Nomination and Remuneration Policy

<h4>CSR Policy</h4>&nbsp;<div class="wp-block-group"><div class="wp-block-group__inner-container is-layout-flow wp-block-group-is-layout-flow">Preamble:Anupam Rasayan India Limited (“Company”) constituted a CSR Committee which in exercise of its authority and discharge of its responsibility formulated the Corporate Social Responsibility Policy (“Policy”) in consonance with Section 135, Companies Act, 2013, as amended (the “Act”) on CSR and in accordance with the Companies (Corporate Social Responsibility) Rules, 2014, as amended (“Rules”). It shall apply to all CSR Projects/ Programmes undertaken by the Company as per liberal interpretation of activities listed in Schedule VII of the Act, within the geographical limits of India, preferably towards the benefits of marginalised, disadvantaged, poor and deprived sections of the community and the sustainable environment. Capitalized terms used in this Policy and not defined herein shall have the meaning as ascribed to them under the Act.The CSR activities which may be undertaken shall be as per the Schedule VII of the Act as may be amended, modified from time to time and all other provisions in respect of the budget and compliances shall be as per the Act as may be amended, modified from time to time.Vision Statement &amp; Objectives:<ul class="text-justify"><li>The Company aspires to be a responsible corporate citizen, by contributing to nation building through CSR Projects/ Programmes, in true letter and spirit, as enshrined in the Act.</li><li>The Policy, which has been formulated in alignment with the vision of the Company, lays down guidelines and mechanisms to be adopted by the Company in order to carry out CSR Projects/ Programmes, as the Company intends to dedicate a percentage of the Company’s profit to social projects.</li><li>All CSR interventions will be conceived and implemented through a focused approach towards target beneficiaries for generating maximum impact.</li><li>CSR initiatives of the Company will be carried out in partnership with credible implementing agencies and by the Company itself too.</li><li>Setting up appropriate procedure and reporting mechanisms to ensure implementation of CSR initiatives.</li></ul>CSR Budget<ul><li class="text-justify">The Board of the Company will ensure that in each financial Year (FY), at least two percent (2%) of the average net profits of the Company (calculated as per prescribed guidelines under the Act) accrued during the three immediately preceding FYs is spent on CSR projects/ programmes.</li><li class="text-justify">In the event that the amount indicated above is not spent in its entirety in that FY, the reasons thereof will be outlined as is required under the Act.</li><li class="text-justify">Projects/ Programmes will be identified and budgets will be allocated for such projects/ programmes through a process incorporating identification of suitable implementation agencies, need assessment (as and where required) and clear outlining of the desired outcomes from the projects.</li><li class="text-justify">An illustrative list of activities and projects under Schedule VII of the Act for investing/expending in CSR initiatives to be undertaken by the Company are as below. Additionally, the Company may also undertake any other projects as may be provided in Schedule VII amended from time to time.<ul class="text-justify"><li>Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swach Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water;</li><li>Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects;</li><li>Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;</li><li>Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga;</li><li>Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional art and handicrafts;</li><li>Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;</li><li>Training to promote rural sports, nationally recognised sports, Paralympic sports and Olympic sports;</li><li>Contribution to the prime minister’s national relief fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the central govt. for socio economic development and relief and welfare of the schedule caste, tribes, other backward classes, minorities and women;</li><li>Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and contributions to public funded Universities; Indian Institute of Technology (IITs), National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE), Department of Biotechnology (DBT), Department of Science and Technology (DST), Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH), Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organisation (DRDO), Indian Council of Agricultural Research (ICAR), Indian Council of Medical Research (ICMR) and Council of Scientific and Industrial Research (CSIR), engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).</li><li>Rural development projects;</li><li>Slum area development; Explanation- For the purposes of this item, the term `slum area’ shall mean any area declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force.</li><li>Disaster management, including relief, rehabilitation and reconstruction activities.</li><li>Any other projects or activities approved by the Central Government pursuant to Section 135 of the Act, from time to time. Keeping in view of the spread of the novel COVID-2019 in India, spending of CSR funds for various activities related to COVID-2019 is an eligible CSR activity.</li></ul></li></ul>Further, the Company shall give preference to the local area and areas around it where it operates, for spending the amount earmarked for CSR activitiesIn the event where the Company makes any surplus or profit from pursuing its CSR projects/ programmes, these will not form part of the business profit (but will, instead, be carried forward to the following year/s as part of either the CSR corpus or as a supplement to the CSR budget.)For all contributions received from other companies/sources towards the CSR Corpus/Budget, the Company will claim CSR expenditure only for funds that are provided from its own resources.Planning and Implementation:The operations of the CSR activities of the Company and the Policy shall be overseen by the CSR Committee.The CSR activities shall be in the form of Projects/ Programmes, which will as far as possible, entail the following components:<ul><li>Need Based Assessment/ Baseline Survey/ Study where considered necessary/ feasible</li><li>Identification of specific &amp; measurable objectives/ goals in identified sectors and geographies</li><li>Identification of timelines</li><li>Annual financial allocation wherever possible</li><li>Identification of beneficiaries</li><li>Identification of milestones for complete duration of the project if possible</li><li>Preparation and signing of agreement with implementing agencies</li><li>Periodic reviews and monitoring</li><li>Evaluation &amp; assessment</li></ul>Opportunities for complementing/ supplementing Government Initiatives/ programmes will be explored.The Company would assign priority to projects/ programmes of medium (1-3 years) or longer duration (more than 3 years) in order to ensure emphasis on long term outcomes/ impacts.The Company will lay emphasis on the sustainability of its projects/ programmes to ensure they remain relevant and viable even upon disengagement at the end of the project period.The Company will explore possibilities for collaborating/ co-operating with other Corporates/ National/ Multi-National/ Bi-lateral International Agencies in order to synergies its efforts and increase both financial resources as well as outcomes and impact.The Company may also consider participating in larger Projects/ Programmes where more than one Corporate/ National/ Multi-lateral/ Bi-lateral/ International Agency is involved.The Company will endeavour at all the times to build and develop the skills of its CSR team and enhance levels of CSR awareness within the organisation.The Company will also endeavour to build and develop the skills of the implementing agency that it engages whenever necessary.Monitoring and EvaluationA comprehensive Monitoring and Evaluation mechanism will be devised by the Company to ensure that the CSR process functions as mandated by the Act and the Rules, ensuring that all Projects/ Programmes are duly implemented as budgeted. This will be done on the basis of the following:<ul><li>Allocation of a separate budget for setting up and running the monitoring system;</li><li>Installation of human architecture that can work together to ensure a firm check on speeds and the actual implementation of activities as planned;</li><li>Release of funds only against valid utilisations.</li></ul>The CSR Committee will be responsible for monitoring approved projects/ programmes.The monitoring system devised by the Company will include:<ul><li>Regular field visits to Projects/ Programme site by designated teams;</li><li>Comprehensive documentation/ compilation of Field Reports;</li><li>Regular interaction with beneficiary communities to obtain feedback;</li><li>Monitoring of timely fund utilisation to ensure that Projects/ Programmes as budgeted are actually carried out and/ or</li><li>Any other activity that the CSR Committee may deem necessary in the larger interest of its CSR initiatives.</li></ul>Impact Assessment/ Evaluation of CSRIn order to assess the impact of its CSR Projects and Programmes, maximise outcomes and build-in sustainability, scalability and replicability, the Company shall ensure that the projects/ Programmes undergo concurrent and final evaluation.DocumentationMeticulous documentation of projects/ programmes is the only way to ensure that progress is continuously tracked, course corrections are provided, lessons learnt and objective feedback received.Comprehensive documentation would include – printed material, audio recordings, video recordings etc. if any. This would also be of great value to the Company in brand building, market positioning, enhancing its competitive advantage and embedding CSR values within the organisation.Accounting &amp; AuditingThe Company will follow the Accounting and Auditing Guidance Note/ Standards duly approved by the Ministry of Corporate Affairs, Government of India.DisclosureThe Company shall comply with Sections 135 (2), 135(4)(1) and 134 (3) (o) of the Act thereby ensuring that it makes a full disclosure of its CSR Policy, Strategy, Projects/ Programmes, Activities, monitoring mechanism, Implementing Agencies, Expenditure details as well as the composition of the CSR Committee of the Board, as required under the Act.Review MechanismThe Policy shall be renewed As and when required by the CSR committee subject to the approval of board of directors but will, at all times be subject to the applicable laws. The policy has been last reviewed on 30th November, 2020.InterpretationIn case of any conflict between the provisions of this Policy and provisions of any applicable law, the provisions of the applicable law shall prevail over this Policy. Any subsequent amendments/modifications in the provisions of applicable law shall automatically apply to this Policy</div></div>

CSR Policy

<h4 class="wp-block-heading">Vigil Mechanism/Whistle Blower Mechanism Policy</h4><ol><li>PREAMBLE &nbsp;Anupam Rasayan India Limited (the “Company”) is a public limited company incorporated under the Companies Act, 1956, as amended.<ul><li>Objectives &nbsp;The Company believes in the conduct of the affairs of is constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behaviour. In pursuit of the same, the Company encourages its employees to raise genuine concern about any malpractices in the work place without fear of retaliation and will protect them from victimisation or dismissal.The Company has adopted a Code of Conduct for Directors and Senior Management Personnel, which lays the principles and standards which shall govern the actions of the directors and the senior management personnel as prevalent from time to time.The vigil mechanism aims to provide a channel to the directors and employees to report genuine concerns about unethical behaviour of any employee of the Company who shall promptly report to the management/Audit Committee when he/she becomes aware of any actual possible violation or an event of misconduct or act not in Company’s interest.The mechanism provides for adequate safeguards against victimisation of directors and employees to avail the mechanism and also provides for direct access to the chairman of the Audit Committee in appropriate cases.</li><li>Approval of the Board &nbsp;Accordingly, the Company establishes Vigil/Whistle Blower Mechanism formulating a policy for providing a framework for responsible and secure whistle blowing/vigil mechanism approved by the Board of Directors of the Company (‘the Board’) at its meeting held on 06th September 2014, which can be amended from time to time by the Audit Committee. The policy has been last amended on 30th November, 2020.</li></ul>Vigil /Whistle Blower Mechanism Policy (the “Policy”) shall be as approved and amended by the Board of the Company from time to time.</li><li>DEFINITIONS &nbsp;<ul><li>The Company shall mean Anupam Rasayan India Limited.</li><li>The Board shall mean the Board of Directors of the Company at any time consisting of the directors duly appointed and not ceased to be directors in terms of the Companies Act 2013, as amended (“Companies Act 2013”).</li><li>The Policy shall mean the Vigil/Whistle Blower Mechanism Policy as contained hereunder in this document.</li><li>The Audit Committee shall mean the Audit Committee of the Company established by the Board of Directors at any time consisting of the members duly appointed and not ceased to be members of such committee from time to time</li><li>Protected Disclosure shall mean a written communication of a concern made in good faith, which discloses or demonstrates information that may evidence an unethical or improper activity under “Scope” of the Policy with respect to the Company. It should be factual and not speculative and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern.</li><li>“Subject” means a person or group of persons against whom or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.</li><li>“Vigilance Officer”/ “Vigilance Committee” shall mean a person authorised by the Audit Committee to receive any Protected Disclosure and to maintain the records from Whistle Blowers and to place same before the Audit Committee for its disposal and informing the Whistle Blower the result thereof. Audit Committee shall act as the Vigilance Committee till such time a separate Vigilance Committee is appointed.</li><li>Whistle Blower(s) shall mean a director or an employee of the Company who makes Protected Disclosure under this Policy and may also be referred in this Policy as “Complainant”.</li></ul> &nbsp;</li><li>SCOPE &nbsp;The Policy is in addition to the Code of Conduct for the Directors and Senior Management Personnel and covers disclosures of any unethical, improper behaviour or malpractices and events which have taken place or suspected to have taken place involving:<ul><li>Breach of Company’s code of conduct</li><li>Breach of business integrity and ethics</li><li>Breach of terms and conditions of employment and rules thereof</li><li>International financial irregularities including fraud or suspected fraud</li><li>Violation of applicable laws to the Company</li><li>Gross wilful negligence causing substantial and specific danger to the health, safety and environment</li><li>Manipulation of Company’s data and records</li><li>Perforation of confidential/proprietary information</li><li>Gross wastage/ misappropriation of Company’s funds and/or assets</li><li>Any incidence of harassment of any employee of the company based on caste, colour, creed, religion, faith, disability, sexual orientation, national origin, age, marital status, sex, veteran or citizenship or other characteristics protected by law.</li><li>Any incidence of harassment of any employee of the company based on caste, colour, creed, religion, faith, disability, sexual orientation, national origin, age, marital status, sex, veteran or citizenship or other characteristics protected by law.</li><li>Any incidence of sexual harassment directed towards a person whether directly or indirectly in form of – physical contact and advances, offensive language, demand or request for sexual favours, sexually coloured remarks and or bawdy humour, showing any pornographic material, any other unwelcome physical, verbal or nonverbal conduct of a sexual nature.</li><li>Instances of leak of Unpublished Price Sensitive Information (UPSI)</li><li>Any other unethical or improper conduct.</li></ul> &nbsp;All the directors and employees of the Company are eligible to make Protected Disclosure under the Policy in relation to the matters concerning the Company and, in any matters, as laid in above paragraph. Further, the Company has established a separate prevention of sexual harassment committee as per the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and any rules made thereunder, each as amended.</li><li>PROCEDURE &nbsp;All the Protected Disclosures should be reported in writing by the Complainant as soon as possible, not later than 30 days after the Whistle Blower becomes aware of the same and should either be typed or written in legible handwriting either in English, Hindi or Gujarati.The Protected Disclosure should be submitted under a covering letter signed by the Complainant in a closed and secured envelop to the Vigilance Officer or may be sent through email at grievances@anupamrasayan.com with the subject “Protected Disclosure under Vigil Mechanism Policy”. The failure to super scribe the complaint as “Protected Disclosure under Vigil Mechanism” shall not relieve the Vigilance Officer from his/her duty to treat such a complaint as Protected Disclosure.All Protected Disclosure should be addressed to the Vigilance Officer of the Company or to the Managing Director in absence of Vigilance Officer or to the chairperson of the Audit Committee.In order to protect the identity of the Complainant, the Vigilance Officer shall not issue any acknowledgement to the Complainant and they are advised neither to write their name/address on the envelope nor enter into any further correspondence with the Vigilance Officer. Anonymous disclosure shall not be entertained by the Vigilance Officer, however, it shall be the duty and responsibility of the Vigilance Officer/Vigilance Committee, to protect the identity of the Whistle Blower/Complainant.On receipt of the Protected Disclosure, the Vigilance Officer shall detach the covering letter bearing the identity of the Whistle Blower and process only the Protected Disclosure.</li><li>INVESTIGATION &nbsp;All Protected Disclosure under this Policy will be recorded and thoroughly investigated. The Vigilance Officer will carry out an investigation either himself/herself or by involving any other officer of the Company at the advice of the Vigilance Committee or through an outside agency before presenting report of the matter to the Vigilance Committee.The Audit/ Vigilance Committee if deems fit, may call for further information or particulars from the Complainant and at its discretion, consider involving any other additional officers of the Company or outside agency for the purpose of investigation.The investigation by itself would not tantamount to an accusation and is to be treated as a neutral fact-finding process. The investigation shall be completed normally within 60 days of the receipt of the Protected Disclosure and is extendable by such period as the Audit Committee deems fit.Any member of the Vigilance/Audit Committee or other officer having any conflict of interest with the matter shall disclose his/her concern forthwith and shall not deal with the matter.</li><li>DECISION AND REPORTING &nbsp;If an investigation leads to a conclusion that an improper or unethical act has been committed, the chairperson of the Audit Committee shall recommend to the Board of the Company to take such disciplinary or corrective action as it may deem fit. Any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures. A report with number of complaints received under the Policy and their outcome shall be placed before the Audit Committee and the Board. A Complainant who makes false allegations of unethical &amp; improper practices or about alleged wrongful conduct of the Subject to the Vigilance Officer or the Audit Committee shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.The company may also opt to reward the Whistle Blower, based on merits of the case.</li><li>CONFIDENTIALITY &nbsp;The Complainant, Vigilance Officer, members of the Audit Committee, the Subject and everybody involved in the process shall, maintain confidentiality of all matters under this Policy, discuss only to the extent or with those persons as required under this Policy for completing the process of investigations and keep the papers in safe custody.</li><li>PROTECTION &nbsp;No unfair treatment will be meted out to a Whistle Blower by virtue of his / her having reported a Protected Disclosure under this Policy. Adequate safeguards against victimization of Complainants shall be provided. The Company will take to minimize difficulties which the Whistle Blower may experience as from making the Protected Disclosure.The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. Any other employee assisting in the said investigation shall also be protected to the same extent as the Whistle Blower.</li><li>DISQUALIFICATIONS &nbsp;While it will be ensured that genuine Whistle Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action.Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle Blower knowing it to be false or bogus or with a mala fide intention.Whistle Blowers, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious, shall be liable to be prosecuted.</li><li>ACCESS TO CHAIRPERSON OF THE AUDIT COMMITTEE &nbsp;The Whistle Blower shall have right to access chairperson of the Audit Committee directly in appropriate or exceptional cases and the chairperson of the Audit committee is authorised to prescribe suitable directions in this regard.</li><li>COMMUNICATION &nbsp;Directors and employees shall be informed of the Policy and contact details of the Vigilance Officer by publishing on the notice board as soon as practicable from the date of its first approval. Further, this Policy shall be disseminated on the website of the Company. In addition, the details of establishment of vigil mechanism/whistle blower policy and affirmation that no personnel have been denied access to the Audit Committee, shall be included in the annual report of the Company.</li><li>RETENTION OF DOCUMENTS &nbsp;All protected disclosures in writing or documented along with the results of investigation relating thereto, shall be retained by for a period of 5 (five) years or such other period as specified by any other law in force, whichever is more.</li><li>AMENDMENT &nbsp;The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever and no such amendment or modification will be binding on the directors and employees unless the same is communicated in the manner described as above.</li></ol>* Mr. Anand Desai, Managing Director of the Company is appointed as the Vigilance Officer of the Company by the Audit Committee.

Vigil Mechanism/ Whistle Blower Mechanism Policy

Risk Assessment & Management Policy

<h4>MATERIALITY POLICIES</h4><ul><li>Identification of material companies to be disclosed as Group Companies;</li><li>Identification of ‘material’ litigation (excluding disciplinary actions against the promoters, criminal proceedings, statutory/regulatory actions and taxation matters); and</li><li>Identification of ‘material’ outstanding dues to creditors.</li><li>Identification of material companies to be disclosed as group companies &nbsp;&nbsp;Requirement:As per the requirements of the SEBI ICDR Regulations, group companies include such companies (other than the subsidiaries, if any, and the promoter) with which there were related party transactions, during the period for which financial information is disclosed in the Issue Document(s), as covered under Ind AS 24, and also other companies as considered material by the board of the issuer.The policy on identification of material companies to be disclosed as group companies (other than those covered under Ind AS 24), as below, shall be disclosed in the Issue Documents.Policy on materiality:For the purpose of disclosure in the Issue Documents, a company shall be considered material and will be disclosed as a ‘Group Company’ in the Issue Documents if it is a member of the Promoter Group (other than the corporate Promoter) and has entered into one or more transactions with the Company during the period for which financial information is disclosed in the Issue Document(s) and individually or in the aggregate, exceed 10% of the total consolidated revenue of the Company for such period.</li><li>Identification of ‘material’ litigation (excluding disciplinary actions against the promoters, criminal proceedings, statutory/regulatory actions and taxation matters) &nbsp;&nbsp;Requirement:As per the requirements of SEBI ICDR Regulations, the Company shall disclose the following outstanding litigation involving the Company, its directors, promoters or subsidiaries (collectively “Relevant Parties”):<ul><li class="text-justify">All criminal proceedings;</li><li class="text-justify">All actions by regulatory authorities and statutory authorities;</li><li class="text-justify">Disciplinary action including penalty imposed by SEBI or stock exchanges against the promoters in the last five financial years including outstanding action;</li><li class="text-justify">Claims related to direct and indirect taxes, in a consolidated manner, giving the number of cases and total amount; and</li><li class="text-justify">Other pending litigations – As per policy of materiality defined by the board of directors of the Company and disclosed in the Issue Documents.</li></ul>Further, as per the requirements of SEBI ICDR Regulations, the Company shall also disclose such outstanding litigation involving the group companies which has a material impact on the Company.Policy on materiality:Other than litigations mentioned in points (i) to (iv) above, any other pending litigation involving the Relevant Parties would be considered ‘material’ for the purpose of disclosure in the Issue Documents, if:<ul><li class="text-justify">the monetary amount of claim by or against the Relevant Parties in any such pending proceeding is in excess of 1% of the total revenue of the Company, as per the last full year restated financial statements included in the Issue Documents; or</li><li class="text-justify">an outcome in any such litigation would materially and adversely affect the Company’s business, prospects, operations, financial position or reputation, irrespective of the amount involved in such litigation.</li></ul></li><li>Identification of ‘Material’ Outstanding dues to Creditors &nbsp;&nbsp;Requirement:As per the requirements of the SEBI ICDR Regulations, the Company shall make relevant disclosures in the Issue Documents and on the website of the Company for outstanding dues to creditors as follows:<ul><li class="text-justify">Based on the policy on materiality defined by the board of directors of the Company, details of the creditors which include the consolidated number of creditors and the aggregate amount involved, will be disclosed in the Issue Documents;</li><li class="text-justify">Consolidated information on outstanding dues to micro, small and medium enterprises and other creditors, separately giving details of number of cases and amount involved will be disclosed in the Issue Documents; and</li><li class="text-justify">Complete details about outstanding dues to material creditors along with the name and amount involved for each such material creditor shall be disclosed on the website of the Company with a web link thereto in the Issue Documents.</li></ul>Policy on materiality:For identification of material creditors, a creditor of the Company shall be considered to be material for the purpose of disclosure in the Issue Documents, if amounts due to such creditor exceeds 5% of the total consolidated trade payables as at the end of the latest period included in the restated financial statements included in the Issue Documents.</li></ul>

Materiality Policies

<h4 class="wp-block-heading">Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Code”)</h4>In pursuance to the Regulation 8(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time (“Insider Trading Regulations”), it is required that the board of directors of every listed company shall formulate a code of practices and procedures for fair disclosure of unpublished price sensitive information.Unpublished Price Sensitive Information<ul><li>Anupam Rasayan India Limited® (“Company“) shall promptly disclose unpublished price sensitive information that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available.</li><li>The unpublished price sensitive information (“UPSI“) shall be uniform and universally disseminated and due care will be taken to avoid selective disclosure.</li><li>In case if the UPSI that gets disclosed selectively, inadvertently or otherwise, prompt steps shall be taken to make such information generally available.</li></ul>Designation and Role of Chief Investor Relations Officer<ul><li>The Chief Financial Officer of the Company shall be the Chief Investor Relations Officer (“CIRO”) for the purpose of the Code. The CIRO shall be responsible for dissemination of information and disclosure of UPSI and also responding to the queries on news reports and requests for verification of market rumours by regulatory authorities.</li><li>In the temporary absence of the CIRO for any reason whatsoever, the managing director of the Company shall nominate any other official of the Company to be responsible for dissemination of information and disclosure of UPSI.</li></ul>General obligations for preservation and disclosure of UPSI<ul><li>All UPSI shall be handled on a need to know basis and in accordance with the provisions of the Regulations and any other applicable codes, policies and procedures of the Company.</li><li>It is clarified that information to be termed UPSI should be specific and intended to be generally made available at a point of time to ensure it does not lead to creation of a false market in securities. For the purpose of disclosure, the CIRO may consult such officials within the Company to ensure the correctness and credibility of the UPSI. The CIRO shall authorise disclosure or dissemination of UPSI (1) by way of intimation to the stock exchanges, such that further disclosure can be made from the stock exchange websites; (2) on the official website to ensure official confirmation and documentation; and (3) in any other manner as may be decided by the CIRO to facilitate uniform and universal dissemination of UPSI.</li><li>All communications of UPSI with the stock exchange shall be approved by the CIRO and communicated through appropriate personnel under his direction.</li><li>The CIRO shall also be responsible for overseeing the contents of UPSI to be posted on the website of Company for the purposes of this Code and shall give appropriate directions for the publication of the same. No other person shall be authorised to post any UPSI in the absence of any directions from the CIRO.</li><li>Information disclosure/ dissemination should normally be approved in advance by the CIRO. If the information is accidentally disclosed without prior approval, the person responsible must inform the CIRO immediately, even if the information is not considered price sensitive and if required, the CIRO shall take all reasonable steps to rectify the same.</li></ul>Sharing of information with analysts and research personnel<ul><li>The Company shall ensure that any information shared with analysts and research personnel is not UPSI and is generally available. Alternatively, the information shared as above shall simultaneously be made public.</li><li>The CIRO shall also develop best practices to make transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the official website to ensure official confirmation and documentation of disclosures made.</li></ul>Responding to Market Rumour’sThe CIRO shall ensure that appropriate and fair responses are provided to queries on news reports and requests for verification of market rumours by regulatory authorities.Legitimate PurposeThe UPSI can be shared by an Insider for Legitimate purposes as per its “Policy for determination of Legitimate Purposes” (Annexure A), provided that such sharing has not been carried out to evade or circumvent the prohibitions of these regulations.Note: Words not defined herein shall have the meaning as per the Insider Trading Regulations as amended from time to time.<hr>Annexure APolicy for Determination of Legitimate Purposes IntroductionThis “Policy for Determination of Legitimate Purposes” hereinafter referred to as the “Policy” is prepared in accordance with Regulation 3(2A) of SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2018.ObjectiveThe objective of this policy is to identify ‘Legitimate Purposes’ for performance of duties or discharge of legal obligations, which will be considered as exception for procuring UPSI relating to the Company. The assessment of whether sharing of UPSI for a particular instance would tantamount to ‘legitimate purpose’ would depend on the specific facts and circumstances of each case. Accordingly, this Policy only sets out the principles that should be considered while assessing if the purpose for which UPSI is proposed to be shared is “legitimate”. Primarily, the following factors should be considered to determine the legitimate purpose:<ul><li>whether sharing of such information is in the ordinary course of business of the Company;</li><li>whether information is sought to be shared to evade or circumvent the prohibitions of the Insider Trading Regulations;</li><li>whether sharing the information is in the best interests of the Company or in furtherance of a genuine commercial purpose;</li><li>whether the information is required to be shared for enabling the Company to discharge its legal obligations;</li><li>whether the nature of information being shared is commensurate to the purpose for which access if sought to be provided to the recipient.</li></ul>It is clarified that in the event there exist multiple purposes for sharing UPSI, each purpose will be evaluated on its own merits, in line with the aforementioned principles.Digital DatabaseA structured digital database shall be maintained containing the nature of UPSI and the names of such persons or entities with whom information is shared or who has shared such information along with the Permanent Account Number or any other identifier authorized by law where Permanent Account Number is not available. Such databases shall be maintained with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database.Restrictions on Communication and Trading by InsidersThe Company shall inform the recipient of UPSI, by way of written intimation and/or contractual agreement, such as confidentiality agreement, that (i) the information being shared is UPSI and that the Company is the exclusive owner of such UPSI; (ii) upon receipt of UPSI, the recipient would be deemed to be an Insider and subject to the provisions of the Insider Trading Regulations, (iii) the recipient must maintain confidentiality of the UPSI at all times, (iv) the recipient may use the UPSI only for the approved purposes for which it was disclosed; (v) the recipient should provide a written undertaking that he/she/it shall not undertake trades in the securities of the Company while in possession of the UPSI; and (vi) the recipient must extend all co-operation to the Company, as may be required in this regard.Definitions“Legitimate Purposes” means sharing of UPSI in the ordinary course of business by an Insider with the following, provided that such sharing has not been carried out to evade or circumvent the prohibitions of these regulations:<ul><li>Company’s partners</li><li>Auditors, Accountancy firms, Legal advisors, Merchant Bankers, Consultants</li><li>Collaborators</li><li>Lenders</li><li>Customers</li><li>Suppliers</li><li>Any other advisors/consultants/partners</li></ul>Any other person with whom UPSI is shared Insider who is in receipt of UPSI pursuant to a “legitimate purpose” shall be considered as an “insider” for purpose of these regulations and due notice shall be given to such persons (Insiders) to maintain confidentiality of such unpublished price sensitive information in compliance with these regulations

Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Code”)

Insider Trading Code (“Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons and their Immediate Relatives”)

<h4 class="wp-block-heading">Document Preservation and Archival Policy</h4><figure class="table"><table border="1" cellpadding="5"><thead><tr><th>Contents</th><th>Page Nos.</th></tr></thead><tbody><tr><td>Preamble</td><td>1</td></tr><tr><td>Objective</td><td>1</td></tr><tr><td>Scope</td><td>1</td></tr><tr><td>Definitions</td><td>1-2</td></tr><tr><td>Classification</td><td>3</td></tr><tr><td>Mode of Preservation and Responsibility</td><td>3</td></tr><tr><td>Archival</td><td>3-4</td></tr><tr><td>General</td><td>4</td></tr><tr><td>Limitation</td><td>4</td></tr><tr><td>Amendments and Reviews</td><td>4</td></tr></tbody></table></figure>PREAMBLE&nbsp;The Board of Directors (“Board”) of Anupam Rasayan India Limited (the “Company”) has adopted this Document Preservation and Archival Policy (the “Policy”) pursuant to Regulation 9 and Regulation 30(8) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI LODR”) as amended from time to time.&nbsp;&nbsp;The said provisions require the listed companies to have a policy for preservation of documents, approved by their board of directors, classifying the documents in at least two categories as follows:&nbsp;<ol style="list-style-type:lower-latin;" type="a"><li class="text-justify">Documents whose preservation shall be permanent in nature;</li><li>Documents with preservation period of not less than eight years after completion of the relevant transactions.</li></ol>The Policy shall also be governed by any other laws and regulations as may be applicable to the Company.OBJECTIVEThis Policy inter alia provides for the Preservation of the Documents (defined hereinafter) so that such Documents should be kept no longer than the period necessary for the proper conduct of the Company’s business. The Policy shall cover all business Records (defined hereinafter) of the Company including written, printed and recorded matter and Electronic Forms (defined hereinafter) of Records.The Policy<ol><li class="text-justify">is formulated to manage the Company’s information in a structured manner, to retain information for as long as it has a business purpose, to satisfy statutory or regulatory requirements, and to protect information which is vital to the Company; and</li><li>outlines the methodology for the archival of material information/ material events that have been disclosed to the stock exchanges where securities of the Company have been listed.</li></ol>In the event of any inconsistency between this Policy and SEBI LODR, or any other Applicable Law, the SEBI LODR as amended from time to time, and/or the Applicable Law (defined hereinafter) will prevail over this Policy.SCOPEThis Policy is applicable to all the departments of the Company. It ensures that the Company maintains both electronic and physical documents as per various statutory requirements and are subject to the same degree of confidentiality and care.This Policy covers all information created, received, managed and retained by the Company (including all its units and division) in hard copy and electronic records in connection with the business of the Company including originals and copies of correspondence, recordings, work papers, video tapes, photographs, product specifications, reports etc.DEFINITIONS“Act” shall mean the Companies Act, 2013 read with the rules framed thereunder and each as amended from time to time;“Applicable Law” means any law, regulations, rules, circulars, guidelines or standards applicable to the Company under which any guidelines/ provisions with regard to the Preservation and Archival of the Documents has been prescribed.“Archival” means accumulation/storage of historical records on server/network or at a physical place.“Board” shall mean the collective body of the directors of the Company constituted from time to time in line with the provisions of section 2 (10) the Act and Regulation 2(1)(d) of SEBI LODR;“Company” Anupam Rasayan India Limited has been referred to as the Company in this Policy;“Current Document(s)” means any document that still has an ongoing relevance with reference to any ongoing litigation, proceedings, complaint, dispute, contract or any like matter.“Document(s)” or “Records” means a piece of written, printed, or electronic matter that provides information, evidence or records or serves as an official record of the Company and includes any summons, notice, requisition, order, declaration, forms or registers, agreements, notices, advertisements, requisitions, orders, declarations, correspondences, minutes, indices, registers and/or any other record, required under or in order to comply with the requirements of any Applicable Law, whether issued, sent, received or kept in pursuance of the Act or under any other law for the time being in force or otherwise, maintained on paper or in Electronic Form and does not include multiple or identical copies.“Electronic Form” means any contemporaneous electronic device such as computer, laptop, compact disc, floppy disc, space on electronic cloud, or any other form of storage and retrieval device, considered feasible, whether the same is in possession or control of the Company, or otherwise the Company has control over or access to it.“Electronic Record(s)” means the electronic record as defined under section 2 (1)(t) of the Information Technology Act, 2000.“Maintenance” means keeping the Documents, either physically or in Electronic Form.“Policy” means this Document Preservation and Archival Policy adopted by the Board and as may be amended from time to time.“Preservation” / to “Preserve” means to keep in good order and to prevent from being altered, damaged or destroyed.“SEBI LODR” shall mean the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 as may be amended from time to time and any circulars, notifications or clarifications issued thereunder from time to time by the Securities and Exchange Board of India.CLASSIFICATIONThe Board of Directors have classified the Documents to be retained and Preserved as mentioned hereunder, in the manner detailed under Annexure<ol style="list-style-type:decimal;" type="1"><li class="text-justify">&nbsp;Permanent Records: Permanent Records are the Records which are of strategic importance and vital to the organization. These Records and Documents shall be kept permanently, such as Certificate of Incorporation/ Certificate of Change of Name, Memorandum and Articles of Association, Minutes of meetings of the members of the Company, the Board and its committees, statutory Registers which are required to be permanently maintained under the Act or Applicable Laws, registration certificate of trademark, patent and copyright and any other document which are required to be permanently maintained under the Act or Applicable Laws etc.</li><li class="text-justify">Other Records: Such Records as are required to be maintained for minimum 8 (eight) years on account of statutory considerations and are important from the perspective of financial record keeping, e.g. books of accounts, vouchers, financial statements, invoices and all contracts, agreements, deeds which are the basis &nbsp;for the financial transactions, annual returns, attendance sheet and agenda papers of Board and Committee meeting, statutory Registers which are required to be maintained for not less than 8 (eight) under the Act or Applicable Laws etc. should be preserved for minimum 8 (eight) years from the closure of the contract and whereas, any contract, agreement or deed shall be required to be preserved for minimum 8 (eight) years or as per the terms of such contract, whichever is higher.</li><li class="text-justify">Temporary Records: Temporary Records are the Records which are required to be retained as long as it has a business purpose or are required to be retained as per relevant business regulations e.g. operational documents such as rating letters, research reports, working papers, etc.The above given list of the Documents is enumerative list which includes but not limited to the aforementioned documents.The Documents concerning other routine matters and having substantial long‐lasting consequences shall be Preserved by all concerned as may be decided by the Managing Director/CEO, CFO, and/or the respective divisional Heads of the Departments of the Company based upon usefulness and necessity.</li></ol>MODE OF PRESERVATION &amp; RESPONSIBILITYThe Documents may be preserved in physical form or Electronic Form. The Preservation of Documents should be such as to ensure that there is no tampering, alteration, destruction or anything which endangers the content, authenticity, utility or accessibility of the Documents. The CEO/ CFO and the divisional Heads of the Departments of the Company shall be responsible for maintenance of the Documents in their respective division/department taking into account this Policy prescribing the minimum period for maintenance of Documents and shall take decision to retain and Preserve or destroy the Documents pertaining to their division/department keeping in view ongoing or anticipated litigation(s), if any or any other statutory requirement.ARCHIVAL<ol><li class="text-justify">Archival Policy for submissions made to Stock Exchanges:The Company shall also disclose on its website all such events or information which has been disclosed to the stock exchange(s) under Regulation 30(8) of the SEBI LODR, where the securities of the Company are listed. Documents submitted to the stock exchanges for dissemination to the stakeholders will be retained on the website of the Company for a minimum period of 5 (five) years.The Documents may thereafter be shifted to the archive section of the website, where it shall be retained for period of one (1) year or such period as may be decided by the management of the Company from time to time.</li><li>Archival Policy for other information hosted on the website pursuant to applicable legislations:All other Documents or information which are hosted on the website of the Company pursuant to any Applicable Law to the Company from time to time, shall be retained on the website for such minimum period of time as may be specified under such Applicable Law. The Documents may thereafter be shifted to the archive section of the website, where it shall be retained for such period as may be determined by the management of the Company.</li><li class="text-justify">Archival Policy for other information voluntarily hosted on the website:All the Documents or information hosted on the website of the Company voluntarily by the management, shall be retained on the website/ archive section of the website for such period of time as may deem fit at the absolute discretion of the management of the Company.</li></ol>GENERAL:The Documents may be archived in physical and/or Electronic Form as the Board of the Company may deem fit. The Documents archived in Electronic Form shall be backed up automatically on a periodic basis. This Policy shall be hosted on website of the Company.LIMITATION:In the event of any conflict between the provisions of this Policy and of the Act or SEBI LODR or Applicable Laws or any amendments thereto, the provisions of the Act or SEBI LODR or Applicable Laws shall prevail over this Policy.AMENDMENTS AND REVIEWS:This Policy has been adopted by the Board and the Board may review and amend the Policy, as and when required to do so due to regulatory changes or under any other circumstances necessitating revision to the Policy.___________________________________Approved on March 31, 2021 and Amended on September 03, 2022

Document Preservation and Archival Policy

<h4>Familiarization Program for Independent Directors</h4><ol><li>OBJECTIVEAnupam Rasayan India Limited (“Company”) believes that a board well informed and having proper familiarization with the Company will contribute positively to the Company. The familiarization programs which may be conducted for Independent Directors from time to time, would aim to provide overall understanding about the Company’s business model, operations, strategies, industry in which the Company operates and other aspects of the business along with roles, responsibilities of the Independent Directors.</li><li>FAMILIARIZATION PROCESSAt the time of joining new Independent Directors are provided with the overview of the Company’s business model, operations, infrastructure, strategies, organizational structure, industry it operates in etc. by the senior management in the form of presentations and discussions. Roles and responsibilities are explained to the Independent Directors. Formal appointment letters outlining roles and responsibilities of Independent Director are provided. Apart from the appointment letters, Independent Directors are provided with policies of the Company such as:<ul><li>&nbsp;<ul><li class="text-justify">Code of conduct for Independent Directors</li><li class="text-justify">Code of conduct for board and senior management team</li><li class="text-justify">Memorandum and Articles of the Company</li><li class="text-justify">Code or practices &amp; procedures for fair disclosure of UPSI</li><li class="text-justify">Code of Conduct-Regulate, Monitor &amp; Report Trading-Designated Persons, Immediate Relatives</li><li class="text-justify">Copy of Directors and officers’ liability and Company insurance policy</li></ul></li></ul>&nbsp;The Company keeps all its directors updated about the operations and key developments inside the Company which may have impacts on the operations of the Company. The Company follows the practice of recommending appointment of Independent Directors to the Company on basis of their experience, expertise, understanding and knowledge of the industry, management, corporate governance, corporate laws etc.To keep the directors updated about the business, the Company will provide opportunities to visit the facilities of the Company.&nbsp;</li><li>DISCLOSURE AND REVIEW OF THE PROGRAMThis policy shall be uploaded on the website of the Company. The board of directors of the Company may review this program and may make changes as maybe required.</li></ol>

Familiarization Program for Independent Directors

Policy on Related Party Transactions and Material Subsidiaries

<h4>DIVIDEND DISTRIBUTION POLICY</h4>This policy shall be termed as ‘Dividend Distribution Policy’ (the “Policy”) of Anupam Rasayan India Limited (the “Company”).<ol><li>OBJECTIVE OF THE POLICYRecognising the need to lay down a broad framework for deciding the matters pertaining to distribution of dividend and/or retaining the profits of the Company, the Board of Directors the Company (the “Board”) has laid down and adopted this policy.The Policy reflects the intent of the Company to reward its shareholders by sharing a portion of its profits after retaining sufficient funds for the growth of the Company. The Policy sets out the circumstances and different factors for consideration by the Board at the time of taking such decisions.The Policy shall not apply to determination and declaration of dividend on preference shares as the same will be as per the terms of issue approved by the shareholders.</li><li>GENERAL POLICY ON DIVIDENDThe Board shall determine the dividend pay-out in a particular year after taking into consideration the operating and financial performance of the Company, the advice of executive management and other relevant factors. The Policy is not an alternative to the decision of the Board for recommending dividend, which is made every year after taking into consideration all the relevant circumstances enumerated hereunder or other factors as may be considered relevant by the Board.The Policy does not constitute a commitment regarding the future dividends of the Company, but only represents a general guidance regarding dividend policy.</li><li>CONSIDERATIONS RELEVANT FOR DECISION ON DIVIDENDThe Board shall consider the following, while taking decisions of a dividend pay-out during a particular year-<ul><li class="text-justify">Statutory requirements:The Company shall observe the relevant statutory requirements including transfer of a certain portion of the profits to any specific reserve(s), as may be applicable to the Company at the time of taking a decision with regard to declaration/recommendation of dividend or retention of profits.</li><li class="text-justify">Inadequacy of profits:If during any financial year the profits of the Company are inadequate, the Board may decide not to declare dividends for that financial year.</li><li class="text-justify">Contractual obligations:The decision regarding dividend pay-out shall take into consideration the restrictions and covenants contained in the agreements as may be entered into by the Company with financial institutions/other lenders of the Company from time to time.</li><li class="text-justify">Prudential requirements:The following strategic matters shall also be considered-<ul><li class="text-justify">to ascertain the needs for capital conservation and appreciation;</li><li class="text-justify">to build sufficient reserves of retained earnings;</li><li class="text-justify">to augment long term financial strength; and</li><li class="text-justify">to build a pool of internally generated funds to provide long-term resources as well as resource raising potential for the Company.&nbsp;</li></ul></li><li class="text-justify">Proposals for major capital expenditures, etc.:The Board should also take into consideration the need for replacement of capital assets, expansion and modernization or augmentation of capital stock, including any major capital expenditure proposals and the provision of depreciation on such new assets.</li><li class="text-justify">Expectations of Stakeholders:The Board, while considering the decision of dividend pay-out or retention of a certain amount or the entire profits of the Company for the year, shall, as far as possible, consider the expectations of the major stakeholders as also the small shareholders of the Company who generally expect a regular dividend pay-out.</li></ul></li><li>OTHER PARAMETERSIn addition to above parameters, the decision of dividend pay-out or retention of profits shall also be based on the following-<ul><li class="text-justify">Operating cash flow of the Company:If the Company cannot generate adequate operating cash flow, it may need to rely on outside funding to meet its financial obligations and sometimes to run the day-to-day operations. The Board should consider the same before taking its decision whether to declare dividend or retain its profits.</li><li class="text-justify">Taxation and other regulatory concerns:-Dividend distribution tax as may be applicable at the time of declaration of dividend.-Any restrictions on payment of dividends by virtue of any regulation as may be applicable to the Company at the time of declaration of dividend.</li><li class="text-justify">Macroeconomic conditions:Considering the state of the Country’s economy, the policy decisions that maybe formulated by the Government and other similar conditions prevailing in the international market which may have a bearing on or affect the business of the Company, the management may consider retaining a larger part of the profits to have sufficient reserves to meet unforeseen circumstances.</li></ul></li><li>PARAMETERS FOR VARIOUS CLASSES OF SHARES<ul><li class="text-justify">The factors and parameters for declaration of dividend to different class of shares of the Company shall be the same as stated above.</li><li class="text-justify">The payment of dividend shall be based on the respective rights attached to each class of shares as per their terms of issue.</li><li class="text-justify">Dividends shall be paid out of the Company’s distributable profits and/or free reserves and shall be allocated among the shareholders on a pro-rata basis according to the type and class of shares held.</li><li class="text-justify">Dividend when declared shall be first paid/apportioned to the preference shareholders of the Company as per the terms and conditions of their issue.&nbsp;</li></ul></li><li>UTILISATION OF RETAINED EARNINGSThe Company will endeavour to utilize the retained earnings for the business requirements including but not limited to working capital, investments, expansions, acquisitions, general corporate purposes, to meet contingencies etc. or any other permitted uses under the Companies Act, 2013.</li><li>MANNER OF DIVIDEND PAYOUTThe declaration and payment of dividends will be as per the laws and regulations applicable to the Company.</li><li>DISCLOSUREThe Policy shall be disclosed in the Annual report and on the website of the Company i.e. at <a target="_blank" rel="noopener noreferrer" href="https://www.anupamrasayan.com/">www.anupamrasayan.com</a> .</li><li>ADOPTIONThe Board of Directors (“Board”) of Anupam Rasayan India Limited (the “Company”) at its meeting held on March 31, 2021 approved and adopted the Dividend Distribution Policy(“Policy”) as required in terms of Regulation 43A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”).</li><li>APPLICABLE LAWSIn case the provisions of this Policy are in with the provisions of the applicable laws (including the provisions of the Companies Act, 2013 or rules framed thereunder each as amended and Listing Regulations as amended), the applicable law shall supersede the provisions of this Policy.</li><li>AMENDMENTThe Board of Directors may review the policy to give effect to any statutory amendments or otherwise. The amended Policy shall be placed on the website of the company immediately after its approval from the Board.</li></ol>

Dividend Distribution Policy

<h4>POLICY ON DISCLOSURE OF MATERIAL EVENTS AND INFORMATION</h4><ol><li>OBJECTIVEThe Board of Directors of Anupam Rasayan India Limited (the “Company”) has framed this Policy in accordance with the requirements of the Regulation 30 and Regulation 30A of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR Regulations”).The objective of the Policy is to determine materiality of events or information of the Company and to ensure that such information is adequately disseminated pursuant to the requirements of the Regulations and to provide an overall governance framework for such determination of materiality.Any regulatory changes /amendment to the LODR Regulations will, automatically, apply and this Policy shall be amended to that extent and the same need not require approval of the Board, shareholders, unless required by law.</li><li>DEFINITION<ul><li>&nbsp;<ul><li class="text-justify">“Act” shall mean the Companies Act, 2013 and the Rules framed there under, including any modifications, clarifications, circulars or re-enactment thereof.</li><li class="text-justify">“Board of Directors” or “Board” means the Board of Directors of Anupam Rasayan India Limited, as constituted from time to time.</li><li class="text-justify">“Company” means Anupam Rasayan India Limited.</li><li class="text-justify">“Compliance Officer” means Company Secretary of the Company designated as Compliance Officer pursuant to Regulation 6 of the LODR Regulations.</li><li class="text-justify">“Key Managerial Personnel” (KMP) means KMP as defined under the provisions of the Act as amended from time to time.</li><li class="text-justify">“Material Event” or “Material Information” shall mean such event or information as set out in this Policy or as may be determined in terms of Clause III of this Policy. In this Policy, the words, “material” and “materiality” shall be construed accordingly.</li><li class="text-justify">“Net Worth” shall have the meaning as defined in Section 2(57) of the Act;</li><li class="text-justify">“Policy” means Policy on Disclosure of Material Events and Information, as amended from time to time.</li><li class="text-justify">“LODR Regulations” means the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 including any modifications, clarifications, circulars or re-enactment thereof.</li><li class="text-justify">“Schedule” means Schedule III of the LODR Regulations.</li><li class="text-justify">“SEBI” means the Securities and Exchange Board of India;</li><li class="text-justify">“Stock Exchange(s)” means BSE Limited and the National Stock Exchange of India Limited, where the equity shares of the Company are listed;</li><li class="text-justify">“Turnover” shall have the meaning as defined under Section 2(91) of the Act;</li></ul></li></ul>&nbsp;Any other term not defined herein shall have the same meaning as defined in the Act, in the LODR Regulations, or any other applicable laws or regulations to the extent applicable to the Company and as amended from time to time.</li><li class="text-justify">EVENTS WHICH ARE DEEMED TO BE MATERIAL EVENTSThe Company shall disclose all such events which are specified in Para A of Part A of Schedule III of the LODR Regulations (as applicable from time to time) (“Para A Events”) without any application of the guidelines for materiality as specified in sub-regulation (2) of Regulation 30 of the LODR Regulations. Events or information specified in Para A of Part A of Schedule III, shall be deemed to be material.</li><li class="text-justify">EVENTS WHICH ARE DEPENDENT ON APPLICATION OF GUIDELINES FOR MATERIALITYThe Company shall disclose all such material events or information pertaining to itself or to its subsidiary(ies), specified in Para B of Part A of Schedule III of the LODR Regulations (“Para B Events”) subject to application of guidelines for materiality, as set out under the LODR Regulations.<ol><li class="text-justify">GUIDELINES FOR DETERMINING MATERIALITY OF EVENTS OR INFORMATION:<ol><li class="text-justify">Quantitative criteria:the omission of an event/ information whose value or the expected impact in terms of value, exceeds the lower of the following:<ul><li class="text-justify">2% of turnover, as per the last audited consolidated financial statements of the Company; or</li><li class="text-justify">2% of net worth, as per the last audited consolidated financial statements of the Company, except in case the arithmetic value of the net worth is negative; or</li><li class="text-justify">5% of the average of the absolute value of profit or loss after tax, as per the last three audited consolidated financial statements of the Company;</li></ul>If the average of absolute value of profit or loss is required to be considered by disregarding the ‘sign’ (positive or negative) that denotes such value, the said value / figure is required only for determining the threshold for ‘materiality’ of the event and not for any commercial consideration.</li><li class="text-justify">Qualitative criteria would mean an event/information:<ul><li class="text-justify">the omission of an event or information, which is likely to result in discontinuity or alteration of event or information already available publicly;</li><li class="text-justify">the omission of an event or information is likely to result in significant market reaction if the said omission came to light at a later date;</li><li class="text-justify">any other event/information may be treated as being material if in the opinion of the Board of directors of Company, the event / information is considered material.</li></ul></li></ol></li><li class="text-justify">GUIDELINES ON OCCURRENCE OF AN EVENT / INFORMATION:The occurrence of material events/information could be either emanating from within or outside the listed entity by the Company’s own accord or for reasons not in the hands of the Company. It can be categorized as under:<ol><li class="text-justify">depends upon the stage of discussion, negotiation or approval; and</li><li class="text-justify">in case of natural calamities disrupting operations etc., it would depend upon the timing when the Company became aware of the event/information.</li></ol></li><li>TIMELINE FOR DISCLOSURE:The Company shall disclose to the stock exchange(s) all events or information which are material in terms of the provisions of the LODR Regulations as soon as reasonably possible and in any case not later than the following:<ol><li class="text-justify">30 minutes from the closure of the meeting of the board of directors in which the decision pertaining to the event or information has been taken;</li><li class="text-justify">12 hours from the occurrence of the event or information, in case the event or information is emanating from within the Company;</li><li class="text-justify">24 hours from the occurrence of the event or information, in case the event or information is not emanating from within the Company.</li></ol>Further, disclosure with respect to events for which timelines have been specified in Part A of Schedule III of the LODR Regulations shall be made within such timelines.</li></ol></li><li>DISCLOSURES OF EVENTS OR INFORMATION<ul><li>&nbsp;<ul><li class="text-justify">The Company shall disclose to the stock exchange(s) all the events or information as specified in Clause 3 and 4 above, within such time as mentioned in the LODR Regulations.</li><li class="text-justify">The Company shall make disclosures updating material developments on a regular basis, till such time the event is resolved/closed, with relevant explanations.</li><li class="text-justify">All the above disclosures shall be hosted on the website of the Company for a minimum period of five years and thereafter archived as per the Archival Policy of the Company.</li><li class="text-justify">The Company shall disclose all events or information with respect to subsidiaries which are material for the Company (if any).</li><li class="text-justify">The Company shall provide specific and adequate reply to all queries raised by stock exchange(s) with respect to the events / information which are material.</li><li class="text-justify">In case where an event occurs or an information is available with the Company, which has not been indicated in Para A or Para B of Part A of Schedule III of LODR Regulations, but which may have material effect on it, the Company shall make adequate disclosures in regard/</li></ul></li></ul>&nbsp;</li><li>AUTHORITYThe Managing Director, Chief Executive Officer, Chief Financial Officer and Company Secretary of the Company are authorised individually or jointly for determining materiality of event/ information and shall ensure disclosures of the same to the stock exchange(s), subject to the provisions of this Policy.</li><li>AMENDMENTSThe Board may subject to the applicable laws amend any provision(s) or substitute any of the provision(s) with the new provision(s) or replace the Policy entirely with a new Policy. However, no such amendment or modification shall be inconsistent with the applicable provisions of any law for the time being in force.</li><li>SCOPE AND LIMITATIONIn the event of any conflict between the provisions of this Policy, the LODR Regulations, the Act, or any other statutory enactments, rules, the provisions of such LODR Regulations, the Act or statutory enactments, rules shall prevail over this Policy and the part(s) so repugnant, shall be deemed to be severed from the Policy and the rest of the Policy shall remain in force.</li><li>AUTHORITY TO AMEND THE POLICY:The Managing Director of the Company is authorised to finalize/ settle any matter or questions arising out of this Policy and is further authorised to amend the Policy from time to time. However, no such amendment or modification shall be inconsistent with the applicable provisions of any law for the time being in force.</li></ol>___________________________________Approved on on March 31, 2021 and last Amended on on November 07, 2023

Disclosure of Material Events Policy

<h4>Sustainability Policy</h4>&nbsp;The Sustainability Committee (the “Committee”) is a committee of the board of directors (the “Board”) of Anupam Rasayan India Limited (“Anupam”) formed by approval of the Board in its meeting held on December 27, 2021.Objective and Role of the Sustainability CommitteeThe Board has formed the Sustanibility Committee to meet the environment social and governance (“ESG”) and Sustanability goals of the Company in ever changing ESG environment and framework. Not only is it a core part of good governance in any organisation, but its role is also to integrate both the business and sustainability priorities so that the organisation is able to thrive. A Sustainability Committee is accountable for the strategy on sustainability and business’ performance.The Committee with respect to Anupam and its subsidiaries, shall oversee the roles and responsibilities as laid below:<ul class="text-justify"><li>development, implementation and monitoring of the policies, procedures, practices and strategies for ESG and sustainability goals;</li><li>implementation of processes to integrate and embed consideration of social, environment and economic related issues, risks and opportunities and other appropriate sustainability objectives into Anupam’s strategies, policies, procedures, practises and decision-making processes;</li><li>to ensure due consideration of risks, opportunities and potential performance improvement relating to social, environment and economic and sustainability matters;</li><li>communication and disclosure of Anupam’s social, environment, economic and other sustainability performance and processes by which Anupam identifies, assesses and manages ESG related and other sustainability risks and opportunities;</li><li>review of reporting and external communication practices including but not limited to assessments of materiality, ESG or Sustainability Report development and approach to analogous disclosure, media and social media campaigns and other written communication with stakeholders;</li><li>taking care of triple bottom line 3Ps i.e. People, Profit and Planet and other sustainability-based risks and opportunities and review and reporting thereof;</li><li>monitoring of the policies laid down by government in interest of communities and industries which can affect the sustainability goals of Anupam.</li><li>Review and report to the Board with respect to the consideration and integration of ESG and sustainability issues in the development of Anupam’s business strategy and financial planning</li><li>The Committee shall receive periodic reports from management regarding Anupam’s initiatives and opportunities to optimize its ESG and sustainability performance including the processes to reduce or substitute energy and water use, reduce emissions and waste and minimize land disturbance;</li><li>Consider and review the setting and performance against appropriate targets, benchmarking, procedures and reporting methods used by Anupam to measure its climate, safety, environmental and other relevant sustainability performance;</li><li>Consider and review third party reports on Anupam’s sustainability performance and peer sustainability performance;</li><li>Review Anupam’s enterprise risk management program relating to identifying, assessing and managing climate related risks, whether physical or transition related and in view of plausible future scenarios, as well as other sustainability related risks, and report to the Audit Committee;</li><li>The Committee shall review shareholder proposals relating to sustainability issues and provide a report to the Board;</li><li>Receive periodic reports from management relating to Anupam’s actions taken against the implementation of ESG objectives as well as the cost of such initiatives;</li><li>Perform any other activities consistent with this Mandate as the Committee or the Board deems necessary or appropriate;</li><li>Give due consideration to the laws and regulations as may be applicable on the Company from time to time.</li></ul>The structure, role and objectives of the Committee may be reviewed and amended by the Board as and when required.Meetings and Administrative Matters<ul class="text-justify"><li>At all meetings of the Committee every question shall be decided by a majority of the votes cast. In case of an equality of votes, the Chairperson of the meeting shall be entitled to a second or casting vote;</li><li>The Chairperson shall preside at all meetings of the Committee, unless the Chairperson is not present, in which case the members of the Committee present shall designate from among the members present the Chair for purposes of the meeting;</li><li>A quorum for meetings of the Committee shall be a majority of its members, and the rules for calling, holding, conducting and adjourning meetings of the Committee shall be the same as those governing the Board unless otherwise determined by the Committee or the Board;</li><li>The Committee shall meet at such times and with such frequency as the Committee may deem necessary to carry out its roles and responsibilities;</li><li>The Committee may invite such officers, directors and employees of Anupam as it may see fit from time to time to attend at meetings of the Committee and assist thereat in the discussion and consideration of the matters being considered by the Committee;</li><li>Minutes of the Committee will be recorded and maintained and to be circulated to the members of the Committee whether or not any member of the Committee had attended such meeting or otherwise made available at a subsequent meeting of the Committee; the minutes shall also be placed before the Board in its meeting;</li><li>The Committee may retain persons having special expertise and/or obtain independent professional advice to assist in fulfilling its responsibilities at the expense of Anupam.</li><li>Any issues arising from these meetings that bear on the relationship between the Board and management should be communicated to the Chair of the Board by the Chair of the Committee.</li></ul>Amendments to the PolicyThe Sustanability Committee is entitled to amend this policy including amendment or discontinuation of any strategies, policies or processes introduced in accordance with this policy; and any amendment in this Policy shall be placed before the Committee and shall be approved by majority votes.

Sustainability Policy

<h4 class="wp-block-heading">Grievance Redressal Policy</h4>OBJECTIVE &nbsp;Anupam Rasayan India Limited (“Company”) holds the fair and transparent approach while dealing with its stakeholders. The objective of this Grievance Redressal Mechanism (the “Policy”) is to address stakeholders’ grievances about any malpractices they have observed during their association with the Company which will also help in strengthening the association with them.SCOPEThis Policy shall apply to all the stakeholders of the Company that covers disclosures of any unethical, improper behaviour or malpractices and events which have taken place or suspected to have taken place during their association with the Company.PROCEDURE<ol><li class="text-justify">Stakeholder of the Company who makes complaint under this Policy (“Complainant”) should file the complaint through email addressed to <a href="mailto:grievances@anupamrasayan.com">grievances@anupamrasayan.com</a> or in writing and dispatch it in closed and sealed envelope and should address to the Vigil Department of the Company. The complaint should carry a valid signature.</li><li>To protect the identity of complainant, the Company will not issue the acknowledgement to the complainant.</li><li class="text-justify">It is encouraged not to write any personal information on the outer envelope in order to protect the identity of complainant. However, it shall be the duty and responsibility of the Vigilance Officer/Vigilance Committee#, to protect the identity of the Whistle Blower/Complainant.</li><li class="text-justify">The identity of the Complainant shall be protected in the manner as set out in the Vigil Mechanism/Whistle Blower Mechanism Policy* of the Company.</li><li class="text-justify">The detailed procedure for filling the compliant may be referred to in Vigil Mechanism/Whistle Blower Mechanism Policy* of the Company.</li></ol>INVESTIGATIONThe investigation of the complaint will be done as per the Vigil Mechanism/Whistle Blower Mechanism Policy* of the Company.CONFIDENTIALITYThe Complainant, Vigilance Officer, members of the investigating team, the Subject and everybody involved in the process shall, maintain confidentiality of all matters under this Policy, discuss only to the extent or with those persons as required under this Policy for completing the process of investigations and keep the papers in safe custody.MISCELLANEOUSAll the other matter and processes covered under the headings i.e. ‘the decision, reporting’, ‘protection’, ‘disqualifications’, ‘access to chairperson of the Vigilance Committee’, ‘communication’, ‘retention of documents’, in the Vigil Mechanism/Whistle Blower Mechanism Policy shall apply mutatis mutandis to this Policy.&nbsp;* Vigil Mechanism/Whistle Blower Mechanism Policy* of the Company is available at the link <a target="_blank" rel="noopener noreferrer" href="https://anupam-rasayan-ui.netlify.app/investors/policies-practices/vigil-mechanism-whistle-blower-mechanism-policy">Vigil Mechanism/Whistle Blower Mechanism Policy</a>.# Vigilance Committee shall be the Audit Committee as per the Vigil Mechanism/Whistle Blower Mechanism Policy of the Company

Grievance Redressal Mechanism for Stakeholders

Code of Coduct Policy

<h4>EHS Policy</h4>Anupam Rasayan India Limited, are committed to high standards of Environmental, occupational Health and Safety (EHS) performance. We are conscious of our responsibility towards creating, maintaining and ensuring safe and clean environment; reduce health and safety hazards through application of efficient technology and safe work practices for sustainable development. We are committed to:  Ensure compliance with all applicable environmental, health, safety and legal laws and regulations in our country and remain a responsible corporate member of society.  Prevent and manage EHS risk through adoption of elimination, substitution, reduction, recycling, reuse and recovery of waste (gas, solid, liquid) at source.  Follow safe work practices and continual improvement in performance and effectiveness of environmental, health and safety system by setting up, meeting and reviewing of EHS standards.  By adopting energy conservation, reduction of waste through 3R methodology, mitigation of climate change risks and its threats to biodiversity, through all our process operations thereby integrating sustainability into our &nbsp;business operations  Inculcate awareness and culture of environment, health and safety in every employee through education, training and motivation.  Strive to continuously improve EHS performance by employing sustainable practices to optimize consumption of natural resources like water, energy consumption etc. and to further prevent local as well as global pollution of air, water, land, noise etc.  Protect employees, communities and the environment, o By reducing the quantity of emissions, including greenhouse gas (GHG) emissions, o By developing opportunities for recycling and pollution prevention and o Effective utilization of paper, energy, water and other resources;  Partner with our clients to ensure that we manufacture, safe sourcing and distribution of products, meet all required safety regulations, and identify opportunities to further minimize their environmental impact;  Ensure safe practices for all activities of contractors and sub-contractors wherever applicable, to reduce the EHS impact of our products throughout their lifecycle.  Ensure manufacturing processes are inherently safe by implementing robust process Safety Management (PSM) systems to prevent any potential incident.  Continually improve emergency response procedure &amp;amp; business continuity plans.  Make EHS policy available to all our employee, business associates, society and all related stake holders.

EHS Policy

<h4>Energy Management Policy</h4> Purpose: Anupam Rasayan India Ltd. strives to use energy in the most efficient, cost effective, and environmentally responsible manner. The purpose of this policy is to optimize energy use throughout organization, improve cost-effectiveness and productivity, enhance working conditions, reduce greenhouse gas emissions, contribute to sustainable development and control the waste associated with the energy usage. Responsibility: Each and every employee including the site contractors and suppliers are responsible to conserve and efficient use of energy Policy: We will promote the efficient use of energy and related practices throughout our workplaces and process to be energy efficient and greener organisation. To implement this policy, we will:  Achieve and maintain compliance with applicable legal and other requirements.  Continuously improve energy efficiency by establishing and implementing strategic energy management practices that support manufacturing and service capabilities while providing a safe and comfortable work environment.  Consider energy efficiency as a factor in product development and in process and facility design and in the procurement of goods and services.  Adopt the green energy/Renewable energy sources to achieve environmental sustainability.  Encourage continuous improvement in energy conservation by employees and supply chain  Use energy consumption data to establish Key Performance Indicators (KPIs) to drive performance improvements. We will measure, review and communicate our progress on a regular basis to ensure availability of information to our employees.  Ensure adequate resources are available to work towards achieving energy KPI goals.&nbsp;

Energy Management Policy

<h4>INFORMATION&nbsp;SECURITY POLICY</h4>TITLE&nbsp;:&nbsp;Information&nbsp;Security&nbsp;PolicyPURPOSE&nbsp;&amp;&nbsp;SCOPE:This&nbsp;Document&nbsp;contains&nbsp;the&nbsp;high&nbsp;level&nbsp;information&nbsp;security&nbsp;policy statements&nbsp;of&nbsp;ARIL,&nbsp;approved&nbsp;by&nbsp;Management&nbsp;,Published&nbsp;and&nbsp; communicated&nbsp;to&nbsp;all&nbsp;employees &amp;&nbsp;relevant&nbsp;external&nbsp;partiesTable&nbsp;of&nbsp;Contents1. PolicyStatement&nbsp;………………………………………………………….……32. Purposeand Objectives…..………………………………………………...33. Scopeof&nbsp;the&nbsp;Policy..………….……………………………………………….34. Responsibilityfor&nbsp;the&nbsp;Policy………………………………………………&nbsp;35. HighLevel&nbsp;Information&nbsp;Security&nbsp;Policy..……………………………..35.1&nbsp;Information&nbsp;Security&nbsp;Management&nbsp;System&nbsp;Vision……………..35.2&nbsp;Information&nbsp;Security&nbsp;Management&nbsp;System&nbsp;Policy……………..36. PolicyImplementation……..………………………………………………..46.1Minimum&nbsp;Baseline&nbsp;Security&nbsp;Control&nbsp;Matrix.……………………….47. ProtectingData…………………………………………………………………..68. ReportingSecurity&nbsp;Incidents……………………………………………….6<ol><li>Policy&nbsp;Statement</li></ol>A&nbsp;detailed&nbsp;organizational&nbsp;asset&nbsp;inventory&nbsp;shall&nbsp;be&nbsp;maintained&nbsp;with&nbsp;owners&nbsp;assigned&nbsp;for&nbsp;all&nbsp;important&nbsp;assets&nbsp;to&nbsp;provide appropriate&nbsp;protection.All&nbsp;Business&nbsp;information&nbsp;shall&nbsp;be&nbsp;classified&nbsp;and&nbsp;handled&nbsp;on&nbsp;the&nbsp;basis&nbsp;of&nbsp;its&nbsp;value,&nbsp;legal&nbsp;requirement,&nbsp;sensitivity and&nbsp;criticality&nbsp;to&nbsp;the&nbsp;organization.2. Purpose&nbsp;and ObjectivesThe&nbsp;Purpose&nbsp;of&nbsp;this&nbsp;policy&nbsp;is&nbsp;to&nbsp;ensure&nbsp;management&nbsp;commitment&nbsp;towards&nbsp;information&nbsp;security&nbsp;and&nbsp;the&nbsp;ISMS.3. Scope&nbsp;of&nbsp;the&nbsp;PolicyThis&nbsp;Policy&nbsp;is&nbsp;directed&nbsp;towards&nbsp;the&nbsp;management&nbsp;of&nbsp;Anupam&nbsp;Rasayan&nbsp;India&nbsp;Ltd.4. Responsibility&nbsp;for&nbsp;the&nbsp;PolicyTop&nbsp;Management&nbsp;of&nbsp;ARIL&nbsp;is&nbsp;responsible&nbsp;for&nbsp;supporting&nbsp;Information&nbsp;security&nbsp;initiatives&nbsp;by&nbsp;ensuring&nbsp;adequate resources&nbsp;and&nbsp;periodically&nbsp;reviewing&nbsp;the&nbsp;effectiveness&nbsp;of&nbsp;security&nbsp;measures.5. High&nbsp;Level&nbsp;Information&nbsp;Security&nbsp;Policy5.1 Information&nbsp;Security&nbsp;Management&nbsp;System&nbsp;VisionOur&nbsp;Vision&nbsp;is&nbsp;to&nbsp;create&nbsp;a&nbsp;committed&nbsp;culture&nbsp;towards&nbsp;information&nbsp;protection&nbsp;and&nbsp;align Information&nbsp;Technology&nbsp;and&nbsp;Security&nbsp;activates&nbsp;with&nbsp;Anupam&nbsp;Rasayan&nbsp;India&nbsp;Ltd.&nbsp;Business&nbsp;processes&nbsp;in&nbsp;order&nbsp;to&nbsp;achieve the&nbsp;vision.5.2 Information&nbsp;Security&nbsp;Management&nbsp;System&nbsp;Policy“The&nbsp;ARIL’s&nbsp;Information&nbsp;Security&nbsp;Policy&nbsp;is&nbsp;an&nbsp;explicit&nbsp;commitment&nbsp;to&nbsp;delivering&nbsp;high standards&nbsp;in &nbsp;information&nbsp;security&nbsp;management&nbsp;and&nbsp;it&nbsp;is&nbsp;integral to&nbsp;our&nbsp;approach&nbsp;for delivering&nbsp;superior&nbsp;business&nbsp;performance&nbsp;in&nbsp;all&nbsp;our&nbsp;operations.&nbsp;This&nbsp;policy&nbsp;supports&nbsp;our&nbsp;commitment&nbsp;to&nbsp;the&nbsp;well-being&nbsp;of&nbsp;our&nbsp;operations and&nbsp;assets.”In&nbsp;implementing&nbsp;this&nbsp;Information Security&nbsp;Policy,&nbsp;management&nbsp;of&nbsp;ARIL&nbsp;will:<ul><li>Identify&nbsp;and&nbsp;periodically&nbsp;assess&nbsp;the&nbsp;security&nbsp;threats&nbsp;arising&nbsp;from&nbsp;its&nbsp;business&nbsp;operations</li><li>Develop&nbsp;and&nbsp;maintain&nbsp;an&nbsp;effective&nbsp;Information&nbsp;Security&nbsp;Management&nbsp;System.</li><li>Accuracy&nbsp;of&nbsp;information&nbsp;assets&nbsp;and&nbsp;processing&nbsp;methods&nbsp;including&nbsp;all&nbsp;company’s&nbsp;physical&nbsp;assets,&nbsp;personnel, corporate&nbsp;image&nbsp;and&nbsp;key&nbsp;business&nbsp;processes,&nbsp;from&nbsp;all&nbsp;forms&nbsp;of&nbsp;harm.</li><li>Consider&nbsp;information&nbsp;security&nbsp;at&nbsp;all&nbsp;stages&nbsp;of&nbsp;planning.</li><li>Mitigate&nbsp;or&nbsp;minimize&nbsp;risks&nbsp;by&nbsp;use&nbsp;of&nbsp;proactive&nbsp;and&nbsp;cost-effective&nbsp;measures&nbsp;and procedures.</li><li>Encourage&nbsp;a&nbsp;positive&nbsp;commitment&nbsp;to&nbsp;information&nbsp;security&nbsp;by&nbsp;all&nbsp;levels&nbsp;of&nbsp;management&nbsp;by&nbsp;providing&nbsp;sufficient resources&nbsp;commensurate&nbsp;with&nbsp;the&nbsp;assessed&nbsp;risks.</li><li>Record,&nbsp;analyse and&nbsp;investigate&nbsp;all&nbsp;reported&nbsp;security&nbsp;incidents&nbsp;and&nbsp;irregularities&nbsp;and&nbsp;deve op&nbsp;improvements&nbsp;to&nbsp;prevent&nbsp;their&nbsp;re-occurrence.</li><li>Introduce&nbsp;programs&nbsp;to&nbsp;develop&nbsp;information&nbsp;security&nbsp;awareness and&nbsp;responsibility&nbsp;among&nbsp;all&nbsp;staff&nbsp;and&nbsp;contractors.</li><li>Ensure&nbsp;compliance&nbsp;with&nbsp;the&nbsp;policy&nbsp;through&nbsp;a&nbsp;process&nbsp;of&nbsp;education,&nbsp;review&nbsp;and&nbsp;audit.</li><li>Develop&nbsp;policies,&nbsp;procedures,&nbsp;guidelines&nbsp;and&nbsp;provide&nbsp;awareness to&nbsp;users&nbsp;for&nbsp;implementation&nbsp;of&nbsp;the&nbsp;same.</li></ul>&nbsp;6. Policy&nbsp;Implementation6.1 Minimum&nbsp;Baseline&nbsp;Security&nbsp;Control&nbsp;MatrixThe&nbsp;requirements&nbsp;in&nbsp;the&nbsp;following&nbsp;table&nbsp;outline&nbsp;the&nbsp;minimum&nbsp;baseline&nbsp;security&nbsp;control (MBSC)&nbsp;mechanisms&nbsp;that&nbsp;must&nbsp;be&nbsp;used&nbsp;for&nbsp;each&nbsp;information&nbsp;classification.<figure class="table"><table class="ck-table-resized" style="border-color:hsl(0, 0%, 100%);border-style:solid;"><colgroup><col style="width:25%;"><col style="width:25%;"><col style="width:25%;"><col style="width:25%;"></colgroup><tbody><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Security</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="2" width="174">Public</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="2" width="211">Internal</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="2" width="319">Confidential&nbsp;and&nbsp;Restricted</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Objective</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Identification</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="3" width="174">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="3" width="211">User&nbsp;IDs&nbsp;&amp;&nbsp;Password</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="3" width="319">Users&nbsp;IDs&nbsp;&amp;&nbsp;Its&nbsp;Password&nbsp;shouldnot&nbsp;be&nbsp;share&nbsp;&amp;&nbsp;with&nbsp;strong&nbsp;authentication.</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">&amp;</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Authentication</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="2" width="156">Availability</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">Virus&nbsp;Scanning,</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">Virus&nbsp;Scanning,</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" rowspan="2" width="319">Virus&nbsp;scanning, strong&nbsp;changecontrol&nbsp;over&nbsp;system configuration,&nbsp;backup/restore</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">Backup/Restore</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">Backup/Restore</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Confidentiality</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="319">Communications&nbsp;(all),&nbsp;and&nbsp;fileson storage media&nbsp;shall&nbsp;be encrypted&nbsp;(whenever&nbsp;it&nbsp;is feasible) or&nbsp;password&nbsp;protected.</td></tr></tbody></table></figure>&nbsp;&nbsp;<figure class="table"><table class="ck-table-resized" style="border-color:hsl(0, 0%, 100%);border-style:solid;"><colgroup><col style="width:25%;"><col style="width:25%;"><col style="width:25%;"><col style="width:25%;"></colgroup><tbody><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">SecurityObjective</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">Public</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">Internal</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="319">Confidential&nbsp;and&nbsp;Restricted</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Electronicsdocuments</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">Storage on all&nbsp;drives</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="319">Storage on secure&nbsp;drives. Storage on shared&nbsp;drive&nbsp;without&nbsp;password&nbsp;protection&nbsp;for&nbsp;reading&nbsp;is&nbsp;prohibited.&nbsp;Password&nbsp;protection&nbsp;of&nbsp;documents&nbsp;preferred.</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Email&nbsp;outsidethe organization</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="319">Email&nbsp;will&nbsp;be&nbsp;encrypted(whenever&nbsp;it&nbsp;is&nbsp;possible) Broadcast&nbsp;to&nbsp;distribution&nbsp;list&nbsp;is&nbsp;prohibited.</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Conversations/&nbsp;Meetings</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="319">Active&nbsp;measures&nbsp;to&nbsp;preventunauthorized&nbsp;parties&nbsp;from overhearing information&nbsp;and close&nbsp;control&nbsp;to&nbsp;limit&nbsp;information&nbsp;to&nbsp;as&nbsp;few&nbsp;persons&nbsp;as&nbsp;possible.&nbsp;Enclosed&nbsp;meeting&nbsp;areas.&nbsp;Public&nbsp;are&nbsp;prohibited.&nbsp;Avoid&nbsp;Public&nbsp;area&nbsp;e.g.&nbsp;elevators,&nbsp;hallways,&nbsp;cafeteria&nbsp;etc.</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Computerscreens</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">To&nbsp;prevent&nbsp;viewingby&nbsp;non-employees.</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="319">Viewing&nbsp;by&nbsp;unauthorized&nbsp;parties.Possible&nbsp;measures&nbsp;include physical&nbsp;location&nbsp;in&nbsp;a&nbsp;secure area,&nbsp;positioning&nbsp;of&nbsp;screen,&nbsp;and&nbsp;use&nbsp;of&nbsp;password&nbsp;protected screen&nbsp;saver&nbsp;(if&nbsp;possible).</td></tr></tbody></table></figure>&nbsp;<figure class="table"><table style="border-color:hsl(0, 0%, 100%);border-style:solid;"><tbody><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="156">Magneticmedia, diskettes</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="174">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="211">None</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="319">Overwrite&nbsp;OR&nbsp;reformat</td></tr></tbody></table></figure>&nbsp;7 &nbsp;&nbsp;&nbsp;&nbsp;&nbsp; &nbsp;Protecting&nbsp;Data7.1 &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;All&nbsp;Key&nbsp;business&nbsp;data&nbsp;shall&nbsp;be&nbsp;assigned&nbsp;a&nbsp;data&nbsp;steward&nbsp;and&nbsp;access&nbsp;to&nbsp;this&nbsp;data&nbsp;monitored&nbsp;and&nbsp;controlled.7.2 &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Secret&nbsp;&amp;&nbsp;Confidential&nbsp;Documents shall&nbsp;not&nbsp;be&nbsp;left&nbsp;out&nbsp;on&nbsp;desks&nbsp;when&nbsp;not&nbsp;being&nbsp;used.Secret&nbsp;and&nbsp;confidential&nbsp;paper&nbsp;documents and&nbsp;computer&nbsp;media&nbsp;shall&nbsp;be&nbsp;stored&nbsp;in suitable&nbsp;locked&nbsp;cabinets&nbsp;or&nbsp;other&nbsp;forms&nbsp;of&nbsp;security&nbsp;furniture.&nbsp;Random&nbsp;checks&nbsp;may&nbsp;be&nbsp;made&nbsp;to&nbsp;check&nbsp;for&nbsp;confidential&nbsp;documents left&nbsp;unattended&nbsp;or&nbsp;unlocked.7.3 &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;When&nbsp;working&nbsp;on&nbsp;a&nbsp;computer&nbsp;located&nbsp;outside of&nbsp;an&nbsp;ARIL&nbsp;office,&nbsp;it&nbsp;is&nbsp;the&nbsp;responsibility&nbsp;of the&nbsp;user&nbsp;to&nbsp;ensure&nbsp;that&nbsp;the&nbsp;computer&nbsp;physically&nbsp;secure&nbsp;and&nbsp;that&nbsp;data&nbsp;cannot&nbsp;be&nbsp;accessed&nbsp;by&nbsp;third&nbsp;parties. Users&nbsp;should&nbsp;refer&nbsp;to&nbsp;ARIL&nbsp;IT&nbsp;Department&nbsp;for&nbsp;further&nbsp;information&nbsp;and&nbsp;guidelines&nbsp;about&nbsp;remote working.7.4 &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Unwanted&nbsp;removable&nbsp;media&nbsp;such&nbsp;as&nbsp;CDs,&nbsp;tapes&nbsp;or&nbsp;USB&nbsp;memory&nbsp;devices,&nbsp;the&nbsp;hold confidential&nbsp;information&nbsp;shall&nbsp;be&nbsp;securely&nbsp;wiped&nbsp;or&nbsp;physically&nbsp;destroyed.7.5 &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Users&nbsp;shall&nbsp;not&nbsp;modify/destroy&nbsp;information&nbsp;without&nbsp;proper&nbsp;authority.8 &nbsp;&nbsp;&nbsp;&nbsp;&nbsp; &nbsp;Reporting&nbsp;Security&nbsp;IncidentsAll&nbsp;IT&nbsp;Related&nbsp;security&nbsp;incidents&nbsp;shall&nbsp;be&nbsp;reported&nbsp;as&nbsp;quickly&nbsp;as&nbsp;possible&nbsp;to&nbsp;IT&nbsp;Service&nbsp;Desk&nbsp;in&nbsp;first&nbsp;instance. Line&nbsp;management&nbsp;should&nbsp;also&nbsp;be&nbsp;informed&nbsp;where&nbsp;appropriate.&nbsp;Non&nbsp;IT&nbsp;related&nbsp;incidents&nbsp;shall&nbsp;be&nbsp;reported&nbsp;to&nbsp;the local&nbsp;information&nbsp;Protection&nbsp;office&nbsp;or&nbsp;Security&nbsp;officer.ARIL&nbsp;IT&nbsp;DepartmentInformation Classifications&nbsp;details<figure class="table"><table style="border-color:hsl(0, 0%, 100%);border-style:solid;"><tbody><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="399">Classifications:</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="395">Internal</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="399">Information&nbsp;Owner:</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="395">Information&nbsp;Security&nbsp;Steering&nbsp;Committee</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="399">Information&nbsp;Custodian:</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="395">Information&nbsp;Security&nbsp;Manager</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="399">Authorization&nbsp;List</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="395">All&nbsp;Employees,&nbsp;Contractors.</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="399">Declassify&nbsp;on:</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;" width="395">Never</td></tr></tbody></table></figure>&nbsp;

IT Security & Data Protection Policy

<h4>SUPPLIER CODE OF CONDUCT</h4>Dear Partners,Greetings from Anupam Rasayan India Limited!!!The objective of this Policy is to increase the consciousness with respect to sustainable business model and ethical work practices, among our valuable supplier like you who plays significant role in achieving our business objectives which leads to growth.Being a conscious and responsible company, we always try to create, maintain and ensure a safe and clean environment along with business ethics which help us to create and maintain the safe and healthy workplace. Ensuring the principles of sustainable development in our supply chain is important to us.For consistent sustainable business approach, we would also like to develop our suppliers and help them to create the vision for ethical and sustainable business. With this, we would like you to please adhere with our Supplier code of conduct or you can develop and follow your own Supplier code of Conduct covering all the aspects of sustainable as well as ethical business practices.Your commitment towards these principles will help us creating the sustainable business relations in long run and further strengthen our vision to establish sustainability which further help us to grow together.We thank you for your continuous support and services which you are providing to us and to further strengthening of business, we seek your cooperation and request you to provide the details mentioned on following page on your company letter head and support us in creating, maintaining and ensuring the sustainable and ethical practices and business relations in long run. We have attached Company’s Policy and Supplier Code of Conduct for your kind reference.Yours’s Partner in growth,Anupam Rasayan India LimitedSUSTAINABLE PROCUREMENT POLICYAnupam Rasayan India Limited (“Company”) has always promoted high ethical standards of professional and personal conduct by our team members and business associates. All of our team members and business associates must be committed to integrity in all aspects of their activities and comply with our values and vision; and raise the sustainability standards in our supply chain.Company is conscious of its responsibility towards creating, maintaining and ensuring a safe and clean environment, through the application of efficient technologies and maintaining safe work practices for sustainable development. Ensuring the principles of sustainable development in our supply chain is important to us.To enhance our sustainable procurement journey, we intend to do the following:<ul><li>Promote awareness about Sustainable Procurement amongst contractors and suppliers</li><li>Identify and address ESG and business sustainability risks and opportunities.</li><li>Develop Management systems for sustainability, energy, quality, environment, occupational health and safety and social accountability progressively.</li><li>Integrate sustainable procurement requirements in the organization’s roles, responsibilities, authorities and accountabilities with respect to sustainable procurement. This shall be done for top management of purchasing function, strategic sourcing, new supplier-part development, supply chain management, supplier performance development, contractors management, projects/ capital buying, vendor performance monitoring and Recognition and rewards.</li><li>Monitor and evaluate sustainable procurement performance and identify continual improvement opportunities.</li><li>Reduce Carbon footprint by conservation of materials, water, energy, using waste to wealth / waste to energy approach and adopting more renewable energy in order to achieve Net zero as a part of Climate change mitigation and adaption.</li><li>Encourage logistics optimization and reduce waste by Reduce, Reuse, recycle approach.</li><li>Enhance bio-diversity within the facilities.</li><li>Promote supplier parks and suppliers siting near the plant locations.</li><li>Encourage suppliers to develop their own sustainability goals and annual sustainability reports.</li><li>Facilitate rewards and recognition.</li><li>Establish Sustainable procurement objectives and targets.</li><li>Support our suppliers through resource competence, building awareness and communication, etc.</li><li>Procure more energy efficient products by defining specifications keeping these aspects in mind.</li><li>Co-create innovation for win-win situation for both suppliers and Company.</li><li>Develop a supplier complaint handling mechanism.</li></ul>The Company acknowledge that long-term sustainable development of our suppliers is critical to our joint success and we value our relationship with suppliers who share the same approach and vision towards doing business. In line with our commitment, we have developed this Policy which is an extension of our values and is applicable to all our suppliers. We expect our suppliers to operate in accordance with the principles as outlined in this Policy and adhere to all applicable laws and regulations.This Policy/Code of Conduct outlines our expectations with regards to ethics, business integrity, human rights, health and safety, environment, the local community and quality of product and operations.<ul><li>BUSINESS INTEGRITY AND ETHICS</li><li>Conflict of interest: &nbsp;Suppliers are expected to report any conflict of interest in any business dealings with Company that supplier is aware of to allow us the opportunity to take appropriate action. It should be disclosed if any Company employee or professional under contract with Company may have significant ownership or interest in a supplier’s business.</li><li>Bribery, corruption, gifts and donations: Suppliers in all commercial dealings with Company or otherwise must not receive or offer to make any illegal payments, gifts, bribes, donations or other improper advantage in order to obtain unethical favours for the business. All suppliers must ensure that no action is taken to violate any applicable anti- bribery or anti-corruption laws and regulations in the locations of their operations and make every effort to eliminate all forms of corruption and bribery.</li><li>POTENTIAL RISK SCENARIOS: RED FLAGS</li></ul>According to several anti-bribery and corruption laws, a list of potential red flags that may emerge when employees are employed by companies, associations of Associates, or business partners with ARIL entities and cause concern is listed below. The list is provided mainly for illustrative reasons and is not meant to be comprehensive.If any Associate or Business Partner encounters any of these red flags while working with the ARIL, they must report them promptly using the procedure set out in our “<a target="_blank" rel="noopener noreferrer" href="https://www.anupamrasayan.com/vigil-or-whistle-blower-mechanism-policy/">Whistle Blower Policy</a>”:<ol><li>You become informed that a third party is involved in or has faced allegations of participating in unethical or inappropriate business activities;</li><li>You discover that a third party has a reputation for receiving bribes or requesting bribes to be paid to them, or that they have a "special relationship" with foreign government officials;</li><li>a third party insists on getting a commission or fee payment before signing a contract with us or performing a government function or operation for us;</li><li>When a third-party requests cash payment and either refuses to sign a formal commission or fee agreement or fails to deliver an invoice or receipt for a payment made, the situation is considered a breach of contract.</li><li>A third party asks for payment to be sent to a location or country that is not their place of residence or business operations.</li><li>a third party asks to "facilitate" a service by demanding an unforeseen extra charge or commission;</li><li>a third party expects expensive entertainment or gifts before beginning or continuing contractual discussions or service fulfilment;</li><li>a third party demands cash to "overlook" any legal infractions</li><li>A request from a third party that you offer employment or any other benefit to a friend or family;</li><li>You receive a non-standard or customised invoice from a third party.</li><li>A third party firmly advocates for the utilization of side letters or declines to formalize the agreed-upon terms in writing.</li><li>You have noticed that we have been charged for a commission or fee payment that looks to be substantial in comparison to the service alleged to have been performed.</li><li>a third party demands or needs the use of an agent, intermediary, consultant, distributor, or supplier who is not commonly utilised or known to us; or</li><li>A third party offers you an extremely large present or luxurious hospitality.</li><li>A foreign government official implies that making a donation to their preferred charitable organization could grant you the ability to influence the process of license approvals.</li><li>Violations of environmental regulations, such as improper disposal of hazardous waste or emissions exceeding permissible levels, can lead to serious legal and reputational consequences.</li><li>Non-compliance with local, national, or international regulations and standards governing chemical manufacturing and handling can be a major concern.</li><li>Failure to report accidents or incidents promptly and accurately may indicate a lack of transparency.</li><li>You observe quality control Issues which are consistent problems with product quality, purity, or consistency.</li></ol><ul><li>Confidentiality: Suppliers shall safeguard and respect Company’s intellectual property; trade secrets and other confidential, proprietary and sensitive information or data at all times and shall not disclose the same. The information provided by Company shall be used only for its intended and designated purpose as decided and agreed upon between Company and the supplier.</li><li>Anti-competitiveand restrictive trade practices: In order to encourage open and transparent business operations suppliers must abide by all relevant national and international regulations.</li><li>HUMAN RIGHTS</li><li>Forced and child labour: Suppliers will not employ ant person below the age of 18 (or as per local law, whichever is greater) and supplier should prohibit use of child labour at any stage of their business process. The use forced labour including prison or debt bondage labour, human trafficking or modern-day slavery should not be entertained by the suppliers.</li><li>Compensation and working hours: The mandatory industry standards and regulations pertaining to minimum wages, overtime pay, working hours and rest periods, must be followed by suppliers.</li><li>Non-discrimination: Suppliers must ensure that there should not be any discrimination in their hiring and employment practices based on race, colour, gender, age, nationality, religion, sexual orientation, marital status, citizenship, disability, veteran status, medical condition etc.</li><li>Supplier Obligation: The Suppliers are obliged to work with the Company’s staff, act within its own authority and abide by directives by the Company and implementation activities.</li><li>Civil and Political Rights: Suppliers should follow international standards on human rights and working conditions help form the basis of this Code, such as the United Nation's Universal Declaration of Human Rights, the conventions of the International Labour Organization (ILO) (especially ILO Convention 29, 87, 98, 100, 105, 111, 138 and 182), Protocol of June 11, 2014 to Convention No. 29, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights.</li><li>GOVERNANCE</li><li>Suppliers must comply with all applicable laws and regulations within the country of operation. All other applicable international laws and regulations should also be complied with. Suppliers should follow guidelines of all the required permits and registrations to be always legally compliant.</li><li>Not to indulge in any form of money laundering activities.</li><li>ACCOUNTABILITY AND TRANSPARENCY</li><li>Maintaining appropriate financial records: We expect suppliers to prepare and maintain accounts of business dealings fairly, accurately and in accordance with accounting and financial reporting standards which represent the generally accepted guidelines, principles, standards, laws and regulations of the country of operation.</li><li>Wealth and income creation: The Supplier shall comply with the tax laws and regulations of the country where they operate to promote responsible wealth and income distribution, prevent exploitation of workers, and encourage sustainable economic growth</li><li>PRODUCT AND SERVICES</li></ul>In today’s world, one must deliver his product with quality consistently and persistently to sustain the competition in the market. To achieve the same, we expect our suppliers to implement quality management systems like ISO which help them to establish quality objectives, policies, manual, procedures and help them to develop robust Quality Management System which they can maintain through periodic management reviews and internal and external audits. These will also help them to comply with local laws and regulation.<ul><li>High quality in the products and the services supplied meeting our specifications, applicable standards, and compliance with all the applicable laws (including product packaging, labelling, after-sales service obligations).</li><li>Suppliers are expected to ensure that products supplied to Company, do not contain metals derived from minerals or their derivatives originated from conflict regions that directly or indirectly finance or benefit armed groups.</li><li>CORPORATE SOCIAL RESPONSIBILITY</li></ul>To be Sustainable in long run, one must fulfil the responsibility towards society and local community in general. At Company, we are following the same and complying with CSR policies developed internally and expect the same from our suppliers.<ul><li>RESPONSIBLE CONDUCT WITH STAKEHOLDERS</li><li>Fair dealing with vendors/suppliers: We encourage all of our suppliers to treat their business partners fairly and transparently during business transactions, particularly in the areas of fair appraisal, appropriate selection, equitable opportunity, fair and open competition for everyone.</li><li>Diversity in workforce: Suppliers should take initiatives to have a diverse and inclusive workforce in terms of age, gender, experience, ethnicity etc.</li><li>Engage and involve local communities: We encourage our suppliers to deal with the concerns of the community affected by their business operations and further work towards the mitigation of the impact.</li><li>ENVIRONMENT, OCCUPATIONAL HEALTH AND SAFETY</li><li>Ensure and encourage safe and environment friendly ways of development, manufacture, transport, use and disposal of products having minimum impact on communities including biodiversity, climate change and water scarcity and compliance with all the applicable environmental, health and safety laws and regulations.</li><li>Suppliers will protect their employees from the Risks and Hazards arising from their business activities in the workplace. We expect our suppliers to adopt robust and relevant management practices to comply with applicable health and safety laws, rules, regulations and industry standards. The suppliers are also encouraged to conduct training and awareness activities for employees on health and safety. We also suggest suppliers to take reasonable actions to prevent accident and injuries by analysing and minimizing risk exposure.</li><li>Suppliers should conserve the natural resources by utilizing in efficient way.</li><li>LOCAL COMMUNITY DEVELOPMENT</li></ul>Being a conscious and responsible Company, we understand that our operations affect our communities along with those who are in contact of our supply chains and our suppliers. Therefore, to mitigate the impacts by our suppliers on community, we expect from our suppliers that they should undertake steps to collaborate and associate with the local community for economic and social development by providing employment, eradicating poverty, developing skills of local people etc. wherever relevant.<ul><li>GREEN FUTURE</li><li>Company has established Green Purchasing Policy and Environmental Targets to promote efforts to purchase environmentally conscious materials and products.</li><li>Company is completely aware of the critical role green purchasing plays in forming a market for environmentally oriented products and how extremely effective green purchasing is in creating a sustainable society. Based on the guidelines described below and in collaboration with the relevant associates, we are making efforts to promote green purchasing when procuring materials.<ol><li>The conditions described below shall be taken into consideration when procuring materials.</li></ol></li></ul><ol><li>Substances harmful to the environment or health are contained.</li><li>Consumption of raw materials or energy is minimal.</li><li>Sustainable raw materials are used.</li><li>It is possible to recycle the material or use the material for a longer period than the previously used material.</li><li>When discarding the product, it is easy to process, treat, or dispose of.</li><li>Usage of renewable energy.</li><li>Usage of packing material with minimal environment impact while designing, usage or disposal</li></ol>Mutual trust and respect are the foundation pillars of our relationship. You may also demonstrate your commitment to these principles through compliance with either your code of conduct or by giving consent to above mentioned principles.&nbsp;However, Anupam may request for verification of your compliance with these standards by any of the following methods and to take corrective action if there is any reason for concern:Self-Assessment:&nbsp;We may ask you to fill in a questionnaire on compliance with these standards, which will be considered as a part of report to understand employment and employment relationship, condition of work and social protection.Third-Party Assessments: We may ask desktop information from a third party, e.g. a data provider, on your compliance and performance concerning these standardsCertification Statements:&nbsp;We may ask you for certification or statement confirming compliance with these standards.On-Site Audits:&nbsp;We or an authorized third party acting on our behalf may contact you and ask for permission to verify compliance with these standards on site.

Supplier Code of Conduct

<h4>Human Rights Policy</h4>&nbsp;OBJECTIVEAnupam&nbsp;Rasayan&nbsp;India&nbsp;Limited&nbsp;(the&nbsp;“Anupam&nbsp;Rasayan/&nbsp;Company”)&nbsp;strives&nbsp;to&nbsp;spread&nbsp;awareness&nbsp;among its&nbsp;sphere&nbsp;of&nbsp;influence,&nbsp;including&nbsp;its&nbsp;employees,&nbsp;internal&nbsp;stakeholders&nbsp;other&nbsp;than&nbsp;employees,&nbsp;and&nbsp;external stakeholders&nbsp;(hereinafter&nbsp;collectively referred&nbsp;to&nbsp;as&nbsp;the&nbsp;“Stakeholders”)&nbsp;about&nbsp;their&nbsp;rights&nbsp;and responsibilities&nbsp;towards ensuring&nbsp;non-violation of&nbsp;human rights.This&nbsp;Human&nbsp;Rights&nbsp;Policy&nbsp;(the&nbsp;“Policy”) is framed to codify the framework&nbsp;of&nbsp;rights&nbsp;and responsibilities&nbsp;of the&nbsp;employees towards&nbsp;the&nbsp;Company&nbsp;and&nbsp;each&nbsp;other,&nbsp;rights&nbsp;and&nbsp;obligations&nbsp;of&nbsp;the Stakeholders&nbsp;and&nbsp;the&nbsp;responsibilities&nbsp;of&nbsp;the Company towards&nbsp;its&nbsp;Stakeholders.SCOPEThis&nbsp;Policy&nbsp;shall&nbsp;uniformly&nbsp;apply&nbsp;to&nbsp;all&nbsp;the&nbsp;Stakeholders&nbsp;of&nbsp;the Company.RESPONSIBILITYAll&nbsp;the employees&nbsp;of&nbsp;the&nbsp;Company shall&nbsp;be responsible&nbsp;to&nbsp;protect&nbsp;its&nbsp;reputation, to&nbsp;‘do the right&nbsp;thing’ and&nbsp;shall&nbsp;ensure&nbsp;that&nbsp;there&nbsp;is&nbsp;no&nbsp;violation&nbsp;of&nbsp;human&nbsp;rights.&nbsp;Further,&nbsp;in&nbsp;respect&nbsp;of&nbsp;any&nbsp;business&nbsp;relationship of&nbsp;the&nbsp;Stakeholders&nbsp;with&nbsp;the&nbsp;Company,&nbsp;we also&nbsp;expect&nbsp;our&nbsp;Stakeholders&nbsp;to&nbsp;protect&nbsp;and&nbsp;respect&nbsp;the&nbsp;ethos of&nbsp;human&nbsp;rights&nbsp;and&nbsp;fair&nbsp;treatment&nbsp;to&nbsp;all&nbsp;the human&nbsp;beings throughout&nbsp;the&nbsp;value chain.OUR&nbsp;COMMITMENTEvery&nbsp;human is&nbsp;entitled to human rights, independent&nbsp;of&nbsp;race, religion,&nbsp;caste, gender,&nbsp;political&nbsp;opinion, social&nbsp;status, or&nbsp;other&nbsp;characteristics.The Company&nbsp;is committed&nbsp;to ensuring&nbsp;the&nbsp;exercise&nbsp;of&nbsp;rights byo&nbsp;all&nbsp;its&nbsp;Stakeholders with&nbsp;respect&nbsp;to:- &nbsp;&nbsp;&nbsp;&nbsp;freedom&nbsp;of&nbsp;speech and expression;- &nbsp;&nbsp;&nbsp;&nbsp;freedom&nbsp;to&nbsp;observe&nbsp;any&nbsp;religion or&nbsp;conscience;- &nbsp;&nbsp;&nbsp;&nbsp;protection&nbsp;and privacy of&nbsp;the information collected of&nbsp;the Stakeholderso&nbsp;and employees with respect&nbsp;to:- &nbsp;&nbsp;&nbsp;&nbsp;freedom &nbsp;of &nbsp;assembly &nbsp;and &nbsp;formation &nbsp;of &nbsp;groups &nbsp;provided &nbsp;no &nbsp;such &nbsp;group &nbsp;acts &nbsp;abusively &nbsp;ordiscriminatory&nbsp;towards&nbsp;the other&nbsp;employees;- &nbsp;&nbsp;&nbsp;&nbsp;personal&nbsp;privacy;- &nbsp;&nbsp;&nbsp;&nbsp;equal&nbsp;opportunities at&nbsp;work&nbsp;based&nbsp;on skill&nbsp;and expertise.The&nbsp;Company&nbsp;believes&nbsp;that&nbsp;being&nbsp;proactive&nbsp;on&nbsp;human&nbsp;rights&nbsp;makes&nbsp;not&nbsp;just&nbsp;good&nbsp;business&nbsp;sense&nbsp;but&nbsp;also morally&nbsp;the&nbsp;right&nbsp;thing to do.&nbsp;The&nbsp;Company&nbsp;is&nbsp;sensitive&nbsp;of&nbsp;its&nbsp;role in&nbsp;contribution&nbsp;towards&nbsp;advancing and&nbsp;practising&nbsp;human&nbsp;rights&nbsp;within&nbsp;its&nbsp;spheres&nbsp;of&nbsp;influence&nbsp;and&nbsp;the&nbsp;benefits&nbsp;such an&nbsp;approach&nbsp;can&nbsp;have on&nbsp;its&nbsp;people&nbsp;and&nbsp;businesses.&nbsp;The&nbsp;Company&nbsp;ensures&nbsp;its&nbsp;supports&nbsp;in&nbsp;the&nbsp;protection of&nbsp;human&nbsp;rights&nbsp;and must&nbsp;not&nbsp;be&nbsp;complicit&nbsp;in abuses of&nbsp;human&nbsp;rights.The&nbsp;Company&nbsp;shall&nbsp;comply&nbsp;with&nbsp;all&nbsp;the&nbsp;applicable&nbsp;laws&nbsp;and&nbsp;regulations&nbsp;wherever&nbsp;it&nbsp;operates.&nbsp;TheCompany acknowledges&nbsp;the national&nbsp;and international&nbsp;codified&nbsp;law on human&nbsp;rights. Other&nbsp;applicable Anupam&nbsp;Rasayan&nbsp;codes&nbsp;and policies&nbsp;are&nbsp;as&nbsp;follows:<ul><li>&nbsp;AnupamCode of&nbsp;Conduct for&nbsp;its employee</li><li>&nbsp;Vigilmechanism&nbsp;or&nbsp;Whistle Blower&nbsp;Policy1</li><li>&nbsp;SexualHarassment&nbsp;Redressal&nbsp;Policy</li><li>&nbsp;Environment,health and&nbsp;safety&nbsp;policy</li><li>&nbsp;CorporateSocial&nbsp;Responsibility&nbsp;Policy2</li></ul>❖ &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Work&nbsp;culture&nbsp;and compensationThe&nbsp;Company&nbsp;is&nbsp;committed&nbsp;to&nbsp;maintaining&nbsp;in its&nbsp;dealing&nbsp;with&nbsp;all&nbsp;its&nbsp;Stakeholders&nbsp;a&nbsp;policy&nbsp;of&nbsp;non- discrimination, protection from&nbsp;any&nbsp;abusive&nbsp;act&nbsp;against&nbsp;its&nbsp;Stakeholders.&nbsp;All&nbsp;the&nbsp;Stakeholders must&nbsp;be treated&nbsp;with&nbsp;dignity&nbsp;and&nbsp;respect.&nbsp;All&nbsp;the&nbsp;permanent&nbsp;or&nbsp;contract&nbsp;basis&nbsp;employees&nbsp;shall&nbsp;not&nbsp;be&nbsp;subjected&nbsp;to abuse&nbsp;or&nbsp;harassing work environment&nbsp;at&nbsp;the workplace.We&nbsp;believe&nbsp;in augmenting the&nbsp;culture&nbsp;of&nbsp;our&nbsp;organisation&nbsp;through&nbsp;diversification in&nbsp;human&nbsp;resources. We&nbsp;practice&nbsp;no&nbsp;discrimination&nbsp;based&nbsp;on&nbsp;religion,&nbsp;caste,&nbsp;creed,&nbsp;gender,&nbsp;ethnic&nbsp;group,&nbsp;colour&nbsp;or&nbsp;race&nbsp;during appointment/recruitment&nbsp;procedure&nbsp;and&nbsp;promotion, increments,&nbsp;bonuses&nbsp;or&nbsp;in providing&nbsp;compensation and&nbsp;any&nbsp;other&nbsp;benefits&nbsp;to&nbsp;the&nbsp;employees.&nbsp;We&nbsp;pay&nbsp;fair&nbsp;and&nbsp;performance-linked&nbsp;compensation&nbsp;which&nbsp;meets or&nbsp;exceeds&nbsp;the legal&nbsp;and&nbsp;industry norms.We&nbsp;believe in&nbsp;providing&nbsp;equal&nbsp;employment&nbsp;opportunities&nbsp;to everyone irrespective&nbsp;of&nbsp;gender,&nbsp;caste, religion&nbsp;and any&nbsp;discriminatory&nbsp;factor.The&nbsp;Company&nbsp;assumes&nbsp;the&nbsp;responsibility&nbsp;for the&nbsp;safety&nbsp;of&nbsp;its&nbsp;employees,&nbsp;neighbours,&nbsp;and&nbsp;any&nbsp;other person around&nbsp;its area&nbsp;of&nbsp;operations, its&nbsp;sites&nbsp;and&nbsp;safe&nbsp;transport system.The&nbsp;Company&nbsp;has&nbsp;in&nbsp;place the&nbsp;systems&nbsp;for&nbsp;maintaining&nbsp;the&nbsp;confidentiality&nbsp;and&nbsp;safety&nbsp;of&nbsp;the&nbsp;sensitive data&nbsp;of&nbsp;the Stakeholders.❖ &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Product&nbsp;ImpactsWe&nbsp;always&nbsp;strive&nbsp;to&nbsp;arrange&nbsp;product&nbsp;solutions that&nbsp;contribute&nbsp;to&nbsp;sustainability&nbsp;for&nbsp;sustainable development.&nbsp;By&nbsp;doing&nbsp;so, we&nbsp;are minimising&nbsp;the&nbsp;risk of&nbsp;harming the environment&nbsp;and&nbsp;people&nbsp;around us.❖ &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Anti-&nbsp;CorruptionCorruption&nbsp;obstructs&nbsp;the&nbsp;realisation of&nbsp;human&nbsp;rights,&nbsp;and&nbsp;thus,&nbsp;the&nbsp;Company focuses&nbsp;on&nbsp;a&nbsp;non-tolerant attitude towards corruption.&nbsp;The&nbsp;Company values&nbsp;ethical&nbsp;behaviour and encourage&nbsp;the practice in its workforce.In&nbsp;case&nbsp;of&nbsp;any&nbsp;violation&nbsp;by any&nbsp;Stakeholders&nbsp;associated&nbsp;with&nbsp;our&nbsp;organisation,&nbsp;disciplinary action&nbsp;will be&nbsp;taken according to&nbsp;the framework&nbsp;outlined&nbsp;in&nbsp;this&nbsp;Policy,&nbsp;Vigil&nbsp;Mechanism/Whistle Blower&nbsp;policy1. Employees&nbsp;shall&nbsp;additionally&nbsp;be&nbsp;governed&nbsp;by&nbsp;the ‘Employees&nbsp;Code&nbsp;of&nbsp;Conduct’&nbsp;as imbibed&nbsp;in&nbsp;the Company’s&nbsp;‘Human Resource’&nbsp;policy.1&nbsp;Vigil&nbsp;or&nbsp;Whistle Blower&nbsp;Policy&nbsp;may&nbsp;be referred&nbsp;to&nbsp;at&nbsp;- &nbsp;<a target="_blank" rel="noopener noreferrer" href="https://www.anupamrasayan.com/vigil-or-whistle-blower-mechanism-policy/">https://www.anupamrasayan.com/vigil-or-whistle-blower-</a>&nbsp;<a target="_blank" rel="noopener noreferrer" href="https://www.anupamrasayan.com/vigil-or-whistle-blower-mechanism-policy/">mechanism-policy/</a>2&nbsp;CSR policy&nbsp;may&nbsp;be referred&nbsp;to&nbsp;at&nbsp;- &nbsp;<a target="_blank" rel="noopener noreferrer" href="https://www.anupamrasayan.com/corporate-social-responsibility/">https://www.anupamrasayan.com/corporate-social-responsibility/</a>Additionally, the senior management&nbsp;shall&nbsp;make&nbsp;efforts&nbsp;to&nbsp;undertake third party audits and certificates wherever&nbsp;feasible to&nbsp;establish&nbsp;the&nbsp;sanctity of the&nbsp;anti-corruption&nbsp;systems&nbsp;and measures&nbsp;put&nbsp;in&nbsp;place&nbsp;by the Company.❖ &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Child&nbsp;&amp;&nbsp;Forced Labour&nbsp;and&nbsp;Human TraffickingThe&nbsp;Company&nbsp;strictly&nbsp;follows&nbsp;the&nbsp;policy&nbsp;of&nbsp;no&nbsp;child&nbsp;labour,&nbsp;forced&nbsp;labour&nbsp;and&nbsp;discourages&nbsp;human trafficking.❖ &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Collective BargainingThere are&nbsp;no&nbsp;areas in&nbsp;the&nbsp;Company’s operations&nbsp;where&nbsp;the&nbsp;right&nbsp;to exercise&nbsp;freedom&nbsp;of&nbsp;association&nbsp;and collective&nbsp;bargaining may be&nbsp;at&nbsp;risk&nbsp;for its&nbsp;employees&nbsp;where,&nbsp;long term&nbsp;settlements are&nbsp;considered equivalent&nbsp;to collective bargaining agreements as we do not&nbsp;have&nbsp;trade&nbsp;unions.❖ &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Business&nbsp;PartnersWe&nbsp;know&nbsp;the&nbsp;human-rights&nbsp;related&nbsp;risks&nbsp;in&nbsp;our&nbsp;business&nbsp;relationships.&nbsp;Wherever&nbsp;any instance&nbsp;of&nbsp;breach of&nbsp;human&nbsp;rights&nbsp;will&nbsp;come to our&nbsp;knowledge, we will&nbsp;urge&nbsp;to end&nbsp;the same&nbsp;promptly.❖ &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Communities&nbsp;and Indigenous PeopleAnupam&nbsp;Rasayan&nbsp;sees&nbsp;itself&nbsp;as&nbsp;a&nbsp;good&nbsp;neighbour,&nbsp;respecting&nbsp;the&nbsp;rights&nbsp;of&nbsp;local&nbsp;residents&nbsp;and&nbsp;contributing to the&nbsp;local&nbsp;region’s&nbsp;development.IMPLEMENTATION&nbsp;AND&nbsp;MONITORINGWe&nbsp;observe the&nbsp;following&nbsp;as part&nbsp;of&nbsp;our&nbsp;human&nbsp;rights&nbsp;due diligence,<ul><li>&nbsp;Commitmentto respect&nbsp;human&nbsp;rights;</li><li>&nbsp;Establishing awareness-raising programs;</li><li>&nbsp;Assessingthe&nbsp;human&nbsp;rights&nbsp;impacts&nbsp;in our&nbsp;organisation;</li><li>Trainandnurture&nbsp;the&nbsp;employees&nbsp;to&nbsp;do&nbsp;the&nbsp;right&nbsp;thing&nbsp;and&nbsp;to&nbsp;ensure&nbsp;the&nbsp;non-violation&nbsp;of&nbsp;human rights;</li><li>&nbsp;Grievanceredressal&nbsp;mechanism.</li></ul>Violation&nbsp;of&nbsp;the&nbsp;Human&nbsp;Rights&nbsp;Policy&nbsp;by&nbsp;Stakeholders&nbsp;will&nbsp;be&nbsp;considered&nbsp;as&nbsp;misconduct&nbsp;and&nbsp;will&nbsp;be dealt&nbsp;with as per&nbsp;disciplinary procedures&nbsp;of&nbsp;the Company.We&nbsp;continuously&nbsp;strive to&nbsp;improve&nbsp;the human rights due diligence process in&nbsp;an&nbsp;inclusive&nbsp;manner.

Human Rights Policy

<h4>POLICY ON BOARD DIVERSITY</h4>INTRODUCTIONThe Policy on Board Diversity (the “Policy”) for the Board of Directors (the “Board”) of Anupam Rasayan India Limited (the “Company”) has been devised by the Nomination and Remuneration Committee (“NRC”) in compliance &nbsp;with Regulation 19(4) read with Part D of the Schedule II of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI Listing Regulations”) to ensure &nbsp;that the Board is fully diversified and comprises of an ideal combination of Executive and Non-Executive Directors, including Independent Directors, with varied skills, experience, background, gender, and perspectives, contributing to the effective governance of the Company and its long-term sustainability.PURPOSE AND OBJECTIVEThe objective of this policy is to ensure that the composition of the Board always have an optimum combination with a wide range of attributes so that the Board of Directors of the Company reflects diversity in terms of gender, age, ethnicity, experience, expertise, and other relevant characteristics. By fostering a diverse Board, the Company aims to promote better decision-making, improved corporate governance and enhance the value it provides to its stakeholders.APPLICABILITYThe Policy applies to the composition of the Board only and does not apply to diversity in relation to the employees of the Company.POLICY STATEMENTThe Company continuously seeks to enhance the effectiveness of its Board so as to maintain the highest standards of corporate governance and for this, it embraces diversity in the Boardroom. The Company sees diversity as a wide concept and believes that a truly diverse Board will include and make good use of differences in the skills, regional and industry experience, background, race, gender, nationality, cultural background and other distinctions between Directors and would support the attainment of its strategic objectives and its sustainable development. In determining its approach on diversity, the Company shall also take into account other factors including its own business model, ethics, policies and industry specific needs from time to time.ROLE OF NOMINATION AND REMUNERATION COMMITTEEThe NRC shall be responsible for recommending the composition of the Board, including the selection of new directors in line with the objectives of this policy. The NRC shall ensure that candidates for the Board have diverse skills, experiences and perspectives that complement the existing members of the Board.When identifying and recommending the candidates for the Board, the NRC shall consider the following:<ul><li>Skills, qualifications, and experience that align with the Company’s strategic direction.</li><li>The need to ensure gender diversity and balance across various categories.</li><li>The diversity of background, age, ethnicity, and professional experience.</li><li>The independence of independent directors, in compliance with the Companies Act, 2013 and SEBI Listing Regulations.</li></ul>The NRC shall ensure that no person is discriminated on the grounds of religion, race, gender or related physical disability, nationality or ancestry, marital status, age or any other personal or physical attribute which does not concern such person’s ability to perform as a Board member.MONITORING, REVIEW AND AMENDMENT OF POLICYThe NRC shall review the policy periodically or as and when required, to reflect any changes in regulatory requirements and to ensure the effectiveness of the Policy. The review shall include:<ul><li>An assessment of the current level of diversity of the Board.</li><li>A comparison of the Board’s Composition with the diversity goals set forth in this policy.</li><li>Evaluation of the effectiveness of the Board in fulfilling its duties with diverse perspectives and expertise.</li></ul>Based on the review, the NRC shall recommend such necessary requirements to the Board for its consideration and approval.DISCLOSURE OF THE POLICYThis policy is available on the Company's website i.e., <a target="_blank" rel="noopener noreferrer" href="http://www.anupamrasayan.com">www.anupamrasayan.com</a>.

Policy on Board Diversity

Policy on Prevention, Prohibition and Redressal of Sexual Harassment (“POSH Policy”)

Policies

Code of conduct for independent directors

Board of Directors and the Senior Management Team

Code of Conduct

Memorandum and Articles of Association

Anupam-Employees Stock Option Plan 2020-ESOP Scheme (Modified)

<figure class="table"><table><tbody><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Name of Establishment&nbsp;</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Anupam Rasayan India Limited</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">EPF CODE&nbsp;</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">SRSRT0018611000</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Registered Name</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">ANUPAM RASAYAN INDIA LIMITED</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Date of Coverage</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">01/10/1990</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">No. Branches</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">07</td></tr></tbody></table></figure>&nbsp;<figure class="table"><table><tbody><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Primary Branches Address –</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Plot No – 8109,8110 &amp; 8111 G.I.D.C Sachin SuratTa. Chorasi Dist Surat</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Branch 1</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Plot No – 701, 2419/1, 2419/2 G.I.D.C Sachin SuratTa. Chorasi Dist Surat</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Branch 2</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Plot No – 8104 &amp; 8106 G.I.D.C Sachin SuratTa. Chorasi Dist Surat</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Branch 3</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Plot No – 2423 &amp; 2425 G.I.D.C Sachin SuratTa. Chorasi Dist Surat</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Branch 4</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Plot No – 268/1 G.I.D.C Sachin SuratTa. Chorasi Dist Surat</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Branch 5</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Plot No – 907/3 G.I.D.CTa.: Jhagadia &nbsp;Dist.: Bharuch</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Branch 6</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Plot No – 905/1 G.I.D.CTa.: Jhagadia &nbsp;Dist.: Bharuch</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Branch 7</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">11th Floor, Icon Rio, Dumas Road,Surat, Gujarat, India.</td></tr><tr><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Regional Office&nbsp;</td><td style="border-color:hsl(0, 0%, 100%);border-style:solid;">Surat</td></tr></tbody></table></figure>

Provident Fund Details

Other

Memorandum_and_Articles_of_Association.pdf

Anupam_Employees_Stock_Option_Plan_2020_ESOP_Scheme_Modified.pdf

Intimation_of_Postal_Ballot_Result_15_03_2022.pdf

Others

Intimation of Postal Ballot Result - March 15, 2022

Reg_30(6)_of_SEBI_LODR_Intimation_of_Q4FY21_and_FY21_Earnings_Call_12_06_2021.pdf

Investors Meetings

Intimation of Earnings Call Q4-FY21, FY-21- June 14, 2021

Intimation_of_Earnings_Call_Q3_FY_2021_22.pdf

Intimation of Earnings Call – Q3 FY 2021-22

Intimation_of_Change_in_CFO_14_03_2022.pdf

Intimation of change in CFO - March 14, 2022

Postal_Ballot_Notice_Intimation_11_02_2022.pdf

Postal Ballot Notice Intimation - February 11, 2022

Other Information

Familiarisation Programmes imparted to Independent Directors

Intimation_for_incorporation_of_Wholly_Owned_Subsidiary_09_03_2023.pdf

result 1

Intimation of incorporation of Wholly Owned Subsidiary - March 09, 2023

result 3

Allotment_under_Grant_1_and_Grant_2_(ESOP)_25_02_2023.pdf

Allotment under Grant 1 and Grant 2 (ESOP) - February 25, 2023

Restarting_of_operations_in_one_plant_at_Sachin_GIDC.pdf

Restarting of operations in one plant at Sachin GIDC

5th_Allotment_1st_Vesting_(ESOP)_12_11_2022.pdf

5th Allotment 1st Vesting (ESOP) - November 12, 2022

Unaudited_Condensed_Consolidated_Interim_Financial_Statements_30_06_2022.pdf

Unaudited Condensed Consolidated Interim Financial Statements - June 30, 2022

Update_on_fire_incident_at_Sachin_plant_23_09_2022.pdf

Update on fire incident at Sachin Plant - September 23, 2022

Update on fire incident at Sachin Plant - September 11, 2022

4th_Allotment_1st_Vesting_(ESOP)_22_07_2022.pdf

4th Allotment 1st Vesting (ESOP) - July 22, 2022

Postal_Ballot_Notice_Intimation_27_05_2022.pdf

Postal Ballot Notice Intimation - May 27, 2022

Letters_of_Appointment_for_Independent_Directors.pdf

Letters of Appointments for Independent Directors

Update_on_Registrar_and_Share_Transfer_Agent_22_04_2024.pdf

Update on Registrar and Share Transfer Agent - April 22, 2024

Allotment_of_Shares_under_ESOP_08_02_2024.pdf

Allotment of Shares under ESOP - March 08, 2024

Intimation_for_Incorporation_of_Wholly_Owned_Subsidiary_28_02_2024.pdf

Intimation of incorporation of Wholly Owned Subsidiary - February 28, 2024

Change_in_Registrar_and_Share_Transfer_Agent_(RTA)_12_02_2024.pdf

Change in Registrar and Share Transfer Agent - February 12, 2024

Intimation of incorporation of Wholly Owned Subsidiary - January 20, 2024.pdf

Intimation of incorporation of Wholly Owned Subsidiary - January 20, 2024

Allotment_of_shares_under_ESOP_09_01_2024.pdf

Allotment of Shares under ESOP - January 09, 2024

Intimation of incorporation of Wholly Owned Subsidiary - December 06, 2023.pdf

Intimation of incorporation of Wholly Owned Subsidiary - December 06, 2023

Appointment_of_Chief_Executive_Officer_September_07_2023.pdf

Appointment of Chief Executive Officer-September 07, 2023

Allotment_under_Grant_1_and_Grant_2_(ESOP)_22_05_2023.pdf

Allotment under Grant 1 and Grant 2 (ESOP) - May 22, 2023

Update_on_shifting_of_registered_office_29_04_2023.pdf

Update on shifting of registered office-April 29, 2023

Shifting_of_Registered_Office15_07_2023.pdf

Shifting of Registered Office-July 15, 2023

Acquisition_of_Equity_Shares_of_ARIL_Fluorospeciality_Pvt_Ltd_01_08_2023.pdf

Acquisition of Equity Shares of ARIL Fluorospeciality Pvt. Ltd.-August 01, 2023

Appointment_of_Company_Secretary_Compliance_Officer_September_07_2023.pdf

Appointment of Company Secretary & Compliance Officer-September 07, 2023

Allotment_of_share_under_ESOP_31_10_2023.pdf

Allotment of Shares under ESOP - October 31, 2023

Credit_Rating_Intimation_CRISIL_Ratings_05_10_2023.pdf

Credit Rating Intimation-CRISIL Ratings-October 05, 2023

Allotment-1st & 2nd Vesting (ESOP) - January 09, 2023

Credit_Rating_Intimation_08_07_2022.pdf

Credit Rating Intimation - July 8, 2022

Intimation_of_Postal_Ballot_e_voting_results_26_06_2022.pdf

Intimation of Postal Ballot e-voting results - June 26, 2022

2nd_Allotment_1st_Vesting_(ESOP)_07_03_2022.pdf

2nd Allotment 1st Vesting (ESOP) - March 7, 2022

Acquisition_stake_in_Tanfac_01_02_2022.pdf

Acquisition-stake in Tanfac-February 1, 2022

Credit_Rating_Intimation_03_06_2021.pdf

Credit Ratings Intimation-June 03, 2021

Credit_Rating_Intimation_India_Ratings_&_Research_29_11_2023.pdf

Credit Rating Intimation- India Ratings & Research - November 29, 2023

Credit Rating Intimation- India Ratings & Research - August 24, 2022

<h2>NOMINATION REMUNERATION POLICY</h2><h3>The Board of Directors of Anupam Rasayan India Limited constituted the Nomination and Remuneration Committee at their meeting held on 25th March, 2015 and re-constituted on 11th November, 2020.</h3><ol style="-webkit-text-stroke-width:0px;background-color:rgb(255, 255, 255);box-sizing:border-box;color:rgb(0, 0, 0);font-family:&quot;Open Sans&quot;;font-size:16px;font-style:normal;font-variant-caps:normal;font-variant-ligatures:normal;font-weight:400;letter-spacing:normal;list-style:decimal;margin-bottom:1rem;margin-right:0px;margin-top:0px;orphans:2;padding-left:15px;text-align:left;text-decoration-color:initial;text-decoration-style:initial;text-decoration-thickness:initial;text-indent:0px;text-transform:none;white-space:normal;widows:2;word-spacing:0px;"><li style="box-sizing:border-box;">ObjectivesThe NRC (as defined hereinafter) and Nomination and Remuneration Policy shall be in compliance with Section 178 of the Companies Act, 2013 read along with the applicable rules, each as amended and Regulation 19 read with Schedule II, Part D (A) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended.Key objectives of this Policy are:<ul style="box-sizing:border-box;list-style:disc;margin-bottom:0px;margin-right:0px;margin-top:0px;padding-left:15px;"><li style="box-sizing:border-box;">To formulate the criteria for determining qualifications, positive attributes and independence of a director and recommend to the Board a Policy relating to the remuneration;</li><li style="box-sizing:border-box;">To recommend to the Board, the remuneration payable to the Directors, Key Managerial Personnel and where required of other employees on significant position; .</li><li style="box-sizing:border-box;">To formulate the criteria for evaluation of performance of Independent Directors and the Board;</li><li style="box-sizing:border-box;">To guide the Board in relation to appointment and removal of the Directors, Key Managerial Personnel and Senior Management Personnel;</li><li style="box-sizing:border-box;">To evaluate the performance of Board and provide necessary report to the Board for further evaluation of the Board;</li><li style="box-sizing:border-box;">To specify the manner for effective evaluation of performance of Board, its Committees and individual Directors to be carried out either by the Board, by the NRC or by an independent external agency;</li><li style="box-sizing:border-box;">To retain and promote talent to ensure long term sustainability of talented managerial persons and create competitive advantage;</li><li style="box-sizing:border-box;">To develop a succession plan for the Board.</li></ul></li></ol>

Policie inside page

Resignation_of_CS_&_Compliance_Officer_15_03_2023.pdf

Resignation of CS & Compliance Officer - March 15, 2023

Appointment_of_Dy_CS_&_Compliance_Officer_16_03_2023.pdf

Appointment of Dy CS & Compliance Officer - March 16, 2023

Appointment_Deputy_CFO_&_KMP_01_02_2022.pdf

Appointment-Deputy CFO & KMP-February 1, 2022

2. Code of Conduct for Independent Directors.pdf

Investor_Meet_Intimation_02_02_2022.pdf

Investor Meet Intimation – February 02, 2022

Investor_Meet_Intimation_01_12_2021.pdf

Investor Meet Intimation – December 10, 2021

<h1>NOMINATION REMUNERATION POLICY</h1><h2>The Board of Directors of Anupam Rasayan India Limited constituted the Nomination and Remuneration Committee at their meeting held on 25th March, 2015 and re-constituted on 11th November, 2020.</h2><ol style="-webkit-text-stroke-width:0px;background-color:rgb(255, 255, 255);box-sizing:border-box;color:rgb(0, 0, 0);font-family:&quot;Open Sans&quot;;font-size:16px;font-style:normal;font-variant-caps:normal;font-variant-ligatures:normal;font-weight:400;letter-spacing:normal;list-style:decimal;margin-bottom:1rem;margin-right:0px;margin-top:0px;orphans:2;padding-left:15px;text-align:left;text-decoration-color:initial;text-decoration-style:initial;text-decoration-thickness:initial;text-indent:0px;text-transform:none;white-space:normal;widows:2;word-spacing:0px;"><li style="box-sizing:border-box;">ObjectivesThe NRC (as defined hereinafter) and Nomination and Remuneration Policy shall be in compliance with Section 178 of the Companies Act, 2013 read along with the applicable rules, each as amended and Regulation 19 read with Schedule II, Part D (A) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended.Key objectives of this Policy are:</li></ol>To formulate the criteria for determining qualifications, positive attributes and independence of a director and recommend to the Board a Policy relating to the remuneration;To recommend to the Board, the remuneration payable to the Directors, Key Managerial Personnel and where required of other employees on significant position; .To formulate the criteria for evaluation of performance of Independent Directors and the Board;To guide the Board in relation to appointment and removal of the Directors, Key Managerial Personnel and Senior Management Personnel;To evaluate the performance of Board and provide necessary report to the Board for further evaluation of the Board;<ul style="box-sizing:border-box;list-style:disc;margin-bottom:0px;margin-right:0px;margin-top:0px;padding-left:15px;"><li style="box-sizing:border-box;">To specify the manner for effective evaluation of performance of Board, its Committees and individual Directors to be carried out either by the Board, by the NRC or by an independent external agency;</li><li style="box-sizing:border-box;">To retain and promote talent to ensure long term sustainability of talented managerial persons and create competitive advantage;</li><li style="box-sizing:border-box;">To develop a succession plan for the Board.</li></ul>

Policie inside page 1

Investor Meet Intimation – December 1 to 3, 2021

Investor_Meet_Intimation_13_11_2021.pdf

Investor Meet Intimation – November 13, 2021

Intimation_of_Earnings_Call_Q2_FY_2021_22.pdf

Intimation of Earnings Call – Q2 FY 2021-22

Intimation_of_Earnings_Call_Q4_FY_21_and_FY_2020_21.pdf

Intimation of Earnings Call Q4-FY 21 and FY 2020-21

IntimationInvestorCall_15_06_2021.pdf

Intimation of Investor Meeting – June 15, 2021

Institutional_Investor_Meet_Intimation_19_06_2021.pdf

Institutional Investor Meet Intimation- June 21, 2021

Outcome_of_Institutional_Investor_Call_20210621.pdf

Investor Meet Outcome- June 21, 2021

Investor_analyst_call_Intimation_202021.pdf

Investor Meet Intimation- June 21, 2021

Investor_Meet_Intimation_26_06_2021.pdf

Investors Meet Intimation – June 28, 2021

Newspaper_Advertisement_Q3_FY_2021_22.pdf

Newspaper Publications

Newspaper Advertisement - Q3 FY 2021-22

Newspaper_Advertisement_Postal_Ballot_Notice_11_02_2022.pdf

Newspaper Advertisement - Postal Ballot Notice - February 11, 2022

Newspaper_Advertisement_Tanfac_Industries_Open_Offer_DPS_Financial_Express_08_02_2022.pdf

Newspaper Advertisement - Tanfac Industries-Open Offer- DPS- Financial Express- February 8, 2022

Outcome_Institutional_Investor_Meet_30_06_2021.pdf

Outcome Institutional Investor Meet- June 30, 2021

Intimation_of_Earnings_Call_Q1_FY_2021_22.pdf

Intimation of Earnings Call – Q1 FY 2021-22

Newspaper_Advertisement_Tanfac_Industries_Open_Offer_DPS_Jansatta_08_02_2022.pdf

Newspaper Advertisement - Tanfac Industries-Open Offer- DPS- Jansatta- February 8, 2022

Newspaper_Advertisement_Tanfac_Industries_Open_Offer_DPS_Makkal_Kural_08_02_2022.pdf

Newspaper Advertisement - Tanfac Industries-Open Offer- DPS- Makkal Kural- February 8, 2022

Newspaper_Advertisement_Tanfac_Industries_Open_Offer_DPS_Navshakti_08_02_2022.pdf

Newspaper Advertisement - Tanfac Industries-Open Offer- DPS-Navshakti- February 8, 2022

Newspaper_Advertisement_Q2_FY_2021_22.pdf

Newspaper Advertisement - Q2 FY 2021-22

Newspaper_Advertisement_Q1_FY_2021_22.pdf

Newspaper Advertisement - Q1 FY 2021-22

Newspaper_Advertisements_Financial_Results_for_Q4FY2020_21_and_FY_2020_21_14_06_2021.pdf

Newspaper Advertisement - Financial Results for Q4 FY 2020-21 and FY 2020-21

Newspaper_Advertisement_Q3_FY_2022_23.pdf

Newspaper Advertisement - Q3 FY 2022-23

Newspaper_Advertisement_Q2_FY_2022_23_Gujarati.pdf

Newspaper Advertisement - Q2 FY 2022-23-Gujarati

Newspaper_Advertisement_Q2_FY_2022_23_English.pdf

Newspaper Advertisement - Q2 FY 2022-23-English

Newspaper_Advertisement_19th_AGM_Notice_17_08_2022.pdf

Newspaper Advertisement-19th AGM Notice-August 17, 2022

Newspaper_Advertisements_Information_Regarding_19th_AGM_14_08_2022.pdf

Newspaper Advertisement-Information regarding 19th AGM Notice-August 14, 2022

Newspaper_Advertisement_Q1_FY_2022_23.pdf

Newspaper Advertisement - Q1 FY 2022-23

Newspaper_Advertisement_Postal_Ballot_Notice_28_05_2022.pdf

Newspaper Advertisement - Postal Ballot Notice - May 28, 2022

Newspaper_Advertisement_Tanfac_Industries_Post_Offer_Financial%20Express_26_05_2022.pdf

Newspaper Advertisement - Tanfac Industries-Post Offer-Financial Express- May 26, 2022

Newspaper_Advertisement_Tanfac_Industries_Post_Offer_Jansatta_26_05_2022.pdf

Newspaper Advertisement - Tanfac Industries-Post Offer-Jansatta- May 26, 2022

Policies & Practices

Announcements