Extract of Whistle-blower Policy

Ather Energy Private Limited (the “Company”) strongly believes in conduct of its business in a fair, transparent, lawful, and ethical manner.

The Company encourages everyone, and it is everyone’s responsibility as well, to raise and report genuine concern(s) regarding unethical behavior, actual or suspected fraud, violation of Company’s policies or applicable laws.

Applicability

The Policy is applicable to all stakeholders including directors, employees, suppliers, vendors, and customers.

Matters that can be reported under the Policy

1. 1) Unlawful or dishonest activities, manipulation of data/documents, misrepresentations, actual or suspected fraud, forgery, theft, bribery, and other corrupt business practices.

2. 2) Accounting or auditing irregularities, billing for services not performed or for goods not delivered, embezzlement, misappropriation of funds and any other fraudulent financial reporting or financial crimes.

3. 3) Antitrust or insider trading violations including leakage of unpublished price sensitive information.

4. 4) Significant environmental, safety, or product quality issues.

5. 5) Misuse/abuse of official position, seeking or making inappropriate favors, abuse of authority or unlawful discrimination or harassment.

6. 6) Proliferation of confidential/proprietary information.

7. 7) Breach of Company’s Code and/or policies or

8. 8) Any other act or genuine concern which may adversely affect the reputation, goodwill, brand, and image of the Company, or has the potential to cause financial loss.
    

   
   Channels of reporting

    

Anyone who wishes to raise any complaint/concern under the Policy can use the following channels:

• I. Ethics Helpline e-mail address at 

  [email protected]

• II. Drop Box located at designated locations.

• III. Employees may also make Disclosure to their functional head.
   

  
  Protection

   

a. No victimization of or retaliation against the complainant shall be permitted.

b. Any person assisting in investigation shall also be protected.

c. Identity of the complainant shall be kept confidential unless otherwise required by law.

d. Any abuse of this protection by the complainant would warrant disciplinary action.

e. Protection under this Policy would not mean protection from disciplinary action arising out of involvement of the complainant in any misconduct or false or bogus allegations knowing it to be false or bogus or with a malafide intention.

Decisions & Actions

Necessary disciplinary or corrective action will be taken in case of proven complaints.