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Vigil Mechanism

Preface

Sri Krishna Pharmaceuticals Limited believes in conducting its business in a fair and transparent manner. The Company has adopted the Code of Conduct, which lays down the principles and standards that should govern the actions of the Company and its employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the Company.

The role of the employees in pointing out such violations of the Code cannot be undermined. Accordingly, this Whistleblower Policy (“the Policy”) has been formulated with a view to provide a mechanism for directors and employees of the Company to voice their concerns about any misconduct, violations of legal or regulatory requirements, manipulation or misrepresentation of any financial statements and reports etc. without fear of punishment or unfair treatment.

Objective

The vigil mechanism is introduced with the objective to strengthen the culture of transparency in the organization and to enable the directors and employees to inform the management against wrongdoings and serious irregularities within the organization.

The spirit behind introducing the policy is to enable the director or employees not to overlook any concern, instead raise it at an early stage and in the right manner, to enable the Company to take immediate action and avoid any further damages to the Company.

Policy

The Whistleblower policy is an extension of Company’s Code of Conduct. This policy intends to cover serious concerns that could have grave impact on the operations and performance of the business of the Company.

The policy neither releases employees from their duty of confidentiality in the course of their work, nor other routes for taking up a grievance about a personal situation.

Protected Disclosures under this policy will be appropriately dealt with by the Chairman of the Audit Committee.

All Employees of the Company are eligible to make Protected Disclosures under the Policy. The Protected Disclosures may be in relation to matters concerning the Company.

Definitions

Scope of the Policy:

The Policy covers malpractices and events which have taken place/ suspected to take place involving:

Guiding Principles

To ensure that this Policy is adhered to and also to assure that the concern will be acted upon seriously, the Company will:

Anonymous Allegation

Whistleblowers must disclose their identity in the Protective Disclosure as follow-up questions and investigation may not be possible unless the source of the information is identified. Disclosures expressed anonymously will ordinarily NOT be investigated

Role of Whistle blower’s

Protection to Whistle blowers

Accountability-Whistle blowers

Accountability-Vigil Officer & Vigil Committee

Rights of Subjects

Management Action on False Disclosures

An employee who knowingly makes false allegations of unethical & improper practices shall be subject to disciplinary action, up to and including termination of employment, in accordance with Company rules, policies and procedures. Further this policy may not be used as a defense by an employee against whom an adverse personnel action has been taken independently for legitimate reasons or cause under Company rules and policies.

Procedure for Reporting & Dealing with Disclosures

Refer Annexure A for details on the procedure for reporting & dealing with disclosures

Confidentiality

All reports and records associated with the Disclosures are considered confidential and access will be restricted to the Whistleblower, Vigil Officer and Chairman of Audit Committee. Disclosures and any resulting investigations, reports or resulting actions will generally not be disclosed to the public except as required by any legal requirements or regulations or by any corporate policy in place at that time.

Retention of Documents

All Protected Disclosures in writing or documented along with the results of investigation relating thereto shall be retained by the Company for a minimum period of 7 years.

Reporting

A quarterly report on the total number of complaints received during the period, along with summary of the findings of the Vigil Committee and the corrective actions taken will be sent to the Chairman of the Audit Committee.

Company Power

The Company is entitled to amend, suspend or rescind this policy at any time. Whilst, the Company has made best efforts to define detailed procedures for implementation of this policy, there may be occasions when certain matters are not addressed or there may be ambiguity in the procedures.Such difficulties or ambiguities will be resolved in line with the broad intent of the policy. The Company may also establish further rules and procedures, from time to time, to give effect to the intent of this policy and further the objective of good corporate governance.

Protection

If the whistle blower or any other person who assisted or participated in the investigation process face any retaliatory action or threats of retaliatory action as a result of making a disclosure or participation, they shall inform the Vigil Officer/Committee/Chairman of Audit Committee in writing immediately.The intimation of such actions or threats will be treated as a separate disclosure and will be separately investigated. Adequate measures will be taken to ensure complete protection to such person until the completion of investigation proceedings.

Penal Provisions

If a person against whom the concern is raised is found guilty, then the company shall take appropriate action which, depending on the person’s culpability may include a suspension, termination, demotion, a decision not to promote or grant a salary increase or revocation of a recent salary increase, a decision to terminate during probation, a performance evaluation in which the employee’s performance is generally evaluated as unsatisfactory, an involuntary retirement, or any other unfavourable change in the general terms and conditions of employment.

Annexure A

Procedure For Making Disclosure

A Disclosure should be made in writing. Letters can be submitted by hand-delivery, courier or by post or through electronic mail addressed to the Chairman of the Audit Committee of the Company.

Address: Dr. C. Gopala Krishna Murthy, Sri Krishna Pharmaceuticals Limited, C-4, Industrial Area, Uppal, Hyderabad – 500039.

Contents of Disclosure

Procedure For Dealing With Disclosure

The Chairman of Audit Committee may allow additional time for submission of the report based on the circumstances of the case.