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Mankind Pharma Limited

Code of Conduct Policy

Version 2.0 (Revised in Year 2020)


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1. OBJECTIVE

This Policy details the general guidelines that all the Stakeholders must follow in the

Company. It is expected that the Stakeholders would exhibit highest standard of

personal integrity, ethics and professionalism at all times. This Policy reflects general

principles to guide the Stakeholders in making ethical decisions/disclosures and is not

intended to address every specific situation.

2. APPLICABILITY AND ELIGIBILITY

2.1 This Policy is applicable to all the Stakeholders of Mankind.

2.2 Mankind also requires its suppliers, service providers, agents and channel partners

(dealers, distributors and others) to conduct their businesses in a legal and ethical

manner and in accordance with the terms of this Policy.

3. RESPONSIBILITY

3.1 It is the personal responsibility of all the Stakeholders of the Company to adhere to

the Code of Conduct and acknowledge the same by submitting the duly signed

Acknowledgement Form (refer enclosed Annexure – 2) to the HR Department.

Periodically, the Stakeholders’ may be asked to provide a written certification that

they have reviewed and understand the Company’s Code of Conduct, comply with its

standards, and are not personally aware of any violations of the Code of Conduct by

others.

3.2 The implementation of this Policy rests with the reporting manager.

3.3 The overall responsibility lies with HR department and Board of Directors.

4. DEFINITION

4.1 “Assets” include physical property, intellectual property of Mankind or tangible

assets such as equipment and machinery, systems, facilities, materials and resources,

as well as intangible assets such as information technology and systems, proprietary

information, intellectual property, and relationships with customers and supplier’s

client, and all other business, proprietary and confidential information of Mankind.

4.2 “Bribes and kickbacks” means offering, promising, giving, accepting or soliciting of

an undue advantage of any value (which could be financial or non-financial), directly

or indirectly, and irrespective of location(s), in violation of applicable law, as an

inducement or reward for a person acting or refraining from acting in relation to the

performance of that person’s duties.


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4.3 “Code of Conduct” is a set of rules outlining the responsibilities or proper practices

for an individual, party or organization.

4.4 “Company” or “Mankind” means Mankind Pharma Limited and all its subsidiaries.

4.5 “Confidential Information” includes, but not limiting to any information concerning

the Company’s decisions, operations, data, procedures, plans, earnings, income,

financial or business forecasts, proposed acquisitions, client or vendor lists, all

customer or vendor records, all customer information, processes, technologies,

methods, trade secrets, strategies, administration etc. that should not be disclosed

to anyone.

4.6 “Conflict of Interest” situation where business, financial, family, political or

personal interests could interfere with the judgment of persons in carrying out their

duties for the organization.

4.7 “Gifts” refers to anything of economic value constituting a benefit for the receiver.

4.8 “Policy” means this Code of Conduct, as may be updated and amended from time to

time.

4.9 “Stakeholder/s” individually and collectively means

All the employees of the Company, on full-time or part-time employment,

with either permanent, probationary, trainee, retainer, temporary or

contractual appointment at the Company;

All the directors on the Board of Directors of the Company; and

All, contractors, vendors and customers of the Company (as and when

applicable).

5. GUIDELINES

5.1 Every Stakeholder shall maintain absolute integrity and shall conduct himself/herself

in the manner which will enhance the reputation of the Company.

5.2 While there are no rigid rules for personal behavior, there exists a standard conduct

for every Stakeholder of the Company and it can be maintained by exercising good

judgment and moderation at all time.

5.3 No Stakeholder will do any misinterpretation, falsification or destruction of the

Company records such as employment application form or expense report records,

forgery of medical claims or any other Company record.

http://en.wikipedia.org/wiki/Procedural_law


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5.4 The Stakeholders shall not do any violation of criminal laws or have unauthorized use

of client’s or the Company’s property.

5.5 The Stakeholders shall not deceive people in the name of the Company.

5.6 Any illegal acts including theft shall be strictly prohibited. Once a Stakeholder is found

to commit such act, he shall be put under “Suspension pending enquiry”. Once the

illegal act has been proved against the Stakeholder, immediate and appropriate

action shall be taken against the employee as per the Disciplinary Procedure.

5.7 A Stakeholder shall not damage any articles and facilities of the Company on purpose

and shall consciously take good care of all facilities and properties of the Company

and maintain hygiene and good working environment.

5.8 A Stakeholder shall abide by laws, observe disciplines and preserve his/her moral

integrity. If the Stakeholder is held responsible for violation of laws on one's own

account, all consequences shall be taken by him/her and have nothing to do with the

Company.

5.9 Corresponding disciplinary actions shall be taken against those Stakeholders who have

violated the rules and regulations of the Company according to the severity of the

circumstances.

6. FEW INSTANCES OF MISCONDUCT

6.1 The list is not exhaustive but it is intended to provide general, practical guidance.

The following activities shall be treated as misconduct:

6.1.1 Theft, fraud or dishonesty in connection with the business or property of the

Company or property of another person within the premises of the Company.

6.1.2 Taking or giving bribes.

6.1.3 Furnishing false information regarding name, age, father’s name,

qualification, ability or previous service or any other matter relating to

employment.

6.1.4 Willful insubordination or disobedience.

6.1.5 Absence without leave or overstaying the sanctioned leave for more than

three consecutive working days.

6.1.6 Habitual late coming or irregular attendance.

6.1.7 Negligence of work including slowdown of work.

6.1.8 Damage to any property of the Company.

6.1.9 Interference or tempering with any safety devices installed in the premises

of the Company.


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6.1.10 Intoxication/Drunkenness/Being under the influence of alcohol and unruly or

indecent behavior in the premise of the Company or outside the premises

where such behavior is connected with employment.

6.1.11 Gambling within the premises of the Company.

6.1.12 Smoking within the premises of the Company where it is prohibited.

6.1.13 Sleeping while on duty.

6.1.14 Commission of any act which amounts to a criminal offence involving moral

turpitude.

6.1.15 Purchasing/selling in the name of the Company without permission from the

competent authority

6.1.16 Unauthorized use or occupation of the Company’s property.

6.1.17 Assaulting any Stakeholder of the Company.

6.1.18 Unauthorized communication of information regarding the Company.

6.1.19 Going on a strike in contravention of the provisions of law.

6.1.20 Breach of any law or conduct rules and any other rules/orders issued by the

Company.

6.1.21 Acting in a manner prejudicial to the interest of the Company.

7. The Stakeholders should follow the following guidelines in their conduct:

7.1 Conduct detrimental to the Company

7.1.1 Theft, destruction, neglect or unauthorized personal use/misuse of the

Stakeholder or the Company property, including telephone and e-mail usage.

7.1.2 Insubordination involving abusive language or disrespectful behaviour, refusal

to comply with Company policies, procedures, or supervisory instructions.

7.1.3 Violations of the Company HR policy, procedures, or practices established by

the appointing authority to whom the Stakeholder reports.

7.1.4 Any act which endangers the safety, health or wellbeing of another

Stakeholders, or which is of sufficient magnitude that the consequences cause

or potentially cause disruption of work or discredit to the Company.

7.1.5 Other such actions, offences, or incidents deemed of sufficient reason to

justify immediate dismissal.

7.2 Conduct off the job

7.2.1 Conduct off the job is ordinarily the personal business of the Stakeholder,

unless and until it conflicts with the employment relationship with the

Company.

7.2.2 Off-duty conduct may pose a problem if it damages Company’s reputation, and

causes Stakeholders to be unable to perform his/her job satisfactorily, hurts

the performance of the work group or interferes with the Company’s ability to

conduct business.

7.2.3 Conduct which may create a conflict of interests is also inappropriate.


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7.3 Conflict of interests/other activities

7.3.1 The Stakeholders will need to disclose to the Human Resources Department or

Legal Department the nature of any material interest or affiliation that may

pose a conflict with the Company.

7.3.2 The Stakeholders needs to inform immediately to the Human Resources

Department or Legal Department, in writing, if he/she or a Stakeholder of

his/her family is or plans to be affiliated with or have a financial interest in a

business enterprise that:

competes with the Company;

is a customer of the Company; or

a vendor of the Company

7.3.3 The Stakeholders cannot recruit any member of his/her family as a

direct/indirect reportee.

7.3.4 The Stakeholders will also need to check with Board of Directors and obtain

approval from HR and Legal team, if he/she is asked to serve on the board of

another business organization. However, it is a Conflict of Interest to serve as

a director of any Company that competes with Mankind.

7.3.5 The Stakeholders should dedicate the whole work day to execute the tasks

assigned to them by the organization.

7.3.6 No outside positions may be accepted nor any other profession pursued

without prior approval of the reporting manager and HR department.

7.3.7 External activities which are detrimental to performance at work may not be

pursued.

7.3.8 The underlying principle is that the official position of any Stakeholder as a

Mankind’s employee should not result in any monetary or non-monetary

benefits (other than salary/perquisites) for themselves or their

relatives/associates.

7.3.9 Failure to adhere to this Policy can attract severe consequences, including

termination of employment.

7.4 Receiving and giving gifts

7.4.1 Giving of gifts or favours to anyone and in particular to government officials

in an effort to sell products or services or to influence business, labour or

governmental decision-making is strictly prohibited.

7.4.2 Receiving of any gifts in cash or in kind (other than sweet boxes on festivals)

that could influence or could reasonable give the appearances of influencing

Mankind’s business relationship with or having a potential conflict of interest

is prohibited.

7.4.3 Special consideration may be given to cultural expectations and customs for

example, Diwali gifts. It is important to note that no deviation without the

prior approval of Chief Financial Officer (“CFO”) are permissible.


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7.4.4 If the Stakeholder is not in a position to refuse the gifts offered to him, the

Stakeholder in such cases is bound to disclose the receipt of such gift and

submit it to the Administration Department in the enclosed Annexure – 1.

7.4.5 The Company should maintain a record regarding details of the circumstances

in which the gift was accepted/ rejected, the description and value of the

gift, details of the giver/ receiver. The Stakeholders who violate the aforesaid

provisions will be subject to disciplinary action.

7.5 Meals and Entertainment

7.5.1 Meals and entertainment may be provided in connection with a meeting on the

Company’s premises for a legitimate business purpose provided it is permitted

under local law.

7.5.2 Meals and entertainment are prohibited to family members or close business

associates of a government official.

7.5.3 The Stakeholders must obtain the prior written approval of the respective

Head of Department and Compliance Officer before intending to offer meals

or entertainment to a public official.

7.5.4 Inappropriate or illegal hospitality and entertainment such as alcoholic

beverages, adult entertainment etc. is expressly prohibited.

7.6 Travel and Lodging

7.6.1 In certain circumstance the Company may pay the reasonable travel expenses,

including airfare, hotel accommodations, meals and other incidentals, of a

government official (to the extent they are permissible as per relevant rules

& regulations). Specifically, the Company may pay bona fide and reasonable

expenses that are directly related to the execution or performance of a

contract for example, reasonable expenses may include trips to a Company

project site to observe the Company’s production processes, or travel

expenses of police officers traveling beyond their usual jurisdiction to

investigate a theft of Company property.

7.6.2 Key policies for payments of travel and lodging related to government official

will include following:

The government agency, government department, or state-owned

enterprise must select the invitees and not the Company.

The government agency, government department, or state-owned

enterprise must approve the proposed visit and itinerary.

Only allow travel that is necessary for the proper undertaking of the duties

of the government official.

Tickets, hotel accommodation and other travel-related expenses need to

be reasonable and commensurate with the Company’s travel policies. The

Company will directly pay airlines and hotels on behalf of the government

official and will not reimburse any per diem to the government

official. However, Company can also make direct payment for per diem


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expenses as per the defined limits to respective government department

for government official.

Payment of hotel accommodations or other forms of lodging shall not

include long-distance telephone calls, mini-bar usage, television pay-per-

view services, or any other additional amenity not included in the base price

of the hotel accommodation or lodging.

7.6.3 Travel will only be for the government official and not for his/ her family

members or close business associates.

7.6.4 The Company will not bear the costs related to travel to tourist destinations

entertainment, sightseeing excursions or other leisure activities.

7.6.5 Expenditures for meals and incidentals must be in accordance with the

Company’s travel policies.

7.6.6 In addition to any respective project site/ department approvals that may be

required, all proposed payments or reimbursements for travel expenses of

government officials must be approved in writing by the CFO before the travel

occurs.

7.7 Smoking, Alcohol and drugs

7.7.1 Smoking, consumption of liquor, tobacco and non-medically prescribed drugs

within the Company’s premises is strictly prohibited.

7.7.2 If someone is considered to be under the influence of alcohol, or non-medically

prescribed drugs, they will be subjected to strict disciplinary action ranging

from verbal warning to dismissal, depending upon the severity of the case.

7.7.3 Any deviations by the Stakeholders under this Policy would be dealt under the

disciplinary procedure policy.

7.8 Bribes and kickbacks

7.8.1 A Stakeholder shall not ask for or accept any gift, money or other benefits by

taking advantage of his/her position at the time of doing business of or deceive

people in the name of the Company. Once a Stakeholder is found to commit

such act, he/she shall be dismissed immediately. If the circumstances are

serious, he/she shall bear legal liability.

7.8.2 The Stakeholders shall not make any payments for the purpose of influencing

the recipient's judgment; for instance, to buy any of Company’s services.

Likewise, the Stakeholders may not solicit or accept a kickback or bribe for

any reason.

7.8.3 This is a serious offence and the Stakeholders who violate this provision will

be subject to disciplinary action.

7.8.4 The Company’s business ethics policy clearly prohibits solicitation and

acceptance of bribes by the Company personnel and anyone working on behalf

of the Company.

7.8.5 For detailed policy in relation to bribery and kickback, please refer to the

business ethics policy of the Company.


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7.9 Protecting Company Assets

7.9.1 All Stakeholders are responsible for safeguarding the tangible and intangible

assets of the organization and shall seek to protect the Company’s assets from

misuse, theft, fraud, damage or loss.

7.9.2 Misappropriation or unauthorized disclosure of Mankind’s assets is a breach of

Stakeholder’s duty to Mankind.

7.9.3 Any suspected loss, misuse or theft of the Company’s assets must be reported

to the Administration Department/Immediate Supervisor or Manager

immediately.

7.9.4 Mankind may monitor individual use of network services, like visits to specific

websites, as may be permitted under applicable laws.

7.10 Dress Code

7.10.1 All the Stakeholders of the Company must ensure to be dressed in formal attire

on all weekdays and decent casuals on the last day of the week within the

office premises.

7.10.2 The Stakeholders are required to be dressed in formal attire whenever they

are representing the Company in a meeting or for any other official purpose.

7.10.3 All the Stakeholders are required to adhere to the clauses as stated in the

dress code policy.

7.11 Equal Employment Opportunity

7.11.1 All employees shall ensure that the concepts of equal employment opportunity

and non-discrimination are well understood, abided by and carried out by

everyone.

7.11.2 The Company shall provide equal opportunities to all its Stakeholders and all

qualified applicants for employment without regard to their race, caste,

religion, colour, ancestry, marital status, gender, sexual orientation, age,

nationality, ethnic origin or disability.

7.11.3 It shall be the responsibility of the Managers to ensure that the work place

climate is conducive for all persons irrespective of sex, race, religion or other

characteristics and employees have the opportunity to grow in the

organization.

7.12 Child Labour Policy

Mankind has a strong policy for prevention of child labour and forced labour in its

organization. The Company do not employ any child labour. The Company’s

permissible age for any employee is over and above 18 years.

7.13 Transparency and accountability

7.13.1 All Stakeholders shall ensure that their actions in the conduct of business are

totally transparent except where the need of business security dictates

otherwise.


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7.13.2 Such transparency shall be brought through appropriate policies, systems and

processes in the departments. All managers shall voluntarily ensure that their

areas of operation are open to audit and the conduct of their activities are

totally auditable.

7.14 Confidential Information

7.14.1 All the Stakeholders are expected to ensure confidentiality of all business

related information.

7.14.2 To maintain the secrecy of the data, it is mandatory that the confidential data

should not be accessible to unauthorized/third party.

7.14.3 Any event displaying non-adherence to this policy is to be reported to the

reporting manager of the Stakeholder. If the issue is not resolved to the

satisfaction of the Stakeholder, it may be reported to the HR Department

immediately.

7.15 Representation to News & Media

7.15.1 No Stakeholder shall formally or informally release any verbal or written

interview, statement, strategy, announcement or photo session with regards

to the Company’s products, business, structure, plans or any other information

that, however, remotely may concern the affairs of the Company directly or

indirectly without the approval of the management.

7.15.2 All media interactions shall be routed through the HR Department for an

approval process (refer enclosed Annexure – 3).

7.16 Violence & Aggression

7.16.1 Violence (physical/threatened) or aggression by any Stakeholder against co-

workers, visitors or anyone else who is either in the office premises or has

contact with employees in the course of their duties is strictly prohibited.

7.16.2 Mankind is committed to a workplace free of harassment. If confronted with

violence or aggression, it must be reported to the immediate

supervisor/Manager or the HR Department.

7.17 Relationships with Regulators

7.17.1 Given the highly regulated environment in which Mankind operate, the

Stakeholders must be vigilant in meeting the responsibilities to comply with

relevant laws and regulations. Mankind expect full cooperation of the

Stakeholders with regulators and to respond to their requests for information

in an appropriate and timely manner. The Stakeholders should be alert to any

changes in the law or new requirements that may affect the business and be

aware that new products or services may be subject to special legal and/or

regulatory requirements. If the Stakeholder become aware of any significant

regulatory or legal concern, the Stakeholder must immediately bring them to

the attention of their functional leader and the Legal Department. Mankind is

committed to maintaining an open, constructive and professional relationship


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with regulators on matters of regulatory policy, submissions, compliance, and

product performance.

7.18 Protecting Customer/Third Party Information

7.18.1 Keeping customer information secure and using it appropriately is a top

priority for Mankind. The Stakeholders must safeguard any confidential

information shared by customers or third parties. The Stakeholders must also

ensure that such information is used only for the reasons for which the

information was gathered. The customer or third party information includes

any information about a specific customer/third party, including such things

as name, address, phone numbers, financial information, etc. Mankind do not

disclose any information about a third party without first obtaining written

approval, unless required by law or regulation (e.g. a court-issued subpoena).

7.19 Intellectual Property and Protecting IP

7.19.1 As a Stakeholder of the Company, the work product you create for Mankind

belongs to Mankind. This work product includes but is not limited to

inventions, discoveries, ideas, trade secrets, know-how, improvements,

software programs, artwork, and works of authorship. This work product is

Mankind’s property (it does not belong to individuals) if it is created or

developed, in whole or in part, during the period of employment. Additionally,

to ensure that Mankind receives the benefit of work done by outside

consultants, it is essential that an appropriate agreement be in place before

any work begins with third parties.

7.19.2 It is incumbent upon the Stakeholders to protect Company’s intellectual

property from illegal or other misuse by making sure it is affixed with or

identified by appropriate trademark, service mark, copyright notice,

confidential marking or patent marking (if applicable). Be sure to disclose to

management any innovation developed on Company or using Company

information or resources, so that Mankind can decide whether to seek formal

protection. Additionally, the Stakeholders must avoid infringing on the IP

rights of others. Please remember not to:

(i) disclose non-public intellectual property inappropriately or without approval from the Legal Department;

(ii) use Company resources or time to create or invent something unrelated to our business;

(iii) use a previous employer’s intellectual property; (iv) make unauthorized copies of software or licensed or confidential

information; (v) copy magazine/journal articles or other publications, unless you have

explicit authority to do so; (vi) affix the trademark of another company on goods; and (vii) hire a competitor’s employee to obtain that competitor’s trade secrets.


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7.20 Maintain Accurate Financial Records/Internal Accounting Controls

7.20.1 Accurate and reliable records are crucial to the Company’s business. Mankind

is committed to maintaining accurate Company records and accounts in order

to ensure legal and ethical business practices and to prevent fraudulent

activities. The Stakeholders are responsible for ensuring that the information

they record, process, and analyze is accurate and recorded in accordance with

applicable accounting or legal principles. The Stakeholders’ also need to

ensure that it is made secure and readily available to those with a need to

know on a timely basis. Company records includes without limitation sales

information, payroll, timecards, travel and expense reports, e-mails,

accounting and financial data, measurement and performance records,

electronic data files and all other records maintained in the ordinary course

of the business. All Company records must be complete, accurate, and reliable

in all material respects. There is never a reason to make false or misleading

entries. Undisclosed or unrecorded funds, payments, or receipts are

inconsistent with our business practices and are strictly prohibited.

7.21 Government Customers/Contracting

7.21.1 When doing business with local, State or Central governments, the

Stakeholders must ensure that all statements and representations to

government procurement officials are accurate and truthful, including costs

and other financial data. If your assignment directly involves working with the

government, or if you are responsible for someone working with the

government on behalf of Mankind, be alert to the special rules and regulations

applicable to the government customers. Additional steps should be taken to

understand and comply with these requirements. Any conduct that could

appear improper must be avoided when dealing with government officials and

employees. Failure to avoid these activities may expose the government

agency, the government employee, Mankind, and the Stakeholder to

substantial fines and penalties. For these reasons, any sale of the Company’s

products or services to any local, State or Central government entity must be

in accordance with Mankind policies.

7.22 Honest Advertising and Marketing

7.22.1 It is Mankind’s policy to comply with all laws and regulations governing the

sales and marketing of our products throughout the world. It is our

responsibility to accurately represent Mankind and its products in the

marketing, advertising and sales materials. It is Mankind’s policy to advertise

and promote its products only through programs and materials that have been

formally approved by the Company to ensure compliance with applicable

central, state and/or local laws and regulations. No Stakeholder is permitted

to give unauthorized discounts, rebates, concessions, commissions or

incentives, or bribes or other payments to obtain or retain business.


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7.23 Antitrust and Fair Competition

7.23.1 All Stakeholders shall comply with all antitrust and competition laws.

Antitrust and competition laws prohibit efforts and actions to restrain or limit

competition between companies that otherwise would be competing for

business in the marketplace. The Stakeholders must be particularly careful

when they interact with any employees or representatives of Mankind’s

competitors. The Stakeholders should use extreme care to avoid any

improper discussions with our competitors, especially at trade association

meetings or other industry or trade events where competitors may interact.

Under no circumstances should you discuss customer information, prospects,

pricing, or other business terms with any employees or representatives of the

Company’s competitors. If the Stakeholders are not careful, they could

potentially violate antitrust and/or competition laws if they discuss or make

an agreement with a competitor regarding:

(i) prices or pricing strategy; (ii) discounts; (iii) terms of our customer relationships; (iv) sales policies or sales practices; (v) marketing plans; (vi) customer selection; (vii) allocating customers or market areas; or (viii) contract terms and contracting strategies.

7.23.2 Agreements with competitors do not need to be written in order to violate

applicable antitrust and competition laws. Informal, verbal, or implicit

understandings (e.g. knowing winks) are also violations. As with all aspects

of this Policy, should you have questions about this you should contact the

Legal Department.

7.24 Guidelines for Work from Home

7.24.1 These guidelines are exclusively made for emergent situations like COVID-19

lockdown and therefore, will be only applicable by the management decision

on the employees recommended by the Head of Department, whose presence

at the worksite is not critical and can support critical functions from home.

It is to be understood and accepted by all stakeholders that all services are

not available or supportable when used from home.

7.24.2 To bring in more clarity, cohesiveness and better co-ordination, the Head of

Department should design an efficient structure for decision making and

effective communication. Smaller cross-functional teams each with a clear

mission and common objectives and reporting line should be constituted.

Wherever, possible separate WhatsApp group should be formed and all virtual

team meetings should be held group wise so as to ensure better time

management.

7.24.3 Employees Responsibilities for Home Based Work:

(i) Adhere to all the Company’s Code of Conduct Policies and Procedures.

(ii) Be contactable during the normal working hours.


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(iii) Ensure fitness for work requirements are met. If any employee

working from home is unwell or unable to work due to other reasons,

then he/she is entitled to leave as per the Company’s leave policy.

(iv) Ensure home worksite complies with health and safety requirements

at all times.

(v) Provide authorized staff, where necessary, for inspections, and

retrieval of any Company-supplied equipment.

(vi) Take reasonable precautions necessary to secure the Company’s

equipment.

(vii) Maintain accurate and up to date records of hours worked at home

within normal span of hours.

(viii) Ensure connectivity with colleagues through WhatsApp messages,

telephone calls, video calls and timely response to all emails.

(ix) Save all files and communication in a backup folder so that work shall

not get affected at time of technical problems.

(x) Employees working from home will be required to work for six days in

a week.

(xi) Be available for support as and when required in this moment of crisis.

7.25 Communication of Sensitive Information to Remote Team Safely

7.25.1 Personal email should not be used for any company business.

7.25.2 Employees need to keep track of what they are printing at home. If a printed

document would be subject to shredding in the office, from the same should

not be printed

7.25.3 All Employees to use company-issued devices when working; using personal

devices is absolutely prohibited.

8. SOCIAL MEDIA POLICY

8.1 The Stakeholders are responsible for both Mankind sponsored social media, as well as

their personal social media accounts, regardless of whether at work or not.

8.2 The Stakeholders should understand and adhere to this Policy i.e. the Company’s Code

of Conduct, Employee Handbook, and other Company policies while using social media

in reference to the Company.

8.3 All the Stakeholders should use prudent judgement and use proper language while

posting on social media.

8.4 No employee without the permission of the management can represent the brand on

any social media platform. Comparison with and disparagement off other brands on

any social media platform is absolutely prohibited.

8.5 The Stakeholders should not publish, post or release any information which is

confidential or not public.


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8.6 Any sensitive Company information or content available within Mankind internal

networks should not be shared on social media.

8.7 The Stakeholders must brand their social media posts as personal and the Company

should not be held liable for any consequences of the content posted.

8.8 While posting on social media, an employee should always comply with copyright law

and any other applicable law, and reference the source of the content if it is not their

own.

8.9 Antinational Post & Activity on social media may lead to immediate termination.

9. POLICY ON PROFESSIONAL ETIQUETTES AT WORKPLACE

9.1 The Company’s policy on professional etiquettes at workplace has been drafted to

further the commitment of the Company to the highest possible standards of ethical,

moral and legal business conduct.

9.2 The main objective of the policy on professional etiquettes at workplace is to provide

to all the Stakeholders of the Company a safe working environment and ensure that

they are treated with dignity and respect. The policy on professional etiquettes at

workplace also endeavours to set expectations regarding moral and ethical workplace

behaviour and provide all the complainant a framework for reporting concerns.

9.3 For detailed policy and information about the reporting mechanism, method of

investigation etc., please refer to the Company’s policy on professional etiquettes at

workplace.

10. WHISTLE BLOWER POLICY

10.1 The Company’s whistle blower policy has been drafted to further the commitment of

the Company to the highest possible standards of ethical, moral and legal business

conduct. The main objectives of the whistle blower policy are:

To provide a vigil mechanism to raise concerns of unethical practices in good faith and a fair framework consistent with the statutory environment for reporting and inquiry; and

To provide necessary safeguards for protection of the Company’s Stakeholder from reprisals or victimization, for whistle blowing.

10.2 The Company has zero tolerance towards unethical or illegal standards of business

conduct.


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10.3 The Company’s Stakeholders are expected to uphold professional integrity, honesty

and ethical behaviour in the conduct of the affairs of the Company’s business across

all locations and entities.

10.4 The whistle-blowing framework at the Company will not be influenced by an

individual’s position, race, colour, sexual orientation, gender identity/ expression,

political belief, religion, marital status, caring responsibilities, national or ethnic

origin, disability, age, citizenship or membership of a representative body.

10.5 For detailed policy and information about the reporting mechanism, method of

investigation etc., please refer to the Company’s whistle blower policy.

11. REGULATORY COMPLIANCE

11.1 Every Stakeholder of the Company shall, in his or her business conduct, comply with

all applicable laws and regulations, both in letter and in spirit, in all the territories

in which he /she operates.

11.2 If the ethical and professional standards set out in the applicable laws and regulations

are below that of the code of conduct, then the standards of the code of conduct

shall prevail.

12. ACTION FOR NON-COMPLIANCE

Allegations of non-compliance with the Code of Conduct will be investigated and

evaluated at the proper level(s). Those found to be in violation of this Policy shall be

subject to appropriate disciplinary action, up to or including termination of

employment. Criminal misconduct may be referred to the appropriate legal

authorities for prosecution.

13. COMMITMENT TO NON-RETALIATION

Mankind prohibits retaliation, in any form, against anyone who, in good faith, reports

violations or suspected violations of this Policy, other policy/ies, or applicable law,

or who assists in the investigation of a reported violation. Acts of retaliation should

be reported immediately to Human Resources or Legal Department.

14. AMENDMENT IN THE POLICY

The Company reserves the right to amend the Policy, as and when it requires.


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ANNEXURE - 1

GIFT DISCLOSURE FORM

RECIPIENT INFORMATION

Employee Name:- Designation:-

Employee Code:- Department:-

GIFT INFORMATION Date of Receipt of Gift __________________

Is the Gift/ Hospitality and Entertainment offered to:

Government Officer ☐

Commercial Party ☐

Others ☐

If the Gift, Hospitality and Entertainment was offered to a Government Official, was compliance officer’s prior approval obtained for the same:

☐ Yes ☐ No

Description* of Gift:

Gifted by:- Estimated Gift Value:-

Contact Details:-

Relationship with Gift Provider:-

I hereby affirm that the gift details reported above is true, accurate and complete. The submission of a false statement shall be considered as a violation of the Code of Conduct Policy. Date:_______________ Employee’s Signature: ______________

ACKNOWLEDGEMENT BY ADMINISTRATION DEPARTMENT (For employees)

Employee Name:-

Gift Description:-

Declaration: I declare that the information provided above is accurate and complete to the best of my knowledge and belief. I further declare that the activities I have engaged in, on behalf of Mankind, are in compliance with the Company’s policies. I also declare that I understand and agree that failure on my part to immediately report an offer of Gifts, Hospitality and Entertainment, constitutes as non-compliance to this Policy and I could be subjected to disciplinary actions as prescribed in this Policy.


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Acknowledged By (Name): ________________________ (Admin Department)

Date: ________________

Signature:______________________

* Attach separate list of gifts if more than one gift received.

ANNEXURE - 2

CODE OF CONDUCT POLICY ACKNOWLEDGEMENT FORM

I acknowledge that I have received a copy of the Mankind Pharma Ltd.’s Code of Conduct

(“Policy”). I have read and understood all my obligations, duties and responsibilities

under each principle and provision of the Policy I hereby agree to comply with the

requirements outlined in the Code of Conduct.

If any situation involving a conflict, potential conflict, or perceived conflict of interest

or violation of the Mankind’s Code of Conduct occurs, I will report it immediately, as

documented within this Policy.

I affirm that non-compliance or violation of aforesaid Code of Conduct (whether wholly

or partially) by me shall constitute material breach of terms of my employment and in

such eventuality(s), the Company shall be authorized to take disciplinary action against

me, including termination of my employment and/or any other legal action as deemed

fit & proper by the Company.

I certify that this is a true and correct statement.

Signature: _______________________________

Name: _______________________________

Employee Code: _______________________________

Date: _______________________________


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ANNEXURE - 3

MEDIA DISCLOSURE FORM

EMPLOYEE INFORMATION

Employee Name:- Designation:-

Employee Code:- Department:-

MEDIA DISCLOSURE INFORMATION

Media Agency Name:-

Contact Person/Details:-

Type of Media Disclosure:-

Details required:-

Target Audience:- Event Date:- Event Time:-

I hereby affirm that the external communication details reported above is true, accurate and complete. The submission of a false statement shall be considered as a violation of the Code of Conduct Policy.

Date: ______________ Employee’s Signature: ______________

Basis of Approval/Rejection: Name: ________________________ (HR Department)

Date: ________________

Signature:______________________

MANAGEMENT APPROVAL/REJECTION


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Approved: Rejected:-

Date: ________________

Signature:______________________

* Attach a final copy of the particulars disclosed to the respective media agency for the final sign-off

from the Management. The particulars shall be published only after the final approval from the

Management

* A copy of this form duly signed by Management is to be kept with the employee.


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ANNEXURE - 2

CODE OF CONDUCT POLICY ACKNOWLEDGEMENT FORM

I acknowledge that I have received a copy of the Mankind Pharma Ltd.’s Code of Conduct

(“Policy”). I have read and understood all my obligations, duties and responsibilities

under each principle and provision of the Policy I hereby agree to comply with the

requirements outlined in the Code of Conduct.

If any situation involving a conflict, potential conflict, or perceived conflict of interest

or violation of the Mankind’s Code of Conduct occurs, I will report it immediately, as

documented within this Policy.

I affirm that non-compliance or violation of aforesaid Code of Conduct (whether wholly

or partially) by me shall constitute material breach of terms of my employment and in

such eventuality(s), the Company shall be authorized to take disciplinary action against

me, including termination of my employment and/or any other legal action as deemed

fit & proper by the Company.

I certify that this is a true and correct statement.

Signature: _______________________________

Name: _______________________________

Employee Code: _______________________________

Date: _______________________________

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