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KW Group

Vigil Mechanism (Whistle-blower) Policy

Channels and protections for the genuine reporting of unethical behaviour, fraud or violation of the Code of Conduct — under Section 177(9) of the Companies Act 2013.

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Who can report

Any director, employee, on-site partner, customer or supplier of KW Group may report concerns through this mechanism in good faith and without fear of retaliation.

How to report

Concerns may be submitted in writing to the Chairperson of the Audit Committee, addressed to the registered office, marked confidential. A dedicated email channel is also maintained; both routes are reviewed by the Compliance Officer.

Investigation procedure

Every report is logged, reviewed for prima facie merit and, where warranted, investigated by an internal committee or external counsel. The identity of the whistle-blower is kept confidential to the maximum extent permitted by law.

Anti-retaliation

No employee or stakeholder who reports a concern in good faith will be subject to retaliation, discrimination or detriment of employment. Any retaliation is itself a violation of this policy and is acted on accordingly.

About this policy

Questions about this policy.