CLARISSA RESORTS PVT LTD sets out its Whistle-Blowing Policy & Procedure as follows,

Whistle-Blowing Policy

The Whistle Blowing Policy (the ‘Policy’) of CLARISSA RESORTS is to encourage and enable associates and third parties, such as customers, vendors, contractors and other stakeholders to raise any serious concerns mentioned below.

The Policy is designed to enable associates or third parties to raise concerns without fear of reprisal, discrimination or adverse consequences. The Policy allows CLARISSA RESORTS to address such concerns by taking appropriate action including, but not limited to, disciplining or terminating the employment and/or services of those responsible.

However, while the Policy is meant to protect genuine whistle-blowers from any unfair treatment as a result of their report, it strictly prohibits frivolous and bogus complaints. The Policy is also not a route for taking up personal grievances.


  • Unusual/questionable accounting or auditing practices.
  • Disclosure matters.
  • Internal controls lapses or override.
  • Insider trading.
  • Conflict of interest.
  • Serious breaches of Company/Group policy.
  • Collusion with competitors.
  • Unsafe work practices.
  • any other matters involving fraud, corruption and employee conduct.


The definitions of some of the key terms used in this Policy are given below:

  • “Whistleblower”: means an Employee or Director making a Protected Disclosure under this policy.
  • “Audit Committee”: means the Audit Committee constituted by the Board of Directors of the Company in accordance with Section 177 of the Companies Act, 2013.
  • “Employee”: means every employee of the Company (whether working in India or abroad), including the directors in the employment of the Company.
  • I“Ethics Policy”: means the Ethics & Compliance Policy of the CLARISSA RESORTS PVT LTD.
  • “Investigators”: mean those persons authorized, appointed, consulted or approached by the Ethics Counsellor/Chairman of the Audit Committee and includes the auditors of the Company and the police.
  • “Protected Disclosure”: means any communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.
  • “Subject”: means a person against or in relation to whom a Protected Disclosure has been made or evidence gathered during the course of an investigation.

Whistle-Blowing Reporting Procedures

All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.

Concerns are better raised in writing. The written report should clearly set the background and history of the matter, giving names, dates and places wherever possible and the reasons for the concerns. Anyone who feels unable to put this concern in writing may telephone or meet the Company Internal Auditor who is the Receiving/Investigating Officer, the contact details of whom are as follows:


Hotline Number:


Complaints raised to other parties within the Company will be directed to the Receiving/Investigating Officer, who is responsible for maintaining a centralized repository of all reported cases and ensuring that issues raised are properly resolved.

All matters reported will be reviewed within a reasonable timeframe, after which a decision shall be made whether to proceed with a detailed investigation. Consultation is sought from the Whistle Blowing Evaluation Team which comprises members of the Audit & Risk Committee and the Company Internal Auditor.

Whistle-blower’s Protection

Genuine whistle-blowers will be adequately protected. If a whistle-blower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the Whistle Blowing Evaluation Team. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.

At the appropriate time, the party making the report may need to come forward as a witness. If an associate or third party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken will be taken against the person.

However, if an associate has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the third party making the report had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

Management and Investigation of Reports/Concerns

It is within the sole discretion of the Whistle Blowing Evaluation Team to assign any personnel of the company to perform the investigation and/or outsource the investigation, where necessary. All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

CLARISSA RESORTS reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations.

Associates who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.

If, at the conclusion of an investigation, the Company determines that a violation has occurred or the allegations are substantiated, effective remedial action commensurate with the severity of the offence will be taken.

Amendment to the Policy

CLARISSA RESORTS reserves the rights to update this Policy as and when it deems necessary.


This is to acknowledge that I have received a copy of the Company’s Whistleblower Policy. I understand that compliance with applicable laws and the Company’s Code of Conduct and Ethics is important and, as a private company, the integrity of the financial information of the Company is paramount. I further understand that the Company is committed to a work environment free of retaliation for employees who have raised concerns regarding violations of this Policy, the Company’s Code of Conduct and Ethics or any applicable laws and that the Company specifically prohibits retaliation whenever an employee makes a good faith report regarding such concerns. Accordingly, I specifically agree that to the extent that I reasonably suspect there has been a violation of applicable laws or the Company's Code of Conduct and Ethics, including any retaliation related to the reporting of such concerns, I will immediately report such conduct in accordance with the Company’s Whistleblower Policy. I further agree that I will not retaliate against any employee for reporting a reasonably suspected violation in good faith I understand and agree that to the extent I do not use the procedures outlined in the Whistleblower Policy, the Company and its officers and directors shall have the right to presume and rely on the fact that I have no knowledge or concern of any such information or conduct.

____________________________ Employee’s Signature

____________________________ Employee’s Name (Printed)

____________________________ Date