- A. Purpose statement:
Dr. Reddy’s Laboratories Limited including its subsidiaries and affiliate companies (hereinafter referred to as “Dr. Reddy’s” or the “Company”) is committed to the highest legal, moral and ethical standards in conducting its business and has articulated the same in its Code of Business Conduct & Ethics (CoBE).
This Ombudsperson Policy (hereinafter referred to as “Policy”) has been formulated to enable the employees and others associated with the Company to report any actual or perceived violations of CoBE, policies and procedures of the Company, any applicable laws and regulations or any other unprofessional and inappropriate conduct (hereinafter referred to as a ‘Concern’). This Policy provides all employees, vendors and business associates of Dr. Reddy’s, the guidelines to report Concerns without fear of reprisal, subsequent discrimination or disadvantage at the workplace.
This Policy is not intended to address individual employee grievances or complaints relating to job performance and terms and conditions of employment, or individual third party grievances relating to terms and conditions of contract, which will be addressed by the respective Departments in line with existing policies.
- B. Definitions:
- All words used in this Policy but not defined, have the same meaning assigned to them in CoBE.
- Audit Committee means the Audit Committee of the Board constituted as per applicable statutory requirements.
- Chief Compliance Officer (CCO) is a designated authority reporting to the Chief Ombudsperson of Dr. Reddy’s for the purpose of compliance with the Ombudsperson Policy.
- Chief Ombudsperson is a designated Independent Director from the Board of Directors.
- Complainant means any employee, vendor or any other business associate raising a Concern under the purview of this Policy.
C. Applicability of the Policy:
This Ombudsperson Policy, is applicable to all employees, directors, retainers, consultants (hereinafter referred to as “Associates”) and also to service providers, distributors, vendors, customers or any other person dealing either directly or indirectly with the Company (hereinafter referred to as “Third Parties”). This Policy is also applicable to those personnel to whom executory contractual relationship is created with the Company by way of issue of offer / intent letter by the Company.
- D. Scope of the Policy:
This Policy encourages Associates to raise Concern regarding malpractices, or fraud related to the affairs of the organization, including but not limited to, financial statement disclosures, accounting, internal accounting controls, auditing matters, human resources aspects, procurement, manufacturing, data integrity or violations of the CoBE or violation of laws, as applicable and amended from time to time.
The Complainant is not expected to conduct any investigation unless directed by the CCO or Chief Ombudsperson.
- E. Assurances under the Policy:
No unfair treatment or retaliation, shall be meted out to the Complainant provided the Concern is raised in good faith, save and except if investigation indicates involvement, other than to an insignificant extent, of the Complainant himself/herself or under instruction from any order of the Court. In case there is any violation of assurance under this Policy, the same may be reported to Chief Ombudsperson.
Confidentiality of the identity of the Complainant will be maintained unless, the Concern cannot be resolved without revealing identity of the Complainant or required by the applicable law or required under any order of the Court.
- F. Guidelines of Ombudsperson Policy:
Types of concerns:
Following are the indicative but not exhaustive heads of possible Concerns:
- i. Frauds or incidents of financial malpractices in the areas of financial statement disclosures, accounting or accounting controls
- ii. Breach of CoBE or any other policy of the Company
- iii. Failure to comply with, or violation of a legal obligation or Statutes as applicable from time to time
- iv. Illegal activity, improper conduct or unethical behavior
- v. Corruption and bribery issues (either soliciting or offering a bribe)
- vi. Any kind of workplace harassment including sexual, physical, psychological or financial abuse or exploitation
- vii. Manipulation of records
- viii. Conflict of interest
- ix. Data Integrity
- x. HR related concerns involving violation of CoBE
Any Concern, the resolution of which is specifically addressed by any other policy of the Company, will be handled in accordance with the respective applicable policy.
Raising of concerns:
The Complainant shall raise the Concern to the CCO. If the violation is pertaining to CCO or any direct reportee of CCO, such concerns shall be reported directly to Chief Ombudsperson. Any past Associate or Third Party needs to raise the Concern within a period of 180 days from the termination of their association with the Company.
The contact details of CCO or Chief Ombudsperson are provided in the Annexure to the Policy.
If any person other than CCO or Chief Ombudsperson receives any Concern made by any Associate or Third Party, then the same must be forwarded to CCO immediately without fail. In such cases, appropriate care must be taken to ensure the confidentiality of Complainant.
Disciplinary action would be taken against Complainant if it is proved that a false Concern was raised with mala-fide intention.
A concern should ideally include the following to help expedite the investigation:
- Nature of concern
- Name of person against whom the concern is raised
- Location or business unit related to the concern
- Details of the concern
- Period during which concern occurred including specific dates and times of the violation
Dr. Reddy’s encourages complainants to identify themselves; however, the CCO may consider anonymous complaints for further investigation if concern is credible and serious in nature and there is a likelihood of the concern being proven from the other sources.
Complainant must provide all corroborating evidences, as available and to the extent possible, to enable commencement of investigation at the earliest.
Handling of concerns:
The CCO at his discretion based on primary facts available may decide to address concerns either by investigating it himself or through identified investigators including external third party service providers, if required. Based on findings sustained by necessary proof, appropriate consequential action will be recommended by the CCO in consultation with management as necessary. Complainants who identify themselves may be invited to provide leads and evidence (including circumstantial) to supplement information gathered by investigators.
CCO will discuss details of concerns received, investigation and recommended actions with Chief Ombudsperson. The Chief Ombudsperson may demand additional information on the investigations carried out and, if necessary, order further investigation. The Chief Ombudsperson has the right to do an independent investigation and also use external third party services, if he deems it fit.
The Company shall provide an opportunity of being heard to the person, against whom the Concern was raised, before taking any further action in this regard.
No employee shall withhold, tamper or destroy any evidence or other document(s) related to the Concern and also should not interfere in the fair proceeding of investigation
CCO may, at his discretion, decide whether the result of investigation of concern should be communicated back to Complainant.
- G. Amendment:
Company reserves the right to amend any rule or guidelines relating to this Ombudsperson Policy at its discretion without assigning any reason whatsoever.
- H. Confidentiality and Retention of Documents:
All the documents received from the Complainant and any evidence obtained during the investigation process will be maintained in strict confidence and retained in accordance with applicable laws unless, disclosure is mandated by a Court order or is otherwise necessary to comply with the requirements of applicable law.
- I. Oversight by the Audit Committee:
In addition to the Chief Ombudsperson being an independent director of the board of directors, the mechanism of Concern handling under this policy is overseen by the Audit Committee and is accessible to the Chairman of the Audit Committee on need basis.
Annexure: Contact details
Chief Compliance Officer:
- (a) Email – email@example.com
- (b) Telephone Number: +91 40 49002000
- (c) Through envelope or note addressed to: Chief Compliance Officer, Dr. Reddy’s Laboratories Limited, 8-2-337; Road No:3, Banjara Hills, Hyderabad, India – 500034
- (a) Email – firstname.lastname@example.org
- (b) Through envelope or note addressed to: Chief Ombudsperson, Dr. Reddy’s Laboratories Limited, 8-2-337; Road No: 3, Banjara Hills, Hyderabad, India - 500034