Whistle Blower Policy

The Company has established a Vigil Mechanism, the details of which are contained in the Whistle Blower Policy. It aims at providing avenues for employees to raise complaints and to receive feedback on any action taken and seeks to reassure the employees that they will be protected against victimization for any whistle blowing conducted by them in good faith. The policy is intended to encourage and enable the employees of the Company to raise serious concerns within the organization rather than overlooking a problem or handling it externally. The Company is committed to the highest possible standard of openness, probity and accountability.

It contains safeguards to protect any person who uses the Vigil Mechanism (whistle blower) by raising any concern in good faith. The Company will not tolerate any form of victimization and will take appropriate steps to protect a whistleblower that raises a concern in good faith and shall treat any retaliation as a serious disciplinary offence that merits disciplinary action.

The Company will protect the identity of the whistle blower if the whistle blower so desires, provided that the whistle blower will need to attend any disciplinary hearing or proceedings as may be required for investigation of the complaint.

The mechanism provides for a detailed complaint and investigation process. If circumstances so require, the employee can make complaint directly to the Chairman of the Audit Committee.

The Company also provides a platform to its employees for having direct access to the Chairman & Managing Director of the Company for raising any concerns. It is through ATP Connect (atpconnect@punjlloyd.com).