The Company is committed to maintaining the highest standard of conduct and professionalism and towards this end has formulated a policy that will provide clarity about the method and process for stakeholders to voice genuine concerns about unprofessional conduct in breach of this Code. This policy should be read in conjunction with bharti's Code of Conduct.

This policy aims to:

• Provide an independent forum by means of the Office of the Ombudsperson, for employees and external stakeholders of the company to raise concerns and complaints about improper practices which are in breach of the bharti Code of Conduct.
• Put in place a fair and equitable inquiry process and redressal mechanism
• Reassure employees and other stakeholders raising the concerns, that each one will be fully protected against possible reprisals, intimidation, coercive action, dismissal, demotion or victimization when a serious and genuine concern of apparent unprofessional conduct has been made in good faith
  
  
  

• This policy is applicable to all employees of the Bharti Group, and to all other stakeholders interacting with the Bharti Group. It allows those individual employees and other stakeholders to raise concerns, issues or information of acts or conduct that are in breach of the company's Code of Conduct.
  
  This policy provides advice and guidance on the procedures to be followed.
  
  
  

• Any employee - be it full-time, part-time or associate employee - or external stakeholder (e.g. strategic partners, vendors, suppliers, contractors) who observes unprofessional behaviour can approach the Ombudsperson to voice his or her concerns. The complainant may be either an observer who is not directly impacted, or a victim who is directly or indirectly affected by such practices.
  
  
  

• The Ombudsperson will administer the policy, for which he/she will have an office with the necessary facilities, ensuring complete confidentiality.
  
  
  

• The process is designed to offer protection to whoever discloses concerns regarding unprofessional conduct to the Ombudsperson or, if the complainant prefers, to any other person in the organization, provided the disclosure is made in good faith and the alleged action or non-action constitutes a genuine and serious breach of what is laid down in bharti's Code of Conduct.
  
  A complainant is not a 'trouble maker' or 'sneak' but a person who has come to the decision to express a concern regarding possible unprofessional conduct, after a lot of thought. The policy only requires that there be a genuine doubt - the person making the complaint is not expected to produce unquestionable evidence in support of the allegation. The Company has an obligation to ensure that a complainant who makes a disclosure in good faith and without malice is protected, regardless of whether or not the concern raised is ultimately found to be correct. No action will be taken against the complainant when an allegation made in good faith is not confirmed by subsequent investigation.
  
  The Company affirms that it will not allow the person raising a concern to be victimized for doing so. In the unfortunate event where the person would be victimized, the Company will treat this as a serious matter and take disciplinary action against the perpetrator. The Ombudsperson will not reveal evidence of unprofessional conduct, and the Company will take disciplinary action if an employee destroys or conceals any relevant evidence.
  
  However, if an allegation is made or a concern is raised frivolously, maliciously or for personal reasons, the Company may decide to take appropriate disciplinary or legal action against the complainant.
  
  
  

• The Ombudsperson will treat all disclosures in a confidential and sensitive manner. The identity of the person raising the concern will be kept confidential so long as it does not hinder or frustrate the investigation process. However, the investigation process may reveal the source of the information on a 'need-to-know-basis' and, under exceptional circumstances, the person making the disclosure may be required legally or otherwise to provide a statement as part of the evidence.
  
  Confidentiality clauses in employment contracts to not have the intention of forbidding or penalizing a person for raising a complaint. Similarly, the policy does not release employees from their duty of confidentiality in the course of their work.
  
  
  
  

How to voice a concern
A person wishing to raise a concern may do so with the Ombudsperson, either verbally or in writing by giving background and history of the unprofessional conduct, the reason and grounds for raising the concern, the identity of the individuals who may be involved and documentary evidence, wherever available. The earlier the concern is raised, the better.

Complaints may be sent in either of these forms:
In writing (through hard copy mail) to:

The Ombudsperson
Bharti Enterprises Ltd.
Bharti Crescent
1, Nelson Mandela Road
Vasant Kunj, Phase II
New Delhi - 110 070
India


In writing (through email) to a secure email id, ombudsperson@bharti.in

the investigation process
The policy provides for an investigation and resolution process in 3 stages:

• When a matter is referred to the Ombudsperson, he/she will conduct a preliminary review to determine whether there is, at first face, a case for pursuing the matter further. The Ombudsperson will hear the complainant and review the documentary evidence, if any
  
• If the findings from stage 1 confirm the complainant's allegations, the Ombudsperson will then instigate a preliminary investigation, in which both complainant and the accused party will be heard. The evidence provided will be investigated more thoroughly. The Ombudsperson may involve the required investigative bodies, such as the Internal Audit team. In most cases, the complaint can be resolved at this stage.
  
• Should this preliminary investigation confirm the issue raised and it is found to be of a nature requiring a full investigation, the Ombudsperson will hear any other parties or witnesses he/she wishes to call. If so required, the Ombudsperson may involve any (external) investigative body, including the police.
  
  When investigating the complaint, the Ombudsperson will take into account the following factors:
  
  • The seriousness of the alleged improper conduct
  • The credibility of the concern
  • The likelihood of getting confirmation about the Improper Practice from attributable sources
  

timescales

Within fifteen working days of raising the concern, the Ombudsperson will send an acknowledgement of receipt of the complaint to the complainant and write to, oor otherwise notify, the individual(s) against whom the allegation has been raised. The identity of the complainant will be kept confidential. It will be disclosed only where strictly necessary or when there is an overriding need for such disclosure. Any requirement for disclosure will be notified to and its implications discussed with the complainant in advance.

position of person against whom a concern was raised

The person against whom the complaint has been made will be given an opportunity to be heard by the Ombudsperson as soon as possible after receipt of the complaint and comment and state his/her position again before the investigation is finally concluded.

resolution and actions taken

A resolution of the complaint may be achieved at any of the 3 levels. The investigation and resolution will be handled as speedily and sensitively as possible. However, to ensure that fairness will not be compromised, hasty investigation procedures will be avoided, which may from time to time lead to some delayed resolution.
In case the findings of the investigative process support the allegation, action will be taken against the perpetrator(s).
The Ombudsperson will prepare a detailed report of the final result, including recommended action to be taken if the complaint/disclosure is found to be genuine. A summary report with recommended action in line with the Company's Consequence Management Policy, will be sent to the relevant operational and HR management members. The Ombudsperson will ensure that any action taken will be in proportion to the severity of the wrongdoing.

communication with complainant
The Ombudsperson will send a note, or inform verbally, on the conclusion of the investigation and where applicable, action taken to the complainant and close the matter.

An annual report will be prepared by the Ombudsperson of which copies will be sent to the Head of Internal Assurance. The report will not contain any names. The Head of Internal Assurance will share the report with the members of the Board Audit Committee.

The implementation of this policy will be the responsibility of the Ombudsperson.

A copy of the policy is available to all employees on the various company intranets. The policy will be explained to new joinees at the time of induction and continuous communication will ensure that awareness of the Code of Conduct and Ombudsperson Policy is cascaded to all in the organization.