PRIVACY POLICY

Our Commitment

KHADIM INDIA LTD. (hereinafter referred to as “KHADIM”) values its customers and is committed to protecting their privacy. This Privacy Policy (hereinafter referred to as the “Policy”) explains what personal information may be collected from you, the purposes for which it is used, how it may be shared, and your rights concerning the collection, use, and disclosure of your information. KHADIM will not collect, use, or disclose your personal data except in accordance with this Policy.

By accessing www.khadims.com and/or purchasing KHADIM products, you expressly agree to the terms and conditions of this Policy. Any changes to the Policy will be communicated by updating it on the website. It is your responsibility to regularly review the Policy for updates.

Your continued use of the website after changes have been posted signifies your acceptance and binding agreement to the updated terms. If you choose to discontinue using the website without taking further action regarding your personal data, your data will remain subject to the terms of the Policy as it existed prior to the changes.

Information Collection

KHADIM collects personal information when you provide it to us, such as during registration on www.khadims.com, account setup, placing orders, contacting us via email or phone, or participating in surveys, promotions, or contests either online or at our retail outlets.

Such information may include, but is not limited to, your name, phone number(s), postal and email addresses, credit card details, names and contact details of individuals receiving shipped orders, financial information, product preferences, and in some cases, your individual preferences and opinions.

KHADIM website is intended for use by adults only. Personal information from individuals under 18 years of age is not knowingly collected. Persons under 18 should not use the website or provide personal data.

Purpose of Use

Your personal information may be used by KHADIM for the following purposes:

• Processing and fulfilling your orders and responding to order-related queries
• Shipping products to you or your authorized recipients
• Communicating with you via post, email, or other channels about services, personalized offers, promotions, surveys, events, and contests
• Understanding your shopping interests to better serve you
• Conducting marketing and performance research, measuring customer service, and enhancing product offerings and shopping experience

You may opt out of receiving marketing or promotional communications as detailed below.

Promotional Communications

KHADIM will only send promotional communications if you consent to receive them. To opt out, please contact us via our toll-free number 1800 103 0501 or email customercare@khadims.com. Kindly provide your full name and the email address used during registration or purchase. Processing of such requests may take up to two weeks, during which communications may continue.

Access and Correction of Personal Information

KHADIM strives to maintain accurate, complete, and up-to-date personal data as required for the purposes described. You have the right to request access to and correction of your personal information. Requests, complaints, or inquiries regarding this Policy or KHADIM privacy practices should be addressed in writing to:

Privacy Officer
Khadim India Ltd.
7th Floor, Tower C, DLF IT Park
08 Major Arterial Road, Block - AF, New Town (Rajarhat)
Kolkata – 700163

You may withdraw consent to the collection, use, or disclosure of your personal data at any time by notifying the Privacy Officer. Your personal data will be retained only as long as necessary for the purposes set out in this Policy or as required by applicable law.

Sharing of Information with Third Parties

KHADIM may share your personal information collected through www.khadims.com, surveys, contests, promotions, or retail purchases with its Affiliates for communication purposes, including promotional offers and information about products, services, and contests that may interest you.

Your personal information will not be sold or rented to non-affiliated third parties except as required or permitted by law. In the event of a sale or transfer of KHADIM business or assets, personal data may be transferred to the buyer or prospective buyer to facilitate the transaction and business operations.

Non-affiliated third parties may process your personal data on behalf of KHADIM under strict confidentiality agreements and security measures that prevent use or disclosure for any other purposes.

KHADIM website may contain links to third-party websites, which have their own privacy policies. KHADIM is not responsible for the data collection practices or content of these external sites. Users are advised to review the privacy policies of any third-party sites visited.

Security

KHADIM acknowledges the sensitive nature of personal data and has implemented appropriate technical, administrative, and physical safeguards to protect against unauthorized access, loss, theft, misuse, alteration, or disclosure of your personal information. This Policy applies to all employees and agents of KHADIM and governs their handling of personal data.

AUDIT / COMPLIANCE

Our factories have been audited and approved for ethical standards

TERMS & CONDITIONS

WEBSITE USAGE

KHADIM INDIA LTD. (hereinafter referred to as “KHADIM”) is the owner of www.khadims.com and operates it for your personal use and information. By accessing and browsing this website, you unconditionally accept the following terms without limitation or qualification. This website is intended solely for adult use. You affirm that you possess the legal capacity to enter into binding agreements. KHADIM reserves the right, at its sole discretion, to cancel orders or refuse service.

PRIVACY POLICY

Your access to and use of this website is governed by KHADIM Privacy Policy. By using this website, you acknowledge your awareness of its terms and agree to be bound by them. You further consent to KHADIM use of your personal data in accordance with the Privacy Policy, which may be amended periodically.

PRODUCT INFORMATION

KHADIM makes every effort to ensure that product information, descriptions, and depictions—including colour and appearance—are accurate. However, due to variations in display quality and other factors, the actual product may differ from what appears on your screen. KHADIM does not guarantee the precision, completeness, or reliability of any product details, descriptions, or images on the site.

If you are dissatisfied with any product description upon receiving the item, you are advised to return the product unused and undamaged, along with the original invoice.

We may establish general limitations concerning the use of the website and its services, including but not limited to restrictions on the size or number of messages, content stored or sent, or the duration such materials remain on the site. KHADIM may modify or delete any website content at any time and bears no responsibility for doing so.

LIMITATION OF LIABILITY

KHADIM shall not be liable for any direct, indirect, incidental, or consequential damages arising from:

• The use or inability to use products, services, or materials provided.
• Any damage caused to your computer or software resulting from your access to the website.

While every effort is made to ensure the site is free from viruses or defects, you are responsible for using suitable equipment and protective software when accessing the site.

WARRANTY EXCLUSION

KHADIM does not guarantee that this website or any associated content, data, software, or material is free from errors, viruses, bugs, worms, Trojan horses, or other harmful components. All information on this site is provided “as is,” without any warranties, whether express or implied.

TRADEMARKS & COPYRIGHTS

All content on this site—including text, images, audio, video, and software—is the property of KHADIM and protected by the Copyright Act, applicable Intellectual Property Laws, and international treaties. You may not reproduce, republish, distribute, post, transmit, modify, or reuse any of the content in whole or in part without written permission. The trademarks, service marks, and logos (collectively “Marks”) displayed are the property of KHADIM or their respective owners. Use of these Marks without express authorization is prohibited. Nothing in these terms confers any license or right to use any such intellectual property.

ELECTRONIC COMMUNICATIONS

By visiting this website or sending emails to KHADIM, you are engaging in electronic communication and consent to receiving communications from KHADIM electronically. Such communications—whether by email or notices posted on the website—meet any legal requirement that such communications be in writing.

SURVEILLANCE

KHADIM may monitor activity on the site and intervene, if necessary, although it does not guarantee such monitoring will occur. You consent to any such monitoring or intervention if it takes place.

CONFIDENTIALITY

Information or material submitted electronically via this site is not considered confidential or proprietary unless required by applicable law or KHADIM Privacy Policy. You understand the risks associated with unsecured internet communication and agree not to submit any material that infringes upon the rights of others. KHADIM is free to use such material, including ideas and concepts, for its commercial purposes. You agree to disclose your identity as required under KHADIM Privacy Policy.

HARMFUL MATERIAL / INFORMATION

You are prohibited from introducing any harmful content through this site, including defamatory, obscene, or unlawful material that could lead to civil or criminal liability.

LINKS

Links to third-party websites are provided for your convenience. KHADIM does not endorse, verify, or assume responsibility for any third-party content, products, or services accessible through such links. You may not link to this website without KHADIM prior written consent.

KHADIM does not warrant that access to the site or its contents will be uninterrupted, error-free, or free of harmful components, nor is it obligated to correct any such issues.

RESERVATION OF RIGHTS

KHADIM reserves all rights not expressly granted under these terms. Nothing herein shall be construed as conferring any license or right to use any intellectual property of KHADIM or third parties.

RESOLUTION OF DISPUTES BY ARBITRATION

Any dispute or claim arising out of or relating to use of this website, including the scope of this arbitration clause, shall be finally resolved by a Sole Arbitrator appointed by KHADIM, pursuant to the Indian Arbitration and Conciliation Act, 1996. Before initiating arbitration, parties must attempt to resolve the dispute by contacting KHADIM customer service. If unresolved after 60 days, either party may request arbitration. KHADIM will appoint the Arbitrator within 15 days of receiving such request. The arbitration shall be held in Kolkata, in English, and governed by Indian law.

The arbitrator’s decision shall be binding and enforceable in any court of competent jurisdiction. Notwithstanding this clause, KHADIM may seek interim or injunctive relief from any competent court to protect its intellectual property or confidential information.

GOVERNING LAW

This website is controlled and operated from Kolkata, India. All matters arising out of or related to this website shall be governed by the laws of India, without reference to conflict of laws principles. Any exports through this site are subject to Indian export laws and regulations.

COOKIES

Cookies are small data files used by this website to recognize your device and store your preferences. These are intended to improve your experience during future visits. Cookies do not transmit information once you leave the site and can be deleted at any time. Re-entering your preferences may be required upon re-login. Cookie Policy

ABSENCE OF WAIVER

KHADIM failure to enforce any provision of these terms or respond to a breach shall not be considered a waiver of its rights to enforce such provisions in the future or respond to similar breaches.

SEVERABILITY / CHANGES TO TERMS

KHADIM reserves the right to modify or update these terms at any time. Continued use of the website constitutes acceptance of such changes. If any term is found invalid or unenforceable, that term shall be severed without affecting the validity or enforceability of the remaining terms.

FULL AGREEMENT

These terms, along with referenced or incorporated policies, constitute the entire agreement between you and KHADIM regarding use of the website and supersede any prior understandings, whether written, oral, or electronic.

TERMINATION

KHADIM reserves the right to terminate your access to the site, in whole or in part, at its sole discretion, with or without notice.

HEADINGS

Headings are provided for convenience only and shall not affect the interpretation of these terms.

SAFE SHOPPING

Security Policy

This Security Policy outlines the security practices of www.khadims.com and describes the measures implemented to prevent the alteration, misuse, or loss of information under the control of KHADIM INDIA LTD.

Online Data Security

The website employs all necessary online and offline safeguards to protect any sensitive information submitted by YOU, the user.

When you provide confidential information (such as credit card details), it is encrypted and secured using SSL (Secure Sockets Layer) technology. This is a widely accepted standard for protecting sensitive data transmitted over the Internet. When you access a secure page, the lock icon in web browsers like Microsoft Internet Explorer or Netscape Navigator is activated, indicating a secure connection—unlike during standard browsing when it appears open or unlocked. This secure connection ensures that data transmitted by you cannot be easily intercepted or accessed by unauthorized parties.

Additionally, our servers that store personally identifiable information are hosted in a secure environment protected against unauthorized access, hacking attempts, and virus threats.

Offline Data Security

Alongside online safeguards such as SSL encryption, we employ comprehensive offline measures to ensure data protection.

All information you provide is securely maintained within our offices. Access to personally identifiable information is strictly limited to employees who need the data to fulfil specific job functions (such as customer service representatives or billing clerks). Furthermore, KHADIM INDIA LTD. regularly educates its employees about privacy and security protocols. Employees are consistently reminded of the importance of protecting customer information and are instructed on best practices to uphold these standards.

For any questions or concerns regarding the security of our website, please contact us at: customercare@khadims.com

COOKIES POLICY

This Cookies Policy is an integral part of KHADIM Privacy Policy and should be read in conjunction with it. All relevant provisions from the Privacy Policy, including those related to transparency, data processing purposes (such as functionality, preferences, analytics, and marketing), consent, third-party data sharing, data retention, and applicable law, shall apply to this policy.

What Are Cookies?

Cookies are small text files stored on your computer or internet-enabled devices (such as smartphones or tablets) when you visit a website. They help the website recognize your device on subsequent visits.

Cookies serve various purposes, including remembering user preferences, tracking activity, and enhancing the overall user experience. This helps us better manage our website and deliver a more personalized service.

Most cookies do not collect personally identifiable information. Instead, they collect general data such as your location or how you navigated to and interacted with our site.

Managing and Deleting Cookies

Your privacy matters to us, and we provide you with control over your cookie preferences. However, please note that disabling certain cookies may impact your experience and the functionality of the site.

You can manage or disable cookies by adjusting your web browser settings. Options include:

• Setting your browser to alert you when a cookie is being placed, allowing you to accept or reject it;
• Automatically rejecting all cookies by default.

For more detailed guidance, refer to your browser’s help section:

• Apple Safari: Manage cookies and website data
• Google Chrome: Manage cookies in Chrome
• Microsoft Internet Explorer: Delete and manage cookies
• Mozilla Firefox: Enable and disable cookies

For more information about how we handle your personal data, please refer to our Privacy Policy.

Privacy Preference Centre

When you visit our website, we may store or retrieve information via cookies, typically used to make the site function as expected and enhance your experience. Although this information generally does not identify you personally, it can offer a more customized browsing experience.

You have the right to manage your cookie preferences. Please note that disabling certain types of cookies may affect your site experience and the services we can offer.

Manage Consent Preferences

1. Strictly Necessary Cookies – Always Active: These cookies are essential for the website’s operation and cannot be turned off. They are usually set in response to actions you take, such as setting privacy preferences, logging in, or filling out forms. They do not store any personally identifiable information.
2. Performance Cookies – Optional: These cookies help us analyse website traffic and performance by collecting aggregated, anonymous data on how users interact with the site. Disabling these will hinder our ability to monitor and improve site performance.
3. Functional Cookies – Optional: These enable the website to provide enhanced features and personalization. They may be set by us or third-party service providers. If disabled, some site functions may not work as intended.
4. Targeting Cookies – Optional: Set by advertising partners, these cookies build a profile of your interests to show you relevant ads on other sites. They don’t directly store personal data but work by identifying your browser and device. Disabling them will reduce targeted advertising.

DISCLAIMER

This website and the information it contains are intended solely for informational purposes. Khadim India Ltd. (hereinafter referred to as “KHADIM”) shall not be held liable for any loss or damage (including consequential loss or damage) suffered, incurred, or arising directly or indirectly as a result of any information provided on this website.

Updates are made regularly to ensure the provision of the most current and accurate information. However, some information may still not be up-to-date. Visitors are therefore advised to consider this when reviewing the content provided on the site.

YOU ARE STRONGLY ADVISED TO VERIFY THE ACCURACY OF ANY INFORMATION PUBLISHED ON THIS SITE DIRECTLY WITH THE COMPANY, EITHER IN WRITING OR BY TELEPHONE, PARTICULARLY IF THE INFORMATION IS TO BE USED FOR LEGAL PURPOSES.

KHADIM does not accept liability for any form of communication, including EMAIL, transmitted via the Internet to or from this website. The Company is not obligated to read, respond to, or act upon any such communications. Any user choosing to contact the Company via these means does so at their own risk and not that of the Company.

Nonetheless, electronic communication is valued by the Company, which endeavours to provide a high standard of customer service comparable to that provided through other communication channels.

COPYRIGHT AND INTELLECTUAL PROPERTY RIGHTS

This website is protected under Intellectual Property Law. Copyright 2013 applies to all materials located under the domain www.khadims.com. Unless expressly stated otherwise, KHADIM holds the copyright for all content under this domain. Every page on this site, including but not limited to the artwork, text content, and source code, is protected by copyright.

Except as permitted under the Copyright Act 1968 or any applicable legislation worldwide, or as explicitly permitted in this copyright notice, no material from this site may be reproduced, published, stored, transmitted, or adapted by any means or in any form—including but not limited to photocopying, recording, or any electronic, mechanical, optical, or magnetic means—without prior written consent from the copyright owner.

All enquiries should be directed to:

Khadim India Ltd.
7th Floor, Tower C, DLF IT Park
08 Major Arterial Road, Block - AF, New Town (Rajarhat)
Kolkata – 700163

Unless otherwise indicated, KHADIM authorizes you to:

• Print copies of material from the site for non-commercial, informational purposes;
• Store a local copy on your computer solely for viewing purposes;
• Distribute or reproduce full pages of material, provided no portion less than a full page or, in the case of multi-page documents, less than the complete document is distributed or reproduced. All such copies must retain this copyright notice and provide proper attribution to KHADIM.

All other rights are reserved by the copyright owner(s).

The KHADIM logo is protected by intellectual property laws and may not be used by you or any other person except as part of an authorized reproduction of the material as described above. Alteration of the KHADIM logo in any form is strictly prohibited.

KHADIM does not represent or warrant that content on external websites linked through this site does not infringe the intellectual property rights of any person. By providing such links, KHADIM neither endorses nor assumes responsibility for any such external content or potential infringements.

TERMS AND CONDITIONS FOR WEBSITE ACCESS

By accessing this website, you agree to use the information provided in the materials on this website entirely at your own risk. While the content is periodically updated, it may contain technical inaccuracies. All information is provided “AS IS,” without warranties of any kind.

KHADIM expressly disclaims all warranties, whether express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, accuracy, and quality. No assurance is given regarding the reliability of the materials provided on this website, nor any guarantee concerning the outcome of using such materials.

This website may contain frames, hyperlinks, or references to external websites and third-party content. As KHADIM does not control the content of these external sites, it makes no guarantees regarding their accuracy, relevance, or subject matter. Inclusion of such references does not constitute an endorsement, sponsorship, or approval of those entities or their services and products.

To the fullest extent permitted by law, KHADIM and its authors disclaim all liability to any individual for actions taken—or not taken—as a result of using, downloading, or relying on any materials from this website. Liability is limited to either the re-supply of the materials or the reasonable cost of re-supplying them.

KHADIM makes no representation or warranty that files obtained from or through this site are free from viruses or defects. Use of such files is at the user’s sole risk, and any resulting loss, damage, or other consequences are the user’s responsibility.

LABOUR COMPLIANCE DETAILS OF KHADIMS INDIA LIMITED

vigil mechanism / whistle blower policy

Preface

Section 177 of the Companies Act, 2013, and the Rules made thereunder (‘Act’) and Regulation 4(2)(d)(iv), 22 and 46(2)(e) of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) (“Listing Regulations”) contain detailed provisions on Vigil Mechanism or Whistle Blower Mechanism which needs to be implemented in all Companies governed under the Statutes. Moreover, Khadim India Limited (‘Company’) believes in the conduct of its affairs in a fair and transparent manner by adopting and upholding highest standards of ethics, professionalism, honesty and integrity.

Through this policy, the Company shall enable all employee and / or associate to raise their complaints / concerns / grievances related to any form of misconduct, mismanagement or any kind of violation of laws, rules or regulations in the Company, in a prescribed method, without any fear of victimization and persecution. This Policy shall also ensure the confidentiality of the complainant’s identity, complaints and disclosures as well as the identity of the person against whom the complaint has been raised and investigation is being carried out by the competent authority, following the basic principles of natural justice.

Short Title, Applicability and Commencement

1. This Policy shall be called as “Khadim India Limited - Vigil Mechanism / Whistle Blower Policy” (‘Policy’).

2. This Policy shall apply to all the employees (including temporary, outsourced and contractual), stakeholders and associates of the Company.

3. This Policy shall come into force with effect from April 01, 2019.

Definitions

1. “Associate” shall mean business associates of the Company including existing or proposed consultants, service providers, Lessors / Owners of Properties etc.

2. “Audit Committee” shall mean the Audit Committee of the Board of Directors of the Company constituted / re-constituted in accordance with Section 177 of the Companies Act, 2013.

3. “Board" shall mean the Board of Directors of the Company.

4. “Competent Authority”” shall mean the following office bearers of Khadim India Limited:

   • Chief Financial Officer and, or
   • VP – HR or Head - HR and, or
   • Company Secretary & Head - Legal and, or
   • Head – Internal Audit and, or

who shall act jointly and severally as the Competent Authority under this Policy.

5. “Disciplinary Action” shall mean any punitive action (more fully and particularly described in clause 10 of this Policy) that can be taken against the accused, where the Committee finds him / her guilty on completion of / during the investigation proceedings.

6. “Employee” shall mean every employee including temporary employee, outsourced employee and contractual employee of the Company including Whole-time Directors.

7. “Whistle Blower” means an Employee or Director who makes a Protected Disclosure / Complaint under this Policy.

8. Un-published Price Sensitive Information (“UPSI”) shall mean any information, relating to a Company or its securities, directly or indirectly, that is not generally available and which, upon becoming generally available, is likely to materially affect the price of the securities and shall, ordinarily include but not restricted to, information relating to the following:

   1. Periodical financial results of the Company;
   2. Intended declaration of dividends (Interim and Final);
   3. Change in capital structure i.e. Issue of securities, buy - back of securities or any forfeiture of shares or change in market lot of the Company’s shares;
   4. Mergers, De-mergers, Amalgamation, Acquisitions, De-listing of Securities, Scheme of Arrangement or Takeover, disposals, spin off or selling division of whole or substantially whole of the undertaking and expansion of business and such other transactions;
   5. Any major expansion plans or execution of new projects or any significant changes in policies, plans or operations of the Company;
   6. Changes in Key Managerial Personnel;

Words and expressions used and not defined herein but defined in Companies Act 2013, Securities Contracts (Regulation) Act 1956, SEBI Act, 1992, and Rules / Regulations framed therein, and the Listing Regulations shall have the meaning respectively assigned to them in those provisions.

Scope of the Policy

In line with the provisions under Regulation 22 of the Listing Regulations, this policy has been designed for directors and employees to report genuine concerns. The policy shall also provide for adequate safeguards against victimization of director(s) or employee(s) or any other person who avail the mechanism and provide for direct access to the chairperson of the audit committee in appropriate or exceptional cases.

This Policy encourages all the Whistle Blowers to report any kind of misuse of Company’s properties, mismanagement or misconduct prevailing / executed in the Company or any kind of violation of laws, rules and regulations, which the Whistle Blower in good faith, believes, evidences any of the following:

1. Breach of Company’s Code of Conduct.

2. Commission of gross misconduct and Business Ethics.

3. Violation of any law or regulations, policies including but not limited to corruption, bribery, theft, fraud, coercion and willful omission and negligence.

4. Criminal Offence having ramifications on the Company or its repute.

5. Rebating of Commission / benefit or conflict of interest.

6. Procurement frauds.

7. Mismanagement, gross wastage or misappropriation of Company’s funds / assets.

8. Manipulation and / or unethical sharing of Company’s data / records.

9. Misappropriating cash / Company’s assets, leaking confidential or proprietary information.

10. Unofficial use of Company’s property (tangible and intellectual) / human assets.

11. Activities violating Company’s policies.

12. A substantial and specific danger to public health and safety.

13. An abuse of authority or fraud.

14. Leak of UPSI

15. Any other activity (ies) or behaviour or events, whether unethical or improper in nature, which are against the interests of the Company.

Competent Authority under the Policy

1. The Board shall constitute a Competent Authority under this Policy, comprising of office bearers of the Company to act, jointly and severally to receive Complaint from the Whistle Blower and conduct investigation of the disclosure made by the Whistle Blower.

2. The office bearers of the Company who shall act as Competent Authority under this Policy are -
   • Chief Financial Officer, and / or
   • VP - HR or Head - HR, and / or
   • Company Secretary & Head – Legal, and / or
   • Head – Internal Audit and / or

3. It shall not be mandatory to have all the five office bearers who are empowered to act as the Competent Authority under this Policy, to conduct particular proceedings on consultation among each other. Any one or more office bearers can act as Competent Authority to conduct particular proceedings, depending on the seriousness of the Complaint.

4. The powers and functions of the Competent Authority shall be:
   1. To conduct the enquiry / investigation in a fair and unbiased manner;
   2. To maintain confidentiality of the investigation / enquiry and the parties involved therein;
   3. To ensure that complete fact finding has taken place with regard to a particular investigation;
   4. To decide on the outcome of the investigation;
   5. To recommend penal provisions / disciplinary actions to the Audit Committee of the Company against the accused, if found guilty (subject to final approval by the Chairman & Managing Director);
   6. To recommend an appropriate course of action and / or disciplinary action against the complainant including his / her accomplices, for false or malicious Complaints / claims under this Policy;
   7. To receive a Complaint raised by the Whistle Blower, by accessing the email id specifically created for receiving Complaints under this Policy and no other person apart from the Competent Authority shall get access the email id, without express written consent of the Competent Authority; Competent Authority may receive the Complaint in a hand written / typed letter form or in exceptional circumstances in verbal or telephonic form.
   8. To appoint investigating officer(s) / agencies (internal or external), if required.

Role and Responsibility of Whistle Blower

The Whistle Blower shall report his / her Complaint / Disclosure with reliable information. The Whistle Blower shall co-operate with the Competent Authority under this Policy and extend all necessary support including production of documentary evidences to investigate the Complaints. He / she is neither required to act as investigator nor permitted to determine the appropriate or remedial action on behalf of the Company.

Malicious Whistle Blowing

1. Whistle Blowers who shall report Complaints which are found to be mala fide, frivolous, baseless, malicious, or reported otherwise than in good faith, the Competent Authority would reserve its right to recommend / pronounce appropriate disciplinary action.

2. If any Whistle Blower lodge Complaint, which is of malicious in nature, in that case the Competent Authority may bar that Whistle Blower from making Complaint under this Policy for a period the Competent Authority deems fit; Competent Authority may take / recommend appropriate disciplinary action as well.

Disclosure / Complaint

1. The Whistle Blower may lodge his / her Disclosure / Complaint to the Competent Authority by sending an e-mail with proper information and details to vigilance@khadims.com or by sending a hand written / typed letter addressed to any of the office bearers who are ex-officio Competent Authority under this Policy or in exceptional circumstances by verbal or telephonic communication.

2. In case the Disclosure / Complaint made by a verbal or telephonic conversation, the Competent Authority may record the communication in a written or electronic / audio recording form at the earliest, to initiate next course of action.

3. The Whistle Blower must indicate his / her name, contact details and relationship with the Company in the Complaint. Relevant supporting documents / evidences and a brief background must form an integral part of the written Complaint.

4. The name and contact details of the Whistle Blower shall not be disclosed by the Competent Authority to anyone except the Chairman of the Audit Committee and / or the Chairman & Managing Director of the Company and / or to the concerned office bearers of the Company who are required to be informed in case of such incident. No unnamed Complaint shall be entertained. If the Complaint relates to a fact / incident, the Whistle Blower must lodge the Complaint within 30 days from the date he / she became aware of such fact / incident.

5. The Whistle Blower shall exercise caution before lodging a Complaint to ensure that he / she is not doing so under influence of any person and / or any past incidence.

Investigation

1. All relevant Disclosures / Complaint reported under this Policy will be recorded and duly investigated. The Competent Authority may at its sole discretion consider the involvement of any other investigator.

2. If Disclosures / Complaint is made against any of the office bearer who is an ex - officio Competent Authority, such office bearer will be barred to act as Competent Authority in the said proceedings / investigation and shall extend co-operation to the Competent Authority if sought for in such proceedings.

3. After completion of investigation process, if it is found that an improper / unethical act has been committed, the Competent Authority shall place their findings / recommendations to the Audit Committee of the Company to take such disciplinary / corrective actions as it may deems fit in consultations with the Chairman & Managing Director of the Company.

Disciplinary Actions

The Company may take the following punitive actions against the accused, where the Committee finds him / her guilty:

1. Issue of an official reprimand cum warning letter;

2. Counselling;

3. Bar from participating in performance bonus review;

4. Cessation in increment of remuneration for a particular period as the Competent Authority deems fit;

5. Termination from employment;

6. Cancellation of Orders placed as per Purchase / Work Order;

7. Recovery of monetary loss suffered by the Company;

8. Legal Suit or / and appropriate legal recourse under civil and criminal laws of the land;

9. Any other punitive action which the Competent Authority shall deem fit, provided it shall be proportionate to the offence committed by the accused;

Confidentiality

During the period of investigation or even after completion of the investigation, the identity of the Whistle Blower and the accused should be confidential. Any disclosure of identity of the accused shall be only to the extent it is necessary considering the progress of investigation process and the legitimate needs of law.

Protection

There will not be any retaliation or victimization against the Whistle Blower for disclosing in good faith any genuine concerns or grievances concerning unethical and improper practice or wrongful conduct prevailing in the Company, provided there is no Malice reporting

Reporting

1. The Head – Internal Audit shall submit an yearly report to the Audit Committee informing the status of all Complaints received from the Whistle Blowers, Complaints resolved and action taken, Complaints under investigation and number of false Complaints lodged by Whistle Blowers.

2. The Head of Internal Audit of the Company (ex-officio Competent Authority under this Policy) may also submit his observations on quarterly basis on the proceedings under this Policy before the Audit Committee of the Company.

The complaint may be sent directly to the Chairman of the Audit Committee, as per the details given hereunder:-

Name: Indra Nath Chatterjee
Address: 7th Floor, Tower C, DLF IT Park,
08 Major Arterial Road , Block - AF, New Town (Rajarhat),Kolkata- 700156
Email: compliance@khadims.com

Amendment

Any subsequent modification/amendment to the provisions of the Act / Regulations shall automatically apply to this Policy.