Nietzsche). The contemporary ethical scenario is a further complex
area of study. The contemporary European ethics in the broadest sense attempts to cover a
generous range of philosophies running from phenomenology to theories of communicative
action. The conditions of contemporary civilization forced philosophers to seek for a genuine
ground for ethics and moral life. In much of the English speaking world G.E. Moore’s Principia
Ethica (1903) is taken to be the starting point of contemporary ethical theory. Others like Martin
Buber, Gabriel Marcel, Emmanuel Levinas, Max Scheler, Franz Brentano and John Dewey too
have made significant contributions to the ethical thinking in other parts of the world.

Professional ethics 
Professional ethics encompass the personal and corporate standards of behavior expected
by professionals.
The word professionalism originally applied to vows of a religious order. By no later than the
year 1675, the term had seen secular application and was applied to the three learned
professions: Divinity, Law, and Medicine. The term professionalism was also used for the
military profession around this same time.
Professionals and those working in acknowledged professions exercise specialist knowledge and
skill. How the use of this knowledge should be governed when providing a service to the public
can be considered a moral issue and is termed professional ethics.
It is capable of making judgments, applying their skills, and reaching informed decisions in
situations that the general public cannot because they have not attained the necessary knowledge
and skills. One of the earliest examples of professional ethics is the Hippocratic oath to which
medical doctors still adhere to this day.
Engineering is the process of developing an efficient mechanism which quickens and eases the
work using limited resources, with the help of technology. Ethics are the principles accepted by
the society, which also equate to the moral standards of human beings. An engineer with ethics,
can help the society in a better way.
Hence the study of Engineering ethics, where such ethics are implemented in engineering by the
engineers, is necessary for the good of the society. Engineering Ethics is the study of decisions,
policies and values that are morally desirable in engineering practice and research.

Morals
The word “Morality” originates from the Latin word “mos” meaning “custom”. Morals are the
principles or habits with respect to right or wrong of one’s own conduct. They are not imposed
by anyone. Morals are what you think is good and bad personally.
Though morals are not imposed, they can be understood as the preaching of our inner self.
Depending on a few factors, our mind filters things as good or bad. These are the ideas that help
frame our personality so that we can distinguish between what is right and what is wrong.
A moral is the code of conduct that you develop over time and set for yourself to follow, just
like

 Being good to everyone

 Speaking only the truth
 Going against what you know is wrong
 Having chastity
 Avoid cheating
 Being a nice human being etc.
Morals are always defined by one’s own personality. Morals can be changed according to one’s
beliefs as they are completely dependent on one’s perception towards the ethical values.

Ethics
The word “Ethics” originates from the Greek word “ethos” meaning “character”. Ethics are a
set of rules or principles that are generally considered as standards or good and bad or right and
wrong, which are usually imposed by an external group or a society or a profession or so.
Ethics can be understood as the rules of conduct proposed by a society or recognized with
respect to a particular class of human actions or a particular group or culture. Ethics are
dependent on others definition. They may or may not vary from context to context.

Ethics in Engineering
Ethics are principles followed depending upon the moral responsibility that a person feels. The
study of related questions about moral ideals, character, policies and relationships of people and
organizations involved in technological activity, can be termed as Engineering ethics.
An engineer whether he works individually or works for a company, has to go through some
ethical issues, mostly under the conditions such as, conceptualization of a product, issues arising
in design and testing departments, or may be on the issues involving the manufacturing, sales
and services. Questions related to morality also arise during supervision and team works.
The ethical decisions and moral values of an engineer need to be considered because the
decisions of an engineer have an impact the products and services - how safe they are to use, the
company and its shareholders who believe in the goodwill of the company, the public and the
society who trusts the company regarding the benefits of the people, the law which cares about
how legislation affects the profession and industry, the job and his moral responsibilities and
about how the environment gets affected, etc.

Not only an engineer, but everyone has to follow a set of morals in order to keep away from
getting morally degraded. Our behavior should include the following −

 Respecting others and ourselves.

 Respecting the rights of others.
 Keeping promises.
 Avoiding unnecessary problems to others.
 Avoiding cheating and dishonesty.
  Showing gratitude towards others and encourage them to work.
Morality commands respect for persons, both others and ourselves. It involves being fair and
just, meeting obligations and respecting rights and not causing unnecessary harm by dishonesty
and cruelty or by hubris.

Steps to Deal with Issues

Whenever there occurs an issue, one should possess a few skills in order to sort out the problem.
The issues that engineers face, have to be dealt with patience and few moral goals have to be
kept in mind while dealing with such issues. They are as follows −
 Moral Awareness − One should be able to recognize the moral problems and issues that
occur in Engineering. The analysis on the problem is necessary in order to differentiate
and judge according to ethics or according to the rules to follow.
 Cogent Moral Reasoning − In order to come to a conclusion on an issue, the argument
has to be assessed and comprehended. The argument on both sides has to be considered
with all the probabilities and the nature of the argument should be logical and moral.
 Moral Coherence − After having gone through all the logical and moral facts, consistent
and comprehensive view points are to be formed based upon a consideration of relevant
facts.
 Moral Imagination − The moral issues and the practical issues have to be dealt
separately. Alternative responses are to be found out for dealing with moral issues while
creative solutions should be found out for practical difficulties.
 Moral Communication − The language to communicate about one’s moral views should
be so precise and clear, that the expression or words should not alter the original
meaning.
Though one has all these moral goals, the ethical reasoning for achieving moral conduct with
responsibility and commitment is obtained by a few skills that are described below.

Important Skills for Ethical Reasoning

Let us now discuss the important skills for ethical reasoning −
 Moral Reasonableness − The ability and willingness to be morally reasonable that one
should have while dealing such issues. Unless one is willing and improve such ability,
justice cannot be done.
 Respect for Persons − The persons involved in the issue, should be treated with genuine
concern by one. Such concern should also be there with oneself along with being there
for others.
 Tolerance of diversity − One should have a broader perspective towards ethnic and
religious differences that the people have. Every person differs with another when
compared on grounds of moral reasoning. The acceptance of those differences is really
important.
  Moral hope − The moral conflicts can be resolved by using better communication and
having rational dialogue which is evident-based and open-ended which is acceptable and
appreciable by both the parties.
 Integrity − The moral integrity has to be maintained. Being honest and having strong
moral principles helps one to resolve an issue in an efficient manner. An individual also
needs to consider other’s professional life and personal convictions while solving a
problem.
Personal ethics defined

Personal ethics are ethical principles that a person uses when making decisions and behaving in
both personal and professional settings. These ethics influence various aspects of a person’s life
and help individuals develop their work ethic, personal and professional goals, and values.
Individuals use their ethics to determine between right and wrong and influence how someone
behaves in challenging situations. Each person’s code of ethics varies, but many people share
common ethics such as honesty and respect.

Why are personal ethics important?

A person’s personal ethical principles are important for several reasons, including that they:

 Allow leaders to more effectively lead their teams: When a leader regularly follows a predictable
and respectable code of ethics, their team is more likely to follow their lead and feel confident in
the contributions they make to the organization as a whole.
 Instill a sense of trust and support in leaders: Leaders and other professionals who regularly
behave in the same way no matter the situation are more likely to be trusted and supported by
colleagues and employees. Individuals who follow a sound ethical code are easier to believe in
and are more likely to establish credibility among others.
 Give individuals a solid basis of which to determine the most appropriate action in any given
situation: When a person has solid personal ethics, they are better able to make decisions and
take action in situations that may otherwise seem challenging.
 Improve the decision-making process: A professional’s ability to make decisions is based on
their personal and professional ethics and what they believe to be good or bad. Having strong
ethics makes the decision-making process easier and more streamlined.
 Set a standard of behavior: In the workplace and in life, ethics help establish an appropriate
standard of behavior for individuals. This behavior is called ethical behavior and refers to a
person’s ability to make sound decisions based on their ethical nature.
 Support motivation: Individuals with strong ethics are often easily self-motivated and willing to
go the extra mile to accomplish a task or goal on time and in the correct manner.
Differences between personal and professional ethics
There are a few key differences between personal and professional ethics. The primary
difference is that a personal set of ethics refers to an individual’s beliefs and values in any area of
life, while professional ethics refers to a person’s values within the workplace.
An example of a personal code of ethics is as follows: A person chooses to return a wallet that
they found on the ground to lost and found rather than keep it for themselves due to their
personal ethic of honesty. In the workplace, an example of professional ethics would be the same
person returns a wallet to their coworker due to a code of conduct rule of no stealing.
Some people differentiate personal and professional ethics by viewing a personal ethical system
as a personal moral code or a person’s conscience, while professional ethics are viewed as a set
code of conduct that must be adhered to in the workplace.
Examples of personal ethics
The following are examples of a few of the most common personal ethics shared by many
professionals:
Honesty
Many people view honesty as an important ethic. This ethic transfers from an individual’s
personal life into their professional life and ensures they are truthful in all scenarios.
Loyalty
Loyalty is another common personal ethic that many professionals share. People who have a
personal ethic of loyalty demonstrate trustworthiness and fidelity in all of their dealings and can
be trusted by others to maintain their loyal behavior no matter the situation.
Integrity
Integrity refers to a person’s commitment to upholding their moral principles in any situation and
is an important component of trustworthy and sound relationships both in and out of the
workplace. People with integrity are reliable, responsible, and hold themselves accountable for
their actions.
Respect
People with sound personal ethics demonstrate respect for those around them both at work and in
their personal lives. They respect others’ autonomy, rights, and interests, and do not discriminate
based on someone’s religion, sex, or race.
Selflessness
People who are selfless put others first and do not act in selfish or self-serving ways. They
consider the needs and situations of others and prioritize these needs before their own.
Responsibility
Someone with a strong moral code is willing to take responsibility for their actions and make
changes or amends when necessary.

How to identify your personal ethics

The following are steps you can take to identify your unique personal ethical beliefs so you can
improve upon them and demonstrate them in your daily life:
1. Get clear on your priorities. Knowing what means the most to you can help you determine your
personal set of ethics. For example, if you regularly put others first, you likely have a personal
ethic of selflessness. Make a list of your personal priorities in life and see if you can connect
each priority with a unique ethic.
2. Write down your goals. Having a concrete idea of your personal and professional goals will help
you establish your unique ethics. For example, if your goal is to maintain honesty and integrity in
everything you do, these are likely two of your personal ethics.
3. Consider your practices and beliefs. What you believe in and the things you practice will shed
light on your unique ethics. For example, if you believe that one should be willing to take
responsibility for their actions no matter the situation, you likely have responsibility as a
personal ethic.

What Is a Code of Ethics?

A code of ethics is a guide of principles designed to help professionals conduct business honestly
and with integrity. A code of ethics document may outline the mission and values of the business
or organization, how professionals are supposed to approach problems, the ethical principles
based on the organization's core values, and the standards to which the professional is held.
A code of ethics, also referred to as an "ethical code," may encompass areas such as business
ethics, a code of professional practice, and an employee code of conduct.

What is a professional code of ethics?

A professional code of ethics is a set of principles designed to help a business govern its
decision-making and distinguish right from wrong. Often referred to as an ethical code, these
principles outline the mission and values of an organization, how the professionals within the
organization are supposed to approach problems and the standards to which employees are held.

In some industries, such as finance or public health, specific laws dictate professional conduct. In
other industries, a code of ethics may be voluntarily adopted. For example, a business that
doesn’t necessarily focus on climate change might still detail its commitment to sustainability in
its official code of ethics.

Professional Codes of Ethics

Values and Ideals – The Cultural Building Blocks of Ethical Codes
This lesson defines and describes the differences between values, ideals, and principles and
shows how these concepts are culturally located. Examples provided show how a culture’s
values and ideals influence its principles, or guidelines for behavior.
Codes, Policies and Laws – Formalizing a System of Ethics
This lesson shows how policies are formalized into codes, policies, and laws. It differentiates
between the three based on their level of formality and structure as well as the extent to which
violators are punished for their behavior.
 A (Brief) History of Codes of Ethics
This lesson gives a background to the use of formalized codes of ethics in business, starting in
the 1980s. It shows the evolution of ethical codes and gives two examples to show how codes of
ethics are often highly situational.
Roles and Responsibilities of Codes of Ethics
This lesson talks about the role that ethical codes play in professional behavior. It shows students
how a code of ethics can be useful to a profession and the importance of all involved parties
understanding the role that the code is intended to play.
Shortcomings of Codes of Ethics
This lesson describes the potential negatives that can arise from utilization of a code of ethics. It
suggests that ethical training, rather than codes, is best suited to promoting ethical behavior in a
profession.
Conflict of Interest

A conflict of interest arises when what is in a person’s best interest is not in the best interest of
another person or organization to which that individual owes loyalty.
For example, an employee may simultaneously help himself but hurt his employer by taking a
bribe to purchase inferior goods for his company’s use.
A conflict of interest can also exist when a person must answer to two different individuals or
groups whose needs are at odds with each other. In this case, serving one individual or group will
injure the other.
In business and law, having a “fiduciary responsibility” to someone is known as having a “duty
of loyalty.” For example, auditors owe a duty of loyalty to investors who rely upon the financial
reports that the auditors certify. But auditors are hired and paid directly by the companies whose
reports they review. The duty of loyalty an auditor owes to investors can be at odds with the
auditor’s need to keep the company – its client – happy, as well as with the company’s desire to
look like a safe investment.
So, those of us who wish to be ethical people must consciously avoid situations where we benefit
ourselves by being disloyal to others.

Gift vs Bribe

What is the difference between an acceptable business gift and a bribe? What kind of
norms and structures should an organisation have in place to help its employees avoid
ethical dilemmas and make the right decision? (200 Words)
 
Difference between Business Gift and Bribe is subtle to understand.
 
Basic difference is
:
Gift is given to someone without any expectation in return. Value of gift are often based on
closeness in relation, time of gifting, economic condition of giver and receiver.
Bribe is given with expectation of favour toward giver. Its economic value are incoherent to
closeness in relation, timing (inappropriate timing) and costly. Business gifts may be a Costly
Cricket match ticket, desk clock, sweets or even a cash envelope. Timing of such gifts makes
them bribe. Suppose a gift from someone just before you are going to roll-out a tender, a
calendar and desk accessories with bold name of pharma companies to doctor. Such things are
actually bribe and not gift. Many MNC organisations have come up with norms and structures
already. Some norms which are still needed are:

1. Reporting to department about any gifts that is received from whom, value and date
details. This part is already applicable to judicial judges in India.
2. Any gifts above certain monetary values should be avoided.
3. No gifts received with brand name should be put on desk as it will tarnish the image of
official/public servant for lenient toward certain brand.
4. Provision of filing gift tax by receiver. IT department should tally the gift received as
mentioned in department books and filed by receiver. Failure to file tax for gift should be
taken seriously.
5. Scrutiny of gifts received by officials regularly and checking of property declaration
regularly. Repeated gift from same person should be brought under Directorate
Enforcement radar.

Bribes are complex thing for receiver because it puts him into moral dilemma for how to return
the favour and makes them corrupt once they receive.

Negligence
  is a failure to exercise appropriate and/or ethical ruled care expected to be exercised amongst
specified circumstances. The area of tort law known as negligence involves harm caused by
failing to act as a form of carelessness possibly with extenuating circumstances. The core
concept of negligence is that people should exercise reasonable care in their actions, by taking
account of the potential harm that they might foreseeably cause to other people or property.]
Someone who suffers loss caused by another's negligence may be able to sue for damages to
compensate for their harm. Such loss may include physical injury, harm to property, psychiatric
illness, or economic loss. The law on negligence may be assessed in general terms according to a
five-part model which includes the assessment of duty, breach, actual cause, proximate cause,
and damages.

DEFICIENCIES IN STATE OF THE ART

The state of the art (sometimes cutting edge or leading edge) refers to the highest level of
general development, as of a device, technique, or scientific field achieved at a particular time.
However, in some contexts it can also refer to a level of development reached at any particular
time as a result of the common methodologies employed at the time.
The term has been used since 1910, and has become both a common term
in advertising and marketing, and a legally significant phrase with respect to both patent
law and tort liability.
In advertising, the phrase is often used to convey that a product is made with the best or latest
available technology, but it has been noted that "the term 'state-of-the-art' requires little proof on
the part of advertisers", as it is considered mere puffery.[1] The use of the term in patent law
"does not connote even superiority, let alone the superlative quality the ad writers would have us
ascribe to the term".

V I GI L MEC HAN I S M
Preamble

Under Section 177 of the Companies Act, 2013, Our Company has designed a vigil mechanism
for the directors and employees to report genuine concerns in such manner as may be prescribed.
Such a vigil mechanism shall provide for adequate safeguards against victimization of persons
who use such mechanism and also make provision for direct access to the chairperson of the
Audit Committee in appropriate or exceptional cases.

Policy Objectives

The Vigil Mechanism aims to provide a channel to the Directors and employees to report
genuine concerns about unethical behaviour, actual or suspected fraud or violation of the Codes
of Conduct or policy. The Company is committed to adhere to the highest standards of ethical,
moral and legal conduct of business operations and in order to maintain these standards, the
Company encourages its employees who have genuine concerns about suspected misconduct to
come forward and express these concerns without fear of punishment or unfair treatment.

Definitions

“Protected Disclosure” means a written communication of a concern made in good faith, which
discloses or demonstrates information that may evidence an unethical or improper activity under
the title
“SCOPE OF THE POLICY” with respect to the Company. It should be factual and not
speculative and should contain as much specific information as possible to allow for proper
assessment of the nature and extent of the concern.
“Subject” means a person or group of persons against or in relation to whom a Protected
Disclosure is made or evidence gathered during the course of an investigation.
“Vigilance Officer/Vigilance Committee or Committee” is a person or Committee of persons,
nominated/appointed to receive protected disclosures , maintaining records thereof, placing the
 same before the Audit Committee for its disposal and informing the person disclosing the result
thereof.

Scope

The Policy covers disclosure of any unethical and improper or malpractices and events which
have taken place/ suspected to take place involving:
o Breach of Business Integrity and Ethics
o Breach of terms and conditions of employment and rules thereof
o Intentional Financial irregularities, including fraud, or suspected fraud
o Deliberate violation of laws/regulations
o Gross or Wilful Negligence causing substantial and specific danger to health, safety and
environment
o Manipulation of company data/records
o Pilferation of confidential/propriety information
o Gross Wastage/misappropriation of Company funds/assets

Egibility

All Directors and Employees of the Company are eligible to make Protected Disclosures under
the Policy in relation to matters concerning the Company.

Procedure
All Protected Disclosures should be reported in writing by the complainant as soon as possible,
not later than 30 days after the complainant becomes aware of the same and should either be
typed or written in a legible handwriting in English. The Protected Disclosure should be
submitted under a covering letter signed by the complainant in a closed and secured envelope
and should be super scribed as “Protected disclosure under the Vigil Mechanism Policy” or sent
through email with the subject “Protected disclosure under the Vigil Mechanism Policy”.
The contact details of the Vigilance Officer are as under or contact the Chairman of the Audit
Committee in case the issue is not solved by the vigilance officer:- Name and Address - Chander
Kant Sharma (Whole Time Director and KMP) House no.-74, Asiad Vill Complex, New Delhi,
110049
On receipt of the protected disclosure the Vigilance Officer shall process the Protected
Disclosure.

Investigation
All Protected Disclosures under this policy will be recorded and thoroughly investigated. The
Vigilance Officer will carry out an investigation either himself/herself or by involving any other
Officer of the Company/ Committee constituted for the same /an outside agency before referring
the matter to the Audit Committee of the Company. The Audit Committee, if deems fit, may call
for further information or particulars from the complainant and at its discretion, consider
involving any other/additional Officer of the Company and/or Committee and/ or an outside
agency for the purpose of investigation. The investigation by itself would not tantamount to an
accusation and is to be treated as a neutral fact finding process.
Decision And Reporting
If an investigation leads to a conclusion that an improper or unethical act has been committed,
the Chairman of the Audit Committee shall recommend to the Board of Directors of the
Company to take such disciplinary or corrective action as it may deem fit. Any disciplinary or
corrective action initiated against the Subject as a result of the findings of an investigation
pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary
procedures. A complainant who makes false allegations of unethical & improper practices or
about alleged wrongful conduct of the Subject to the Vigilance Officer or the Audit Committee
shall be subject to appropriate disciplinary action in accordance with the rules, procedures and
policies of the Company.

Confidentially
The complainant, Vigilance Officer, Members of Audit Committee, the Subject and everybody
involved in the process shall, maintain confidentiality of all matters under this Policy.

Disqualifications
While it will be ensured that genuine complainants are accorded complete protection from any
kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary
action. Protection under this Policy would not mean protection from disciplinary action arising
out of false or bogus allegations made by a complainant knowing it to be false or bogus or with a
mala fide intention. Complainants, who make any Protected Disclosures, which have been
subsequently found to be mala fide, frivolous or malicious, shall be liable to be prosecuted.

Communications
Directors and Employees shall be informed of the Policy by publishing on the notice board and
the website of the Company.

Retention of Documents
All Protected disclosures in writing or documented along with the results of Investigation
relating thereto, shall be retained by the Company for a period of 5(five) years or such other
period as specified by any other law in force, whichever is more.

Amendment
The Company reserves its right to amend or modify this Policy in whole or in part, at any time
without assigning any reason whatsoever. However, no such amendment or modification will be
binding on the Directors and employees unless the same is not communicated in the manner
described as above.

WHISTLE BLOWING

A whistleblower (also written as whistle-blower or whistle blower) is a person, usually an

employee, who exposes information or activity within a private, public, or government
organization that is deemed illegal, illicit, unsafe, or a waste, fraud, or abuse of taxpayer funds.
Those who become whistleblowers can choose to bring information or allegations to surface
either internally or externally. Over 83% of whistleblowers report internally to a supervisor,
human resources, compliance, or a neutral third party within the company, with the thought that
the company will address and correct the issues. Externally, a whistleblower can bring
allegations to light by contacting a third party outside of the organization such as the media,
government, or law enforcement. The most common type of retaliation reported is being
abruptly terminated. However, there are several other activities that are considered retaliatory,
such as sudden extreme increase in workloads, having hours cut drastically, making task
completion impossible or otherwise bullying measures. Because of this, a number of laws exist
to protect whistleblowers. Some third-party groups even offer protection to whistleblowers, but
that protection can only go so far. Two other classifications of whistleblowing are private and
public. The classifications relate to the type of organizations the whistleblower works in: private
sector, or public sector. Depending on many factors, both can have varying results. About 20%
of whistleblowers are successful in stopping the illegal behaviors, usually through the legal
system, with the help of a whistleblower attorney. For the whistleblower's claims to be credible
and successful, the whistleblower must have compelling evidence to support their claims, that
the government or regulating body can use or investigate to "prove" such claims and hold
corrupt companies and/or government agencies accountable. A whistleblower case would never
continue on legally, or ever be reported via the news, without substantial and compelling
evidence.

What is a protected disclosure? 

A protected disclosure is a qualifying disclosure that is made by a worker that they

reasonably believe shows serious wrongdoing within the workplace. This will typically
relate to some form of dangerous or illegal activity that the person has witnessed at
work, where they “blow the whistle” to either their employer directly, a member of
senior management or the appropriate regulatory body.
Subject to the disclosure satisfying all of the relevant statutory requirements under the
Employment Rights Act (ERA) 1996, the worker will be protected by law from any form
of unfair treatment at work, including dismissal , because they have reported past, present
or even potential wrongdoing.
There are several common examples of complaints that fall within the scope of
whistleblowing law including, for example, the commission of a criminal offence such as
bribery and corruption, or where a company or organisation is deliberately breaching
obligations relating to health and safety at work .
 

What are the criteria to be a protected disclosure? 

Not every concern raised or complaint made by a worker will count as whistleblowing.
For a whistleblowing disclosure to be classed as a protected disclosure under the ERA,
all of the following requirements must be met:
 There must be a “qualifying disclosure” within the meaning of the ERA
 This must be in the public interest
  This must be made to an appropriate or prescribed person or body
 
A qualifying disclosure
A qualifying disclosure is defined under the ERA as any disclosure of information that,
in the reasonable belief of the worker making the disclosure, tends to show one or more
of the following:
 That a criminal offence has been committed, is being committed or is likely to be
committed
 That a person has failed, is failing or is likely to fail to comply with any legal
obligation to which they are subject
 That a miscarriage of justice has occurred, is occurring or is likely to occur
 That the health or safety of any individual has been, is being or is likely to be
endangered
 That the environment has been, is being or is likely to be damaged, or
 That information tending to show any matter falling within any one of the above
has been, is being or is likely to be deliberately concealed
 
To count as a qualifying disclosure, the information provided by the worker must relate
to one of these six types of relevant failure – from the commission of a crime to
concealing evidence relating to a wrongdoing – ‘and’ the worker must have a reasonable
belief that the information tends to show one of these failures has happened, is
happening now or believes will happen.
A worker need not necessarily be correct about their concerns or complaint, as long as
they have reasonable grounds for believing that the information disclosed is substantially
true, and that this belief was honestly held in all the circumstances prevailing at the time
of the disclosure. Protection is not afforded to those who make wild allegations or are
merely repeating gossip.

1. What is GST in India?

GST is known as the Goods and Services Tax. It is an indirect tax which has replaced many
indirect taxes in India such as the excise duty, VAT, services tax, etc. The Goods and Service
Tax Act was passed in the Parliament on 29th March 2017 and came into effect on 1st July 2017.
In other words,Goods and Service Tax (GST) is levied on the supply of goods and services.
Goods and Services Tax Law in India is a comprehensive, multi-stage, destination-based
tax that is levied on every value addition. GST is a single domestic indirect tax law for the
entire country.
Before the Goods and Services Tax could be introduced, the structure of indirect tax levy in
India was as follows:
Under the GST regime, the tax is levied at every point of sale. In the case of intra-state sales,
Central GST and State GST are charged. All the inter-state sales are chargeable to the Integrated
GST.
Now, let us understand the definition of Goods and Service Tax, as mentioned above, in detail.

Multi-stage
An item goes through multiple change-of-hands along its supply chain: Starting from
manufacture until the final sale to the consumer.
Let us consider the following stages:

 Purchase of raw materials

 Production or manufacture
 Warehousing of finished goods
 Selling to wholesalers
 Sale of the product to the retailers
 Selling to the end consumer

Stakeholders involved in GST e-payments

Before understanding the process involved in e-payments, it is important to list
the stakeholders involved in this mode of payment. The following stakeholders
will pay a key role in establishing an effective e-payment network in the proposed
GST scenario:
a) GSTN (Goods and Service Tax Network);
b) e- FPBs (Electronic Focal Point Branches) of authorized banks;
c) e-Kuber of RBI;
d) Central Accounts Section (CAS) of RBI, Nagpur;
 e) e-PAOs (Electronic Pay and account Offices) / e-Treasuries of State
Governments;
 f) Pr. CCA, CBEC (Principal Chief Controller of Accounts) / Accountant General
of the States;
 g) Tax authorities of Centre and States.