TVS INDUSTRIAL & LOGISTICS PARKS PVT LIMITED

CIN: U45200MH2005PTC154628

VIGIL MECHANISM

Objective

a) To provide for safe avenues for all Directors and employees to raise concerns when
violations take place directly or indirectly, intentionally or otherwise, which would bring
disrepute to the strong edifice built by TVS Industrial & Logistics Parks Private Limited
(“Company” which expression shall also include its subsidiary companies), on the
foundations of high standards of integrity, dedicated customer service, fair business
practices, efficient, safe and trusted financial policies, highest levels of compliance
with all applicable laws in letter and spirit.

b) To provide necessary safeguards for protection to the directors and employees from
victimization for whistle blowing in good faith.

Applicability
This policy shall be applicable to all directors and employees of the Company.

Main features

To be used for reporting any serious actual or suspected frauds, concerns relating to
financial matters/ reporting, unethical or illegal conduct or actual or possible violation of
code of conduct / ethical standards actions which are not in line with the applicable policies
of the Company, actions which would affect the Company’s image or reputation, actions
which are in the nature of harassment or actions that would amount to serious improper
conduct.

Procedure

1) Whistle Blowers
Directors and Employees making disclosure under this policy is referred to as “Whistle
Blower” or “Complainant”. The Whistle Blower has to demonstrate or provide sufficient
grounds for his / her concern, but should not make any malicious allegations which would
result in disciplinary action.

2) Whom to Report
The Complainant should submit the report raising the concern to the Chairman of the
Audit Committee of the Company.

3) When to Report
The Complainant shall raise the issue immediately / promptly but within a reasonable
period of the event / action / finding but not later than 45 consecutive days.

4) How to Report
The report should include as much information about the suspected violation. Where
possible, it should describe the nature of the suspected violation; the identities of persons
involved in the suspected violation; a description of documents that relate to the suspected
violation and the time frame during which the suspected violation occurred. The
Complainant may be required to give further information.

5) Making a protected disclosure
Any Director/employee covered by this policy and the issue concerning financial/
accounting matters may make a disclosure in writing, duly addressed to the Chairman of
the Audit Committee as early as possible, but not later than 45 consecutive days after
becoming aware of the issue, through email/letter.
.
The Complainant must put his / her name to allegations, for timely resolution of the issue
and for ensuring that adequate protection is granted to him / her under the policy. No
anonymous allegation will be entertained.
The written disclosure must ensure the following:
 disclosure to be typed or written in legibly either in English or Hindi or in
regional language of place of employment.
 clear understanding of the issue is brought out.
 actual facts are explained in the issue, and it is not merely speculative.
 specific information is provided to the maximum extent to allow conduct of
Investigation.
 financial or other impact (if any) to be detailed.
 in case the issue was previously brought out, outcome of the same.

6) Contact Details
Chairman of the Audit Committee, TVS Industrial & Logistics Parks Private Limited, B –
106, 10th Floor, ‘B’ Wing, Mittal Tower, Nariman Point, Mumbai 400021.

7) Investigation
All reports under this policy will be investigated promptly by the Chairman of the Audit
Committee or any committee formed by the Chairman of the Audit Committee at his
discretion.
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 offence. Reasonable and necessary steps will also be taken to prevent any further
violations.

8) Safeguards against victimization
i) No adverse action shall be taken or recommended against a Complainant in
retaliation to his/her blowing the whistle. Harassment / victimization of the
Complainant will constitute sufficient ground for dismissal of the concerned
director/ employee.
ii) Source of information to the Complainant shall be disclosed to facilitate
investigation.
iii) Every effort will be made to protect the Complainant’s identity subject to any legal
constraints that may arise from time to time.
iv) This policy will also be reviewed by the Audit Committee based on necessity.