WHISTLE BLOWER POLICY

• Objective
  ‘Whistleblowing’ policy empowers employees to inform suspected misconduct, illegal acts or failure to act within or with third party dealing with the organization without threat of designation and position. The aim of this Policy is to encourage employees and others who have serious concerns about any aspect of the Colleagues/Manager at work to come forward and voice those concerns to the designated Compliance Officer. Employees are often the first to realize that there may be something seriously wrong within or with third party dealing with the organization. ‘Whistleblowing’ is viewed as a positive act that can make a valuable contribution.
• Scope
  The Policy is applicable::
  • Employees of all branches/Zone/State at all levels
  • Employees of contractual nature, agency staff, Temporary workers, Management Trainees, Probation employees and directors
  • Voluntary workers, Trainees, interns working with ISFC
  • Employees of suppliers and those providing services under a contract or other agreement with ISFC.
  • ISFC customer.
• Policy
  No adverse personnel action shall be taken or recommended against an employee in retaliation to his disclosure in good faith of any unethical and improper practices or alleged wrongful conduct in the organization or amongst its employees. This policy protects such employees from unfair termination and unfair prejudicial employment practices. However, this policy does not protect an employee from an adverse action which occurs independent of his disclosure of unethical and improper practice or alleged wrongful conduct, poor job performance, any other disciplinary action, etc. unrelated to a disclosure made pursuant to this policy. The Whistle Blowing Policy aims to:
  • Encourage employee to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about Unethical and Improper practice
  • Provide avenues for employees to raise those concerns and receive feedback on any action taken and in case of disagreement the process of escalation.
  • Reassure employee that they will be protected from possible reprisals or victimisation if they have made any disclosure in good faith.
  Unethical and Improper Practices
  Unethical and improper practices shall mean –
  1. An act which does not conform to approved standard of social and professional behaviour;
  2. An act which leads to unethical business practices;
  3. Improper or unethical conduct;
  4. Breach of etiquette or morally offensive behavior;
  5. An act against the accepted business practices or values of the organization, etc.
  6. Fall below established standards of practice; or
  7. Conduct which is an offence or a breach of the law (a criminal offence has been committed or failing to comply with any other legal obligation)
• Interpretation
  Terms that have not been defined in this Policy shall have the same meaning assigned to them in the Companies Act, 1956 and/or SEBI Act and/or any other SEBI Regulation(s) as amended from time to time.
• Guidelines
  • Disclosure & Maintenance of Confidentiality
    An employee / vendor who observe or notices any unethical & improper practices or alleged wrongful conduct in the Company may report the same to the Head of Department or Head HR or in case it involves Managerial Personnel to the Managing Director. Confidentiality of whistle blower shall be maintained to the largest extent possible.
  • Compliance Officer
    Compliance officer is Chief Operations Officer, of the company.
  • Procedures
    Any employee / vendor who observes any unethical & improper practices or alleged wrongful conduct shall make a disclosure to the Head of Department or Compliance Officer or Head HR or in case it involves Managerial Personnel to the Managing Director. Employee can write an e-mail to sayit@isfc.in or call the Compliance Officer at 7829906637 as soon as possible but not later than 45 consecutive calendar days after becoming aware of the same.
    The following process shall be followed:
    • The Departmental Head shall immediately forward the Whistle Blower Report Compliance Officer.
    • The Compliance Officer may cause such enquiry to be conducted as deemed appropriate given the nature of the complaint lodged.
    • An Anonymous Complaint will be taken up only if it has substance and full details are given.
    • If the complaint is against the Compliance Officer, it can then be directed to MD of the company and shall be directed by MD.
    • The Compliance Officer, after due enquiries, pass orders for remedies as per the disciplinary policy.
    • The cases reported shall be updated in Executive Committee and Audit Committee.
    • For every legitimate complaint received from the employees, the employee shall be awarded with the maximum bonus slab applicable for the year as per PMS process.
• False Allegation & Legitimate Employment Action
  An employee / vendor who knowingly makes false allegations of unethical & improper practices or alleged wrongful conduct to the Audit Committee shall be subject to disciplinary action, up to and including termination of employment, in accordance with Company rules, policies and procedures. Further, this policy may not be used as a defence by an employee against whom an adverse personnel action has been taken independent of any disclosure of information by him and for legitimate reasons or cause under Company rules and policies
• Notification
  All departmental heads are required to notify & communicate the existence and contents of this policy to the employees of their department. The new employees shall be informed about the policy by the HR department.
  This policy as amended from time to time shall be made available at the internet site of the Company which is accessible to its employees/vendors.

Pricing Policy

Indian School Finance Company Private Limited will follow the following internal guiding principles and interest rate model for determining Interest rate, processing fees and other charges to our customers, as laid out by the board the Indian School Finance Company. ISFC will apply best industry practices so long as such practice does not conflict with or violate RBI guidelines.The policy of ISFC for determining Interest Rates, Processing and Other Charges is as follows:

Corporate Social Responsibility Policy