Integrated Annual Report 2024-2025

6. Company policies 6.1 Compliance Compliance certificates confirming due compliance with statutory requirements are placed at the Board meeting for review by the Directors. A system of ensuring material compliance with the laws, orders, regulations and other legal requirements concerning the business and affairs of the Company is in place. Instances of non-compliance, if any, are also separately reported to the Board and subsequently rectified. 6.2 Code of Conduct The Code of Conduct is available on the website of the Company at www.atul.co.in/investors/policies. All the Directors and the Senior Management personnel have affirmed their compliance with the Code of Conduct. A declaration to this effect signed by the Chairman and Managing Director forms a part of this report. 6.3 Prevention of sexual harassment of women at workplace Pursuant to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, the Company has framed a policy on the prevention of sexual harassment of women at the workplace and constituted Internal Complaints Committee. The status of complaints during 2024-25 is as under: Filed during 2024-25 Nil Disposed of during 2024-25 Nil Pending as at the end of 2024-25 Nil 6.4 Related party transactions The Company has formulated a Related Party Transactions Policy and the same is disclosed on the website of the Company at www.atul.co.in/investors/policies 6.5 ‘Material’ subsidiary companies The Company has formulated a policy for determining ‘material’ subsidiary companies and the same is disclosed on the website of the Company at www.atul.co.in/investors/policies 6.6 Familiarisation programmes The details of familiarisation programmes imparted to Independent Directors are disclosed on the website of the Company at www.atul.co.in/about/directors/ 6.7 Whistleblower Policy The Company has formulated a vigil mechanism (Whistleblower Policy) and the same is displayed on the website of the Company at www.atul.co.in/investors/policies 6.8 Commodity price risk or foreign exchange risk and hedging activities a) Risk management policy on commodities, including through hedging T he Company has established a comprehensive Risk Management Policy to identify, assess and mitigate potential risks arising from commodity price fluctuations and supply volatility. Key raw materials that are derivatives of various commodities are procured, sourced both domestically and globally. Although formal hedging instruments are not available for most of the core chemicals procured, the Company mitigates short-term procurement risks through strategic sourcing arrangements are mitigated. This includes entering into annual or semi-annual contracts linked to published benchmark prices or input cost indices. Further, a de-risking approach is followed by diversifying the supplier base, avoiding dependency on a single source and limiting spot market purchases to manage volatility in pricing and availability. b) Exposure of the Company to commodity and commodity risks faced throughout the year T he Company continuously monitors its exposure to commodity price volatility and supply chain disruptions. However, during the year under review, material impact due to commodity price fluctuations is not faced. Exposure to commodity risk remains limited due to proactive procurement planning and sourcing strategies adopted by the Company. c) Foreign exchange risks are tracked and managed within the risk management framework. Short-term foreign currency asset-liability mismatch is continuously monitored and hedged. The foreign exchange market is highly regulated and the Company ensures compliance with all the regulations. 86 86 Integrated Annual Report 2024-25

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