Effective date April 2016
Revision 2
1st Revision date Nov 2021
2nd Revision date July, 2022

whistle Blower Policy


Swarna Tollway Private Limited follows the highest possible standards of ethical, moral and legal business conduct. Hence individuals are enabled to voice concerns in a responsible and effective manner.

This policy enables employees, directors, consultants and contractors to raise “concerns” internally at a sufficiently senior level and to disclose information which the individual believes shows malpractice or wrongdoing.

This whistle blowing policy provides protection to individuals who make disclosure (whistle blower):

  • In good faith;
  • In the reasonable belief of the individual making the disclosure that the concern tends to show malpractice or impropriety; and
  • To an appropriate person.
  • The confidentiality of the whistle blower’s identity will be maintained to the extent possible, subject to reasonable and necessary requirements of the law.
  • Anonymous disclosures are much less credible, but they may be considered at the discretion of the company (STPL) based on seriousness of the issues, credibility of the concern likelihood of confirming the allegation from attributable sources.
  • Due care should be exercised to ensure the accuracy of the information. If an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual.

    Exception: malicious or vexatious allegations-disciplinary action may be taken.

Procedure for Making a Disclosure

The complainant can reach out to the below mentioned Email whistleblower@swarnatoll.com

The Company will display the whistle blower posters at all its site and head office

Investigation Procedure:

  • No unfair treatment will be meted out to a Whistle Blower or to a person involved in investigation by virtue of his/her having reported a Disclosure under this Policy. They shall extend all reasonable co-operation to the Investigators, provided such co-operation shall not compromise self-incrimination protections available under applicable laws.
    They shall be free at any time to engage counsel at their own cost to represent them in the investigation proceedings. However, the Assumed will be reimbursed costs by the Company, if investigations reveal that he/she is not guilty.
  • If there is evidence of criminal activity, the Investigators or the Board may inform the police.
  • The Investigators will keep confidential records of all documents relating to allegations of concerns and report back to the Board on a regular basis. All Disclosures in writing as well as all documents related to any investigation and the results of the investigation relating thereto shall be retained for a period of at least 8 years.


  • No unfair treatment will be meted out to a Whistle Blower by virtue of his/her having reported a Protected Disclosure under this Policy. The Company condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle Blowers. Complete protection will, therefore, be given to the Whistle Blowers against any unfair practice like retaliation, threat or intimidation of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his duties/functions including making further Protected Disclosure The Company shall take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus, if the Whistle Blower is required to give evidence in criminal or disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice about the procedure, etc.


Investigators are required to conduct a process towards fact-finding and analysis. Investigators shall derive their authority from the Board when acting within the course and scope of their investigation.

Technical and other resources may be drawn upon as necessary to augment the investigation process. All Investigators shall be independent and unbiased both in fact and as perceived.

Investigators have a duty of fairness, objectivity, thoroughness, ethical behavior, and observance of legal and professional standards

Investigations will be launched only after a preliminary review which establishes that either:

  1. The alleged act constitutes an improper or unethical activity or conduct, or
  2. The allegation is supported by information specific enough to be investigated, or
  3. Matters that do not fulfill (a) or (b) above may be worthy of management review


If an investigation leads the Chairman of the Board to conclude that an improper or unethical act has been committed, the Chairman of the Board shall recommend to the management of the Company to take such disciplinary or corrective action as the Chairman of the Board deems fit. It is clarified that any disciplinary or corrective action initiated against the Assumed as a result of the findings of an investigation pursuant to this Policy shall adhere to the procedures under applicable laws, besides the internal procedure adopted by the Company.

Policy Management

This Policy may be amended from time to time by the Board.

The Company is entitled to amend, suspend or rescind this Policy at any time without assigning any reasons therefor. Whilst, the Company has made best efforts to define detailed procedures for implementation of this Policy, there may be occasions when certain matters are not addressed or there may be ambiguity in the procedures. Such difficulties or ambiguities will be resolved in consonance with the broad intent of this Policy. The Company may also establish further rules and procedures, from time to time, to give effect to the intent of this policy and further the objective of good corporate governance.