Aparna Constructions and Estates Private Limited (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). We make every effort to treat your personal information as safely and securely as reasonably possible. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application (the “Aparna Customer App”). Please read the following privacy policy to better understand how your personal information may be collected and used as you access various areas of our Application.


We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

We do not sell, rent, share, or otherwise disclose personally identifiable information from customers for commercial purposes. We do not intend to disclose any personal information of yours without your consent to any third party who is not bound to act on our behalf unless such disclosure is required by law.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.


This Application is for our customers to provide them with a convenient way to manage their project booking details, stay updated on construction progress and make secure payments online. We may collect information about you in a variety of ways based on your purchase history and previous interactions with us. The information we may collect via the Application depends on the content and materials you use, and includes:

Personal Data

Demographic and other personally identifiable information (such as your name and email address) that you voluntarily give to us when choosing to participate in various activities related to the Application.

Derivative Data

Information our servers automatically collect when you access the Application, such as your native actions that are integral to the Application, including other interactions with the Application and other users via server log files.

Financial Data

Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you make a payment from the Application. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor.

Geo-Location Information

We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data

Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Push Notifications

We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.


Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Application to:

  1. Compile anonymous statistical data and analysis for use internally or with third parties.
  2. Create and manage your account.
  3. Deliver targeted advertising, newsletters, and other information regarding promotions and the Application to you.
  4. Email you regarding your account or purchase.
  5. Fulfill and manage purchases, orders, payments, and other transactions related to the Application.
  6. Generate a personal profile about you to make future visits to the Application more personalized.
  7. Increase the efficiency and operation of the Application.
  8. Monitor and analyze usage and trends to improve your experience with the Application.
  9. Notify you of updates to the Application.
  10. Offer new products, services, mobile applications, and/or recommendations to you.
  11. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
  12. Process payments and refunds.
  13. Request feedback and contact you about your use of the Application.
  14. Resolve disputes and troubleshoot problems.
  15. Respond to product and customer service requests.
  16. Solicit support for the Application.


We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Application. These companies may use information about your visits to the Application and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.


We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.


Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. When you access the Application, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Internet-Based Advertising

Additionally, we may use third-party software to serve ads on the Application, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.

Application Analytics

We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.


The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Application.


We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.


Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.


You may at any time review or change the information in your account by:

  • Logging into your account settings and updating your account
  • Contacting us using the contact information provided below

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.


If you have questions or comments about this Privacy Policy, please contact us at:

#802 Door No: 6-3-352/2&3,
Astral Heights, Road No.1,
Banjara Hills, Hyderabad - 500 034.

Phone: +91-23352708
Fax: +91-40-23352710

Any person logging on to or using the site ("the Visitor") has unconditionally accepted the terms and conditions of use and these constitute a binding and enforceable agreement between the visitor and Aparna Constructions and Estates Private Limited ("ACEPL") or Aparna group.

  1. The information on this website is presented as general information and no representation or warranty is expressly or impliedly given as to its accuracy, completeness or correctness.
  2. The visitor is presumed to have read the terms and conditions of the website and is deemed to have agreed, understood and accepted unconditionally all the terms, conditions, procedure and risks of logging onto the website and cannot claim, at anytime, ignorance of any or all of them. All relationships of any visitor of this website wheresoever's situated is governed by and in accordance with the laws and jurisdiction of Hyderabad, India.
  3. ACEPL uses all diligence, skill and expertise available to provide information on this website but does not accept or undertake any express or implied warranty of any nature whatsoever and ACEPL disclaims all or any errors and mistakes to the fullest extent. ACEPL does not warrant that the information offered will be error-free, or that the defects will be corrected, or that this site or the server that makes it available are or will be free of viruses or other harmful components. ACEPL shall not be under any obligation to ensure compliance or handle complaints.
  4. This website, may unintentionally include inaccuracies or errors with respect to the description of a plot/flat size, site plan, floor plan, a rendering, a photo, the elevation, prices, taxes, adjacent properties, amenities, design guidelines, completion dates, features, zoning, buyer incentives etc. Square footage and room sizes are approximate and may vary.
  5. The plans, specifications, images and other details herein are only indicative and ACEPL reserves the right to change any or all of these in the interest of the project/development. The Website does not constitute an offer and/or contract of any nature whatsoever. Any purchase/leave and license in any project shall be governed by the terms of the agreement entered into between the parties and no details mentioned on this website shall govern the transaction. ACEPL and its respective subsidiaries and affiliates, and their respective officers, directors, partners, employees, agents, managers, trustees, representatives or contractors of any of them, related thereto and any successors or assigns of any of the foregoing shall not be liable for any direct, indirect, actual, punitive, incidental, special, consequential damages or economic loss whatsoever, arising from or related to the use of or reliance on this Website. ACEPL reserves the right to alter, amend and vary the layout, plans and specifications or feature without prior notice or obligation, but subject to the approval of the competent authorities as applicable.
  6. The visitor has, by the act of logging onto the website and/or submitting information or giving his name, address, email addresses as identification to ACEPL through the website, on phone, fax or e-mail, deemed to have consented and has expressly and irrevocably authorized ACEPL to use, reveal, analyze or display and transmit all information and documents as may be required by it. The visitor represents and warrants that he has provided true, accurate, current and complete information about himself and if any information is found to be untrue, inaccurate, not current or incomplete, ACEPL has the right to take any action it deems appropriate without any limitation.
  7. The visitor represents and warrants that he/she is fully aware of the laws of the country/state he/she resides in and also those of India particularly those governing use, sale, lease, transfer of real estate and the visitor is neither violating nor attempting to violate any law.
  8. The contents, information and material contained in this website are the exclusive property of ACEPL and are protected by copyright and intellectual property laws. No person shall use, copy, reproduce, distribute, initiate, publish, display, modify, create derivative works or database, use, transmit, upload, exploit, sell or distribute the same in whole or in part or any part thereof without prior express written permission from ACEPL. Facility to print an article or portion of text or material on this website through computer/electronic device does not tantamount to prior written consent.
  9. Notwithstanding anything stated hereinabove or in this website, it is clarified, understood and agreed that ACEPL through this website does not intend to make any offer, proposal or contract as per prevailing laws in India or any similar or relevant law in the country of residence or access of the visitor.
  10. ACEPL has the right to reproduce, monitor, disclose any transmission or information received and made to this website. Visitors may be sent information or contacted through the email addresses, phone numbers and postal addresses provided by the visitor on the website. Any visitor who may not desire to receive email from ACEPL may give clear instructions.
  11. The visitor shall not use or post any computer programs in connection with his/her use of the website that contain destructive features such as viruses anomalies, self-destruct mechanisms, time/logic bombs, worm, Trojan horses etc.
  12. Notwithstanding anything, in no event shall ACEPL, their promoters, directors, employees and agents be liable to the visitor for any or all damages, losses and causes of action (including but not limited to negligence), errors, injury, whether direct, indirect, consequential or incidental, suffered or incurred by any person/s or due to any use and/or inability to use this site or information or its links, hyperlinks, action taken or abstained or any transmission made through this website.
  13. Any links to off-site pages or other sites may be accepted by the visitor at his/her option and own risk and ACEPL assumes no liability for and shall be held harmless from any resulting damages. ACEPL strongly recommends that the visitor carefully reads the terms and conditions of such linked site(s).
  14. ACEPL reserves the right to terminate, revoke, modify, alter, add, and delete any one or more of the terms and conditions of the website. ACEPL be shall be under no obligation to notify the visitor of the amendment to the terms and conditions and the visitor shall be bound by such amended terms and conditions

- Aparna Constructions and Estates Pvt Ltd - CIN NO - U24219TG1996PTC025330

Whistle Blower Policy



Aparna Constructions and Estates Private Limited (herein after referred as “the Company”) being a Company Incorporated the Companies Act, 1956 and governed by the Companies Act, 2013, having borrowings from banks in excess of Rs. 50 Crores, requires to establish a vigil mechanism for directors and employees to report the genuine concerns as per the provisions of the section 177 of the Companies Act, 2013 read with Rule 7 of Companies (Meeting of Board and its powers) Rules, 2014 in such manner as may be prescribed.

These provisions provide a mandatory requirement for all such companies having the conditions prescribed therein to devise an effective whistle blower mechanism for directors and employees to report concerns about unethical behaviour, actual or suspected fraud or violation of the company's code of conduct or ethics policy.

These provisions provide a mandatory requirement for all such companies having the conditions prescribed therein to devise an effective whistle blower mechanism for directors and employees to report concerns about unethical behaviour, actual or suspected fraud or violation of the company's code of conduct or ethics policy.

In view of the above, Aparna Constructions and Estates Private Limited, being a company covered under these provisions here by proposes establish a Vigil Mechanism and to formulate a Vigil Mechanism/Whistle Blower Policy.


The purpose and objective of this Policy is to provide a framework to promote responsible and secure Vigil Mechanism/whistle blowing. It protects the employees wishing to raise a concern about serious irregularities within the Company and provides a platform for grievance addressal.

To maintain the standards and objectives mentioned above, the Company encourages its directors and employees who have genuine concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment.

A Vigil (Whistle Blower) mechanism provides a channel to the employees and Directors to report to the Management, any concerns about unethical behaviour, actual or suspected fraud or violation of the Codes of conduct or policy. The mechanism provides for adequate safeguards against victimization of employees and Directors to avail of the mechanism and also provide for direct access to the Vigilance Officer appointed for this purpose including exceptional cases.

This policy, however, neither releases employees from their duty of confidentiality in the course of their work nor can it be used as a route for raising malicious or unfounded allegations against people in authority and/or colleagues in general.


This Policy covers malpractices and events which have taken place, suspected to have taken place, misuse or abuse of authority, fraud or suspected fraud, violation of the company rules, manipulations, negligence causing danger to public health and safety, misappropriation of monies, and other matters or activity on account of which the interest of the Company is affected and formally reported by whistle blowers. This Policy is intended to encourage and enable employees to raise serious concerns within the Company prior to seeking resolution outside the Company.


"Board" means the Board of Directors of the Company.

"Company" means Aparna Constructions and Estates Private Limited and its entire offices pan India.

"Code" means Code of Conduct for Directors and Senior Management adopted by Aparna Constructions and Estates Private Limited.

"Employee" means all the present employees and Directors of the Comp any (Whether working in India or abroad).

"Protected Disclosure" means any communication in good faith that discloses or demonstrates information that may evidence unethical or improper activity.

"Subject" means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.

"Vigilance and Ethics Officer" means an officer appointed to receive protected disclosures from whistle blowers, maintaining records thereof, take appropriate steps for its disposal and informing the Whistle Blower the result thereof.

"Whistle Blower" is an employee or group of employees who make a Protected Disclosure under this Policy and also referred in this policy as complainant.


All employees of the company are eligible to make protected disclosures under the policy in relation to matters concerning the company. The Company does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing. This Policy ensures that employees are empowered to pro-actively bring to light such instances without fear of reprisal, discrimination or adverse employment consequences.

This Policy is not, however, intended to question financial or business decisions taken by the Company that are not Protected Disclosures nor should it be used as a means to reconsider any matters which have already been addressed pursuant to disciplinary or other internal procedures of the Company. This policy shall not be used:

  1. For raising grievances related to employees' own career/other personal grievances.
  2. For raising grievances related to career of other employees/colleagues.
  3. Grievances arising out of the policies/procedures of the Company and any decision taken by the superior/management in this respect.
  4. Grievances related to such other similar issues like i, ii and iii hereinabove.

All Protected Disclosures should be reported in writing by the Whistle Blower as soon as possible after the Whistle Blower becomes aware of the same so as to ensure a clear understanding of the issues raised.

Employees can lodge a Protected Disclosure in one of the following ways:

  1. By sending an email to with the subject "Protected Disclosure under the Whistle Blower Policy".
  2. By sending letter in a closed and secured envelop and super scribed as "Protected Disclosure under the Whistle Blower Policy" to the Vigilance and Ethics Officer (as notified from time to time). Letter should either be typed or written in a legible handwriting in English.

All Protected Disclosures should be addressed to the Vigilance and Ethics Officer of the Company including exceptional cases.

The contact details of the Vigilance and Ethics Officer are as under:-

Name and Address –

Sri D Someswara Prasad

E-mail :

Address : 802 , Astral Heights, Road No 1, Banjara Hills, Hyderabad – 500034

In order to protect identity of the complainant, the Vigilance and Ethics Officer will not issue any acknowledgement to the complainants and they are advised not to writ e their name/address on the envelope nor enter into any further correspondence with the Vigilance and Ethics Officer. The Vigilance and Ethics Officer shall assure that in case any further clarification is required he will get in touch with the complainant.

Anonymous/Pseudonymous disclosure shall not be entertained by the Vigilance and Ethics Officer. While this Policy is intended to protect genuine Whistle Blowers from any unfair treatment as a result of their disclosure, misuse of this protection by making frivolous and bogus complaints with malafide intentions is strictly prohibited. An employee who makes complaints with malafide intentions and which is subsequently found to be false will be subject to strict disciplinary action.

The Whistle blower's role is that of a reporting party. Whistle blowers are not investigators or finders of facts; neither can they determine the appropriate corrective or re medial action that may be warranted.

All Protected Disclosures should be addressed to the Vigilance and Ethics Officer of the Company including exceptional cases.

Protected Disclosure against the Vigilance and Ethics Officer should be addressed to the Board of Directors of the Company.

Although a Whistle blower is not required to furnish any more information than what he/she wishes to disclose, it is essential for the Company to have all critical information in order to enable the Company to effectively evaluate and investigate the complaint. It is difficult for the Company to proceed with an investigation on a complaint, which does not contain all the critical information such as the specific charge. The complaint or disclosure must therefore provide as much detail and be as specific as possible in order to facilitate the investigation.

To the extent possible, the complaint or disclosure must include the following:

  1. The employee, and/or outside party or parties involved ;
  2. The sector of the Company where it happened (Location, Department, office);
  3. When did it happen: a date or a period or time
  4. Type of concern (what happened);
    1. Financial reporting;
    2. Legal matter;
    3. Management action;
    4. Employee misconduct; and/ or
    5. Health & safety and environmental issues.
  5. Submit proof or identify where proof can be found, if possible;
  6. Who to contact for more information, if possible; and/or
  7. Prior efforts to address the problem, if any.


On receipt of the Protected Disclosure the Vigilance and Ethics Officer shall make a record of the Protected Disclosure and also ascertain from the complainant whether he was the person who made the protected disclosure or not. He shall also carry out initial investigation either himself or by involving any other Officer of the Company before referring the matter to the Board of Directors of the Company for further appropriate investigation and needful action. The record will include:

  1. Brief facts;
  2. Whether the same Protected Disclosure was raised previously by anyone on the subject, and if so, the outcome thereof;
  3. Details of actions taken by the Vigilance and Ethics Officer processing the complaint
  4. Findings and recommendations.

The Vigilance and Ethics Officer, if he deems fit, may call for further information or particulars from Complainant.


The decision to conduct an investigation is by itself not an accusation and is to be treated as a neutral fact finding process. Subject(s) will normally be informed in writing of the allegations at the outset of a formal investigation and shall have opportunities for providing their inputs during the investigation. Such Person shall have a duty to co-operate with the Vigilance and Ethics Officer or any of the Officers appointed by him in this regard and shall be subject to strict disciplinary action p to and including immediate dismissal, if they fail to cooperate in an investigation, or deliberately provide false information during an investigation.

Subject(s) shall have a right to consult with a person or persons of their choice, other than the Vigilance and Ethics Officer / Investigators appointed by him for this purpose and /or the Whistle Blower. He has a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed or tampered with and witness shall not be influenced, coached, threatened or intimidated by him.

Unless there are compelling reasons not to do so, he will be given the opportunity to respond to material findings contained in the investigation report. No allegation of wrong doing against him shall be considered as maintainable unless there is good evidence in support of the allegation. He has a right to be informed of the outcome of the investigations. If allegations are not sustained, he should be consulted as to whether public disclosure of the investigation results would be in the best interest of him and the Company.

The investigation shall be completed normally within 90 days of the receipt of the protected disclosure and is extend able by such period as the Vigilance and Ethics Officer deems fit.

All information disclosed during the course of the investigation will remain confidential, except as necessary or appropriate to conduct the investigation and take any remedial action, in accordance with any applicable laws and regulations. The Company reserves the right to refer any concerns or complaints regarding Protected Disclosure to appropriate external regulatory authorities.


If an investigation leads the Vigilance and Ethics Officer to conclude that an improper or unethical act has been committed, the Vigilance and Ethics Officer shall suo moto, or in exceptional cases recommend to the management of the Company to, take such disciplinary or corrective action commensurate with the severity of the offence, as he may deem fit. The company may also take reasonable and necessary measures to prevent any further violations which may have resulted in a complaint being made. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures.

The Vigilance and Ethics Officer shall submit a report to the Board of Directors as and when required about all Protected Disclosures referred to him /her since the last report together with the results of investigations, if any.

A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the Subject to the Vigilance and Ethics Officer shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.


No Personnel who, in good faith, makes a disclosure or lodges a complaint in accordance with this Policy shall suffer reprisal, discrimination or adverse employment consequences. Accordingly, the Company prohibits discrimination, retaliation or harassment of any kind against a Whistle blower, who based on his/her reasonable belief that one or more Protected Disclosure has occurred or are, occurring, reports that information. Any employee, who retaliates against a Whistle blower who has raised a Protected Disclosure or Complaint in good faith, will be subject to strict disciplinary action up to and including immediate termination of employment or termination of his/her relationship with the Company.

If any employee, who makes a disclosure in good faith, believes that he/she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he/she must immediately report those facts to his/ her supervisor, manager or point of contact. If, for any reason, he/she do not feel comfortable discussing the matter with these persons, he/she should bring the matter to the attention of the Vigilance and Ethic Officer including exceptional cases. It is imperative that such employee brings the matter to the Company's attention promptly so that any concern of reprisal, discrimination or adverse employment consequences can be investigated and addressed promptly and appropriately.

A Whistle Blower, who reports any violation of the above clause to the Vigilance and Ethic Officer, who shall investigate into the same and recommend suitable action to the management

The company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. Any other Employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.

The Whistle Blower shall have right to access to the Vigilance and Ethics Officer directly in exceptional cases and the Vigilance and Ethic Officer is authorized to prescribe suitable directions in this regard.


The Company shall maintain documentation of all Protected Disclosures or reports subject to this Policy. The documentation shall include any written submissions provided by the complainant, any other Company documents identified in the complaint or by the Company as relevant to the complaint, a summary of the date and manner in which the complaint was received by the Company and any response by the Company to the complainant. All such documentation shall be retained by the Company for a minimum of five (5) years or such other period as specified by any other law in force, whichever is more, from the date of receipt of the complaint. Confidentiality will be maintained to the extent reasonably practicable depending on the requirements and nature of the investigation, as indicated above.


The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. Modification may be necessary, among other reasons, to maintain compliance with local, state, central and federal regulations and/or accommodate organizational changes within the Company. However, no such amendment or modification will be binding on the Employees and Directors unless the same is notified to them in writing.