The Board of Directors of EWAC Alloys Limited have adopted the Whistle Blower Policy so that the employees of the company have a secure mechanism to report any concerns that they may have of actual, suspected or planned wrongdoings (hereinafter “wrongdoings”) involving an ESAB Company (EWAC Alloys Limited or any of its subsidiaries or associate companies) or any of its directors, officers or employees.
The employees of the company have a right to report any such concerns through this policy, knowing fully well that such an act of whistle blowing on his / her part would not lead to any discrimination or recrimination against him / her.
The Chairman of the Audit Committee shall be the person to whom such concerns can be addressed. Correspondence on this may be addressed to them at the address of the Registered Office.
Any employee of the Company making a report in good faith, can do so in the knowledge and confidence that the Board of Directors of EWAC Alloys Limited will ensure that the act will not lead to the employee facing any recrimination, punishment or victimization.
Reports made in good faith must be based on a reasonable belief that a Wrongdoing has occurred or is likely to occur. If a subsequent investigation reveals that there was no Wrongdoing the employee making the report would not be subjected to any victimization or disciplinary action if he/she had acted in good faith.
The policy applies to all ESAB Companies in India, including joint ventures and other investments in which any ESAB Company has a participating interest. The policy applies regardless of the jurisdiction in which the Wrongdoing occurs or is suspected to have occurred, or whether or not such Wrongdoing or suspected Wrongdoing occurs in the home country or jurisdiction of another Country.
This is an illustrative list and employees can report other concerns.
Where an Employee of the Company suspects there is a Wrongdoing or has been asked to participate in a Wrongdoing, the employee has a paramount duty to report the concern immediately
In the circumstances where any EWAC Employee is directed to carry out or account for a transaction or series of transactions, that, in such EWAC Employee's opinion are outside normal policies and procedures, he should bring his concerns to the attention of the Chairman of the Audit Committee.
Reports should be made to the individuals referred to in paragraph 1 above
If an employee, who has a concern that the Code of Conduct is not being properly complied with, should report it, in the first instances, to his immediate superior. In case the concern involves the superior or the employee believes that his/her report has not been acted upon, he / she should report the matter to the Chairman of the Audit Committee.
Wherever possible an EWAC Employee should make a report disclosing his/her identity. However, if he/she makes a disclosure anonymously then consideration will only be given to such disclosures if:-
The subject matter is serious enough to justify it;
Sufficient information is provided to take further action;
Anonymity does not harm the credibility of the disclosure; and anonymity does not prevent the confirmation of details with other sources
All reports under this Policy will be promptly and thoroughly investigated, and all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action, in accordance with applicable law.
All reports will be investigated by persons with the appropriate authority and who are not directly linked with any aspect of the Wrongdoing as may be instructed to by the Chairman of the Audit Committee.
Wherever necessary, or required by law, a report may be referred to an external body for further investigation. Where feasible any such referral will be subject to the agreement of the Chairman of the Audit Committee.
All employees of EWAC Alloys Limited have a duty to cooperate in the investigation of reports of Questionable Accounting / Audit Matters or the reporting of fraudulent financial information or of Grave Misconduct or of discrimination, retaliation or harassment resulting from the reporting or investigation of such matters
An employee shall be subject to disciplinary action, including the termination of their employment, if the employee fails to cooperate in an investigation, or deliberately provides false information during an investigation. If, at the conclusion of its investigation, the Company determines that a violation of policy has occurred, the Company will take effective remedial action commensurate with the severity of the offense. This action may include disciplinary action against the accused party, up to and including termination. Reasonable and necessary steps will also be taken to prevent any further violations of policy
All documents related to the reporting, investigation and enforcement of this policy, as a result of a report of questionable accounting, internal accounting controls, or auditing matters, or the reporting of fraudulent financial information or matter pertaining to Misconduct, or of the discrimination, retaliation or harassment of an employee who made such a report, shall be kept in accordance with the retention policy under applicable law
The results of an investigation shall be communicated to the EWAC Employee if considered appropriate by the Chairman of the Company or the Chairman of the Audit, provided the employee concerned has agreed to maintain confidentiality
The Board of Directors of the Company may modify this Policy. Modification may be necessary, among other reasons, to maintain compliance with local, state and central regulations and / or to accommodate organizational changes within the Company.
These Guidelines provide guidance on business ethics. They supplement the principles set out in the Code of Conduct to show that all Colfax entities operate fairly, transparently and with integrity
The purpose is to ensure that Colfax and its subsidiaries (“Colfax”) comply fully with all applicable laws and operate to ethical standards wherever they conduct business
These Guidelines apply to all employees of Colfax, ESAB, Howden and EWAC with the exception of employees employed by AGI or its subsidiaries who are covered by separate guidelines issued by AGI.
These Guidelines apply throughout the group irrespective of the country where business is conducted and/or a particular business unit is situated. The principles contained in these Guidelines must be applied in all countries, even if they are more stringent than local law. Where local laws are more stringent than these Guidelines, then they must also be complied with.
Everyone at Colfax must show that all business is performed to the highest ethical standards and complies both with these Guidelines and all applicable laws.
No one at Colfax will engage in any form of bribery.
A “bribe” is the promise of money, reward, favour or a benefit to a person or public official in order to influence the conduct or judgment of that person.
In particular, no Colfax employee will
Senior Management (which means the MD/ Chief Executive and the FD / Head of Finance), of the relevant business unit, are responsible for implementing these Guidelines and enforcing them.
EWAC Alloys Limited is an equal employment opportunity company and is committed to creating a healthy working environment that enables employees to work without fear of prejudice, gender bias and sexual harassment. The Company also believes that all employees of the Company have the right to be treated with dignity. Sexual harassment at the work place or other than work place if involving employees is a grave offence and is, therefore, punishable.
This Policy extends to all employees of the Company and is deemed to be incorporated in the service conditions of all employees and comes into effect immediately.
The term employee refers to a person employed at a workplace for any work on regular, temporary ad hoc or daily wage basis, either directly or through an agent, including a contractor with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise whether the terms of employment are express or implied and includes a co-worker, contract worker, probationer, trainee, apprentice or called by any other such name.
Sexual harassment would mean and include any of the following:
The following circumstances, among other circumstances, if it occurs or is present in relation to or connected with any act or behavior of sexual harassment may amount to sexual harassment:
This policy, encompasses the company’s philosophy for delineating its responsibility as a Corporate Citizen and lays down the guidelines and mechanism for carrying out socially useful activities / projects and programmes for welfare and sustainability, development of community at large and is titled “EWAC’s CSR Policy”.
EWAC ALLOYSLIMITED recognizing its social and statutory responsibilities has adopted a policy to make a positive difference to the society. The Company recognizes that it cannot be present at all places and hence the fewer projects under the CSR which could have impact on the society at large and tradesmen in particular.
The Concept of CSR has gained prominence and EWAC has adopted a CSR policy as a strategic tool for sustainable growth not with just and intent to invest funds in social activity but to integrate the business processes with the social processes.
To commit for enhanced value-creation for the Society, to compete for our shareholders, stakeholders and the communities we live in, by taking up activities and initiatives for sustainable growth for the society, the safety and well being of workers being deeply committed to socio economic development in its areas of operation.
To mobilise core competencies of EWAC and resources of business to facilitate working in partnership on projects that benefit communities and workers.Our focus is safety, skill development of workers along with working with communities in our vicinity.
The main objective of this CSR policy is to lay down guidelines to make CSR a key business process for sustainable development of the society, while complying with the statutory requirements of the Companies Act, 2013.
This policy would ensure increased commitment at all levels in the organisation to operate its business in an economically, socially and environmentally sustainable manner, while recognising the interests of all its stakeholders. The CSR activities and initiatives would enable the company to get the good will of the community and help reinforce a positive and socially responsible image for the Company.
For achieving the CSR objectives, EWAC will allocate 2% of its average net profits arrived at for the three preceding years as provided under Section 135 of the Companies Act, 2013.
a. Promoting Education, vocations skills
b. Safety, Right Usage for external Workers.
c. Environment Management
d. Any other areas as may be decided by the Internal Committee.
CSR programmes will be undertaken by the Corporate Office to the best possible extent within the defined ambit of the above identified heads. By and large it may be ensured that at least 50% of the CSR programmes are executed in and around the areas adjoining EWAC Offices / Plant.
EWAC may employ the assistance of voluntary organisations (NGOs), Education Institutions, Trusts, Missions, Self-help groups, Government and semi government organisations, professional consultancy organisation and others.
The above guidelines would form the framework around which the CSR activities would be undertaken. EWAC will review the policy from time to time based on changing needs and aspirations of the target beneficiaries, statutory needs and make suitable modifications as may be necessary