In case of any suspected violation of any law that applies to the Company and any suspected violation of the Company’s Code of Conduct, an Employee or Director may report the same in the manner mentioned in this Policy. Such violations include, but are not limited to, accounting or financial reporting violations, fraud, misappropriation of money, discrimination or harassment based on gender, race, religion, languag, etc., unlawful manipulations, insider trading, bribery, or violations of the anti-retaliation aspects of this Policy. Retaliation includes adverse actions, harassment, or discrimination in employment relating to a report of a suspected violation.

Failure to report any reasonable belief that a violation has occurred or is occurring is itself a violation of this Policy and such failure will be addressed with appropriate disciplinary action.

HOW TO REPORT

A report of suspected violation may be made either with name or anonymously to : debopriya@halderventure.in or by sending an anonymous letter to the Company Secretary at :
DIAMOND HERITAGE BUILDING
16, STRAND ROAD, UNIT-1012, 10TH FLOOR
KOLKATA-700 001, INDIA
with copy to md@halderventure.in

If you have reason to believe that the Managing Director, the Director, Finance or the Company Secretary is involved in the suspected violation, report may be made in sealed envelope to the Audit Committee of Board of Directors (the “Audit Committee”) at:
Audit Committee
Halder Group of Companies
DIAMOND HERITAGE BUILDING
16, STRAND ROAD, UNIT-1012, 10TH FLOOR
KOLKATA-700 001
with copy to md@halderventure.in
Investigations after Report

RETALIATION IS NOT TOLERATED

No one may take any adverse action against any employee for complaining about, reporting, or participating or assisting in the investigation of a reasonably suspected violation on the basis of this Policy. Incidents of retaliation against any employee reporting a violation or participating in the investigation of a reasonably suspected violation will result in appropriate disciplinary action against anyone responsible.

CONFIDENTIALITY

Employees and Directors will maintain confidentiality obligations. Reporting in accordance with this Policy does not amount to breach of confidentiality obligations.

MALICIOUS AND UNFOUNDED ALLEGATIONS

Employees and Directors are not to make malicious or unfounded allegations but may make allegations in good faith where there is reasonable ground of suspicion and basis.

NO PROTECTION FROM ADVERSE ACTION

This policy does not protect an employee from an adverse or a disciplinary action taken independently against any disclosure made pursuant to this policy

ACTION IN TERMS OF OTHER LAWS

This policy does not prevent a person or the Company from taking an action under any applicable law.

DOCUMENT RETENTION

All documents related to reporting, investigation and enforcement pursuant to this Policy may be retained by the Company.

MODIFICATION

The Board of Directors of the Company can modify this Policy unilaterally at any time without notice.