Atul Ltd 2022-23

SECTION C: PRINCIPLE-WISE PERFORMANCE DISCLOSURE PRINCIPLE 1 Businesses will conduct and govern themselves with integrity and in a manner that is ethical, transparent and accountable. Essential indicators 2. Fines | penalties | punishments | awards | compounding fees | settlement amount paid in proceedings (by the Company or by Directors | KMP) with regulators | law enforcement agencies | judicial institutions, in the financial year a. Monetary Type NGRBC principle Name of the regulatory | enforcement agencies | judicial institutions Amount (`) Brief of the case Has an appeal been preferred? Penalty | fine NA NA Nil NA Settlement NA NA Nil NA Compounding fee NA NA Nil NA b. Non-monetary Type NGRBC principle Name of the regulatory | enforcement agencies | judicial institutions Brief of the case Has an appeal been preferred? Imprisonment NA NA NA NA Punishment NA NA NA NA 1. Percentage coverage by training and awareness programs on any of the Principles during the financial year Segment Number of programs Topics | Principles % of persons BOARD OF DIRECTORS KMP EMPLOYEES (excluding Executive Directors and KMP) 4 5 7 100% 100% 100% • Code of conduct • Corporate governance • Human rights • Prevention of sexual harassment (POSH) • Code of conduct • Human rights • POSH • Whistleblower • Acceptance of gifts and business courtesies • Atul Values • Code of conduct • Equal employment opportunity and anti-discrimination • Human rights • POSH • Whistleblower 73

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