Whistle Blower Policy

The whistleblower policy is intended to cover serious concerns that could have a large impact on the company such as actions (actual or suspected) that:

- May lead to incorrect financial reporting

- Are not in line with applicable company policy

- May be detrimental to the image of the group

- Violate the accepted values of the group

- Are unlawful

- Amount to serious improper conduct (including any kind of harassment)

The complainant or the whistleblower as he or she is called is not expected to prove the truth of an allegation; the complainant needs to demonstrate to the ombudsperson that there are sufficient grounds for concern. Certain safeguards have been provided which will prevent harassment or victimisation of the complainant.

Every effort will be made to protect the complainant's identity, subject to legal constraints. Complainants must put their names to allegations as follow-up questions and investigations may not be possible unless the source of the information is identified. Concerns expressed anonymously WILL NOT usually be investigated, BUT subject to the seriousness of the issue raised, the ombudsperson can initiate an investigation independently. Malicious allegations by employees may result in disciplinary action.

The ombudsman for the Murugappa Group is Shyam C. Raman, Senior Vice President — Group HR and he is authorised by the Statutory Boards of the respective companies for the purpose of receiving all complaints under this policy and ensuring appropriate action. His contact details are: