CODE OF CONDUCT

FOR

EMPLOYEES
Version 2.0 / October 2024

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 Record of Release:

Version Release
Doc. ID Created by Reviewed by Authorized by Remarks
No. Date

Namarata Dr. C. October Second

2.0 COC01 Kunal Mistry
Verma Jayakumar 2024 Release

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Contents
I. PREAMBLE .......................................................................................................................................................... 4

II. APPLICABILITY................................................................................................................................................... 4

III. CODE OF CONDUCT.......................................................................................................................................... 4

i. Honesty, Integrity, Accountability and Ethics ................................................................................................... 4

ii. Respect for Individuals ........................................................................................................................................ 4
iii. Customer Need and Stakeholder Value ........................................................................................................... 5
iv. Fair Competition and Anti-trust ........................................................................................................................... 5
v. Sharing of Official Information ............................................................................................................................ 5
vi. Maintaining Confidentiality .................................................................................................................................. 6
vii. Dealing in Securities While in Possession of Unpublished Price Sensitive Information (UPSI) ............... 6
viii. Professional Engagement and Public Advocacy ............................................................................................. 6
ix. Use of Company Assets and Brand Logo ......................................................................................................... 7
x. Intellectual Property ............................................................................................................................................. 7
xi. Social Media Code of Conduct ........................................................................................................................... 7
xii. Use of Information Technology ........................................................................................................................... 8
xiii. Working Environment and Dress Code Policy ................................................................................................. 8
xiv. Environment, Health and Safety (EHS) ............................................................................................................. 9
xv. Respect for Human Rights .................................................................................................................................. 9
xvi. Sustainability ......................................................................................................................................................... 9
xvii. Corporate HR Policy ........................................................................................................................................... 10
xviii. Risk Management Framework .......................................................................................................................... 10
xix. Prohibited Items .................................................................................................................................................. 10
xx. Anti-Bribery, Anti-Corruption ............................................................................................................................. 10
xxi. Gift and Entertainment Policy ........................................................................................................................... 10
xxii. Political Activity ................................................................................................................................................... 11
xxiii. Information Security ........................................................................................................................................... 11
xxiv. Endeavor to Contribute ...................................................................................................................................... 11
xxv. Conflict of Interest ............................................................................................................................................... 12
IV. Whistleblowing: ................................................................................................................................................ 12

V. Training & Acknowledgement: ..................................................................................................................... 12

VI. Mechanism for implementation and monitoring ...................................................................................... 12

VII. ECOM Disclosure ............................................................................................................................................. 13

VIII. Review & Amendment ..................................................................................................................................... 13

IX. Non-Compliance: .............................................................................................................................................. 13

Reporting Matrix ............................................................................................................................................................. 14

Form on Acknowledgement and Receipt of Code of Conduct………………………………………………..……………………15

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 I. PREAMBLE

Larsen & Toubro Limited is a professionally managed Indian multinational, committed to total
customer satisfaction and enhancing stakeholders’ value. The Company’s philosophy on
corporate governance is built on a rich legacy of fair and transparent governance and disclosure
practices. This includes respect for human values, individual dignity and adherence to honest,
ethical and professional conduct. “L&T-ites” are guided by the vision statement and values
mentioned therein for the success and reputation of L&T.

II. APPLICABILITY

This Code of Conduct is applicable to all the Executive Directors, Senior Management Personnel
and Employees of Larsen & Toubro Limited and its group of Companies (hereinafter also referred
to as “L&T-ites”).

For the said purpose, Employee shall mean ‘every employee of the Company including regular
employees in supervisory cadre and above, deputed employees and employees engaged on a
direct contract basis’.

III. CODE OF CONDUCT

i. Honesty, Integrity, Accountability and Ethics

All L&T-ites shall act in conformity with professional standards of personal integrity,
accountability, honesty and ethical conduct, especially when on Company’s business, at
Company sponsored events, or when representing the Company.

Ethical conduct is one that is free from fraud and deception and includes actual or potential
conflicts of interest between personal advantages as against organization’s needs and/or
values.

ii. Respect for Individuals

Success can be achieved only when we treat everyone, both within and outside our Company,
with respect. Respect in the workplace, along with individual excellence and collaborative
teamwork, is how we will accomplish our goals.

L&T-ites shall treat their colleagues and business associates with dignity and respect,
irrespective of caste, creed, gender, race, religion, region, nationality, appearance or any
disability.

All L&T-ites shall encourage their subordinates/ colleagues to express their professional views
in meetings/ discussions, candidly and without fear. Feedback on performance will be provided
as far as possible in private. All employees shall be treated with equity and fairness. L&T-ites
shall not use abusive or offensive language, tone or gesture with their colleagues or business
associates. L&T-ites shall not insult/ demean their subordinates. Any form of harassment is
antithetical to the direction of our Company. L&T-ites shall commit to create an environment
which is free of any type of sexual harassment and abide by the Company’s Policy for Protection
of Women’s Rights at the Workplace.

L&T-ites shall exercise diligence with respect to professional interactions with fellow colleagues.
It is the responsibility of each employee to be fully aware of the relevant provisions of law and
repercussions of violations.

L&T-ites shall adhere to Protection of Women’s Rights at Workplace and HIV / AIDS Policy.

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 iii. Customer Need and Stakeholder Value

L&T-ites are passionate about meeting customers’ needs and delivering to stakeholders. L&T-
ites shall:
▪ Demonstrate a passion for understanding and meeting the needs of customers and
stakeholders.
▪ Shall be fair, professional and transparent in its dealings with the customers and
stakeholders.
▪ Take active responsibility for the quality of service we provide to customers and
stakeholders.
▪ Are open to change and readily implement better ways of doing things.
▪ Have high performance expectations and a mindset of excellence.
▪ Be innovative in identifying new opportunities and approaches for our customers,
stakeholders and ourselves.
▪ Respect customers’ right to privacy in relation to their personal data.
▪ In dealing with all customers and stakeholders, comply with all data privacy laws that
prescribe how to responsibly collect, store, use, share, transfer and dispose off personal
information, and strive to comply with those laws everywhere the Company operates.

iv. Fair Competition and Anti-trust:

L&T believes in fair and open competition that benefits customers, stakeholders, and society as
a whole. L&T supports the development and operation of competitive open markets and the
liberalisation of trade and investment in each country and market in which we operate.

L&T-ites shall not enter into any activity constituting anti-competitive behaviour such as abuse
of market dominance, collusion, participation in cartels or inappropriate exchange of information
with competitors. L&T-ites shall collect competitive information only in the normal course of
business and obtain the same through legally permitted sources and means.

L&T-ites should avoid conducting Company business in any significant way with a relative (as
defined in the Companies Act, 2013), or with a business in which a relative is associated.

L&T-ites shall not have a personal relationship with another employee if they have any influence
over the other employee's salary or career path. If such a relationship exists, it must be reported
to management.

v. Sharing of Official Information

L&T-ites shall not divulge or communicate in any manner sensitive/ confidential information to
third parties, except when authorized to do so for business reasons. Company’s Policy
Guideline on Designated Spokespersons authorized for communicating to the media in this
regard, shall be strictly followed.

L&T-ites shall not speak ill about the organization to any external agency which would tarnish
the image of the organization.

Similarly, L&T-ites shall desist from indulging in rumour mongering/ loose talks, about the
organization that is detrimental to the interest of L&T.

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 vi. Maintaining Confidentiality

The employees and personnel of L&T Group may in the course of their employment and
engagement, become aware of and possess information of L&T Group or third parties disclosed
to the L&T Group that is not generally known. This may include information which if disclosed
could jeopardize the interests of the L&T Group.

Therefore, it is imperative that all employees shall maintain the integrity of internal
communications. Care shall be taken to mitigate various risks emanating out of communication
such as misrepresentation of facts/ events, leakage of price sensitive information, unfavourable
reports on developments in the Company and inconsistent communication at the times of crisis.
The contents of all the internal & external communications shall conform to the guidelines of
Communication Risk Management Policy issued jointly by the Corporate Brand Management &
Communication Department and Corporate Risk Management Department.

As an HR process the Company conducts Development Centre (DC) regularly to assess

leadership potential. The participants in these centres will be expected to maintain utmost
confidentiality with respect to the content, material received in the DC and conduct themselves
with the highest sense of professional ethics.

L&T-ites have been entrusted with the duty to keep such information strictly confidential and use
it only for proper purposes in accordance with the law. This would apply during the course of
employment as well as post separation.

L&T-ites shall adhere to the Company’s Communication Risk Management Policy and
Confidentiality Policy.

vii. Dealing in Securities While in Possession of Unpublished Price Sensitive Information

(UPSI)

L&T-ites will be considered as an ‘INSIDER’ under the provisions of the SEBI (Prohibition of
Insider Trading) Regulations, 2015 as amended from time to time. As an Insider, it is the duty
of the employee not to deal in or advocate trade in securities (e.g. equity shares/ preference
shares/ derivatives/ debt securities) of the Company when in possession of any UPSI and till
such time the information comes in the public domain.

The onus will be on the employee to demonstrate that he / she was not in possession of UPSI
at the time of dealing in securities.

L&T-ites shall adhere to the Company’s circular on Prevention of Insider Trading, L&T Securities
Dealing Code and the SEBI (Prohibition of Insider Trading) Regulations.

viii. Professional Engagement and Public Advocacy

L&T-ites are encouraged to associate themselves with activities of professional bodies/ fora to
enrich their knowledge and also help in building organization’s image.

The government is an important stakeholder in our business, and we therefore engage with it
through multiple business forums and trade organisations. We shall engage with the
government, regulators, policy makers, trade associations and other stakeholders in a
constructive manner in order to promote good governance. Our senior executives are active
members of industry bodies that participate in the development of public policy that addresses
issues affecting industry, business, products and customers. However, such engagement
should not result in dereliction of duty or in discrediting the organization’s image/ reputation or
abuse of organization’s resources.

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 L&T-ites shall adhere to the Company’s Public Advocacy Policy.

ix. Use of Company Assets and Brand Logo

L&T-ites shall not exploit the organizational resources for one’s own personal gain/ pecuniary
advantage. In discharge of official duties, one shall strive for effective and judicious use of
resources entrusted to them. Resources include both tangible assets like equipment and
facilities etc. or intangible assets like designs, information, trademarks, patents, software or
network with suppliers/customers, etc.

L&T-ites are entrusted with the duty of using the brand logo without modifying the same. All the
employees shall abide by the guidelines for Brand applications/ usages including on official
communication and visiting cards. Deviations from the specific logo templates will not be
permitted.

L&T-ites shall adhere to the Company’s Master Brand Guidelines.

x. Intellectual Property

Intellectual property of L&T is an invaluable asset that must be protected at all times. L&T-ites
shall respect and protect all confidential information and intellectual property of the Company.

L&T-ites shall safeguard the confidentiality of all third-party intellectual property and data. L&T-
ites shall not misuse such intellectual property and data that comes into their possession and
shall not share it with anyone, except in accordance with applicable Company policies or law.

L&T-ites shall promptly report misuse, loss, theft or destruction of any intellectual property and
data of the Company or that of any third party.

xi. Social Media Code of Conduct

L&T encourages social media interaction (during the employees’ personal time) in an individual
capacity, and we trust our employees to act responsibly adhering to the policies of the Company
with respect to messages pertaining to the business and/ or brand.

L&T-ites are expected to use social media in the best interests of the Company wherever there
is any reference to the Company’s name, brand or reputation. Social media interaction includes
all digital social platforms and online interaction including interaction on platforms such as
LinkedIn/ Facebook/ X (formerly Twitter)/ YouTube/ Snapchat/ Blogs or Review platforms/
Whatsapp/ Instagram, etc.

Responsibility of L&T-ites:

▪ They are responsible for what they post. They have to be aware that social media
interactions for or on behalf of the Company (intended or unintended) can have legal
repercussions that make the Company liable.
▪ They should not use the L&T logo or trademarks as their display pictures/ images.
▪ They should not share information about clients, partners, L&T leadership, L&T
Businesses and their performance. They should not be involved in plagiarism or
infringement of any copy right, in the context of any reference made about L&T, its
business, products or services.
▪ They should avoid anonymous postings.

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 What can be posted on social media:

▪ Confidentiality of information should be kept in mind. One may share awards/

accomplishments pertaining to the Company after they become public information.
Personal views and perspectives shared in the form of blogs, articles, stories, narrations
or any form of postings should have a disclaimer that these views are views of the
individual and not of the Company.
▪ One should not share information on or comment on current or former employees,
clients, competitors, vendors or suppliers.
▪ One should not share any content that is protected by a third party's copyright. When
sharing content created by someone else, due credit should be given to the creator.
▪ One should not film or photograph internal events and post them to social media unless
one has the authorisation from their department head.

Tone:

▪ One should be respectful. L&T does not condone any abuse and trolling on social
media.
▪ One should use first person (don’t use ‘we’ or ‘us’) when sharing opinions. It should be
made clear that what is shared or said, is representative of one’s personal views and
opinions only and are not necessarily the views and opinions of L&T.
▪ One should be proactive and take responsibility in accepting and clarifying
controversies (if any) around one’s post on social media.

L&T reserves the right to monitor, edit, forbid, stop or/ and filter comments or discussions about
its group or companies, employees, clients and the industry, including products and
competitors, posted by any L&T-ites on the Internet/ in Social Media. If any content violates
L&T’s Code of Conduct or the Social Media Policy, or the Communication Policy, L&T reserves
the right to seek clarification, and if required, ask the employee to delete that content.

L&T-ites shall adhere to the Company’s Master Brand Guidelines.

xii. Use of Information Technology

L&T-ites shall judiciously use the Information Technology facilities provided to them. They shall
conform to the policy on Information Technology.

E-mails form a major portion of the network usage. In order to make the best utilization of the
resources and to prevent undesirable fallouts resulting from the use of E-mails, users should
comply with the Corporate E-mail Usage Guidelines.

During interactions through all virtual platforms, L&T-ites shall:

▪ Use a respectful and professional tone in all messages and conversations.
▪ No sensitive or confidential information shall be shared without proper authorization.
▪ Dress appropriately during video calls and ensure the background is suitable.
▪ Use video and microphone features to foster engagement.

L&T-ites shall adhere to the Company’s Corporate E-mail Usage Policy.

xiii. Working Environment and Dress Code Policy

L&T-ites shall not engage in any activity that is likely to result in disturbing peace and harmony
in the workplace or engage in activities that are likely to create tension, bitterness or confusion
in the minds of colleagues.

All L&T-ites shall endeavour to create a climate that ensures the above.

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 All L&T-ites are expected to project a professional image through attire and bearing.

L&T-ites shall adhere to the Company’s Dress Code Policy.

xiv. Environment, Health and Safety (EHS)

Safety is the core component of the Company’s responsibility; it is also the foundation of its
long-term viability. Company is committed to the safety and health of employees and Company
believes that all injuries and occupational illnesses are preventable. Company has a
commitment to zero injuries in the workplace.

L&T-ites shall endeavour to create a safe working environment by following the policies and
procedures as laid down in the Corporate Environment, Health & Safety Management Systems
framework. Towards this, all the L&T-ites shall:
▪ Incorporate EHS considerations in all business decisions.
▪ Ensure compliance to statutory and other requirements.
▪ Prevent adverse environmental impacts and occupational health and safety risks.
▪ Conserve natural resources, minimize waste generation and environmental emissions
▪ Impart structured training for employees and stakeholders for effective EHS
performance.
▪ Encourage communication, consultation and collaboration with all the stakeholders.

L&T-ites shall strive to keep ones’ own place and surrounding workplace clean and hygienic.

L&T-ites shall report any accident, injury, illness, or unsafe condition to HR department
immediately.

L&T-ites must be aware of the emergency procedures that apply respective areas of work.

L&T-ites must use all the relevant safety gears and equipment at workplace and shall not resort
to methods which can result in untoward accidents.

L&T-ites shall adhere to the Company’s EHS Policy.

xv. Respect for Human Rights

The Company respects human rights everywhere it works and while doing business with others.
The Company does not employ children at the workplaces. The Company also does not use forced
labour in any form. There are grievance mechanisms in place to address concerns related to human
rights abuse. Such principles are integral to the Company’s values and practices, promoting a safe
and ethical working environment..

xvi. Sustainability

L&T-ites are committed to fulfilling our economic, environmental and social responsibilities
while conducting business. All the L&T-ites shall follow the guidelines laid down in the
‘Sustainability Policy’ and strive to conserve natural resources, and achieve sustainable
growth, through a culture of trust and care.

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 xvii. Corporate HR Policy

People are the most valuable resources that contribute towards realizing the dynamic vision of
the Company. Hence in consonance with the HR functions, L&T-ites shall be relentlessly
committing themselves to:
▪ Acquiring, developing and retaining a pool of high-calibre talent.
▪ Enabling and empowering our employees to be creative and innovative.
▪ Establishing systems and practices for maintaining transparency, fairness and equality.
▪ Creating a culture of continuous learning, competitiveness and excellence through
change management.
▪ Respecting ethics, values and good governance.
▪ Provide equal opportunity for growth & development.

L&T-ites shall adhere to the Company’s Human Resource Policy.

xviii. Risk Management Framework

L&T-ites must comply with all the laws applicable to the Company, adhere to the Risk
Management Policy and abide by the Internal Control Guidelines.

xix. Prohibited Items

Use, sale, purchase or possession of alcohol/ narcotic drugs/ arms/ weapons by L&T-ites at
workplace or when on duty, is prohibited. Smoking is allowed only at designated places.

Medication prescribed by a physician is acceptable if it is not misused or abused. If any L&T-

ite is taking a prescription drug that may affect their ability to perform their job, they should
notify their HR.

xx. Anti-Bribery, Anti-Corruption:

L&T-ites should never offer, directly or indirectly, any form of gift, entertainment or anything of
value to any government official or commercial partners including customers or their
representatives to:
▪ Obtain or retain business;
▪ Influence business decisions; or
▪ Secure an unfair advantage.

L&T-ites should not accept, directly or indirectly, any form of gift, entertainment or anything of
conspicuously high value from existing and potential business partners, vendors or their
representatives.

Both the above-mentioned scenarios include bribes, kickbacks and facilitation payments.

Gifts/ Honorarium of nominal value accepted or offered on the occasion of festivals, talks for
academic sessions, contribution to academic boards etc. will be permitted, as mentioned in
‘Gift and Entertainment Policy’ as defined in this document.

xxi. Gift and Entertainment Policy

A gift is anything of value and would encompass any gratuitous monetary or non-monetary
benefit. It includes tangible items such as cash, precious metals, stones, jewellery, art and any
of their equivalents, but also intangible items such as discounts, services, loans, favours,
special privileges, advantages, benefits and rights that are not available to the general public.
For the avoidance of doubt a “gift” also includes meals, entertainment, hospitality, vacations,

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 trips, use of vacation homes, tickets to sporting or music events, outings, vendor familiarization
trips and use of recreational facilities.

L&T-ites are prohibited from offering and/ or receiving gifts, in connection with the business
and/or in the capacity of an employee, which might influence their decision in relation to the
business of the Company.

However, only customary exchange of gifts/honorarium of nominal value, such as, flowers,
sweets, dry fruits or chocolates, accepted or offered on the occasion of festivals will be
permitted under this Policy. The Senior Management (BU Heads, IC Heads and Functional
Heads, etc.) may offer or accept appropriate corporate gifts linked to (i) the business of the
Company (such, a replica of the Statue of Unity) or (ii) the corporate social responsibility
activities undertaken by the Company (for instance, paintings made by marginalised
communities). Gifts of this nature can also be accepted on behalf of the Company and be kept
on the Company’s premises.

In addition, and subject to prior approval from the relevant Department Head or an equivalent
authority, L&T-ites may, on certain occasions, initiate or participate in business meals,
celebratory events, or entertainment activities involving business partners, including clients
and suppliers. These engagements must be conducted in a transparent manner, with the
purpose of fostering healthy professional relationships and goodwill. Under no circumstances
should such interactions be intended, or perceived, to improperly influence any business
decisions or compromise the integrity of the Company.

xxii. Political Activity:

▪ L&T-ites shall act in accordance with the constitution and governance systems of the
countries in which the Company operates. The Company does not seek to influence the
outcome of public elections, nor it undermines or alters any system of government.
▪ L&T-ites have the right to personally participate in the political process in accordance with
the rights enshrined in the Constitution of India.
▪ L&T-ites may join and/or support any political party, provided any such political activity is
lawful and appropriate. However, such activities of L&T-ites should not interfere with the
performance at work and responsibilities towards the Company.
▪ L&T-ites may nominate themselves or contest elections for any political position. However,
in the event an L&T-ite decides to pursue nomination and/or participate in such elections,
then they are required to disclose this decision to the Legal and HR departments and
relinquish his or her employment with the Company, prior to or before such nomination or
participation.
▪ L&T-ites should not influence other L&T-ites to join or support a political party.
▪ L&T-ites shall ensure that their personal and political views and actions are expressed
independently and must not be attributed to or represent the views of the Company.

xxiii. Information Security

The Information Security Policy sets out the expectations on every employee to safeguard
confidential information of the Company and our third parties with the assurance of security,
availability, integrity and confidentiality. This policy provides employees with the mandatory
directive of safeguarding L&T and its stakeholder’s information. L&T-ites shall abide by the
Company’s information Security Policy and safeguard Company information from data leaks,
cyber and phishing attacks, etc.

xxiv. Endeavor to Contribute

All L&T-ites besides being good employees, shall endeavour to contribute towards:
▪ Development of the community and society.
▪ Supporting national and humanitarian causes.

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 xxv. Conflict of Interest:

L&T-ites shall always act in the interest of our company and ensure that any business or
personal association including close personal relationships which they may have, does not
create a conflict of interest with their roles and duties in the Company or the operations of the
Company. Further, L&T-ites shall not engage in any business, relationship or activity, which
might conflict with the interest of the Company or our group Companies.

IV. Whistleblowing:

Each L&T-ite has a responsibility to speak up if we see something unsafe, unethical, retaliatory, or
potentially harmful.

Whistleblowing policy provides a structured process which encourages and facilitates the
Employees and Directors to communicate to the Company any Protected Disclosures through an
appropriate forum for taking appropriate Disciplinary Action after conducting investigation. The
objective of this Policy is also to establish a vigil mechanism for Employees and Directors to report
genuine concerns about any unethical behaviour, actual or suspected fraud or violation of the Code
of Conduct.

Protection of Whistleblowers: All L&T-ites should feel free to make Protected Disclosures to the
WBIC (Whistle Blower Investigation Committee) or the ILIC (Information Leakage Investigation
Committee) without fear of any repercussions on themselves. The Management assures
maintaining confidentiality of the identity of Whistleblower at all times. The Management also affirms
and assures that the Whistleblower will be protected from unfair termination of employment and any
other unfair prejudicial employment practices, due to making the Protected Disclosure.

V. Training & Acknowledgement:

i. It is mandatory for each new joinee to read, understand and acknowledge this document on
joining and sign the acknowledgement form annexed with this document.
ii. All L&T-ites have to re-read, understand and digitally acknowledge the Code of Conduct
document on our Shared Service Portal each year in the month of April.
iii. Training module in Code of Conduct shall be made accessible to all L&T-ites on the digital
learning platform of L&T. All L&T-ites are required to go through the Code of Conduct training
module.

VI. Mechanism for implementation and monitoring

Approvals/ Disclosures under the points mentioned above should be as per the respective policies.

Violations of the Code of Conduct should be reported as per the Reporting Matrix which is annexed
and forms an integral part of the Code of Conduct.

As a practice, any violations should be reported to the First Level Reporting Authority who shall
investigate the same and take necessary action. However, if the violation is by the First Level
Reporting Authority itself, then it should be reported to the Second Level Reporting Authority.

In case the Reporting Authority comes to the conclusion that the violation is of a grave nature, the
same shall be reported to the Whistleblower Investigation Committee for further action within a
reasonable time frame.

The concerned Reporting Authority will give a summary of the violations reported of the Code of
Conduct and the action taken thereon on a monthly basis to the IC HR Head who in turn shall provide
the same to Corporate HR and keep the respective IC Head apprised of the same.

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VII. ECOM Disclosure

Corporate HR Head will provide a summary of the violations reported of the Code of Conduct and the
action taken thereon on a quarterly basis.

VIII. Review & Amendment

The Code of Conduct shall be reviewed as and when required to ensure that it meets the objectives
of the relevant legislation and remains effective. The ECOM has the right to change/ amend the Code
of Conduct as may be expedient taking into account the law for the time being in force.

IX. Non-Compliance:

Non-compliance of the provisions of this Code of Conduct shall be treated as dereliction and an act
of misconduct.
********

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 Reporting Matrix
MATRIX - AUTHORITIES FOR BREACH REPORTING & CLARIFICATIONS /SEEKING PERMISSIONS

Reporting Structure

Sl No Breach reporting 1st Level 2nd Level Remarks

Workplace Conduct (Abusive or offensive
1 DH/IC HR Head CHR Head #
language or any other)
2 Reporting of Bribe/ Fraud WBIC @
Breach of Confidentiality/Intellectual Property -
3 sharing trade secrets and confidential WBIC @
information
Dealing in securities while in possession of
4 Company Secretary ECOM Member
UPSI
5 Misuse of Company's Assets DH/ IC HR Head CHR Head #
IC IT Head/ DH/IC Group IT Head/ CHR
6 Breach of information security #
HR Head Head
8 Sexual Harassment ICC

Sl No Clarification /Permissions Authority

1 Dealing in securities CS Team
Professional Engagement and Public
2 DH
Advocacy
3 Company Assets & Brand Logo CBMC
4 Social Media Code of Conduct CBMC/Legal
5 Information Technology DH/Corporate IT
6 Work Environment Dress Code Policy CHR
7 Environment, Health & Safety DH

Note: In case of any violation of Code of Conduct by any Board of Directors, it shall be reported to the Audit Committee
DH Department Head
WBIC Whistle Blower Investigation Committee
ICC Internal Complaints Committee
Corporate Brand Management &
CMBC Communications
CHR Corporate Human Resources

# If not attended to, can be escalated to WBIC

The Complainant has the option to write directly to the Chairperson of the Audit Committee at
@ [email protected].

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