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The revised policy took effect from April 13, making each provision clearer. It gives multiple reporting options for whistleblowers, with the addresses and emails of the company officials they could contact, in case of any 'suspected violation of law' and the 'company's code of conduct and ethics'.
The 2003 policy was used by one of its ex-employees in America to bring serious allegations against the company, taking it to court there. "We have basically made certain provisions in the policy more clear and explicit as per the requirements of the (US) Dodd-Frank Act," V Balakrishnan, chief financial officer and and member of the board, told Business Standard.
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Using the 2003 policy, Jack Palmer, one of its American employees, had filed a whistleblower report on October 11, 2010, alleging H-1B and B-1 visa violations by the company.
Subsequently, alleging he was being subjected to "constant harassment, threats and retaliation" by the company, Palmer filed a complaint in court.
This case was later shifted to a federal court in Alabama and trial is to start from August 20 this year. Palmer alleged, "The whistleblower team failed and refused to promptly investigate" on his report.
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In the amended policy, Infosys has said all suspected violations must be reported either to the immediate supervisor of the person making the complaint or the Global Head of Compliance, Immigration and Employees Matters, Nithyanandan Radhakrishnan, who is located in the US (any staffer, anywhere, can also tell him).
Or, it can be reported by sending an anonymous email to a designated address.
Also, if an employee feels all these officials are involved in the suspected violations, he/she can write to the audit committee of Infosys' board of directors, at a given address.
"Because you have several means of reporting, you need never report to someone you believe may be involved in the suspected violation or from whom you would fear retaliation," the revised policy says.
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Further, the policy has said the company won't tolerate any adverse action against any whistleblower for "a reasonably suspected violation of any law".
"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, including possible termination of employment. Those working for or with the company who engage in retaliation against reporting employees may also be subject to civil, criminal and administrative penalties," it adds.