MAHINDRA & MAHINDRA LTD. | Integrated Annual Report 2022-23

74 MAHINDRA & MAHINDRA LTD. Integrated Annual Report 2022-23 The Company’s Vigil mechanism process is clearly defined for identifying and resolving breaches related to the Code of Conduct and the Company’s Ethics Policies. It is regularly communicated throughout the Company vide the ‘Speak Up campaign’. Data relating to such breaches are reviewed by the Corporate Governance Council and the Audit Committee that helps in determining the allocation of resources for future policy development, any review of policies, 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 decisions on substantiated cases are taken in a 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. The 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/investor-relations/policies-and- documents . It enables 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) and provides for adequate safeguards against victimisation of persons who use such mechanism and makes provision for direct access to the Chairman of the Audit Committee. A quarterly report on the whistle-blower complaints, as received, is placed before the Audit Committee for its review. During the year, the Company received 147 whistle-blower complaints, out of which 132 complaints were investigated and appropriate actions were taken and investigations were underway for the remaining 15 complaints. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 The Company has Zero Tolerance towards sexual harassment at the workplace. A detailed POSH Policy is in place as per the requirements of The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“Act”). The POSH Policy of the Company is available on the website of the Company and can be accessed in the Governance section at the Web-link: https://www.mahindra. com/investor-relations/policies-and-documents. All employees (permanent, contractual, temporary, trainees) as defined under the Act are covered in this Policy. The POSH Policy is gender inclusive and the framework ensures complete anonymity and confidentiality, the details of which may be referred to in the Board’s Report. Internal Complaints Committees (“ICC”) have been constituted to redress complaints of sexual harassment and the Company has complied with the provisions relating to the constitution of ICC under the Act. While maintaining the highest governance norms, ICC are constituted for various locations. Half of the total members of the ICC are women. The external members with requisite experience in handling such matters are also part of the ICC. The ICC is presided over by a senior woman employee in each case. Inquiries are conducted and recommendations are made by the ICC at the respective locations. The ICC is updated on judicial trends and trained regularly on the nuances of the Act. During the fiscal year under review, 9 complaints alleging sexual harassment were filed and 9 were resolved vide taking appropriate actions as per the provisions of the Act. No complaints are pending inquiry as of 31 st March, 2023. Continuous awareness in this area has been created vide the POSH campaign reiterating Mahindra’s commitment to providing a safe workplace to all its employees. During the year, the Company organised sensitization and awareness programs vide inductions for new joiners, e-learning modules for all employees, trainees, associates including sending emailers, creating standees and posters to sensitise all employees to conduct themselves in a professional manner. Further, virtual and classroom training sessions were conducted by the Company’s Ethics Counsellors. The Company also organised offline leadership conversations on gender sensitisation and employee interactive sessions including conscious inclusions. Business Responsibility and Sustainability Report SEBI vide its Notification dated 5 th May, 2021 had amended Regulation 34 of the Listing Regulations, wherein SEBI has mandated that Business Responsibility Report (“BRR”) shall be discontinued after the Financial Year 2021–22 and thereafter, with effect from the Financial Year 2022–23, the Top 1,000 listed entities based on market capitalization shall submit a Business Responsibility and Sustainability Report (“BRSR”) in the format as specified by SEBI from time to time.