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WHISTLEBLOWER POLICY
Preamble
An updated version of the Whistleblower Policy ("Policy") is being implemented. Reference is
also drawn to RBI circular no [RBI/2006-2007/328: DO DBS .FrMC No. BC 5 /23.02.011 /2006-
07] dated April 18, 2007 (Annexure-1), the SEBI (Lisng Obligaons and Disclosure
Requirements) Regulaons, 2015 ("SEBI LODR Regulaons") and the Companies Act, 2013 as
amended from me to me. This Policy sets out the current version of the ‘Whistleblower
Policy’ which has been framed and adopted by Axis Bank Limited (“Bank”) in terms of the
applicable law.
The Policy was adopted by the Bank in 2005 and has been periodically reviewed and revised.
This Policy gives Whistleblower(s) (as dened herein) a plaorm to report Protected
Disclosures (as dened herein) without fear of retribuon or vengeful acon from the persons
against whom the Protected Disclosure was submied, in addion to providing for requisite
acons to be taken on a Protected Disclosure being received by the Bank.
The Policy has been referred to in the Code of Conduct and Ethics Policy (as dened
hereinaer), and is hosted on the Bank’s website as well as in MyConnect and One Axis App
under the Code of Conduct and Ethics Policy. All employees are required to submit annual
declaraons of having read and understood this Policy.
The potenal Whistleblowers are advised to go through the Policy's contents carefully and
exercise their rights judiciously.
1. Preface
A central tenet in the Bank's policies on corporate governance is a commitment to ethics,
integrity, accountability, and transparency. To ensure that the highest standards are
maintained in these aspects on an ongoing basis and to provide safeguards to various
stakeholders, the Bank has formulated this Policy to provide Whistleblowers with the
opportunity to address serious concerns arising from actual or suspected occurrence(s) of
illegal, unethical, or inappropriate acon(s), behaviour(s), or pracce(s) commied by any
Subject (as dened herein) as per the process detailed in this Policy. It shall be the duty of
every Employee, and the Bank encourages all Whistleblowers (dened hereinaer), to blow
the whistle i.e., to immediately communicate any actual or suspected occurrence(s) of illegal,
unethical, or inappropriate acon(s), wrongdoing(s), behaviour(s), or pracce(s) by a Subject
without fear of retribuon. In case the oences are commied by senior management, this
Policy also enables the Whistleblower to report the concerns to the Audit Commiee (as
dened hereinaer).
2. Glossary of Terms
The capitalised terms used in this Policy shall have the meaning as described below:
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a) “Audit Commiee” shall mean the Audit Commiee of the Board constuted by the
Bank.
b) “Board” shall mean the Board of Directors of the Bank.
c) “Code of Conduct and Ethics Policy” shall mean the Code of Conduct and Ethics Policy
of the Bank, as may be amended from me to me.
d) “Commiee(s)” shall mean collecvely the Audit Commiee or the Whistleblower
Commiee, as applicable.
e) “Conict of Interest Policy” shall mean the Conict of Interest Management Policy of
the Bank, as may be amended from me to me.
f) "Designated Authority" refers to the Whistleblower Commiee or the Chairman of
the Audit Commiee of the Board.
g) "Director" refers to a member of the board of directors of the Bank.
h) "Employee" refers to the personnel employed by the Bank on a full me, part-me or
contractual basis in India or overseas.
i) “Internal Complaints Commiee" shall mean the commiee set up to deal with
maers regarding sexual harassment in accordance with the Sexual Harassment of
Women at Workplace (Prevenon, Prohibion, and Redressal) Act, 2013.
j) "Protected Disclosure" shall mean any communicaon by a Whistleblower, made in
good faith, relang to any maer specied under Clause 3 of this Policy (provided such
maers is not covered under the exclusions set out under Clause 3 of this Policy).
k) "Subject" refers to any Employee or Director in respect of whom a Protected
Disclosure has been made in terms of this Policy.
l) Third-Party Stakeholder" refers to customers, shareholders, depositors, vendors,
suppliers, contractors, or agencies providing goods or services to the Bank.
m) "Whistleblower" refers to an Employee, Director, Third-Party Stakeholder, or any
other person who, makes a Protected Disclosure of any actual or suspected
occurrence(s) of illegal, unethical, or inappropriate acon(s), wrongdoing(s),
behaviour (s), or pracce(s) by a Subject in relaon to the business, operaons, or
aairs of the Bank, in the form and manner as provided in this Policy.
n) “Whistleblower Commiee” shall mean the whistleblower commiee of the Bank.
3. Scope, Coverage and Exclusions of the Whistleblower Policy
This Policy is applicable to Protected Disclosures with respect to actual or suspected
occurrence(s) of illegal, unethical, or inappropriate acon(s), behaviour(s), or pracce(s)
commied by any Subject including the following (the list given below is only an indicave list
and not exhausve in nature):
a) Misuse of oce and authority.
b) Violaon of internal accounng/ internal control/ operaonal guidelines/policies etc.
c) Any fraud in the preparaon of nancial statements of the Bank.
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d) Manipulaon of data/documents.
e) Leakage/ suspected leakage of unpublished price sensive informaon in violaon of
the Securies and Exchange Board of India (Prohibion of Insider Trading) Regulaons,
2015.
f) Failure to comply with legal, compliance and regulatory requirements.
g) Misappropriaon of funds.
h) Actual or suspected fraud, corrupon or irregularies, including forgery or alteraon
of documents.
i) Any unlawful act, whether criminal or civil, or other oences commied or likely to be
commied that may implicate the Bank or adversely aect its reputaon.
j) Discriminaon against a member of sta, service recipient or service provider on the
grounds of sex, caste, sexual orientaon, gender, creed, religion, or disability.
k) Violaons of the laid down policies, rules, regulaons, communicated procedures of
the Bank , including the following policies:
i. Code and Conduct and Ethics Policy;
ii. Conict of Interest Policy;
iii. Insider Trading Policy;
iv. POSH Policy (subject to exclusions specied under this Clause below);
v. KYC/AML policies;
vi. An-Bribery and An-Corrupon Policy
l) Data breach and/or unauthorised disclosure of Bank's proprietary data including
customer data.
m) Any other form of inappropriate/unethical/unlawful acon or conduct of a Subject
(conduct may be considered unethical if it undermines universal core ethical values
such as integrity and honesty), including if such act has a potenal to cause nancial
or reputaonal loss to the Bank.
n) Violaon of central or state laws, rules, regulaons, and/or any other regulatory/
judicial direcves.
Exclusions:
The following types of complaints are excluded from the scope of this Policy:
a) Repeve complaints which are largely unsubstanated and/or without any value
addion.
b) Complaints which are vague, ambiguous and do not contain specic and veriable
informaon so as to establish a prima facie case for invesgaon.
c) Complaints which are personal and are not related to the business, operaons, or
aairs of the Bank.
d) Complaints of sexual harassment, which will require to be led and which shall be dealt
with in accordance with Sexual Harassment of Women at Workplace (Prevenon,
Prohibion, and Redressal) Act, 2013 and the POSH Policy of the Bank.
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e) Complaints which have been made by an Employee and/or a Third-Party Stakeholder
and/or any other person only to Banking Ombudsman/ PNO /Regulatory desk of the
Bank, MD escalaon desk of the Bank, CNO team, other forums of the Service Recovery
Team of the Bank (and such complaint has not been made to the Banks’ Whistleblower
forum/ Commiee(s) by the complainant as a protected disclosure or in the capacity
of a whistleblower). Complaints made to such other departments/forums may be
referred to the applicable invesgaons department directly by the
departments/channels receiving the complaint and the complaint would be dealt with
as per the extant/exisng process.
4. Roles and Dues of the Whistleblower
a. A Whistleblower is a person who makes a Protected Disclosure, without acng as an
invesgator and cannot, therefore, require or instruct the invesgaon to be
conducted as per the Whistleblower’s own will, nor does he/she have a right to
parcipate in any invesgave acvity other than to the extent that his/her
cooperaon is sought by the invesgaon ocer(s).
b. The Whistleblower is not entled to determine/direct what type of correcve or
remedial acon may be warranted with respect to a Protected Disclosure.
c. The Whistleblower should provide specic and veriable details in the Protected
Disclosure in an appropriate language that is not oensive.
d. The Whistleblower can seek claricaons with respect to this Policy, including the
Whistleblower’s role and the implicaons of subming the Protected Disclosure
from the Ethics Department (Whistleblow[email protected]om). The nal decision to
make the Protected Disclosure will, however, be solely that of the Whistleblower.
e. Though the Whistleblower would not necessarily be required to conclusively prove
the points contained in the Protected Disclosure, in order to support such disclosure,
the Whistleblower should provide all available evidence (which should be specic and
veriable and relate to the business, operaons or aairs of the Bank) to establish a
prima facie case for invesgaon.
5. Protecon available to the Whistleblower
a. The identy of the Whistleblower (in case revealed by the Whistleblower) shall be kept
condenal and will not be revealed other than as specied here under.
b. Complete protecon will be given to the Whistleblower against retaliaon or
retribuon consequent upon his/her having reported a Protected Disclosure. In the
event the Whistleblower experiences any such incidents, the Whistleblower should
immediately report the same by email to the Whistleblower Commiee at
whistleblow[email protected]om or the Chairman of the Audit Commiee at
[email protected]om.
c. Any Whistleblower raising a concern under the Policy in good faith, believing it to be
substanally true, is assured of the protecon.
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d. The Bank will take steps to minimize dicules that a Whistleblower may face in the
submission of a Protected Disclosure. For instance, the Whistleblower will be
reimbursed for the expenses incurred in travel, boarding, and lodging for tendering
evidence, if warranted, as per applicable internal policies.
e. In case any acon has been iniated against the Whistleblower (for acts of omission
or commission aributed to the Whistleblower), the disciplinary authority in such
cases should comprise of Ocers of grade not lower than President.
f. Any person who assists in invesgang a Protected Disclosure and/or assists in
disciplinary/ whistleblower proceedings relang to the Protected Disclosure will also
be protected to the same extent as the Whistleblower.
g. In case the protecon to the Whistleblower as well as persons assisng in the
invesgaon (and/or assisng in the disciplinary/ whistleblower proceedings) is
violated in any manner, the same may be reported by email to the Whistleblower
Commiee at whistleblow[email protected]om or the Chairman of the Audit Commiee
at wbacb@axisbank.com.
The protecons available under this Policy will not be extended to the following
circumstances:
i. If the Whistleblower has raised a complaint/protected disclosure to a forum other
than the Commiee(s) and has revealed his/her identy.
ii. If the protecon is sought from departmental acons arising out of false or bogus
disclosure made with mala de intenon or complaints made to sele personal
grievance;
iii. If the disclosures made by the Whistleblowers are subsequently found to be mala
de or frivolous or with a malicious intenon. Such Whistleblowers shall be liable
to be prosecuted and appropriate disciplinary acon will be taken against them
under the applicable Bank’s policies, when it is established that the Protected
Disclosure has been made with intenon of malice;
iv. If any adverse acon has been taken against the Whistleblower which is
independent of his/her disclosure under this Policy or alleged wrongful conduct,
poor job performance, any other disciplinary acon, etc. unrelated to a disclosure
made pursuant to this Policy.
v. The identy of the Whistleblower will not be protected and may be revealed in
the following scenarios (i) as required in terms of any law or regulaon or orders
of any courts or tribunals; (ii) to the invesgaon ocers and the team carrying
out the invesgaon into the Protected Disclosure;(iii) to members of the
Commiee(s); (iv) to the ocials assisng the Commiee(s); (v) to the ocials of
the Ethics Department; (vi) as permied/required by the Whistleblower; (vii) [to
the ‘ Subject’ if the allegaons are of a personal nature and the Subject is required
to know the identy of the Whistleblower for co-operang in the invesgaon as
per assessment of the applicable invesgaon department(s)]; (viii) if the identy
has been disclosed in the public domain by the Whistleblower, or by any other
person other than as a breach of this Policy.
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vi. Any employee who is found to be involved in misuse or malicious use of the Policy,
or making of false allegaons or seeking personal advantage would not get
protecon under the policy and would face strict disciplinary acon.
vii. A Whistleblower will not get protecon under this Policy if the Whistleblower is
also found guilty of any misconduct (with respect to the Protected Disclosure or
otherwise). It is claried that, while the Commiee(s) will take cognizance of the
Protected Disclosure, the Whistleblower's misconduct will be dealt with
separately and is liable for disciplinary acon, if such misconduct is proven.
6. Protected Disclosures received from Anonymous Whistleblower(s)
The Bank encourages Whistleblower(s) to disclose their identy while making the Protected
Disclosure under the Policy. However, if the Whistleblower wishes to keep the identy
anonymous, such Protected Disclosure may be invesgated by the Bank only if the Commiee
is sased that such anonymous Protected Disclosure contains specic and veriable
informaon along with evidence (to the extent available with the Whistleblower) to establish
a prima facie case for invesgaon. However, it is claried that unl the Commiee is sased
that such anonymous Protected Disclosure contains specic and veriable informaon, the
Bank/ Commiee is not bound to take any specic steps/acons or conduct invesgaon(s) in
relaon to such Protected Disclosure. Neither the Bank nor the Commiee(s) bear any liability
or responsibility in this regard.
If in the opinion of the Bank, the informaon provided by the anonymous Whistleblower is
insucient, the Bank will aempt to reach out to the anonymous Whistleblower (if possible)
to obtain addional informaon to enable the conduct of an invesgaon.
Where such Protected Disclosures are not invesgated due to a lack of specic and veriable
informaon, these shall, in any event, be kept on le and in the records. If at any subsequent
stage the Whistleblower comes forward with idenfying the Whistleblower or provides
sucient proof to the sasfacon of the Commiee, the Bank shall consider the same afresh.
With respect to anonymous Protected Disclosures, the Bank (including the invesgang
departments and the Whistleblower/ Disciplinary departments) may request the
Whistleblower to disclose his/her identy, if allegaons in the Protected Disclosure are of a
personal nature and the identy is required for the purposes of conducng the invesgaon
into such allegaons. For example, Bank may request the Whistleblower to disclose his/her
identy, including if the allegaons related to the following:-
a) PMS rang of the Whistleblower;
b) discriminaon or other behavioural harassment suered by the Whistleblower;
c) unethical/illegal/wrongful transacons where the Whistleblower may also be involved /
is a party to the transacon and such details are required for the invesgaon.
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7. Whistleblower Commiee
The Whistleblower Commiee will comprise of members from the pool of members approved
by the Audit Commiee of the Board. The composion, constuon, quorum, meengs, and
other maers relang to the Whistleblower Commiee shall be in accordance with the
framework approved by Vercal Head for Ethics Department (in the Rank of GE and above).
8. Role of the Whistleblower Commiee
a) The Whistleblower Commiee will consider the credibility of the Protected Disclosure,
the gravity of the issue raised and the likelihood of proving the allegaon(s) from
independent, veriable sources.
b) The Whistleblower Commiee shall have the discreon to appoint any ocial(s) of the
Bank/ external expert/agency to carry out any invesgaon as it may feel necessary,
and require Chief of Internal Vigilance (CIV)/Invesgaons Departments Head to
oversee and monitor the external expert/agency, if deemed appropriate by
Whistleblower Commiee.
c) The Whistleblower Commiee, may in its sole discreon, refer back an invesgaon
report(s) (IVR) to the invesgaon unit for further re-examinaon if the Commiee
members are of the view that the ndings with regard to the allegaons made in the
Protected Disclosure are not adequately addressed. Further, the Whistleblower
Commiee may also require a fresh invesgaon to be conducted or expand the scope
of the exisng invesgaon, if the Whistleblower Commiee is of the view that such
acons are warranted.
d) Any member of the Whistleblower Commiee who has a conict of interest shall
promptly disclose the same to the other members and recuse himself/herself from the
maer. If any such conict of interest is discovered (whether or not disclosed) the
concerned member of the Whistleblower Commiee shall be removed.
9. Procedure for Reporng Protected Disclosures
a) All Protected Disclosures reported against ocials in the ranks of President and below
should be addressed to the Whistleblower Commiee, which may be reported through the
following channels:
i. By post to
The Whistleblower Commiee
Axis Bank Limited
2nd Floor
Axis House
C2 Wadia Internaonal Centre
Pandurang Budhkar Marg
Mumbai 400025
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ii. Web-based portal - hps://whistleblower.axisbank.co.in
iii. Email to the Whistleblower Commiee at whistleblower@axisbank.com..
All communicaons to the Whistleblower Commiee should carry the capon "Protected
Disclosure under the Whistleblower Policy" in the subject eld.
The envelope/email containing the Protected Disclosure should be marked "Condenal".
b) All Protected Disclosures against the members of the Whistleblower Commiee, Directors,
and employees in the rank of Execuve Directors ("EDs")/ Group Execuves ("GEs"), Board
members and above, including Dy Managing Director /Managing Director & Chief Execuve
Ocer ("MD & CEO") may be reported through the following channels :-
i. By email to the Chairman of the Audit Commiee of the Board at wbacb@axisbank.com.
The email should have as the subject line “Protected Disclosure under the Whistleblower
Policy”;
ii. By post with the subject line “Protected Disclosure under the Whistleblower Policy” in the
subject eld/ cover of the envelope addressed to:
The Chairman, Audit Commiee of the Board
Axis Bank Limited
Axis House
C2 Wadia Internaonal Centre
Pandurang Budhkar Marg Mumbai
400025
The envelope/email containing the Protected Disclosure should be marked "Condenal".
c) Any member of the Audit Commiee who has a conict of interest, shall promptly disclose
the same to the other members and recuse himself/herself from the maer. If any such
conict of interest is discovered (whether or not disclosed) the concerned member of the
Audit Commiee shall be removed.
d) Protected Disclosures should preferably be reported using electronic channels and if
submied in hard copy, should either be typed or wrien in legible handwring in English,
Hindi or in the regional language of the place of employment of the Whistleblower.
e) Without prejudice to Clause [9 (d)] above, the Protected Disclosure should be forwarded
under a covering leer (or as an aachment to the email message) such that only the
covering leer/email message bears the identy of the Whistleblower. The Whistleblower
should, preferably, disclose the personal details only as part of the separate covering
leer/e-mail sent together with the Protected Disclosure and such personal details should
not be a part of the Protected Disclosure itself.
f) In case the Whistleblower has a personal interest in the maer, it should be disclosed at
the outset in the forwarding leer/email message.
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g) Copies of documents that will help in establishing the veracity of the Protected Disclosure
should be aached to the Protected Disclosure. Please also note that Bank requires specic
and veriable informaon along with evidence (to the extent available with the
Whistleblower) to establish a prima facie case for invesgaon in case of anonymous
Protected Disclosures.
h) The Designated Authority shall detach the covering leer/email message and forward only
the Protected Disclosure to the invesgators for invesgaon.
i) An acknowledgement of receipt of the Protected Disclosure will be sent to the
Whistleblower through the prescribed electronic channels and, in case of handwrien
Protected Disclosures, if the complete address is provided within a reasonable me.
10. Invesgaon and Redressal of the Protected Disclosure
a) The Protected Disclosure received under this Policy will be examined to determine if a
prima facie case exists for inquiry. The same would be forwarded for invesgaon to the
concerned invesgaons department.
b) However, the decision to conduct an invesgaon is by itself not an acceptance of the
allegaons. In other words, the invesgaon process is to be treated as a neutral
facinding process.
c) Stringent disciplinary or other acon may be iniated against Whistleblowers
making/facilitang frivolous complaints/ Protected Disclosures.
d) The Subject(s) shall have a duty to co-operate with the Commiee or the invesgaon
authority /any of the invesgaon ocers during invesgaon.
e) Once the invesgaon is completed and an appropriate acon has been taken by the
Commiee, the Whistleblower will be informed about the closure, as maybe authorized
by the Commiee.
f) If it is deemed necessary by the invesgaon authority, that it is necessary to verify the
contents of the Protected Disclosure, the invesgaon authority (Internal/ External) may
contact the Whistle Blower at the address/ phone number/ e-mail ID given in the
Protected Disclosure for the purpose of invesgaon (wherein the details have been
revealed by the Whistleblower).
g) If the Whistleblower is dissased with the disposal of the Protected Disclosure, the
Whistleblower may approach the MD & CEO (if the maer has been handled by the Audit
Commiee) or the Chairman of the Audit Commiee( if the maer has been handled by
the Whistleblower Commiee) for review.
h) However, the Commiee/MD & CEO/ Chairman of the Audit Commiee, as the case
maybe, will not be liable to disclose to the Whistleblower the outcome of the invesgaon
and acon taken in this regard. Further, any requests by the Whistleblower on the status
of the Protected Disclosure/outcome of the invesgaon/ acon taken etc. will not be
entertained.
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11. Outcome of Invesgaons into Allegaons under a Whistleblower Policy
If the invesgaon report reveals that an illegal, unethical, or inappropriate acon(s),
behaviour (s), or pracce(s) has been commied, the Protected Disclosure along with the
invesgaon report shall be (a) referred for disciplinary procedure/ acon against the erring
Subject(s) in accordance with the Code of Conduct and Ethics Policy of the Bank; (b) in respect
of behavioural issues/ HR related maers, the Designated Authority can direct correcve
acon by HR such as: counselling, transfer, role change, etc. against the erring Subject(s) as
deemed t by the Designated Authority basis the invesgaon report; or (c) any other acons
as the relevant commiee deems t basis the invesgaon report. It is claried that any
disciplinary or correcve acon iniated against the Subject(s) as a result of the ndings of an
invesgaon pursuant to this Policy shall be as per the applicable disciplinary procedures of
the Bank enumerated in the Bank’s Code of Conduct and Ethics Policy and Bank may also take
other acons against the Subject(s) as deemed t, including acons under other polices of
Bank.
12. Reporng to the Audit Commiee
A quarterly report on synopsis of Protected Disclosures made pursuant to this Policy shall be
submied to the Audit Commiee for informaon. The Ethics Department shall assist the
Whistleblower Commiee with administraon of the policy and will monitor and submit
quarterly reports to the Audit Commiee.
13. Display and Nocaon
The Policy shall be displayed on the Bank's website. The same is available under Code of
Commitment. Further, this Policy is also available on My Connect (as a part of annual
declaraons under the Code of Conduct) and One Axis App.
14. Retenon of Documents
a) All Protected Disclosures, along with other documents relang thereto shall be
retained by the Bank for a minimum of Ten years or as maybe required under the
Bank’s internal policies/ applicable laws and guidelines.
b) The invesgaon report of each invesgaon duly approved/ reviewed by the
Competent Authority / by the concerned Invesgaon Ocers shall be retained for the
same period as set out in Clause 14.a) for future requirement of either the Bank or the
external authority.
Page 11 of 14
15. Administraon of the Whistleblower Policy
Ethics Department is responsible for the administraon of this Policy. The Policy shall be
reviewed, on an annual basis at a minimum, and submied to the Audit Commiee and Board
for approval.
Version
Review
Date
Policy
Owner
Authored
by
Reviewed/
Proposed
by
Change
descripon
2023. 01
14.09.2023
Head
Ethics
Head
Ethics
Head
Ethics
Revised
Version
2024. 2
18.06.2024
Mahim
Bhandari,
SVP I &
Head-
Ethics
Nisha Ochani,
VP & Team
Lead
Whistleblower
Mahim
Bhandari,
SVP I &
Head-
Ethics
Revised
Version
Annexure- 1
RBI circular no [RBI/2006-2007/328: DO DBS .FrMC No. BC 5 /23.02.011 /2006-07
Annex
Protected Disclosures Scheme for Private Sector and Foreign Banks
1. Introducon
1.1 Disclosure of informaon in the public interest by the employees of an organisaon is
increasingly gaining acceptance by public bodies for ensuring beer governance standards
and probity / transparency in the conduct of aairs of public instuons. Large scale corporate
frauds had necessitated, internaonally, various legislave measures for safeguarding public
interest, through enactments such as Whistleblower Protecon Act in USA and Public Interest
Disclosure Act in UK. In the Indian context, the Government of India had passed a resoluon
on April 21, 2004 authorizing the Central Vigilance Commission (CVC) as the ‘Designated
Agency’ to receive wrien complaints or disclosure on any allegaon of corrupon or of
misuse of oce and recommend appropriate acon. The jurisdicon of the CVC in this regard
is restricted to employees of the Central Government or of any corporaon established by it
or under any Central Act, Government companies, sociees or local authories owned or
controlled by the Central Government.
Page 12 of 14
1.2 As a proacve measure for strengthening nancial stability and with a view to enhancing
public condence in the robustness of the nancial sector, RBI has formulated a scheme called
“Protected Disclosures Scheme for Private Sector and Foreign Banks”. The salient features of
the Scheme are as under:
2. Scope and Coverage
2.1 As Public Sector Banks and Reserve Bank of India (since it is an enty established under
Central Statute) have already been brought under the purview of Government of India
scheme, with a view to avoid duplicaon, this Scheme would cover all private sector and
foreign banks operang in India.
2.2 The complaints under the Scheme would cover the areas such as corrupon, misuse of
oce, criminal oences, suspected / actual fraud, failure to comply with exisng rules and
regulaons such as Reserve Bank of India Act, 1934, Banking Regulaon Act 1949, etc. and
acts resulng in nancial loss / operaonal risk, loss of reputaon, etc. detrimental to
depositors’ interest / public interest.
2.3 Under the Scheme, employees of the bank concerned (private sector and foreign banks
operang in India), customers, stake holders, NGOs and members of public can lodge
complaints.
2.4 Anonymous / pseudonymous complaints will not be covered under the Scheme and such
complaints will not be entertained.
2.5 Reserve Bank of India (RBI) will be the Nodal Agency to receive complaints under the
Scheme. RBI would keep the identy of the complainant secret, except in cases where
complaint turns out to be vexaous or frivolous and acon has to be iniated against the
complainant as menoned at para 2.6 below.
2.6 The instuon against which complaint has been made can take acon against
complainants in cases where movated / vexaous complaints are made under the Scheme,
aer being advised by RBI. An opportunity of hearing will, however, be given by the concerned
bank to the complainant before taking such acon.
2.7 Final acon taken by RBI on the complaint will be inmated to the complainant.
3. Procedure for lodging the complaint under the Scheme
3.1 The complaint should be sent in a closed / secured envelope.
3.2 The envelope should be addressed to The Chief General Manager, Reserve Bank of India,
Page 13 of 14
Department of Banking Supervision, Fraud Monitoring Cell, Third Floor, World Trade Centre,
Centre 1, Cue Parade, Mumbai 400 005. The envelope should be superscribed “Complaint
under Protected Disclosures Scheme for Banks”.
3.3 The complainant should give his / her name and address in the beginning or end of the
complaint or in an aached leer. In case of an employee making such complaint, details such
as name, designaon, department, instuon and place of posng etc. should be furnished.
3.4 Complaints can be made through e-mail also giving full details as specied above. For this
purpose, a specic e-mail id has been created.
3.5 The complainant should ensure that the issue raised by him involves dishonest
intenon/moral angle. He should study all the relevant facts and understand their signicance.
He should also make an eort, if possible, to resolve the issue through internal channels in
order to avoid making the complaint.
3.6 The text of the complaint should be carefully draed so as not to give any details or clue
to complainant’s identy. The details of the complaint should be specic and veriable.
3.7 In order to protect the identy of the complainant, RBI will not issue any
acknowledgement of receipt of the complaint and the complainants are advised not to enter
into any further correspondence with the RBI in their own interest. RBI assures that, subject
to the facts of the case being veriable, it would take necessary acon, as provided under the
scheme. If any further claricaon is required, RBI will get in touch with the complainant.
3.8 If the complaint is accompanied by parculars of the person making the complaint, the
RBI shall take the following steps :
a) If necessary, it would ascertain from the complainant whether he was the person who
made the complaint or not.
b) The identy of the complainant will not be revealed unless the complainant himself
has made the details of the complaint either public or disclosed his identy to any other
authority.
c) If the identy of the complainant is concealed, RBI shall make discreet inquiries to
ascertain if there is any basis for proceeding further with the complaint.
d) Either as a result of the discreet enquiry, or on the basis of complaint itself without any
inquiry, if RBI is of the opinion that the maer requires to be invesgated further, RBI may
consider calling for the comments / response from the Chairman / Chief Execuve Ocer of
the concerned bank.
e) Aer obtaining the response of the concerned bank and / or on the basis of an
independent scruny conducted / ordered by RBI, if RBI is of the opinion that the allegaons
are substanated, the RBI shall recommend appropriate acon to the concerned bank. These
shall, inter alia, include the following :
• Appropriate acon to be iniated against the concerned ocial.
Page 14 of 14
• Appropriate administrave steps for recovery of the loss caused to the bank as a result
of the corrupt act or mis-use of oce, or any other oence covered by the Scheme.
• Recommend to the appropriate authority / agency for iniaon of criminal
proceedings, if warranted by the facts and circumstances of the cases.
• Recommend taking correcve measures to prevent recurrence of such events in
future.
• Consider iniang any other acon that it deems t keeping in view the facts of the
case.
3.9 If any person is aggrieved by any acon on the ground that he is vicmized due to ling
of the complaint or disclosure, he may le an applicaon before the RBI seeking redressal in
the maer. RBI shall take such acon, as deemed t. In case the complainant is an employee
of the bank, RBI may give suitable direcons to the concerned bank, prevenng iniaon of
any adverse personnel acon against the complainant.
3.10 Either on the basis of applicaon of the complainant or on the basis of informaon
gathered, if the RBI is of the opinion that either the complainant or the witnesses in the case
need protecon, the RBI shall issue appropriate direcons to the concerned bank.
3.11 The system evolved herein shall be in addion to the exisng grievances redressal
mechanism in place. However, secrecy of identy shall be observed, only if the complaint is
received under the scheme.
3.12 In case RBI nds that the complaint is movated or vexaous, RBI shall be at liberty to
take appropriate steps.
3.13 In the event of the identy of the informant being disclosed inspite of RBI's direcons
to the contrary, the RBI shall be authorized to iniate appropriate acon as per extant
regulaons against the person or agency making such disclosure. RBI may also direct such
person or agency to suitably compensate the complainant.
4. Framing of protected disclosure policy by banks
All private sector and foreign banks operang in India may frame a ‘Protected Disclosures
Scheme’ duly approved by their respecve Boards of Directors, keeping in view the broad
framework given above. The policy should clearly lay down norms for protecon of identy of
employees making disclosures under the scheme and safeguarding them from any adverse
personnel acon. The role and responsibilies of the Board of Directors may also be well
dened in dealing with the complaints received under the scheme. The Board, or a commiee
of Directors of the Board may be made responsible for monitoring the implementaon of the
scheme. Banks may factor suggesons of the unions / associaons of ocers / employees
before framing such a policy. Suitable mechanism should be put in place to make newly
recruited employees of the bank aware of the existence of such a scheme in the bank.