Whistle Blower Policy 2023-24

Annexure-II

WHISTLE BLOWER POLICY 2023-24

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Table of Contents

Sr.No. Particulars Page No.

1 Preamble 3
2 Objective of the Policy 3-4
3 Governing Laws 4
4 Definitions 4-5
5 Scope of Policy 5
6 Aim/Objective of the Policy 5
7 Matters covered under the Policy 5-6
8 Who can blow the whistle 6
9 Whistle Blower Mechanism – Process Flow 6-8
10 Resolution Structure & Mechanism for handling Whistle 8-12
Blower Complaints
11 Reporting to the Audit Committee 12
12 Closure of complaints 12-13
13 Protection to Whistle Blower 13
14 Retaliation 13
15 Responsibilities of Whistle Blower 14
16 Escalation Matrix 14
17 Display of Policy 14
18 Periodicity of reiteration 14
19 List of Documents to be maintained 14-15
20 Record retention 15
21 Recognition 15
22 Validity of the Policy 15

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WHISTLE BLOWER POLICY 2023-24

1. Preamble:

To safeguard the Bank against internal /external threats like frauds, bribery,
corruption, abuse of authority, non-compliance with laid down systems and
procedures, Transgression of Delegated Authority etc. involving financial and
reputational implication, constant vigilance at all levels is necessary through
a process called ‘participative vigilance' where each and every employee /
director has certain role-play and is duty bound to execute the same. The staff
members/directors are expected not to be silent spectators to any wrong doing
in the branch/ office but to report the same to the higher authority/
authorities concerned. The same is intended to ensure that a few unscrupulous
staff members are not vitiating the overall atmosphere / work culture and
putting the Bank's interest in jeopardy.

It is also observed that these acts do not take place overnight but are b eing
carried out/ perpetrated over a period of time. It is unlikely that such acts
could escape the knowledge of other colleagues working in the Branch /
Office. Had such instances of frauds, bribery, corruption, abuse of authority,
non-compliance with laid down systems and procedures etc. been brought to
the notice of the higher authority/ authorities concerned in time, further
damage could have been avoided.

Staff members/directors, many a time, are hesitant to come forward and

report to higher authorities about wrongdoings, mishaps around them fearing
disclose of identity and probable retribution/ victimization from the official/s
concerned. In order to instil confidence in the staff members/directors as well
as to prevent the mishap at the initial stage itself, a need was felt for
introduction of ‘Whistle Blower Policy’ which will lead to ensure more
effective Corporate Governance.

2. Objective of the Policy : The Bank is committed to adhere to the highest

standards of ethical, moral and legal conduct of business operations.
2.1 To maintain these standards, the Bank encourages its employees who have
concerns about suspected misconduct, to come forward and express these
concerns without fear of punishment or unfair treatment.
2.2 The policy aims at providing an avenue for employees to raise concerns on any
violations of regulatory or legal requirements, non-compliance of laid down
system and procedures, wrong-doing, misconduct, irregularities, governance
weaknesses, financial reporting issues e.g. mis-selling, corrupt business
practice, violation of provision of applicable laws.
2.3 To disseminate among and encourage all staffs/Directors of Bank to report

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suspected or actual occurrence of illegal, unethical or inappropriate actions

and at the same time to assure confidentiality of identity as well as safeguards
and protection to staffs/Directors who raise/report instances of illegal,
unethical or inappropriate business practices/behavior observed in Bank.

3. Governing Laws:
Whistle Blower Mechanism is governed by the provisions of Section 177 of the
Companies Act, 2013; guidelines dated 17.04.2014 issued by Securities and
Exchange Board of India (SEBI) regarding Clause 49 of Listing Agreement
between the listed entity and the Securities and Exchange Board of India (SEBI)
regarding clause 49 of Listing Agreement between the listed entity and the
Stock Exchange; and guidelines/directions dated 01.07.2016 issued by Reserve
Bank of India under section 35 (A) of Banking Regulation Act read with the
Whistle Blower Protection Act,2014 (Act 17 of 2014) and the resolution on
Public Interest Disclosure & Protection of Informers(PIDPI) and Guidelines
issued by Central Vigilance Commission etc., as the case may be, which
specifically provide for a “Whistle Blower Mechanism” for the employees of
the organizations, to report allegations of corruption or misuse of office by
the authorities of that organization.

4. Definitions:
4.1 Employee: Employee means every employee of Union Bank of India (Regular
or Contractual) whether working in India or abroad.
4.2 Director: Director means an appointed or elected member of the Board of
Directors of Union Bank of India.
4.3 Audit Committee: The Audit Committee of the Board constituted by our Bank.

4.4 Nodal Officer: The Executive Director(ED) looking after HR vertical will act as
a designated Nodal Officer. The Nodal Officer shall place before the
Designated Committee, all complaints pertaining to Union Bank of India, action
taken and investigation results.

4.5 Designated Committee: A committee comprising of Chairman of Audit

Committee, Executive Director handling Audit & Inspection Vertical, Executive
Director handling HR Vertical would constitute the Designated Committee of the
Bank.
The Chairman of the Audit Committee will be Chairman of the Designated
Committee. The quorum of the meeting would be minimum 2 members.
Chairman of the Audit Committee and Nodal Officer shall be a mandatory
member. The ED looking after HR vertical of the Bank would work as a Nodal
Officer for the activities as defined and mentioned in this policy.

4.6 Senior Management: Senior Management means executives in the grades

equivalent to Chief General Manager and above, including Directors of the
Bank and shall include any head of a department even if not in the grade
equivalent to Chief General Manager. In case of overseas Branches /

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Representative Office, Chief Executive Officer (CEO) shall also be considered

as Senior Management.

4.7 Modes of Communication for a “Whistle Blower”: The Bank has provided the
following modes of communication to employees to raise a concern within the
Bank :

4.7.1 For Employees:

a. Write an e-mail to: [email protected]

b. Write a letter to The Executive Director (Nodal Officer-WB), 14 th floor, Union
Bank Bhawan, Vidhan Bhawan Marg, Nariman Point, Mumbai-400021.
4.7.2 For Senior Management / Directors:

a. The Senior Management/Directors may also raise concern within the bank
directly to the Chairman of ACB/Designated Committee.

4.7.3 Direct access to the Chairman of the Designated Committee, in appropriate

and exceptional cases to the whistle blowers irrespective of whether he is an
employee or Director.

4.8 Protected Disclosure: Protected Disclosure means a complaint raised online

or offline in good faith that discloses or demonstrates information that may
have evidence of unethical conduct or improper activity. But it should be
factual and not speculative i n nature.

4.9 Whistle Blower: Whistle Blower is someone (staff/director of the bank) who
makes a Protected Disclosure under this Policy.

4.10 Good Faith: A Whistle Blower may communicate i n "good faith" if there is a
reasonable basis for communication of unethical and improper practices or any
other alleged wrongful conduct. Good Faith shall be deemed lacking when the
Whistleblower does not have personal knowledge on a factual basis for the
communication or where the employee knew or reasonably should have known
that the communication about the unethical and improper practices or alleged
wrongful conduct is malicious, false or frivolous.

5. Scope of the Policy:

The Policy shall cover Directors on Board of the Bank and all the staff of the
Bank in Branches / Offices domestically as well as abroad.

6. Aim / Objective of the Policy:

The aim of the Policy is to bring transparency in the system and provide
freedom to the Staff / Director/s to raise the concerns while maintaining the
secrecy of the Whistle Blower.

7. Matters covered under the Policy:

The Whistle Blower's role is that of a reporting party with reliable information
and it intends to unearth serious concerns that could have grave impact on the

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operations and performance of the business of the organization. Only, Nodal

Officer will be responsible to open the envelope and access the mail received
from Whistle Blower. It will be sole responsibility of the Nodal Officer to
maintain the secrecy of the Whistle Blower. Any disclosure of the name of the
Whistle Blower may be considered as the Breach of Trust by Nodal Officer and
accordingly action can be initiated. The Nodal Officer shall place before the
Designated Committee all complaints pertaining to Union Bank of India, action
taken and investigation results. The report to be placed to the Designated
Committee may cover areas such as:
7.1. Breach of Bank's Code of Conduct
7.2. Questionable accounting or auditing matters
7.3. Any Bank matters involving abuse of authority
7.4. Fraud, bribery or corruption
7.5. Employee Misconduct
7.6. Illegality
7.7. Wastage/ misappropriation of Bank's funds / assets
7.8. Victimization of employees and Directors
7.9. Harassment
7.10. Breach of IT security and data privacy
7.11. Any other unethical conduct.
7.12. Breach of any law, statute or regulation by the Bank
7.13. Issues related to accounting policies and procedures adopted for any area or
item
7.14. Acts resulting in financial loss or loss of reputation
7.15. Misuse of office, suspected/actual fraud and criminal offences
7.16. Further, the list as mentioned above is of indicative in nature and not
exhaustive. No action is required to be taken on anonymous/ pseudonymous
complaints irrespective of the nature of allegations and such complaints should be
filed. Sexual harassment complaints and HR process related grievances will be
referred to Human Resource Department for investigation, resolution and
closure.

8. Who can blow the whistle?

Any employee (working in India or abroad) or Director of the Bank who has
definite and verifiable information about wrong doing/unfair practices carried
out in the Bank and wishes to make a protected disclosure can blow the
whistle.

9. Whistle Blower Mechanism - Process Flow for making Complaint:

9.1 Complaints through e-mail:
Whistle Blower will have the option of lodging his/her complaint only through
offline/e-mail mode. The detailed procedure to be followed by the
complainant for lodging the complaint under ‘Whistle Blower' category is as
under:

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a. The access right to open/view/access the complaints under "Whistle

Blower" category is restricted only to the Nodal Officer i.e. Executive
Director looking after HR Vertical. It will be sole responsibility of the
Nodal Officer to maintain the secrecy of the Whistle Blower. User ID and
password to access the mail will be with the Nodal Officer only.
b. Nodal Officer would ensure to conceal the personal information viz. name,
PF number, branch, location etc. of the Whistle Blower while, taking
print-out the complaint, to safeguard the identity of the complainant and
accordingly place it before the committee. This will ensure in protecting
the identity of the complainant as also confidentiality of the contents
since only Nodal Officer will have right to access the complaint. All such
complaints received should be kept in a Safe Custody i.e. in a Lock and
Key in the custody of the Nodal Officer only.

9.2 For lodging the complaint off line (i.e. in physical form)
a. Any employee or director can also use the off line mode to lodge the
whistle blower complaint.

b. The complaint should be necessarily in a closed /sealed envelope, which

shall be opened by Nodal Officer only.

c. The envelope should be addressed to the Nodal Officer and should be

super scribed ‘Complaint under Whistle Blower Policy’. If the envelope
is not super scribed and not closed, it will not be possible for the Nodal
Officer to protect the identity of the complainant and the complaint will
be dealt with as per the normal complaint handling policy. Any such
envelops/complaints received need to be opened only by the Nodal
Officer in confidence. The Complainant has to provide his/her name and
address in the beginning or at the end of the complaint or in separately
attached letter. While placing before the committee, Nodal Officer shall
ensure that the personal information viz. name, PF number, branch,
location etc. are concealed/masked from the contents of the complaint.
All such complaints received should be kept in a Safe Custody i.e. in a
Lock and Key in the custody of the Nodal officer only.

d. No action is required to be taken on anonymous/ pseudonymous complaints

irrespective of the nature of allegations and such complaints should be filed.

e. In order to protect the identity of the complainant, Nodal Officer/

Designated Committee should ensure that proper acknowledgement is
provided to the complainant by securing total secrecy. Nodal Officer
should ensure that personal information of the Whistle Blower containing
Name, PF No., Place of posting, Contact Number, email ID, Proof of
identity can be obtained on a different page so that, while sharing the
legitimate material/concern of the complaint with any internal or
external Decision Making Committee or Investigating officer/Committee,
the identity of the Whistle Blower is not disclosed.

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9.3 The disclosure/complaint shall contain as full particulars as possible and shall
be accompanied by supporting documents or other material.

10. Resolution Structure & Mechanism for handling Whistle Blower

Complaints:
10.1 Handling of Complaints:

a. Through e-Mail: Only Nodal Officer shall have the rights to view and add
observations to the whistle blower complaint/s. The Nodal Officer shall
separate the identity from the complaint and shall place it before the
Designated Committee (defined above) for deliberation and taking
appropriate course of action on the complaint.

b. Physical Mode: The whistle Blower Complaints in offline mode shall be

received by the office of Nodal Officer (on the address given at point No.4.7.1
(b)). and placed before the Designated Committee by taking due care.

c. If the complaint is made against the Senior Executive or against any Directors,
then it may be referred directly to the Chairman of ACB/ Designated
Committee, by taking due care.

10.2 The Designated Committee & mechanism outlined below shall deal with the
Whistle Blower complaints.

10.3 Nodal Officer, after receipt of the complaint shall take-up with the Designated
Committee by shielding/detaching the identity of Whistle Blower. No action is
required to be taken on anonymous/ pseudonymous complaints irrespective of the
nature of allegations and such complaints should be filed.

10.4 Only Nodal Officer will have the rights to view e-mail and the details of
complaints received. User ID and password to access the email will remain with
the Nodal Officer only. In case of complaints in physical form, the Nodal Officer,
will open the envelope by keeping the name of the whistle blower strictly
confidential. While, presenting the complaint to the Designated Committee, the
Nodal Officer shall not disclose the name of the Complainant.

10.5 Investigation Initiation Process: The Nodal Officer upon receipt of the
complaint/concern shall ascertain the identity of the complainant and make
discreet inquiry before proceeding further with the complaint and putting up
before the designated committee. As per the PIDPI resolution as well a s the
Whistle Blowers Protection Act, the nodal officer has to “make, in the first
instance, discreet inquiries to ascertain if there is any basis of proceeding
further with the complaint” An appropriate mechanism is also to be devised
for inquiry. It is further provided that “either as a result of the discreet
inquiry, or on the basis of the complaint itself without any inquiry, if the
designated agency/authority is of the opinion that the matter requires to be
investigated further, the designated agency/authority shall officially seek

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comments/ or explanation.

10.6 Investigating arm: The designated committee shall generally use the Audit and
Inspection Wing for investigating the matter further wherever required. After the
Completion of the same, the Audit and Inspection Wing will submit to Nodal
Officer for further placing it to Designated Committee.

10.7 Investigation Report: After conducting investigation, if it reveals that there

was misuse of office and/or substance in the allegations of corruption, the
designated committee, shall recommend appropriate course of action which
shall inter-alia include following:
a. Appropriate proceedings against the concerned staff member,

b. Recommend to appropriate authority / agency for initiation of criminal

proceedings in suitable cases, if warranted, by facts and circumstances of
the case
c. Recommend corrective measures to prevent recurrence of such events in
Future
d. Any other action as deemed fit by the Designated Committee.

10.8 Decision of the Designated Committee: The identity of the complainant will not
be revealed unless the complainant himself has made the details of the complaint
public or disclosed his identity to any other office or authority. If the allegations
made in the complaint are specific and verifiable then the same will be placed
before the designated committee for deliberation. The designated committee
shall make discreet inquiry through Investigating Arm or otherwise to ascertain
whether there is any basis for proceeding further to investigate the matter. If the
Committee is of the opinion that there is no sufficient ground for proceeding
further in the complaint, it shall decide for closure of the matter. If the
committee, as a result of the discreet inquiry or otherwise is of the opinion that
the complaint requires further investigation, it will forward the complaint to the
Investigators through Nodal Officer, for further investigation and to seek report
in the matter. Investigations will be commenced only after review by the
Committee.

10.9 Role of Fraud Monitoring Group: However, wherever there is an element of fraud
in the complaint, the designated committee, post investigation, may refer to
Fraud Monitoring Group (FMG) for their inputs and further course of action. The
designated committee may also take the inputs of FMG for taking any final view on
the complaint, if required or may direct Fraud Monitoring Group (FMG) for
deliberating and taking a decision in the matter.

10.10 Maintaining Transparency in the Investigation: On receipt of matter with the

relevant papers/ documents in respect of the matter raised in the complaint,
the committee may advise the authority/ies from whom such report sought,
to keep the identity of the complainant as secret, even if for any reason/s,
the said authority/ies come to know the identity of the complainant. In spite
of the directions of committee to protect the identity of the complain ant, if

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the identity of the complainant gets disclosed, Nodal Officer, in consultation

with other members of the designated committee shall be authorized to
recommend appropriate action against the authority/person responsible for
making such disclosures. Hence, it is of utmost importance that the
Investigating Arm or any machinery or Official part of investigation are under
this policy, bound to maintain the transparency and secrecy as outlined in this
policy. Designated Committee may question to Nodal Officer for any such
disclosure, since, it is required to be strictly confidential.
10.11 Confidentiality Concern for Whistle Blower Investigations: In specific cases
Designated Committee through Nodal Officer may constitute a committee or a
group of executives with requisite skills/expertise to investigate into the
complaint. The committee/group shall submit its report to Nodal Officer in a
time bound manner. Investigator will maintain confidentiality about identity
of Whistle Blower. The investigator shall also maintain confidentiality about
the investigation process and about the investigation findings.
10.12 Investigation by external Agencies: External technical and other resources
may be drawn upon as necessary to augment the investigation. Designated
Committee through Nodal Officer, will decide on the appointment of external
agencies, depending on the nature of investigation. In case of appointment of
external agency, Nodal Officer will keep Designated Committee informed
through quarterly reporting. Investigating agency, including investigators
working for the agency, shall be bound to maintain confidentiality about
identity of the Whistle Blower.

10.12.1 Confidentiality is made as an important element of the Whistle Blower

Policy and should be ensured at all level.
10.13 Timelines for Investigation: Inquiry into the concerns received by Nodal
Officer shall be normally completed within 45 to 90 days of the date of receipt
of the concern. Concerns requiring additional time to investigate shall be
intimated to the Nodal Officer to take it further to Designated Committee for
extension of time, at the time of reporting the status of the inquiry and action
on a quarterly basis.
10.14 Interviews: Permission need to be obtained from the Designated Committee
for disclosing the name of the Whistle Blower, in case of inquiry compulsions,
during the course of investigation. On obtaining permission from the
Designated Committee, authorized officials may interview relevant person to
seek information. Such interviews can be in the form of in person, telephonic
discussions, explanation sought through email and seeking written
explanation. Prior intimation of the interview may be given through the Nodal
Officer, and it will not be a discretion of the Investigation Officer. In person
and telephonic discussions may be recorded to ensure integrity of the
investigation process and to maintain proper records. Recordings shall not be
provided to any authority except with the prior approval of Nodal
Officer/Designated Committee.

10.15 Filing of Police Complaints: In case of criminal breach of trust, fraud or such

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activity is detected during the course of investigation, falling within ambit of

criminal proceedings, and if required under prevalent law/regulations, Bank
would initiate action and Legal Support Service Department will be responsible
to file the complaint under the directions of Nodal Officer/Designated
Committee. Responsibility of Fraud Monitoring Report if any be with Risk
Management Department in case of Fraud Cases.

10.16 Reporting to Regulators: First Person Responsible (FPR’s) embedded within

each business group assigned with specific responsibility of reporting frauds in
Fraud Monitoring System would be responsible for reporting frauds reported
under Whistle Blower Policy, in line with extant fraud reporting procedures.

10.17 Recovery of fraud losses/misappropriation: In case of any loss to the Bank,

respective Business/Operations group will initiate recovery proceedings with
the involvement of Human Resource Department and Legal Support
Department and take suitable legal recourse as may be necessary.

10.18 Categorization of complaints: Based on conclusion of investigation,

complaints will be categorized in three categories as follows:

a. Allegations substantially proven: In case of genuine complaints, action will

be initiated and will be reported to the designated committee.
b. Allegation investigated and proven “False” : In case of false alarm cases,
if investigators find proof that complaint was made with malicious intent,
matter would be reported to the Designated Committee for initiating any
action if required against the Complainant. Accordingly, on receipt remarks
from Designated Committee, Human Resources Department will suggest the
appropriate action within parameters of Bank’s Code of Conduct and report
to Nodal Officer to obtain consent of the Designated Committee for execution
of the said action. Designated Committee may even relinquish the charges
with warning.

c. Allegations could not be proven: Allegations could not be proven due to

lack of evidence incomplete information and lapse of substantial time
between occurrence of the event and complaint. In case of complaints which
could not be proven, no action would be taken and as such, the status will
be reported to Audit Committee accordingly/Nodal Officer/ Designated
Committee.
10.19 The Committee shall make recommendations to appropriate authorities for
taking suitable action within ten working days from the date of receipt of the
report.

10.20 Technical and other sources may be drawn upon as necessary to augment the
investigation. The designated committee, if deems fit, may call for further
information and may involve any other/additional Officer or outside agency
for investigation. While doing so, it must be ensured that the confidentiality
of the personal information of the staff member/Director is not compr omised
and his confidence is not shaken.

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10.21 The Investigation by itself would not tantamount to an accusation and is to be

treated as a neutral fact finding process. The investigation shall normally be
completed within 45 to 90 days of the receipt of the protected disclosure and
is extendable by such period as the designated committee deems fit.

10.22 If the complaint is found out to be frivolous or Bank is not taking any action,
then the same will be intimated to the whistle blower by updating the status
of the complaint through email to the whistle blower or by letter addressed
to whistle blower.

11. Reporting to the Audit Committee :

11.1 Reporting Frequency: In relation to Whistle Blower Complaints and Senior

Management Escalations, on a quarterly basis, Nodal Officer will provide
details of cases received, as well as complaints under investigation, during the
period, to the Audit Committee. Details would include gist of the complaints,
investigation status and actions taken, but not the identity of the Whistle
Blower. Further, action will also be taken by Nodal Officer based on the
feedback received from members of the Audit/ Designated Committee. All
complaints received and status of investigations/actions thereto, will be
reported at the subsequent quarterly Audit Committee Meeting.

11.2 Contents to be Reported: A quarterly report on Whistle Blower complaints

will be submitted to the Audit Committee containing following information:

a. MIS of complaints received and action taken during reporting quarter and
status of pending cases which were received during previous quarters
b. Case wise information including details of action taken on directions of the
Committee
c. Such other details as desired by the Committee from time to time

11.3 Review of Complaints: A senior official designated by Nodal Officer will

monitor and review the progress, status of investigation, investigation reports
and compliance of closure related actions on regular basis.

11.4 Submission of Report: The investigators shall submit their report to Nodal
Officer in a time bound manner, report should be in a closed and sealed
envelope, to ensure that the matter is kept confidential.

12. Closure of Complaint:

12.1 Criteria for closure of complaints:
False alarms and complaints which could not be proven will be considered as
“Closed” immediately on conclusion of investigation and briefed to that effect
to the Nodal officer. Closure status would be approved by Nodal Officer. In
case of genuine complaints, a case will be considered as “Closed” once
following actions, as applicable and appropriate have been taken:
a. Action against person/persons against whom charges were proven
b. Initiation of recovery of the losses suffered due to fraud, if any

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c. Police complaints being filed

d. Reporting in Fraud Monitoring System in case of frauds

Only after confirmation of compliance with the above requirements, a case

will be reported as “Closed” to the Audit/Designated Committee.

13. Protection to Whistle Blower:

13.1 No one who has made a complaint under this policy should be victimized by
initiation of any proceedings or otherwise merely on the ground that such
person had made a complaint under this policy. Either on the application of
the complainant, or on the basis of the information gathered, if the nodal
officer is of the opinion that either the complainant or the witnesses need
protection, the Nodal Officer shall take up the matter with the designated
committee for issuing appropriate directions. As a result of reporting under
Protected Disclosure the protection is available provided that:
a. The Whistle Blower has chosen to identify himself.
b. The communication/disclosure is made in good faith
c. The Whistle blower reasonably believes that information and any allegations
contained in it, are substantially true.
d. The Whistle Blower is not acting for personal gain.
A whistle blower has the right to protection from retaliation. But this does not
extend to the immunity for involvement in the matters that are subject of the
allegations and investigations.

13.2 Anyone who abuses the procedure (for example by maliciously raising a
complaint knowing it to be untrue) will be subject to investigation by external
investigative agency as per law of natural justice clause of Constitution.
However, no such investigation will be carried out against anyone who makes
an allegation in good faith, reasonably believing it to be true, even if the
allegation is not subsequently confirmed by the investigation.

13.3 Further, if any official/ director is aggrieved by any action on the ground that
he is being victimised due to the fact that he had filed a complaint, he may
file an application before the Chairman of Designated Committee/Audit
Committee of the Board seeking redressal in the matter. Chairman of the
Designated Committee/ Audit Committee of the Board will ensure that no
punitive action is taken by any concerned authority against any person on
perceived reasons /suspicion of being "Whistle Blower".

14. Retaliation: Whistle Blower will not in any way be liable to disciplinary action
or loss of benefits, right or prospects as a result of his/her action. Retaliation
shall not be permissible against any Whistle-Blower and the Bank will not
tolerate any attempt on the part of anyone to apply any sanction or
disadvantage or to discriminate against any person who has reported concern.

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15. Responsibilities of Whistle Blower

The intent of this Policy is to bring genuine and serious issues to the fore and
i t is not intended for petty disclosures. Employees are expected to exercise
their rights under this Policy in a judicious manner by adhering to the following
guidelines.

a. The disclosure/ complaint shall contain as full particulars as possible and

shall be accompanied by supporting documents or other material available.

b. Avoid anonymity when raising a concern.

c. Follow the procedures prescribed in the Policy for making a disclosure.
d. Bring to early attention of the Bank any improper practice he/she become
aware of delay in reporting may lead to loss of evidence and also financial
loss for the organization.
e. Co-operate with investigating authorities, maintain full confidentiality.

16. Escalation Matrix:

If the Whistle Blower/Complainant is not satisfied with the response of the
Designated Committee or is not satisfied with the decision of the Investigating/
Screening Committee he/she is free to take up the matter with the Chairman
of the Audit Committee through written communication for reconsideration.

17. Display/Awareness of the Policy:

Union Bank of India Whistle Blower Policy will be displayed on the web-site of
the Bank, UBINET as well as Union e-Docs. Branches/Offices will disseminate
the contents of the policy amongst all staff members.

18. Periodicity of reiteration: Whistle Blower Policy will be reiterated to all

employees, at least every six months communications will be sent through
email and records of the same will be maintained under records retention
policy for a period of 10 years.

19. List of Documents to be maintained (As applicable)

a. Copy of complaint in hard form that can be filed and preserved

b. Copy of the complaint in soft form that can be provided through email
whenever required
c. Records collected during investigation including, electronic data and
documents
d. Reports submitted by the investigators
e. Final reports submitted to concerned Business/Operations group
f. Audit Committee reports/reviews

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g. Back-up of Committee papers

h. Any communication to/from Business Group, Operations Group, HRD etc.
i. Records of action taken
j. Notes/details submitted to Audit Committee
k. Any other working papers relevant to the case.

20. Record retention : To provide protection to whistle blower and to maintain

secrecy about identity of complainant, records collected during investigation,
including complaint copy need to be preserved with strict controls by HR/Legal
Support Service Department. Further, to avoid leakage of information and to
avoid misuse of the information, data maintenance and retrieval need to be
under proper controlled environment.

21. Recognition:
In case a complaint results in detection of unethical practices/abuse of
authority/fraud/other wrong doings and thereby averts or minimizes the
financial / reputational loss to the Bank, the moral courage shown by the
whistle blower will be recognized by the Bank by way of appropriate indirect
incentives /benefits.
Towards this end, Chairman of the Audit Committee/Nodal Officer will ensure
along with the Chief General Manager (HR) that such genuine informants are
given due weightage in career growth and placement as deemed fit. A dossier
will be personally maintained by the Chief General Manager (HR) in strict
confidence for the purpose. The Designated Committee will ensure full
protection against disclosure of identity of the whistle blower.

22. Validity of the Policy:

The policy shall be valid till 31.03.2024 and its continuity may be extended
for a further period not exceeding three months with the specific approval of
MD & CEO.

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