MAHINDRA & MAHINDRA LTD. | Integrated Annual Report 2021-22

68 COMPANY OVERVIEW BOARD’S REPORT MANAGEMENT DISCUSSION AND ANALYSIS CORPORATE GOVERNANCE BUSINESS RESPONSIBILITY REPORT STANDALONE ACCOUNTS CONSOLIDATED ACCOUNTS The Company has put in place an implementation framework through annual awareness program. All new joiners are required to undertake on-line training of the Code, POSH and ABAC on joining the employment. For reinforcing Code and Policies, all employees are further required to complete mandatory e-Learning refresher training, annually. In addition to this, an annual Compliance module is mandated to all employees. Your Company has a stellar support of 150 Ethics Counsellors who help in a continuous cycle of effective communication of Code and Policies with their cohorts. The processes for identifying and resolving breaches of the Code and Policies are clearly defined and regularly communicated throughout the Company. Data relating to such breaches is reviewed by the Corporate Governance Council and by relevant Board Committees that helps to determine the allocation of resources for future Policy development, process improvement, training and awareness initiatives. The Corporate Governance Council ensures that the Ethics & Governance framework is executed effectively. The Group Ethics and Governance Committee and Business Ethics and Governance Committees help to ensure that the decisions are taken in fair, just and consistent manner across various functions of that business. Vigil Mechanism The Vigil Mechanism as envisaged in the Companies Act, 2013, the Rules prescribed thereunder and the Listing Regulations is implemented through the Company’s Whistle Blower Policy to enable the Directors, employees and all stakeholders of the Company to report genuine concerns (about unethical behaviour, actual or suspected fraud, or violation of the Code), to provide for adequate safeguards against victimisation of persons who use such mechanism and make provision for direct access to the Chairman of the Audit Committee. A quarterly report on the whistle blower complaints received is placed before the Audit Committee for its review. The Whistle Blower Policy was updated during the year, the details of which may be referred to in Annexure VIII of this Board’s Report. Whistle Blower Policy of your Company is available on the Company’s website and can be accessed in the Governance section at the Web-link: https://www.mahindra.com/investors/reports-and-filings. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 The Company has a detailed Policy on Prevention of Sexual Harassment (POSH Policy) in place in line with the requirements of The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (Act). Internal Complaints Committees (ICC) have been set up to redress complaints received regarding sexual harassment and the Company has complied with provisions relating to the constitution of ICC under the Act. All employees (permanent, contractual, temporary, trainees) are covered under this Policy. The POSH Policy is gender inclusive, and the framework ensures complete anonymity and confidentiality. The POSH Policy was updated during the year, the details of which may be referred to in Annexure VIII of this Board’s Report. While maintaining the highest governance norms, the various ICC have appointed internal members with 50% being women and external members with relevant experience. The ICC is presided by a senior woman employee in each case. The ICC has been updated on judicial trends and trained regularly on the nuances of the Act. During the year under review, 9 complaints with allegations of sexual harassment were filed and 7 were resolved as per the provisions of the Act. 2 complaints are pending as of 31 st March, 2022. Awareness in this area has been created vide Speak Up campaign with focus on virtual workings and reiterating Mahindra’s commitment for providing safe workplace to all its employees. The Company has organised induction training for new joiners, online training and refresher modules, virtual and classroom trainings by Ethics Counsellors, emailers and posters to sensitise the employees to conduct themselves in a professional manner. Business Responsibility Report The ‘Business Responsibility Report’ (BRR) of your Company for the Financial Year 2021-22 forms part of this Annual Report as required under Regulation 34(2)(f) of the Listing Regulations.