Vigil mechanism design under Companies Act Section 177, SEBI whistleblower framework, anonymous reporting channels, investigation management and retaliation protection.
Short, direct, on the record.
A vigil mechanism is mandatory for every listed company (SEBI LODR Regulation 22), every company that accepts deposits (Section 73 read with Rule 7), and every company with borrowings exceeding INR 50 crore from banks and financial institutions. Private companies meeting these criteria must also establish one.
Termination in retaliation for protected disclosures can be challenged. The Companies Act requires the vigil mechanism to provide safeguards against victimisation. Listed companies must ensure that no person is unfairly treated or victimised for using the vigil mechanism, with direct access to the audit committee chairperson if needed.
Yes. The SEBI (Prohibition of Insider Trading) Regulations provide an informant mechanism under Regulation 7C where informants providing original information about insider trading violations can receive a reward of up to INR 1 crore. The informant identity is protected.
Internal investigations should be initiated at the direction of legal counsel to maintain attorney client privilege. Investigation reports, interview notes and evidence summaries should be prepared under legal supervision. Fact finding reports should be separated from legal analysis and advice.
Share the company type, current mechanism status and the compliance or investigation context for a preliminary assessment.