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| CORPORATE GOVERNANCE |
| COBE AND OMBUDSPERSON PROCEDURE |
| As a value-based, socially responsible organisation, we strive to adhere to the highest ethical standards in our operations and our behaviour. We have earned the trust and respect of our stakeholders by doing what is right - consistently and convincingly. In this process, we are governed by a Code of Business Conduct and Ethics (CoBE) (hereafter referred to as the Code). The Code applies to every employee, regardless of level or position, and lays down the principles that guide our conduct. It has been articulated so as to provide information and resources that help employees make informed business decisions and act on them with integrity. The Code has been designed to comply with the provisions of the Sarbanes-Oxley Act of 2002 and its implementing regulations. |
| It is the responsibility of all Directors and employees to familiarise themselves with this Code and comply with its standards. The Board and all employees across the globe annually affirm compliance with the Code. |
Every employee affirms compliance at the time of induction by
signing on the declaration page and renews this affirmation
annually through an online process which assesses his/her
understanding of the Code. |
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| Ombudsperson Procedure |
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The ombudsperson procedure has been institutionalised under
the Code to review concerns on actual or suspected violations
of the Code. This procedure: |
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Describes the Ombudsperson framework |
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Takes into account procedures for communication and investigation of any report on any violation or suspected violation of the Code |
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Accepts appeal against any decision; and |
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Encourages the submission of complaints against any retaliation |
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| An Independent Director is the Ombudsperson. The complaints and reports submitted to the Company and their resolution status are reported through the Ombudsperson to the Audit Committee and, where applicable, to the Board. |
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