CODE OF CONDUCT

Grasim Industries Limited is in the business of production of Pulp & Fibre, Chemicals including Advanced Materials
and Fertilizers, Textiles, and Insulators. Grasim Industries Limited is a values driven organization. Our core values
are Integrity, Commitment, Passion, Seamlessness, and Speed. These values are the foundation for all actions and
decisions in our Business.

The Company is committed to Aditya Birla Group’s corporate principles. These include:

1. Employees: People build our Group's Success

We believe that our employees provide us with the cutting edge. They help us deliver value for our
shareholders, our customers and society at large. Our employees are our strength. We respect the individual
rights and dignity of all employees.
2. Customer: Customer is the focus of everything we do
We are committed to our customers, for fulfilling their present needs and anticipating their unmet needs.
We are dedicated to continuously improving the quality, usefulness and value of our products that help our
customers.
3. The Government
We respect the Government and maintain an open and co-operative relationship with our regulators and
comply with all the applicable laws, rules and regulations. While participating in democratic processes, we
remain apolitical.
4. Environment, Health & Safety
Respect for the environment forms part of everything we do. As an environment responsive Group, our ongoing
endeavour is to operate through processes that have as little impact on the environment as possible.

This Code is applicable to all the employees of the Company and every employee, upon joining the organization,
shall commit to the Code of Conduct by signing a declaration. These practices to be adopted by each and every
employee irrespective of the job/role performed by her/him and any breach or casual attitude towards any of these
shall attract disciplinary action.

Code of Conduct:

I. Integrity in Personal Conduct

• All employees shall abide by the laws of the land in whichever country we operate in.
• All employees shall transact with others (including each other) in a fair and dignified manner, including
being diversity sensitive.
• Each employee shall be responsible to the best of his/ her knowledge, for fair representation and
accuracy of information in the documents prepared or signed off by him / her.
• Each employee shall ensure that his/ her personal information provided to the organization is factual
and accurate including prior work experience, educational qualification, compensation details, etc.

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 • Each employee shall be responsible to ensure that official expenses and personal claims e.g. Travel
expenses, Medical, LTA, HRA, Vehicle running expenses, etc shall be factual, correct and within the
organization rules.
• No employee shall use organization time and resources for personal gain
• No employee shall receive any gift, consideration or favour in cash or kind for self (or any family
members or relatives) from business partners or anyone with whom he/she has dealings on behalf of
the Company / Aditya Birla Group.

Employees are also expected not to receive “expensive gifts” from business partners at the time of social functions
or occasions such as their children’s wedding or their own personal anniversaries. However, small business gifts
such as pen stands, leather items carrying logo of the gifting organization, sweets, dry fruits, chocolates at the time
of Christmas, Diwali, New Year, etc are exempt from this provision. The essential determinant here being: the size
and cost of gift received and the obligation that it creates which puts our actions and decisions subsequently in a
questionable light.

II. Conduct at Work

• All employees shall take decisions in the best interest of the Company and Aditya Birla Group..
• All employees shall adhere to the Company / Aditya Birla , processes, systems and regulations in letter
and spirit.
• All employees shall secure the physical, financial and intellectual property/ assets, interests of the
organization by observing the discipline of internal controls.
• Each employee shall highlight deviations to his/her manager from stated Organization process and
policy by an individual or a team.
• All employees shall ensure safe and secure working environment for themselves and others by
observing discipline on internal guidelines.
• Each employee shall support the team / larger organization by sharing knowledge, information and
resources available with him/her or within his/her area of influence.
• Each employee, who comes across or handles confidential data about the organization, business and
personnel working within the organization, must maintain confidentiality of information (e.g.
acquisition plan, personal details, health record, family, performance, etc) and share the same only with
authorized personnel for legitimate purposes.
• Each Manager shall take and communicate people related decisions fairly, objectively and only on need
to know basis.
• Each employee shall promote cooperative and professional relationship of his/her team with other
functions and businesses within the Company / Aditya Birla Group to promote its larger intent.
• No employee shall indulge in providing, promising or accepting a request of money or other benefits
through gifts, gratuities, donations, sponsorships, hospitality and entertainment expenses in
whatsoever form from Company's business associates.

• No employee should offer, promise, pay or authorize payments, directly or indirectly, to influence the
decisions of any government official, authority or third-party.

• All employees shall respect and protect the confidential information and intellectual property of the
partners and other companies that are provided to us under agreement for specific use and shall pay
appropriately for technology / software usage.
• Each employee shall take prompt action/ decision on any complaint that is received regarding a Value
departure/ Violation or Code of Conduct.
• All employees shall report unethical business practices or any incidents of non-adherence to the Code
of Conduct as per the procedure laid in Grasim’s Whistle Blower Policy and all such complaints shall be
addressed as per the Guidelines in the Whistle Blower Policy.
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 • All employees shall be provided equal opportunities and shall treat all employees with respect and
dignity in their place of work and provide them with a working environment, free of discrimination that
promotes inclusion and diversity.

III. Conflict of Interest

• Each employee shall ensure that all people related decisions including hiring, allocation of job
responsibilities, performance rating, promotion, etc. are free from bias and personal interest.
• Each employee shall ensure that if there is a perceived conflict of interest in a transaction, e.g. the
vendor is “personally known” to individual, he/ she shall inform his/her interest to the team/ individual
concerned and his/her manager and refrain from being part of the decision making process.
• No employee shall indulge in any action that may be construed as conflict of interest. e.g. Insider trading,
Moonlighting, Personal investment in Business Partners/ Competition, etc.
• Each employee shall ensure that all policies of the Company / Aditya Birla Group dealing with conflict
of interest are adhered to e.g. employment of near relations, business dealing with friends and relatives,
reemployment of Ex- employees, etc.

IV. Non-Discrimination and Harassment

Grasim strongly believes that mutual respect promotes productivity, minimizes disputes, reduces conflicts and
enhances reputation. We expect that every employee should respect each other, our customers, suppliers and
vendors. Harassment by co-workers, supervisors, or any third parties is a form of misconduct that destroys our work
environment and undermines the integrity of the employment relationship. Grasim is committed towards providing
a work environment that is free of unlawful discrimination, including harassment and will not tolerate any form of
harassment or discrimination that violates this code.

• All employees shall ensure mutual respect in the workplace. Grasim prohibits harassment of any kind,
including sexual and non-sexual harassment. These include verbal or written remarks related to religion,
race, ethnicity, gender or age, physical or sexual advances or visual displays, threatening gestures or
expressions of violence, threats of violence etc.
• Bullying and harassment in any form is totally inappropriate in the workplace. Grasim shall take
appropriate and immediate action in response to complaints or knowledge of violations of this Code.
• This code on Non-discrimination in employment applies to recruitment, hiring, compensation,
promotions, transfers, discipline, demotions, terminations, layoffs, access to benefits and training and
all other aspects of employment.
• Employees with questions or concerns about any type of discrimination in the workplace are
encouraged to bring these issues to the attention of their Manager or the Human Resources
department.
• Employees are encouraged to voice their concerns and submit reports without fear of retaliation.
• Any Grasim employee found to be engaging in any type of unlawful discrimination will be subjected to
disciplinary action as decided by the Management

V. Anti- Corruption and Bribery

All Grasim personnel are strictly prohibited from engaging in any form of corruption or accepting any kind of bribe.
This Policy extends across all of the Company's business dealings and territories in which the Company operates. All
persons covered by this Policy, in discharging their duties on behalf of Grasim are required to comply with the laws,

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rules and regulations applicable in the location in which Grasim is performing business activities, and in particular
with respect to anti-bribery and corruption laws, rules and regulations.

Grasim endeavors to foster and maintain organizational culture of zero tolerance against Corruption and Bribery.

Prohibited activities under this Code

It is prohibited, for any staff or individual acting on behalf of Grasim to offer, give, request or accept any bribe
directly or indirectly (i.e. gifts with mala-fide intentions, loan, payment, reward or advantage, either in cash or any
other form of inducement), to or from any person or company in order to gain commercial, contractual or regulatory
advantage for the Company or in order to gain any personal advantage for an individual or anyone connected with
the individual in a way that is unethical.

Further this Code strictly mandates to abide by the following principles:

• Not to offer, promise or make any bribe or unauthorized payment of any kind to anyone
• Not to solicit business by offering, promising or making any bribe or unofficial payment to suppliers,
vendors or contractors
• Not accepting any sponsorships/donations for accepting requests from any of the stakeholder
• Payment of any costs for government officers and their relatives (or in their interests) or other agencies
in order to obtain commercial advantages
• Accepting or giving gifts/entertainment options for Government officials, Suppliers, Vendors etc. in
return of any offers

Reporting and Investigation

Grasim has well developed whistleblower mechanism for complaint handling and processing of cases related
to violation of laws and rules.
The Company shall communicate, create awareness and disseminate the Anti Corruption and Anti Bribery
Codes to all its employees, vendors, suppliers and subsidiaries through various channels like orientation and
induction to Directors, new recruits, regular training on changes in the Code to all staff on forms of corruption
and bribery, repercussions of being involved in such an Act. Grasim shall regularly spread the word among all
relevant stakeholders that accepting or giving bribe is a Criminal offence under Indian Penal Code and there
can be Legal consequences
Any Grasim personnel shall not take any action casually or lightly in case of detecting an act that constitutes to
be an act of corruption or bribery. Also, it is the duty of the personnel to notify the concerned persons of such
an undue activity and give full support and co-operation in investigating the facts.

VI. Health and Safety

• All employees shall comply with laws, standards, regulations and good practices on health and safety
and cooperate on compliance with international agreements to prevent or mitigate possible impacts.
• All employees shall report to the Manager/Functional head/Unit Head if he/she becomes aware of any
circumstances relating to operations or activities which poses a real or potential risk on health or safety,
or any incident with a probability to impact ‘Business as Usual’ scenario.
• No employee shall work if under the influence of alcohol or drugs

VII. Use of Information Technology

• No employee shall use the organization’s IT systems, internet access, e-mail accounts or any other
information and communication media for illegal or unethical purposes.

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 • Any employee searching, downloading or forwarding information that is abusive or offensive may lead
to disciplinary measures.
• All employees must be aware that he/she is not allowed to use or copy software or data from the
organization's IT systems for private purposes or install private software at the workplace or on any
company device.

VIII. Interface with the External World

• All employees shall ensure that their interactions and transactions with customers and partners are
transparent, professional and leave a positive image of the Company and Aditya Birla Group.
• All employees shall ensure that commitments that are legitimately made are honored.
• No employee shall encourage our business partners to indulge in unfair trade practices with their
customers.
• Each employee shall respect free market and fair competition, and shall not seek to violate anti-trust
and competition laws.
• No employee shall deride or criticize the Company and Aditya Birla Group, its businesses and policies at
any public forum. Any such criticism shall be voiced within the organization.
• Only official spokespersons shall represent the Company and Aditya Birla Group with the Media. In case,
the media attempts to talk to any employee either formally or informally regarding the Group, and its
businesses, the same should be redirected to the official spokespersons.
• Any disclosure of organization information informally to the media shall constitute violation of Code of
Conduct.
• All employees shall ensure that their personal conduct in a public place and with public is dignified and
reflective of Group Values.
• All employees shall bring to attention, in case they notice infringement of intellectual property of the
Group such as misuse of logo, misrepresentation of product, malicious propaganda, etc.