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As per Listing Agreement Clause 49, it was a non mandatory requirement to have a Whistle Blower Policy in an organisation. Accordingly, in our bank, it was observed that the bank has well defined systems and procedures and also a proper reporting system and therefore this mechanism was not introduced.
Though the bank is having a proper complaint handling system in place ye t a scheme for public interest disclosure that ensures protection of informers is to be framed / implemented. As such, formation of a Whistle Blower Policy would be a good step from the view of Corporate Governance.
This Whistle Blower Policy is based on the Government of India Resolution on "Public Interest Disclosures & Protection of Informer" (PIDPI) in the Bank.
As a socially responsible organization, the Bank believes in conducting its affairs in a fair & transparent manner by adopting the highest standards of professionalism, honesty, integrity and ethical behavior. The Bank is committed to develop a culture, where it is safe for all, who alarms concerns about any unacceptable/unethical practice or misconduct at any level.
As such, in case the complainant has reasonable grounds of having observed unethical and improper practices or any other wrongful conduct in any of the departments / offices / Branches of the Bank, he may lodge a complaint under this policy, which shall b e known as "Whistle Blower Policy" in the Bank .
The Government of India has authorized the Central Vigilance Commission (CVC) as the `Designated Agency` to receive written complaints for disclosure on an allegation of corruption or misuse of office and to recommend appropriate action. The jurisdiction of the Commission in this regard is extended to any corporation established by or under any Central Act. Our Bank, being established under the Central Act, therefore, comes under the purview of the Central Vigilance Commission.
In accordance with the aforesaid Resolution of the Government of India, the CVC, which will accept such complaints has the responsibility of keeping the identity of the complainant secret. As such, they have formulated norms for acceptance of complaints under the PIDPI. Bank is required to inform its employees, officers and general public, the laid down norms of the CVC in this regard and this policy is intended to provide for the same .
A copy of the deta iled notification is also available on the website of the Commission http://www.cvc.nic.in issued in public interest by the Central Vigilance Commission, INA, Satarkata Bhawan, New Delhi .
The complainant shall lodge the complaint to the CVO in a closed / secured envelope marked as "Complaint under the Public Interest Disclosure (PIDPI)" at the following address:
The Chief Vigilance Officer
Punjab National Bank
Head Office: 7, Bhikhaiji Cama Place
New Delhi -110 607
The CVO shall be authorized to deal with the complaints received under PIDPI. Complainant shall be known as "Whistle Blower" and the policy shall be known as "Whistle Blower Policy". The confidentiality of whistle blower shall generally be maintained.
Any complaint which is to be made under PIDPI should comply with the following aspects: -
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