Whistle Blower Policy: Maruti Suzuki India ltd

Key points in Maruti’s WBP:

Areas: Employees can report to Management instances of:

 unethical behavior
 actual or suspected fraud
 violation of Company’s Code of Conduct or ethics policy

Coverage: Includes only employees

Anonymous or not: Anonymous concerns will not be investigated, the employee has to sign his name on the
Protected Disclosure Document

Manner in which it can be raised: “Protected Disclosure” with name, within 30 consecutive days after becoming
aware of the misdoing

Investigation Process:
 Initial enquiries by Ombudsperson
 If further investigation required then will be carried through by Ombudsperson or Whistle Officer/ committee
appointed by Ombudsperson
 A detailed written record of Protected Disclosure will be made
 Report submission within 15 days of appointment

Frivolous/ Bogus complaints: Whistle Blowers with frivolous or malicious Protected Disclosures shall be liable to be
prosecuted under Company’s Code of Conduct.

Outcome/ Actions: If Protected Disclosure is:

 Proved then take action
 Not proved then extinguish matter
 Very serious, then refer the matter to Committee of Directors who may further refer to Audit Committee who
also may further refer to the Board.
 Direct appeal to the Chairperson of the Audit Committee in exceptional cases, where Whistle Blower is not
satisfied with outcome or decision

Reporting: A quarterly report with number of complaints received under the Policy and their outcome shall be placed
before the Audit Committee and the Board.

Critically evaluating this policy:

 Anonymity should be allowed to Whistle Blowers
 Here only employees are covered, it could include: ex-employees, vendors, customers, others
 The entire matter rests in the hands of 1 person, Ombudsperson, and as a result the outcome could be
affected by the personal bias of the Ombudsperson.
 The aim should be to curtail frivolous complaints not dissuade them by penalizing the Whistle Blower
 The whistle blower policy is not independent. A Hotline or a separate email-id could have made it more
independent