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LAST UPDATED 12 JANUARY, 2024

Grievance Reporting and Whistleblowing at Sun King

Sun King believes in conducting fair, ethical business, and all of Sun King's employees and contracted sales agents have agreed to conduct themselves with integrity in all business related interactions.

Our code of conduct specifies that Sun King’s employees commit to:

  • Treating all people with respect.
  • Disclosing conflicts of interest.
  • Representing Sun King’s work and the Company's products and services honestly.
  • Refusing to accept or offer bribes, unauthorized additional payment, gifts, or other benefits for doing our work.
  • Keeping political, religious, or other advocacy interests out of our work.
  • Honoring and respecting confidentiality and access to confidential information.
  • Not retaliating against reporters of misconduct.
  • Not discriminating on the basis of culture, race, color, caste, nationality, ethnicity, age, religion, pregnancy status, sex, gender identity or expression, sexual orientation, marital status, disability, or HIV/AIDS status.

 

Moreover, Sun King has a strict policy against sexual harassment and assault:

  • Any form of sexual harassment is a serious violation of Sun King’s core belief system.
  • This extends to interactions with agents, investors, prospective employees, distributors, affiliates of any sort, vendors, consumers, and everyone Sun King employees might interact with on a professional basis.

 

We encourage anyone, regardless of their affiliation with Sun King, that is aware of wrongdoing or any conduct by Sun King employee or contracted representative that contradicts or violates these principles to inform Sun King’s leadership about such behavior.

How to report a grievance

Grievances and observed misconduct can be reported by email to [email protected] which will reach Sun King’s designated ombudspersons:

  • T. Patrick Walsh, co-founder and CEO
  • Anish Thakkar, co-founder
  • Vinod Krishna Kumar, Global Head of HR
  • Radhika Thakkar, VP of Corporate Affairs

 

You are also welcome to contact any of the ombudspersons individually.

 

Sun King takes violations of our code of conduct, and all of our policies, seriously. We commit to investigating all allegations of misconduct and to taking appropriate disciplinary action where necessary.

Whistleblowing

 

Sun King also encourages whistleblowing if any Sun King staff or a third party believes there is impropriety in any aspect of individual, team, or company conduct, including:

  • All forms of financial malpractice, fraud, corruption, bribery, theft and concealment.
  • Actions detrimental to health and safety or the work environment.
  • Any form of criminal activity
  • Improper conduct or unethical behavior that undermines our values or code of conduct.
  • Non-disclosure of personal interests or conflict of interest.
  • All forms of discrimination against our staff, as outlined in our anti-discrimination policy.
  • Intimidation of a staff, customer or partner.
  • Physical or verbal abuse, or sexual harassment.
  • Asset misappropriation.
  • Breach of any company policy.

 

To report an allegation of misconduct or malpractice, please send an email to [email protected].

 

Sun King's full Whistleblowing Policy can be found below.

Sun King’s Whistleblowing Policy

Sun King holds all employees, contracted representatives, and agents to the standards implicit in our corporate values. We know that practices that conflict with our core values detract from our mission to power the lives of underserved customers, and we encourage those within, and external to, the company to tell us when they observe behavior that is misaligned with our ethics. This is referred to as whistleblowing.

 

This policy is designed to ensure that customers, agents, members of the public, vendors, distributors, and Sun King employees can raise concerns about wrongdoing or malpractice without fear of victimization, subsequent discrimination, disadvantage or retaliation of any kind.

 

It is also intended to encourage and enable observers of wrongdoing to recognize their responsibility in raising serious concerns to leaders within Sun King rather than ignoring a problem, remaining silent, or coping with unjust, unethical, illegal or unfair conduct.

 

We encourage whistleblowing if any Sun King staff or a third party believes there is impropriety in any aspect of individual or team conduct, including:

  • All forms of financial malpractice, fraud, corruption, bribery, theft and concealment.
  • Actions detrimental to health and safety or the work environment.
  • Any form of criminal activity.
  • Improper conduct or unethical behavior that undermines our values or code of conduct.
  • Non-disclosure of personal interests or conflict of interest.
  • All forms of discrimination against our staff, as outlined in our anti-discrimination policy.
  • Intimidation of a staff, customer or partner.
  • Physical or verbal abuse, or sexual harassment.
  • Asset misappropriation.
  • Breach of any company policy.

What happens when a case is reported?

  • Sun King will investigate all cases of whistleblowing, and all investigations will be directed and monitored by the Head of Human Resources and/or CEO.
  • Initial inquiry into the allegations will be carried out by an internal Fact Finding Committee (FFC) or an appointed HR representative upon directive from the Head of Human Resources and / or CEO.
  • Based on the facts and findings of any investigation, Sun King will pursue corrective action, which may include pursuing an internal disciplinary hearing; termination of employment where appropriate, in line with Sun King’s disciplinary action process; or cooperation with local law enforcement where necessary.
  • We will treat whistleblowing with confidentiality, and whistleblowers will be assured of their security with anonymity unless legally required otherwise.
  • Detrimental action of any kind will not be taken against a person within, or external to, Sun King for making a complaint of the nature described above, provided that it is done without malice and in good faith, reasonably believing it to be true.
  • Sun King encourages whistleblowers to identify themselves or to report through an anonymous email ID to enable the possibility of ongoing, bilateral communication to properly investigate the complaint.

Whistleblowing process

To report an allegation of misconduct or malpractice, please send an email to [email protected].

 

The email will be sent to Sun King’s dedicated ombudspersons:

  • T. Patrick Walsh (Co-Founder and CEO)
  • Anish Thakkar (Co-Founder)
  • Radhika Thakkar (VP Corporate Affairs)
  • Vinod Krishna Kumar (Head of Human Resources)

Sun King’s dedicated ombudspeople are charged with preventing and dealing with cases of wrongdoing within the organization. They will maintain confidentiality to the extent possible while investigating issues brought to their attention and will ensure the whistleblower’s anonymity and protection from retaliation of any sort.

 

Please provide a detailed account of the observed wrongdoings in your communication and share as much information as is available to enable a thorough investigation. After receiving your report, a designated ombudsperson will get in touch to arrange an interview.

 

At this stage, you will be asked whether you wish your identity to be disclosed and will be reassured about protection from possible retaliation. You will need to provide the following information:

  • the nature of your concern and why you believe it to be true
  • the background and history of the concern (giving relevant dates)

Formal investigation

The identity of any person making an allegation using the whistleblowing procedure will be kept confidential until a formal investigation is launched. Thereafter, the identity of the person making the allegation may be kept confidential, if requested, unless this is incompatible with a fair investigation (e.g. the need of the person(s) against whom the allegation is made to know the identity of his/her accuser) or unless there is an overriding reason for disclosure.

Where appropriate, the matters raised may:

  • Be investigated by management or through Sun King’s internal disciplinary/grievance process.
  • Be referred to the police.
  • Be referred to an external auditor.
  • Be referred to our labor law consultants.

Within ten working days of a concern being raised, the person investigating your concern will write to you:

  • Acknowledging that the concern has been received.
  • Indicating how the organization proposes to deal with the matter.
  • Supplying you with information on staff support mechanisms.
  • Telling you whether further investigations will take place and if not, why not.

Commitment to no retaliation

If it turns out that the reported behavior was not in fact a case of wrongdoing, and it is confirmed that the whistleblower reported out of genuine concern and was not acting maliciously, Sun King will ensure that the employee does not suffer from retaliatory actions.

 

Any form of retaliation, whether overt or suggestive, is prohibited and should be reported. Retaliation in any form is a serious violation of Sun King’s policies and would be subject to a disciplinary process on its own accord. If anyone suspects retaliation in any form, they should report that to one of Sun King’s ombudspersons right away.