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Express Your Concerns Policy

This Express Your Concerns Policy (the ‘Policy’) aims to :
To ensure that our employees and associates feel free to raise concerns about workplace wrongdoing, the Company has put in place this Policy, so that Company has the opportunity to address the issues raised before they become problems. This policy shall achieve the following :

1. Establish a vigil mechanism for Directors and Employees of BPTP Limited (the ‘Company’) to report their genuine concerns;
2. Initiate appropriate steps to investigate and correct the concerns expressed;
3. Provide adequate safeguards against victimization of members using this mechanism; and

Accordingly, this Policy details the following :
1. Disclosure procedure for any wrongdoing in the Company;
2. Protection shall be available only to the Whistle Blowers making such disclosures in good faith;
3. Mechanism for actioning and reporting on such disclosures to the relevant authority within the Company; and
4. Relevant authority and its powers to review each disclosures and initiate appropriate action.


The Company endeavours to maintain highest business and ethical standards while conducting its business. The Company aims to regulate and build a strong culture by promoting transparency and ethical conduct of its business operations. The Policy is intends to provide a vigil mechanism for its employees, directors and associates of the Company to disclose in good faith any actual or suspected workplace wrongdoing for appropriate reporting and action.


Some of the key terms used in this Policy shall have the meanings assigned hereunder :

“Audit Committee” means the Audit Committee constituted by the Board of Directors in terms of the provisions of Section 177 of the Companies Act, 2013;
“Company” means BPTP Limited;
“Director” means any executive, non-executive, nominee, independent, additional or alternate director of the Company;
“Disclosure” means written communication about an actual or suspected workplace wrongdoing, including an anonymous disclosure, made in good faith by the Whistle Blower to the designated personnel under this Policy;
“Employee” means any employee or director of the Company;
“Investigator” means any person duly appointed/consulted by the Investigation Committee to conduct an investigation under this Policy;
“Subject Employee” means an employee or director against or in relation to whom a Disclosure is made under this Policy;
“Workplace Wrongdoing” means and includes, but not limited to, the following activities/improper practices being followed in the Company:

(a) manipulation of Company data/records;
(b) abuse of authority at any defined level in the Company;
(c) disclosure of confidential/propriety information to any unauthorized person;
(d) any violation of applicable law and regulations applicable to the Company, thereby exposing the Company to prosecution, penalties or fines;
(e) any instance of misappropriation of Company’s assets;
(f) activity violating any laid down Company Policy, including the Code of Conduct; and
(g) any other activities whether unethical or improper in nature and adverse to the interests of the Company;

“Whistle Blower” shall have the meaning assigned under Para IV of the Policy;
“Investigation Committee” means a Committee comprising of Mr. Sandeep Bedi, Director – Systems and Strategy and Mr. Rajeev Kumar, Company Secretary and any other member nominated by the Audit Committee for the time being. The Investigation Committee may co-opt one or more members for any specific issue(s) at its discretion. Mr. Sandeep Bedi shall be the Chairman of the Investigation Committee.

Whistle Blowers

Whistle Blowers shall mean the following :
1. Directors of the Company;
2. Employees of the Company;

Procedure for Reporting


a) If the Disclosure is against a Subject Employee, the same can be made to Mr. Gobind Gulati. The contact details of Mr. Gulati are as under:
Director ,
BPTP Limited
BPTP Crest, 15, Udyog Vihar Phase-IV,
Gurugram – 122 015, Haryana.
Email Id:

b) Though Whistle Blowers are advised to disclose their identities in the Disclosures for ensuring that they get adequate protection under the Policy, however, anonymous Disclosures may also be made.

c) While reporting any Disclosure under the Policy, the Whistle Blower must address the following issues :
(i) The Disclosure should bring out a clear understanding of the issue being raised;
(ii) The Disclosure should not be made merely on speculative grounds, but should be based on the actual facts;
(iii) The Disclosure should not be in the nature of a conclusion and should contain specific and quantitative information with supportings to enable proper conduct of the investigation/inquiry.
(iv) The Whistle Blower is not required to give any reasons for such Disclosure.


1. The Investigation Committee is empowered to investigate, inquire or oversee any Disclosures reported under this Policy. The Investigation Committee may, at its own discretion, take the assistance of any expert or an employee or Director of the Company while conducting the investigation or inquiry into any Disclosure.

In case the Disclosure is made by a Whistle Blower under this Policy against any member of the Investigation Committee, such member shall recuse himself from the inquiry or investigation of such Disclosure and the Chairman or the remaining member of the Investigation Committee shall appoint one person as a member of the Investigation Committee to investigate, inquire or oversee such Disclosure reported.

2. All Disclosures made under this Policy shall be recorded and duly actioned, if required, in accordance with the recommendation made by the Investigation Committee.

3. The Investigation Committee may, at its sole discretion, conduct an investigation. However, an investigation shall not be conducted unless the Investigation Committee after the review of Disclosure is prima facie of the opinion that:

(a) (a) The Disclosure made, constitutes an Workplace Wrongdoing, as defined in this Policy;
(b) (b) The Disclosure made is supported by adequate information to support an investigation.

4. The confidentiality of the Whistle Blower shall be maintained during the inquiry conducted by the Investigation Committee.

5. Any inquiry/investigation conducted against any Subject Employee shall not be construed by itself an act of accusation and shall be carried out as a neutral fact finding process, without presumption of any guilt.

6. The inquiry/investigation shall be conducted in a fair manner and shall provide an equal opportunity of being heard to the Subject Employee and a written report of the findings shall be prepared.

The chairman of the Investigation Committee and the Investigators (after obtaining adequate authorization from the Chairman of the Investigation Committee) shall have right to call for and examine any information/document and/or employees of the Company, as may be deemed necessary, for the purpose of conducting inquiry/investigation under this Policy.

7. The inquiry/investigation shall be completed within a period of 3 months from the date of receipt of Disclosure made by the Whistle Blower. However, if the Investigation Committee is of the opinion that the inquiry/investigation cannot be completed within the said period, the Investigation Committee, after recording the reasons, may extend the period in exceptional cases and report the same to the Chairman of the Audit Committee.

Subject Employee

1. All Subject Employees shall be duly informed about the Disclosures made against them at the commencement of the formal inquiry/investigation and shall be provided the opportunity of being heard during the course of the inquiry/investigation process.

2. No Subject Employee shall directly/indirectly interfere with the investigation process, till the completion of the inquiry/investigation.

3. The Subject Employee shall not destroy or tamper with any evidence, and shall have a duty to co-operate with the Investigation Committee, its Members and Investigators in the inquiry/investigation till the time the inquiry/investigation is completed.

4. During the course of the inquiry/investigation, all Subject Employees shall have a right to consult any person(s) of their choice, other than the Investigators, and engage any legal counsel at their own cost to represent them in any inquiry/investigation proceedings.

5. All Subject Employees shall have a right to be informed about the results of the investigation and shall be so informed in writing by the Head-HR after completion of the inquiry/investigation.

6. All Subject Employees shall be given an opportunity to respond to results of the inquiry/investigation as contained in an investigation report. No allegation of wrong-doing against any Subject Employee shall be considered as tenable unless the allegations are duly supported by valid evidence in support of the allegation.

7. Where the result of the inquiry/investigation highlight that the allegations made against the Subject Employee are eventually dismissed as non-tenable, then the Company shall reimburse all such reasonable costs as shall have been incurred by the Subject Employee to defend him/her, during the process of inquiry/investigation. In such cases, the Subject Employee will also be consulted whether a public disclosure of the investigation result should be in their best interest. The Investigation Committee shall have the final discretion on whether such disclosure is necessary and if so, the scope and medium of such disclosure.

8. Where a Disclosure gets substantiated, the Investigation Committee shall forward its findings to the Head – HR with recommendations of the steps/actions to be taken against the Subject Employee.


1. The identity of the Whistle Blower, Subject Employee and any other Employee assisting the inquiry/investigation, shall be kept confidential at all times, except during the course of any legal proceedings, where a Disclosure/statement is required to be filed.

2. The Company, as a policy, strongly condemns any kind of discrimination, harassment or any other unfair employment practice being adopted against the Whistle Blower for Disclosures made under this Policy. No unfair treatment of any kind shall be vetted out towards the Whistle Blower by virtue of his having reported a Disclosure in good faith under this Policy and the Company shall ensure that full protection has been granted to him against:

(a) Unfair employment practices like retaliation, threat or intimidation of termination/suspension of services, etc.;
(b) Disciplinary action including transfer, demotion, refusal of promotion or increments, etc.;
(c) Direct or indirect abuse of authority to obstruct the Whistle Blower right to continue performance of his duties/functions during routine operations, including making further Disclosures under this Policy.


If an employee or Director knowingly make false disclosures under this Policy, such employee shall be subject to disciplinary action on the terms deemed fit by the Investigation Committee.


This Policy may be amended or modified by the Company only after consultation with the Audit Committee.


All Disclosures made by the Whistle Blower or documents obtained during the course of inquiry/investigation, alongwith the results of investigation relating thereto, shall be retained by the Company for such period as the Investigation Committee may recommend at its sole discretion.