Dr. Reddy’s Laboratories Limited including its subsidiaries and affiliate companies (hereinafter referred to as “Dr. Reddy’s”or the “Company/strong>”)is committed to the highest legal, moral and ethical standards in conducting its business. The Company has adopted the Code of Business Conduct and Ethics (“COBE”), which lays down the principles and standards that should govern the actions of the Company and its employees.
- 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 of the Company.
- Complainant means any employee or third party raising a Concern under the purview of this Policy.
- Third parties includes retainers, consultants, service providers, distributors, vendors, customers or any other person dealing whether directly or indirectly with the Company.
Applicability and scope
This Ombudsperson Policy has been formulated to enable the employees and others associated with the Company to report any actual or perceived violations of COBE, internal 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 and third parties of Dr. Reddy’s, the guidelines to report Concerns without fear of retaliation, 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.
Guidelines of ombudsperson policy
Types of concerns:
This Policy encourages employees and third parties to raise Concern regarding malpractices, or fraud related to the affairs of the organization, including but not limited to:
- Frauds or incidents of financial malpractices in the areas of financial statement disclosures, accounting or accounting controls
- Breach of COBE or any other policy of the Company
- Failure to comply with, or violation of a legal obligation or Statutes as applicable from time to time
- Illegal activity, improper conduct or unethical behavior
- Corruption and bribery issues (either soliciting or offering a bribe)
- Any kind of workplace harassment including sexual, physical, psychological or financial abuse or exploitation
- Manipulation of records including data integrity violations
- Conflict of interest
- False reporting and falsification of documents
- Theft/pilferage and unauthorized use of Company property
- Sharing of internal information to unauthorized personnel
- Violation of marketing guidelines
- Retaliation against person reporting a concern in good faith
- Theft of confidential information, Personal Data (as defined in Privacy Notice), breach and unauthorized use
The complainants are not required or expected to act as investigators or finders of facts, nor would they determine the appropriate corrective or remedial action that may be warranted in a given case.
The complainant should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the CCO or the Chief Ombudsperson.
Raising of concerns:
a) 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. Concerns can be raised either through email, phone or post or any other mode of communication addressed to CCO. Following are the 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 post or any mode of communication addressed to: Chief Ombudsperson, Dr. Reddy’s Laboratories Limited, 8-2-337; Road No: 3, Banjara Hills, Hyderabad, India - 500034
b) Any past employee / third party needs to raise the Concern within a period of 180 days from the termination of their association with the Company.
c) If any person other than CCO or Chief Ombudsperson receives any Concern made by any complainant, 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.
d) A concern should ideally include the following to help expedite the investigation:
- i. Nature of concern
- ii. Name of person against whom the concern is raised
- iii. Location or business unit related to the concern
- iv. Details of the concern
- v. Period during which concern occurred including specific dates and times of the violation
- vi. Necessary supporting evidences/proofs, if any
Handling of concerns:
a) 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. Complainants who identify themselves may be invited to provide leads and evidence (including circumstantial) to supplement information gathered by investigators.
b) Based on findings substained by necessary evidences, appropriate consequential action will be recommended by the CCO in consultation with management, as necessary.
c) 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.
d) Unless there are compelling reasons not to do so, person against whom the concern is raised shall be provided with an opportunity of being heard, before taking any further action in this regard.
e) No one shall create, 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
f) CCO may, at his discretion, decide whether the result of investigation of concern should be communicated back to Complainant.
Dr. Reddy’s will not tolerate any retaliation against an employee who in good faith raises concerns or who assists in an investigation of suspected wrongdoing. Reporting “in good faith” means making a genuine attempt to provide honest, complete, and accurate information, even if it later proves to be unsubstantiated or mistaken. Disciplinary action may be initiated if an employee knowingly raises a false or misleading concern.
Confidentiality and retention of documents
All the documents received from the Complainant and evidence obtained during the investigation and the report shall be maintained in strict confidentiality 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 laws.
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.
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 employees and directors unless the same is notified to the employees and directors in writing.