“Vigil Mechanism” (“the Policy”)

The Salient Features of the “Vigil Mechanism” of the Company as approved by The Board of Directors are given below:

• The Policy is applicable to all full time employees and Directors of the Company for reporting their genuine concerns which would cover malpractice, unethical behavior, fraud or suspected fraud, manipulation, misappropriation of monies and violation of the Company codes and instances of leak of unpublished price sensitive information. (“the Information / Protected Disclosure”).

The person (“the Informer / Whistle Blower”) who wants to disclose the Information shall send the same by e-mail to a protected address “[email protected]“, addressed to the Designated Officer Mr. Dhwanee Buch.

• In case the Information is in respect of Designated Officer, or the Managing Director separate protected e-mail addresses are provided for disclosing Information.
• On receipt of the Information, the Recipient will get in touch with Informer to ascertain from the Informer whether he was the person who made the Disclosure and then refer the same to the Vigil Committee (as constituted by Audit Committee), which will examine the same to find out whether the Information received falls within parameters defined under Policy and will take action as per directions given by Audit Committee of Board of Directors. In case of the Information received by MD, Audit Committee will be consulted for further action. In case the Information is received by the Chairman of Audit Committee, then he will consult Audit Committee.
• The Information/Protected Disclosures should be factual and not speculative and as much specific as possible.
• Anonymous / Pseudonymous Information shall not be entertained.
• If it is found that the Information was not given in good faith, then it shall be viewed seriously and the Informer shall be subject to disciplinary action.
• The Mechanism, does not release employees from their duty of confidentiality in course of their work nor can it be used as a route for raising malicious or unfounded allegations against people in authority and or colleagues in general.
• The Mechanism provides for adequate safeguards against victimization for those who avail this Mechanism and also provides for direct access to the Chairman of the Audit Committee of the Company in exceptional cases.
• No unfair treatment will be meted out to a Informer by virtue of his / her having reported the Information under this Policy.
• The identity of the Informer shall be kept confidential to the extent possible given the legitimate needs of law and investigation. The Informer are cautioned that their identity may become known for reasons outside the control of the Vigil Committee/Audit Committee (e.g. during investigations carried out by Investigators).

It is expressly made known to all that the above information is given in summary form, for easy understanding of the Policy. For all purposes including any point of law or interpretation, the full text of “Vigil Mechanism”, as approved by the Board of Directors, shall be relied / acted upon.

The entire Text Vigil Mechanism is available with Designated Officer and has been uploaded at “Policy Documents Library” of GTFL Intranet.