Human Resource Manual

WHISTLE BLOW POLICY

1.1 Introduction

The whistle blow policy promotes fair, ethical and transparent dealings. It defines the process to
report/ exposes any kind of information or activity that is deemed illegal, unethical, or in direct
conflict with the standards of fair practices defined in the Urban Unit’s code of conduct.

Moreover, as an employee and/ or consultant of the Urban Unit it is our duty to report
immediately and without delay report any misappropriation or unintended use or disclosure of
confidential information, unintended use of company assets, fraudulent activities, accounting
malpractices, gaps in employee safety and well-being and instances of harassment which places
Urban Unit employees at risk. Additionally concerns raised under this policy may also relate to
the actions of a third party, such as a contractor, sub-contractor, or joint venture partner.

1.2 Applicability

This Policy has been established to ensure that all cases of suspected wrongdoing and
violation(s) of the code of conduct are reported and managed in a timely and appropriate
manner.

The policy extends to all Urban Unit employees, contractors, suppliers, shareholders,
consultants, third- party associations, private and/ or public corporations representing the Urban
Unit or engaging in business, directly or indirectly, with the Urban Unit.

1.3 Raising a concern

As a responsible citizen of this country and a dignified employee, it is your moral, ethical and
legit right to highlight, expose and report non-compliance and deviance from the code of
conduct, suspected violations and malpractices observed at the Urban Unit. You can raise your
concerns by email, orally or in writing while invoking the provisions defined in the Whistle
Blowing Policy.

Owing to the sensitive nature of the disclosure, we understand that an employee may face stress
and anxiety while raising his/ her concerns. Keeping employee well-being in mind we aim to ease
employee distress by providing a number of resources to whom an employee can reach out to
gain clarity over any aspects of the whistle blow policy and/ or to disclose any violation of the
code of conduct in a safe and comfortable environment. Competent authority in this regard are
any individuals who hold the following positions within the Urban Unit.

a. Sector Head
b. Chief Internal Auditor
c. Human Resources Sector Head
d. Chief Executive Officer
Human Resource Manual

Additionally, in situations where you feel uncomfortable approaching the resources listed above
or if you feel they may not be able to appropriately handle your concerns, you may also reach
out to the company secretary and raise your concern directly with the Board Audit Committee.

It is imperative that while raising your concern and as far as possible, the following aspects must
be observed:

a. an outline of the known or suspected wrongdoing;

b. details, to the best of your knowledge, about when, where and how it occurred;
c. a list of the names of those suspected of being involved (both within the Urban Unit and
externally);
d. a list of the names of anyone who may have relevant information;
e. details of how you came to know about the suspected activities;
f. what, if any, do you estimate to be the value of the loss to the Urban Unit or other
parties;
g. what, if any, breaches of internal controls, policy, procedure or other requirements you
believe took place;
h. the names of anyone who you have discussed or reported this incident to;
i. preferred communication medium through which the member of the investigation team
may establish contact with you and
j. the date and time of making the report.

After reporting your concern and before any formal investigation into your concern is initiated
you will have the option to withdraw your application, if in the process you find your concerns
were invalid, your circumstances have changed from the time of the initial complaint and/ or
your concern was ill-founded.

1.4 Reporting in good faith

In line with Urban Unit’s zero tolerance policy on harassment, unethical dealings and while being
a trustworthy member of our community we place a great deal of emphasis on safe-guarding the
reputation of our organisation and our employees from malicious slander and unfounded
allegations.

As employees it is our duty to abstain from making speculative allegations against fellow
colleagues which are unsubstantiated and lack evidence. It is important that when raising a
concern you are reporting it in good faith ensuring that documentary evidence to the same
effect is available. If you make an allegation in good faith, but it is not confirmed by
investigation, no action will be taken against you. If, however, you make allegations that are
malicious or are simply made to cause anger, irritation or distress, disciplinary action may be
taken against you.

1.5 Anonymous disclosure

We understand that disclosures made under this policy may involve highly confidential and
sensitive matters and that you may prefer to make an anonymous disclosure. It is important to
note here that all communication and the ensuing investigation process will be kept strictly
Human Resource Manual

confidential. Moreover, you will not be expected to prove the wrongdoing that you believe you
have witnessed or suspect.

1.6 Whistle-blower protection

Under the whistle blower protection programme an employee raising a concern in good faith
will not be subjected to any detriment for coming forward, regardless of whether or not the
concern is ultimately substantiated. In the event that a whistle blower believes that they are
being victimised or subjected to a detriment by any person within the company as a result of
reporting a concern or assisting the company in any investigation under this policy they must
immediately inform the HR sector head and/ or the Chief Executive Officer. Any manager or
employee who knowingly retaliates against others for speaking up will be subject to disciplinary
action.

1.7 Formal Investigation Process

To ensure proper and timely handling of concerns raised under the whistle blow policy, an
investigation will be conducted as speedily and sensitively as possible in accordance with all
relevant laws and regulations. The purpose of this investigation is:

a. To establish if a wrongdoing has occurred, and if so to what extent.

b. To minimise the risk of further wrongdoing, to prevent any further loss of assets,
damage to reputation and to protect all sources of evidence.

If the complainant and/ or member(s) of the investigation team feel that any deviation from the
formal investigation process took place then such deviation shall be communicated and
recorded in writing. These deviations will be a part of the formal investigation documents. If
appropriate, you will be regularly informed on the progress of these investigations and any
action to be taken.

The various steps in the formal investigation process are as follows:

a. As a complainant you can record your concern with anyone of the resources listed as
competent authority under clause 1.3.
b. The competent authority who has received the complaint is liable to acknowledge
receipt of the concern raised within 3 working days and reply to the complainant on the
mode of communication shared by the complainant. The communication must include
the proceeding steps with the complainant and any input or details which need to be
provided by the complainant.
c. Next, the person who received the initial complaint will report the incident and/ or
report to other internal departments and members of the Joint Investigation Team and
the Chief Internal Auditor. All proceedings with regards to the concern raised will be
kept strictly confidential. Morover, where possible, the details of the person or persons
reporting the incident will be removed.
d. The Chief Internal Auditor will convene a meeting with the members of the Joint
Investigation team to further probe into the matter. The joint investigation team will
identify the concerned individuals/ sector and/ or employee directly and/ or indirectly
Human Resource Manual

involved in the complaint registered. Moreover, any information, records, documents

and/ or emails required to further investigate will be identified and requested for by
concerned person(s). The meeting will be closed with all in agreement on the next
meeting date.
e. The Chief Internal Auditor will subsequently collect all related information before the
next meeting to be evaluated for shortfalls/ gaps in relation to the complaint reported.
f. During the next meeting, the joint investigation team will evaluate the documents and
review any evidence that may exist in relation to the registered concern. If the evidence
reviewed in found to be conclusive then the joint investigation team will share their
findings and recommendations with the Chief Internal Auditor. If however, such
evidence exists and if it is inconclusive then concerned employee(s) accused to such
wrong-doing shall be identified for a physical testimony or otherwise named by the
complainant in the original complaint. Additionally any other employee(s) and/ or
external individual deemed necessary for the investigation may also be contacted by the
joint investigation team.
g. Following the meeting, testimony will be sought from aforementioned resources in a
confidential and private setting. The details of the testimony, witness and the
proceedings will be kept strictly confidential. It must be highlighted here that any
proceedings with regards to the formal investigation will be recorded. Physical and/ or
any written testimony sought from any employee will be recorded and maintained as a
part of the formal investigation documents. As a complainant/ grieved party/ witness/
accused, you may choose to be accompanied to any meetings that are conducted as part
of the investigation process by a work colleague and/ or a Qualified Legal Professional.
h. After reviewing all documents and listening to testimonies provided by resources
identified as directly/ indirectly associated with the investigation process the joint
investigation team will share its findings and subsequent recommendations with the
Chief Internal Auditor.
i. The Chief Internal Auditor will consolidate the findings and recommendations and share
them with the Chief Executive Officers for review.
j. The Chief Executive Officer will then share them with Sector Head, Human Resources for
execution and subsequent inclusion into the employee personal records.

It is important to note here that owing to the nature of the complaint registered, availability of
the joint investigation team and ensuing investigation it will not be possible to set a specific
timeframe for completion of investigations in advance.

1.8 Role of the Joint Investigation Committee

The joint investigation team comprises of the members of HR sub-committee, including the Chief
Internal Auditor who will lead and execute all official proceedings in relation to the complaint
received and investigative process that would follow.

The joint investigation team must exercise extreme caution when reviewing evidence and
handling sensitive information. To avoid any distasteful incident, it is strongly advised that the
members of the joint investigation team observe the following:
Human Resource Manual

a. The person against whom the allegation is made cannot be a part of the investigation
team and must immediately distance him/herself from all proceedings unless invited by
the joint investigation team to testify and/ or share details pertinent to the investigation.
b. Avoid discussing any details of the complaint and proceeding investigations at public
places or within hearing distance of person(s) internal/ external to the organisation.
c. Ensure confidentiality as each and every step of the process.
d. Avoid hiding, concealing, and misrepresenting and / or misinterpreting information
while conducting the investigation.
e. Protect and/ or safeguard individual and/ or Urban Unit’s interest or interest of any
internal/ external party involved in wrongful practices highlighted in the complaint.

1.9 Recommendations of the Joint Investigation Committee

The joint investigation team will share both its findings and recommendations with the Chief
internal Auditor who will then consolidate and share the same with the Chief Executive Officer
within 3 days of the completion of the formal investigation process.

While consolidating the findings and subsequent recommendations the following must be
observed:

a. Findings must be referenced to related documents and must be fact-based as far as

possible to remove subjectivity. The recommendations as per the disciplinary action
policy put forward by the investigation team must match the offence/ misconduct/
violation of the code of conduct verified in the course of the investigation.
b. Findings and recommendations are shared with the Chief Executive Officer once the
investigation team completes the investigation process.
c. Once the Chief Executive Officer has reviewed the case files, s/he will share the same
with Sector Head, Human Resources for placing the same in concerned employee
personal file.
d. The findings and subsequent recommendations as suggested by the investigation team
will be communicated to the complainant and the accused.
e. Sector Head, Human Resource will ensure implementation of the recommendations
suggested by the joint investigation team upon the directives received from the Chief
Executive Officer.
f. To fulfill any legal obligations which may arise and in accordance with the law, it is
imperative that all documents and testimonies in regards to the registered complaint
and following investigation are properly documented and maintained with the Chief
Internal Auditor for future reference.

If you are not satisfied with the investigation or its conclusion, you may reach out to the Chief
Executive Officer for further clarification. However, if a complainant is still dissatisfied, s/he
should write directly to the Chairman of the Board of Directors for further escalation and
resolution of the said concern.