List of active policies

Full policy

1.Purpose and Overview

• Application:

The Code is applicable to all employees, temporary employees, consultants and contractors (each, a “Covered Person”) of ANAROCK.

• Purpose:

The code summarizes the values, principles and business practices that guide the business conduct of the Company and also provides a set of basic principles to guide Covered Persons regarding the minimum ethical requirements expected of them. All Covered Persons are expected to become familiar with the Code and to apply these principles in the daily performance of their jobs.

• Overriding Responsibilities:

It is the responsibility of all Covered Persons to maintain a work environment that fosters fairness, respect and integrity. The Company requires all Covered Persons to conduct themselves in a lawful, honest and ethical manner in all of the Company’s business practices.

• Questions:

All Covered Persons are expected to seek the advice of a supervisor, a manager, the Human Resources Department, the Legal Department or the Ethics Ombudsman for additional guidance or if there is any question about issues discussed in this Code.

• Violations:

If any Covered Person observes possible unethical or illegal conduct, such concerns or complaints should be reported as set forth in section 12 below.

2. Compliance with Laws, Rules and Regulations

All Covered Persons of the Company are required to comply with all of the applicable laws, rules and regulations of India. Local laws may in some instances be less restrictive than the principles set forth in this Code. In those situations, Covered Persons should comply with the Code, even if the conduct would otherwise be legal under applicable local laws. On the other hand, if local laws are more restrictive than the Code, Covered Persons should comply with applicable local laws. Further, any provision of this Code that is contrary to law in a particular jurisdiction will have no force or effect in that jurisdiction solely with respect to such provision(s), although this Code (including any such provision) will remain applicable in all other jurisdictions.

Special attention is drawn to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH). All Covered Persons are required to be aware of the provisions of the Act and ensure compliance. Covered Persons are encouraged to report any cases that are in violation of the provisions of this Act. This will be treated as gross misconduct and would be dealt with accordingly.

3. Conflicts of Interest

1. Avoidance of Conflicts. All Covered Persons are required to conduct themselves in a manner and with such ethics and integrity so as to avoid a conflict of interest, either real or apparent.

2. Declaration of conflicts. All employees are required to declare any existing or potential conflicts at the time of joining or when the situations develop during the course of employment. Omitting to declare any conflict of interest would be considered an unethical act.

3. Conflict of Interest Defined. A conflict of interest is any circumstance where an individual’s personal interest interferes with the interests of the Company. All Covered Persons have a duty to avoid financial, business or other relationships (including relationships of an intimate or romantic nature) that might be opposed to the interests of the Company or might cause a conflict with the performance of their duties.

4. Potential Conflict Situations. Conflicts can arise when a Covered Persons take actions or have interests that may make it difficult to perform their Company related work objectively and effectively. Conflicts also may arise when Covered Persons, or a member of their families, receives improper personal benefits as a result of their position in the Company. Conflicts may also arise when Covered Persons are involved in romantic or intimate relationships with either a team member or a member of any other department of the Company.

5. Examples of Potential Conflicts. Some of the areas where a conflict could arise include:

a. Employment by a competitor, regardless of the nature of the employment, while employed by the Company.

b. Placement of business with any firm or organization in which a Covered Person, or any member of the Covered Person’s family, has a substantial ownership interest or management responsibility.

c. Omitting to declare at the time of appointment that a sibling, spouse, sister in law, partner or other family member is in employment of the Company.

d. Disclosing the Company’s confidential information to a third party (other than as permitted in accordance with Section 7 below) without the prior consent of senior management.

6. Questions Regarding Conflicts. All questions regarding conflicts of interest and whether a particular situation constitutes a conflict of interest should be directed to the Legal Head or the Ethics Ombudsman.

4. Corporate Opportunities

Covered Persons are prohibited from (i) taking for themselves or their families opportunities that are discovered through the use of Company property, information or position, (ii) using Company property, information or position for personal gain, and/or (iii) competing with the Company.

For example:

1. To the extent that a Covered Person learns of an investment or sales opportunity because of their position with the Company, the Covered Person must not take any actions that result in the Company losing revenue or a business opportunity.

2. Giving access to friends, competitors, family or any 3rd Party to the sales pipeline or sales leads will be considered an unethical act.

3. Entering into an arrangement with a client directly or through a friend/family member/associate such that the Company loses current or future revenue is an unethical act.

5. Gifts, Entertainment and Contributions

• Receipt of Gifts and Entertainment

The Company’s aim is to deter providers of gifts or entertainment from seeking or receiving special favours from Covered Persons in connection with activities performed by or for, or business relationships established with, the Company. The concern is that gifts of more than a nominal value may cause Covered Persons to feel placed in a position of “obligation” and/or give the appearance of a conflict of interest. Covered Persons should not solicit any third party for any gift, gratuity, entertainment or any other item regardless of its value. Covered Persons, including members of their immediate families, may accept or participate in “reasonable entertainment”. As a guideline, covered persons should ensure that gifts or entertainment do not exceed Rs. 2500. In case of any confusion or query on whether a gift should be accepted the Covered Persons should reach out to either their immediate boss or the legal head to seek clarification/approval.

• Anti-Corruption:

All Covered Persons are strictly prohibited from offering or giving gifts, meals or entertainment to business partners or others in order to improperly influence them. For example, gifts to be given at the wedding or to a client’s child should be reasonable. In general, the guideline of a limit of Rs. 2500 is to be adhered to. Any queries/clarifications should be directed to the immediate boss or the Legal head.

6. Outside employment

Restrictions and approvals:

Subject to any departmental restrictions, Covered Persons are not permitted to engage in outside employment unless it is specifically approved and authorised by the Company.

Self-Employment:

For purposes of this Code, outside employment includes self-employment.

7. Confidential Information Obligations

Confidentiality:

Covered Persons are responsible for maintaining the confidentiality of information entrusted to them as a result of their roles with the Company, except when disclosure is authorized or legally mandated.

As a result of employment or service with the Company, a Covered Person may produce, receive, or become acquainted with the confidential information or trade secrets of the Company, information the Company has received from others that the Company is required to treat as confidential, including information concerning the Company’s employees, clients, customers, business partners, and other commercially sensitive information the privacy, confidentiality, and secrecy of which is valued by the Company (collectively, “Confidential Information”). Each Covered Person must comply with all applicable Company policies concerning confidentiality and/or public statements, as they may be amended from time to time.

Each Covered Person should endeavour to deal fairly with the Company’s customers, suppliers, competitors and Covered Persons and not to take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.

9. Protection and use of company property

All Covered Persons should protect the Company’s assets and ensure they are used for legitimate business purposes. Improper use includes unauthorized personal appropriation or use of the Company’s assets, data or resources, including computer equipment, software and data.

10. Standards of business conduct

• Respectful Work Environment

The Company is committed to fostering a work environment in which all individuals are treated with respect and dignity. Each individual should be permitted to work in a business-like atmosphere that promotes equal employment opportunities.

• Prohibited Conduct:

The following conduct will not be tolerated and could result in disciplinary action, including termination:

• Disciplinary Action:

Since each incident of misconduct may have a different set of circumstances or differ in its severity, the Company will take such disciplinary action as it deems appropriate and commensurate with any misconduct of the Covered Person.

11. Accountability for Adherence to the Code

• Honesty and Integrity:

The Company is committed to uphold ethical standards in all of its corporate and business activities. All Covered Persons are expected to perform their work with honesty, truthfulness and integrity and to comply with the general principles set forth in the Code. Covered Persons are also expected to perform their work with honesty and integrity in any areas not specifically addressed by the Code.

• Disciplinary Actions:

A violation of the Code may result in appropriate disciplinary action including the possible termination from employment with the Company. Nothing in this Code restricts the Company from taking any disciplinary action on any matter pertaining to the conduct of a Covered Person, whether or not expressly set forth in the Code.

• Training and Educational Requirements:

• Orientation. New Covered Persons will receive a copy of the Code during the orientation process conducted by representatives of the Human Resources Department and shall acknowledge that they have received, read and understand the Code and will comply with the requirements of the Code.

• Continuing Education. Covered Persons shall be required to complete such additional training and continuing education requirements regarding the Code and matters related to the Code as the Company shall from time to time establish.

• Questions and Concerns. Described in this Code are procedures generally available for addressing ethical issues that may arise. As a general matter, if Covered Persons have any questions or concerns about compliance with this Code, they are encouraged to speak with their supervisor, manager, representatives of the Human Resources Department, the Legal Department, the Ethics Ombudsman.

• Compliance and Ethics Hotline. Compliance and Ethics Hotline. If a Covered Person does not feel comfortable talking to any of the persons listed above for any reason, the Covered Person should e mail to this id: ethics.hotline@anarock.com

• Responsibility to Report Violations of the Code and Law. As part of its commitment to ethical and lawful conduct, the Company strongly encourages Covered Persons to promptly report any suspected violations of this Code or law.

• Confidentiality and Investigation. The Company will treat the information set forth in a report of any suspected violation of the Code or law, including the identity of the complainant, in a confidential manner and will conduct a prompt and appropriate evaluation and investigation of any matter reported. Covered Persons are expected to cooperate in any investigations of reported violations.

• Protection of Covered Persons. It is a violation of this Code to retaliate against anyone who has communicated to the Company information that such person reasonably believes constitutes a violation of the Code or which is otherwise illegal or unethical. A Covered Person may not be discharged, demoted, suspended, threatened, harassed or in any other manner discriminated against in the terms and conditions of employment on account of having provided the Company with information about, or otherwise assisted the Company in any investigation regarding, any conduct which the Covered Person reasonably believes constitutes a violation of the Code or is otherwise illegal or unethical.

I confirm that I have read the Code of Ethics carefully and have understood it fully. I commit that I shall abide by it at all times and encourage my colleagues to do so as well.

Full policy

ANAROCK is committed to establishing a culture where everyone feels free to raise concerns regarding illegal or unethical behaviour. To achieve this goal Anarock strives to maintain an environment where everyone can speak up without the fear of retaliation.

ANAROCK strictly prohibits Retaliation against any of its employees for reporting or inquiring in Good Faith about what the employee believes to be wrongful or unlawful activity, or for participating in an investigation or proceeding related to such activity. ANAROCK considers such reporting, inquiring, or participating to be Protected Activities in which all ANAROCK employees may freely engage.

This Policy establishes ANAROCK’s position on Retaliation against anyone who speaks up to share concerns made in Good Faith. It is intended to help employees speak up with confidence and without fear of Retaliation.

Full policy

Full policy

A) Purpose and Overview

• Application

The policy is applicable to all the employees, temporary employees, consultants and retainers of Anarock.

• Purpose

•The policy summarizes set of basic guidelines to be followed when a company asset is handed over to you on your joining.

• Physical Security - Laptop Policy

The company does not tolerate inappropriate use of any company property. Use your laptop only for business purposes

Your laptop is the property of the Company; do not lend it to anyone or permit use to anyone.

Offensive, pornographic, racist or abusive content found on company laptops will be considered under Company's disciplinary policy.

If you receive any inappropriate material by email report to the IT Team for investigation and subsequently delete it.

Always lock your computer when not in use to protect your data and privacy.

Only visit Web sites you know and trust.

Don't install unauthorized application, if any requirement please reach out to IT Team

Report any issues, malfunctions or security concerns to the IT department promptly

• Public Transport and Public Places

Laptops are particularly vulnerable to theft and loss while using public transport. Be vigilant.

If IT asset lost or damaged by you, the cost of laptop is to be borne by the employee.

• Email Protection

Do not use email for sending unsolicited mail

Do not open unknown attachments

Secure your devices and avoid using public Wi-Fi networks for email access.

Exercise vigilance when encountering unfamiliar emails and potential phishing attempts. Refrain from clicking on any dubious links or divulging sensitive information.

Be cautious about phishing emails and avoid clicking on suspicious links or providing sensitive information

• IT- Breach

Do not format your laptop at any point

Do not delete official emails & data.

Unauthorized storage of organizational data on personally owned removable media is not

permitted.

Uploading or distributing organization-owned software, documents, or materials online requires explicit permission from the IT team

• Internet

Installing screen savers, games or programs from internet sites is risky

Be careful about providing personal, sensitive information to an internet site

• Backup

Save all your folders on One Drive

• Password

Use strong password protection and authentication.

• FOR ANY HARDWARE & SOFTWARE ISSUE CONTACT IT TEAM

North Region

Name: Hitesh Arora

Contact :9873848308

hitesh.arora@anarock.com

West Region

Name: Vinayak Wayade

Contact :8655557057

vinayak.wayade@anarock.com

South Region

Name: Prahallad Swain

Contact :9113257965

prahallad.swain@anarock.com

• ESCALATION MATRIX

Brijlal Gupta brijlal.gupta@anarock.com | Priti Puri priti.puri@anarock.com