Vigil Mechanism Policy

1. Purpose

The purpose of this Vigil Mechanism Policy is to provide a structured process for HMM employees, contractors, stakeholders, and other parties to report any unethical behaviour, actual or suspected fraud, or violation of the organization’s code of conduct. The policy aims to ensure that concerns are raised in a secure, confidential, and unbiased manner without fear of retaliation.

2. Scope

This policy applies to all HMM employees, contractors, vendors, stakeholders, and other parties associated with the organization. It covers any incident of unethical behaviour, actual or suspected fraud, or violation of the organization’s code of conduct, policies, and legal or regulatory requirements.

3. Definitions

• Whistleblower: Any person, including employees, contractors, stakeholders, or others associated with the organization, who reports any unethical behaviour, actual or suspected fraud, or violation of the organization’s policies.
• Vigil Mechanism: A mechanism provided to the whistleblower for making a protected disclosure to the authorized persons in the organization.
• Protected Disclosure: Any communication made in good faith that discloses or demonstrates information that may evidence unethical behaviour, fraud, or violation of laws or regulations.

4. Principles

• Confidentiality: All reports of misconduct will be treated with the highest confidentiality to protect the identity of the whistleblower and the integrity of the investigation process.
• Non-Retaliation: The organization will not tolerate any form of retaliation against a whistleblower who makes a report in good faith. Any act of retaliation will be subject to disciplinary action.
• Good Faith: Whistleblowers are encouraged to make disclosures in good faith, with reasonable belief that the information is true. Reports made with malicious intent will be subject to disciplinary action.

5. Reporting Mechanism

• How to Report: Reports of unethical behaviour, actual or suspected fraud, or violations can be made in writing, via email, or through an anonymous hotline to the designated Ethics Officer or the Vigil Mechanism Committee.
• Information Required: The whistleblower should provide as much detail as possible, including the nature of the concern, parties involved, relevant dates, and any supporting evidence.
• Anonymous Reporting: The organization allows anonymous reporting, but it encourages whistleblowers to provide their identity to facilitate a thorough investigation.

6. Vigil Mechanism Committee

• The organization will establish a Vigil Mechanism Committee to oversee the investigation of all reports made under this policy.
• The committee will consist of senior management representatives, the Ethics Officer, and a representative from the legal department.
• The committee is responsible for reviewing all reports, conducting investigations, and recommending appropriate actions based on the findings.

7. Investigation Process

• Initial Review: Upon receipt of a report, the Vigil Mechanism Committee will conduct an initial review to determine whether the report falls within the scope of this policy.
• Investigation: If the report is deemed valid, the committee will conduct a thorough and impartial investigation, which may include interviews, document review, and other relevant procedures.
• Outcome: Upon completion of the investigation, the committee will prepare a report outlining its findings and recommendations for corrective action, if necessary.
• Follow-Up: The committee will ensure that corrective actions are implemented and will provide feedback to the whistleblower, where appropriate and possible.

8. Protection of Whistleblowers

• Identity Protection: The organization will make every effort to protect the identity of the whistleblower, unless required by law or necessary for the investigation.
• Protection Against Retaliation: Any form of retaliation against a whistleblower for making a report in good faith is strictly prohibited. Whistleblowers who experience retaliation are encouraged to report it immediately to the Vigil Mechanism Committee or the Ethics Officer.
• False Reports: Whistleblowers who knowingly make false or malicious reports will be subject to disciplinary action, up to and including termination of employment.

9. Communication and Awareness

The organization will regularly communicate the Vigil Mechanism Policy to all HMM employees, contractors, and stakeholders to ensure awareness and understanding. Training programs and awareness sessions will be conducted to promote a culture of ethical behaviour and compliance.

10. Policy Review and Amendments

This Vigil Mechanism Policy will be reviewed periodically to ensure its effectiveness and alignment with legal and regulatory requirements. Any amendments to the policy will be approved by the Board of Directors.

11. Acknowledgment

All HMM employees, contractors, and stakeholders are required to acknowledge that they have read, understood, and agreed to abide by this Vigil Mechanism Policy.