The Vigil Mechanism and Whistle Blower Policy of WAHCOMS is aimed at providing a secure and transparent framework for employees, members, and other stakeholders of the cooperative society to report concerns related to unethical behavior, fraud, corruption, or any violation of legal or regulatory requirements without fear of retaliation or unfair treatment.

The objectives of this policy are to:

• Promote ethical practices and a culture of accountability within the cooperative.
• Provide a channel for employees, members, and other stakeholders to report concerns in a confidential and secure manner.
• Ensure that reported concerns are properly investigated and appropriate corrective actions are taken.
• Safeguard whistleblowers from victimization, harassment, or any form of retaliation.

This policy applies to:

• All employees, members, officers, and stakeholders of the cooperative society.
• Any concerns related to fraud, financial irregularities, unethical behavior, or violations of the cooperative's code of conduct, bylaws, or regulatory requirements.
• All aspects of the society's operations, including financial transactions, management decisions, member services, and human resource practices.

• Whistleblower: An individual (employee, member, or stakeholder) who reports a concern regarding unethical behavior, fraud, or misconduct.
• Vigil Mechanism: The formal process through which concerns related to unethical practices, violations of rules, or potential fraud are reported, investigated, and addressed.
• Audit Committee: The body responsible for overseeing the implementation of this policy and ensuring that concerns are properly investigated.

• Whistleblower Channels:

Whistleblowers can report concerns through the following channels:

• A confidential email address set up specifically for whistleblower complaints.
• A secure hotline or telephone number.
• Written complaints submitted to a designated officer or the Audit Committee.

• Anonymous Reporting:

Whistleblowers have the option to report concerns anonymously. However, individuals are encouraged to provide sufficient details to enable a thorough investigation.

• Confidentiality:

The identity of the whistleblower will be kept confidential, and their concerns will be handled discreetly. Information will only be disclosed to those involved in the investigation process, unless required by law.

The whistleblower may report any of the following:

• Financial irregularities or fraud.
• Corruption, bribery, or misappropriation of funds.
• Breach of the cooperative’s policies, bylaws, or regulatory requirements.
• Unethical behavior, abuse of power, or conflicts of interest.
• Any criminal or illegal activity within the cooperative.
• Discrimination, harassment, or any other form of misconduct by employees or officers.

• Acknowledgment: Upon receiving a whistleblower complaint, the Audit Committee or designated officer will acknowledge receipt within a specified timeframe.
• Preliminary Review: The Audit Committee will conduct an initial review of the complaint to assess its credibility and determine whether a full investigation is warranted.
• Full Investigation: If necessary, a detailed investigation will be conducted by an independent team, which may include legal, financial, or compliance experts. The investigation process will be impartial, thorough, and completed in a timely manner.
• Report and Actions: Once the investigation is completed, a report will be submitted to the Board of Directors or Audit Committee. Corrective actions, including disciplinary measures or legal proceedings, will be initiated based on the findings.

• Non-Retaliation: Whistleblowers will be protected from any form of retaliation, including dismissal, harassment, discrimination, or threats. The cooperative society is committed to ensuring that whistleblowers can raise concerns without fear of negative consequences.
• False Allegations: While whistleblowers are encouraged to raise concerns in good faith, false or malicious allegations will be viewed seriously, and the cooperative reserves the right to take disciplinary action against individuals who knowingly make false claims.

• Audit Committee: Policy. It will ensure that complaints are handled properly and that corrective actions are taken.
• Whistleblower Protection Officer: A designated officer will be appointed to receive whistleblower complaints and provide updates to the Audit Committee. This officer will ensure the confidentiality and protection of the whistleblower.
• Board of Directors: The Board of Directors will review whistleblower complaints and reports and ensure that corrective actions are taken based on the findings of investigations.

• The cooperative society will take steps to raise awareness about the Vigil Mechanism and Whistle Blower Policy through training, meetings, and regular communication with employees and members.
• The policy will be made accessible to all employees, members, and stakeholders via the society’s website and office premises.

• This policy will be reviewed periodically by the Audit Committee and the Board of Directors to ensure it remains effective and relevant to the cooperative's operations.
• Any amendments to this policy will be communicated to all employees, members, and stakeholders.