Whistle Blower policy

The Company has developed and has been strictly following for decades a culture of absolute transparency in Management, record maintenance, financial transactions, code of conduct and business ethics. Being an ISO certified Company until recently, its policy has been “SAY WHAT YOU DO AND DO WHAT YOU SAY”, which has been strictly practiced by the Company. This culture of openness is monitored by internal control, internal audit and statutory audit, which in their reports reveal the departure if any from the transparency in all the Company’s dealings. The customers, suppliers and employees can any time walk into the Managing Director’s / Senior Executives’ room or communicate at any point of time any lacuna in the managerial dealings. Corrective action if called for is immediately taken and the complainant informed of the same so that he and others are encouraged to avail the facility of the whistle blowing facility of the Company.
In the context of the above background and culture practiced for decades, a Whistle Blower Policy is designed and attached.


The Company is committed to complying with Company’s Code of Conduct and Ethics, and particularly to assure that business is conducted with integrity and that the Company’s financial information is accurate. If potential violations of Company policies or applicable laws are not recognized and addressed promptly, both the Company and those working for or with the Company could face governmental investigation, prosecution, fines, and other penalties, which can be costly. Consequentially, and to promote the highest ethical standards, the Company has to maintain a workplace that facilitates the reporting of potential violations of Company policies and applicable laws. Thus this policy is to enable to raise concerns regarding such potential violations easily and free of any fear of retaliation.


Everyone is thus required to report to the Company any suspected violation of any law that applies to the Company and that of the Companys Code of Conduct and Ethics. This includes possible accounting or financial reporting violations, insider trading, bribery, or violations of the anti-retaliation aspects of this Policy.
Under this policy an employee must, when he/she reasonably suspects that a violation of an applicable law or the Companys Code of Conduct and Ethics has occurred or is occurring, report that potential violation. Reporting is crucial for early detection, proper investigation and remedy, and deterrence of violations of Company policies or applicable laws. One should not fear any negative consequences for reporting reasonably suspected violations because retaliation for reporting suspected violations is strictly prohibited by Company policy. Failure to report any reasonable belief that a violation has occurred or is occurring is itself a violation of this Policy.


One must report all suspected violations to the Chairman of Audit Committee or The Managing Director by personally meeting by sending an email to: wicottonltd@gmail.com or by sending a written communication, which could be even anonymous.


All reports under this Policy will be promptly and appropriately investigated, and all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action, in accordance with applicable procedure. Everyone working for or with the Company has a duty to cooperate in the investigation of reports of violations. Failures to cooperate in an investigation, or deliberately providing false information during an investigation, can be the basis for disciplinary action. If, at the conclusion of its investigation, the Company determines that a violation has occurred, the Company will take effective remedial action commensurate with the nature of the offense. This action may include disciplinary action against the accused party. Reasonable and necessary steps will also be taken to prevent any further violations.


No one will take any adverse action against any employee for complaining about, reporting, or participating or assisting in the investigation of, a reasonably suspected violation of any law, this Policy, or the Company’s Code of Conduct and Ethics. Incidents of retaliation against any employee reporting a violation or participating in the investigation of a reasonably suspected violation will result in appropriate disciplinary action against anyone responsible.


This Policy is circulated to all employees for strict compliance.

Date: 18-08-2010