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This Policy sets out how Kshema General Insurance Limited (“Kshema”, “the Company”) obtains and honours your consent to collect and process personal information, and the channel through which any person may report a concern about wrongdoing at the Company without fear of retaliation.
It applies to all customers, prospects, claimants, employees, agents, intermediaries, vendors and other stakeholders who deal with the Company, and it should be read together with the Company’s Privacy Policy and Terms & Conditions.
The Company collects personal information only for lawful, specified purposes connected with the business of general insurance - issuing and servicing policies, underwriting and pricing risk, settling claims, detecting and preventing fraud, and meeting its obligations under the Insurance Act, 1938, the IRDAI regulations made under it, and applicable data-protection law.
Consent is obtained on the following basis:
You may withdraw consent at any time by writing to the Company at info@kshema.co. Where withdrawal prevents the Company from continuing to service a policy or process a claim, the Company will tell you what the consequence is before acting on the request. Withdrawal does not affect processing already carried out on the basis of the consent you had given, and it does not override information the Company is required by law to retain.
The Company does not sell personal information. It is shared with reinsurers, intermediaries, service providers, repairers, surveyors, hospitals and other parties only to the extent needed to give effect to the cover, and those parties are bound to use it for that purpose alone.
The Company expects every person acting on its behalf to conduct business honestly. This Policy gives employees and other stakeholders a protected route to report conduct that falls short of that expectation, so that a genuine concern reaches the Audit Committee rather than going unreported.
Protected Disclosure means a concern raised in good faith about actual or suspected wrongdoing at the Company. It includes, but is not limited to:
A Protected Disclosure should be a concern about conduct, supported by whatever facts the person raising it has. It is not a route for personal grievances about employment terms or for customer complaints about a policy or a claim - those have their own channels, and a customer complaint should go to the Company’s Grievance Redressal officer instead.
A Protected Disclosure may be sent to the Whistle Blower Officer at whistleblower@kshema.co, or in a sealed envelope marked “Private and Confidential - Whistle Blower” to the Whistle Blower Officer, Kshema General Insurance Limited, #413, 4th Floor, My Home Tycoon, Kundan Bagh, Begumpet, Hyderabad, Telangana - 500016, India.
Where the concern involves the Whistle Blower Officer, or where the person raising it would rather not route it through management, it may be addressed directly to the Chairperson of the Audit Committee at the same postal address.
Disclosures may be made anonymously. An anonymous disclosure is investigated on its merits, though the Company may be limited in what it can establish if it cannot ask follow-up questions.
The identity of the person making a Protected Disclosure is kept confidential and is disclosed only where the Company is compelled to disclose it by law or by a direction of a court or regulator. Access to the disclosure is restricted to those conducting the investigation.
Every disclosure is acknowledged, recorded, and assessed to decide whether an investigation is warranted. Where one is, it is conducted by a person with no involvement in the matter and no reporting line to anyone implicated in it. The outcome and any action taken are reported to the Audit Committee, which oversees the operation of this Policy.
The Company will not tolerate retaliation of any kind against a person who makes a Protected Disclosure in good faith. Retaliation includes dismissal, demotion, suspension, transfer, withholding of a promotion or increment, harassment, exclusion, termination of an agency or vendor arrangement, or any other detriment imposed because a disclosure was made.
This protection applies whether or not the concern is ultimately substantiated. What matters is that it was raised in good faith. Any act of retaliation is itself treated as misconduct under this Policy and is dealt with accordingly, up to and including termination of employment or of the contractual relationship concerned.
The protection does not extend to a disclosure the person knew to be false when they made it. A knowingly false or malicious allegation is misconduct in its own right.
No person is required to seek permission before making a Protected Disclosure, and nothing in this Policy prevents any person from reporting a matter directly to IRDAI or to any other authority entitled to receive it.
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