Equifax India is committed to fostering a culture of integrity, transparency, and accountability. This whistleblowing / disclosure procedure provides a secure channel for any individual, including employees, customers, and external stakeholders, to report concerns about unethical practices, misconduct, or violations of laws, regulations, or internal policies.
Types of Qualifying Disclosures
- A criminal offence has been committed, is being committed, or is likely to be committed;
- A person has failed, is failing, or is likely to fail to comply with a legal obligation;
- A miscarriage of justice has occurred, is occurring, or is likely to occur;
- The health and safety of any individual has been, is being or is likely to be endangered; or
- The physical environment has been, is being or is likely to be damaged.
How to Report Whistle Blowing
In the event of an individual wishing to make a qualifying disclosure, they should follow the steps below:
-
Report it by writing, email to whistleblowerindia@equifax.com (anonymity will be maintained, as required)
OR
- via the Equifax Reporting Line (see below)
Equifax Integrity Line: (anonymous reporting option available)
| Country | Toll Free |
|---|---|
| India | 022-50972521 |
OR
- Report the situation to their direct manager or the next level of management;
OR
- Report it to the Human Resources Department or a member of the Privacy & Compliance Team, or the Legal Team. The relevant Departmental Heads may also be emailed directly if preferred.
Disclosures should be made promptly so that an investigation may proceed and any action taken expeditiously.
Whistle Blowing Complaint Management
Confidentiality and Non-Retaliation
- A whistleblower can choose to report wrongdoing without revealing their identity. They have the right to either report anonymously, where their name is completely unknown, or to report confidentially, where their identity is protected and only known to a trusted few who are bound by privacy. This choice helps ensure their safety and encourages them to come forward with important information.
- Confidentiality will be maintained during the investigatory process to the extent that this is practical and appropriate in the circumstances.
- If in case it becomes necessary to disclose the Whistleblower’s identity, Equifax will make efforts to inform the Whistleblower that his or her identity is likely to be disclosed.
- In order not to jeopardise the investigation, the Whistleblower is also expected to keep the fact that they have raised a concern, the nature of the concern and the identity of those involved confidential.
- A whistleblower will not face negative or harmful consequences—such as demotion, harassment, or termination—for reporting a concern in good faith.
Investigation Process and Timelines
- The length and scope of the investigation will depend on the subject matter of the disclosure.
- Equifax reserves the right to arrange for another investigator to conduct the investigation other than the individual with whom the individual raised the matter.
- In addition, an investigative team with experience of operating workplace procedures or specialist knowledge of the subject matter of the disclosure may be appointed.
- If initial enquiries by the Investigating Officer indicate that the concern has no basis, or it is not a matter to be investigated, it may be dismissed at this stage and reason for dismissing the complaint, without further investigation, will be documented and communicated.
- The investigation report along with disciplinary action as the Investigating Officer may think fit and preventive measures to avoid reoccurrence of the matter shall be prepared within 45 days from the receipt of the complaint, on a best effort basis. In case any extension in the timeline is required due to unforeseen reasons, the approval of the Audit committee will be obtained.
- Once the investigation has been completed, the individual will be informed in writing, where their contact details have been provided, of the outcome, together with Equifax's conclusions and decision in a timely manner.
- Equifax is committed to taking appropriate action with respect to all qualifying disclosures which are upheld.
- When the conclusions have been finalised, the appropriate & necessary action will be taken. This could include either reporting the matter to an appropriate external Government Department or Regulatory Agency and/or taking internal disciplinary action against relevant employees.
- Equifax will endeavour to inform the individual if a referral to an external agency is about to or has taken place, although it may be necessary to make such a referral without the individual’s knowledge or consent if this is appropriate in the circumstances.
- Depending upon the seriousness of the matter, the investigator may inform the Audit Committee within 45 days from the date of the complaint with proposed disciplinary action/ counter measures for necessary action.
- The Audit Committee may decide the matter as it deems fit within the next 45 days. The decision of the Audit Committee would be final and binding.
- In the event the complaint is against the Chairperson of the Audit Committee or the Chairperson discloses any conflict with respect to complaint received, he/she shall recuse themselves from the proceedings and the role of the Chairperson shall be carried out by one of the members selected by the remaining members of the Audit Committee.
- If, upon conclusion of the above stages, the individual reasonably believes that appropriate action has still not been taken, they may then report the matter to the appropriate external authority in good faith.