WHISTLE BLOWER POLICY: Aditya Group of Industries

Objective: The Company encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving the Company’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal. It shall be abiding by all employees on payroll or contractual for all business verticals of the group.

In keeping with the policy of maintaining the highest standards of conduct and ethics, the Company authorities will be bound to investigate any and all complaints of suspected wrong doing occurring within its operation; fraudulent or dishonest, use or misuse of its resources or property; discrimination or violations of existing company policy; and violations of moral issues on integrity aspect. Employees, vendors, contractors, and clients are encouraged 1 to report all suspected wrongdoing pursuant to the procedures set forth below.

Accountability: A person reporting concerns under this policy must act in good faith and have reasonable grounds for believing that the information reported indicates that Suspected Wrong doing / Violation has occurred. A person who makes an allegation maliciously or if proven to believe that the allegation was false will be subject to stern disciplinary action including termination of employment. Employee Id, Group Company name must be quoted along with name of the employee.

Reporting Procedure: Any person’s concern about Suspected Wrongdoing should raise a mail to ethics@adityagroupindia.org with evidence to believe in the complaint reported. The complainant must be ready to talk on the issue to add conviction to the reported allegation.

Reported Suspected Wrongdoing should contain the names of the individuals involved, dates and a description of the actions believed to be Suspected Wrongdoing. At no time should an individual who has reported or is considering reporting Suspected Wrong doing undertake any independent investigation into the matter to obtain additional information.

The organization encourages anyone reporting Suspected Wrongdoing to make himself or herself accountable while making a report and co-operate to facilitate the investigation of Suspected Wrongdoing.

Confidentiality: All reports of Suspected Wrongdoing will be kept strictly confidential unless the need to conduct an adequate in-depth investigation with the accused himself arises.

Investigation: Reports of Suspected Wrongdoing will be promptly reviewed and analysed by the topmost authority.

Appropriate corrective action will be as warranted by the investigation, and findings may be communicated to the reporting person, to the extent reasonably possible and consistent with any privacy and confidentiality limitation.

If necessary Investigations may be conducted by independent persons such as auditors or experts in any field at the discretion of the authorities. Show cause notice, warning letters highlighting the wrong doing will be issued wherever deemed fit.

No Retaliation : No one involved in the investigation of the Suspected Wrongdoing, or whoever cooperates in the investigation of Suspected Wrongdoing, shall suffer harassment, retaliation, or adverse employment consequences. Any such retaliation should be further reported, and the Authorities will promptly investigate and align to be consistent with the procedures as contained in this policy. The company vouches to undertake an unbiased probe into every complaint received.