Social Accountability Policy

1. Introduction

The United Nations Guiding Principles on Business and Human Rights (UNGPs) set out expectations for all businesses to respect human rights above and beyond their compliance with national laws and regulations.

At PMC Rubber Chemicals India Pvt. Ltd.(PMCRCI), we are committed to the principles of sustainable development protecting human rights, respecting the
dignity, well- being and worth of the employees and business partners and guaranteeing equal rights to all people. PMC is committed towards conducting its businesses in a fair and equitable manner, meeting its social responsibilities as a direct and indirect employer, and respecting the human rights of all our stakeholders in accordance with the United Nations Declaration on Human Rights (UDHR), International Finance Corporation-

Performance Standards (IFC-PS), and International Labor Organization’s Declaration on Fundamental Principles and Rights at Work (ILO Declaration) ILO.

2. Scope and Applicability

We are committed to respecting the fundamental rights of all people directly or indirectly related to our business across the value chain which includes our employees, business partners and communities where we operate.

3. Principles of the Policy

a. Gender Pay Equality

Be compliant with all the relevant and applicable Central and State labour laws, rules and regulations and
ensure that our employees and business partners are fairly and reasonably paid, and remuneration structure
is compliant with statutory obligations of the jurisdictions in which we operate.

b. Working conditions

Promote fair working environment and uphold human rights aligned with national laws, regulations and
international standards and conventions.

C. Human Right Violations

Do our utmost to avoid being complacent with adverse human rights impacts including benefitting from
the human rights violations caused by others.

d. Forced and Child Labor

Have zero tolerance for any form of forced, compulsory or child labor either directly or through business partners.

e. Human Dignity

Be an equal opportunity employer and treat all employees with respect and dignity and judge solely on their performance irrespective of their race, religion, caste, gender, sexual orientation, age, or disability.

f. Equal Opportunity and Non-Discrimination

Respect and preserve the culture and heritage of local communities, including socially vulnerable groups which are impacted by our operations and work towards developing a constructive relationship with such groups. Work with Government agencies to develop a common understanding and agreement to protect human rights in the event of unforeseen situations while protecting our people, equipment and assets.

g. Occupational Health and Safety

We are committed to focusing on holistic wellbeing and fitness of all employees. We provide continuous support for initiatives that promote a healthy lifestyle and the physical and mental well-being of our employees. We have in place various practices and policy measures to ensure a safe and healthy
workplace.

h. Modern Slavery

We have a zero-tolerance policy towards all facets of modern slavery, as elaborated under the Modern Slavery Act, 2015, Commonwealth Modern Slavery Act, 2018, the UN

Declaration of Human Rights and the conventions of the International Labor Organizations relating to forced or compulsory labor. PMCRCI commits to treating all employees and everyone related to its operations with dignity, respect and nurturing an environment of fairness, transparency, and trust.

i. Freedom of Association

Respects the right of employees to exercise free association, participation and provides access to appropriate redressal mechanisms.

j. Harassment Free Workplace

We have zero-tolerance for harassment, intimidation, or humiliation of any kind in the workplace, whether sexual, physical, virtual, verbal or psychological.

k. Fair Compensation

The Company ensures that all employees are paid adequately as per the governing laws. We always strive to ensure that our employees are paid in line or higher than the minimum wages prescribed by law.

I. Management System

A Social Performance Team (SPT) has been established and will, along with

management, implement all of the elements of SA8000. The SPT will conduct bi-annual meetings with management to review and monitor the policies and procedures implemented within the SA8000 program and make any revisions as necessary and address any non-conformance(s) to the SA8000 standard. Risk assessments and internal audits will be conducted on an annual basis and reviewed at management meetings.

4. Grievance Redressal Mechanism

PMCRCI has a Grievance Redressal Policy to have a corrective action approach for any conflict or complaint related to human rights.

5. Governance

PMCRCI shall implement this policy as per the prevailing standards. This policy is overseen by PMCRCI’s Board of Directors. Business leaders will be responsible for human rights related performance and line managers shall be responsible for the full implementation of the related human rights standards.

6. Review

We will measure and report the performance on a periodic basis including sharing of good practices throughout the organization. The content and implementation of this policy will be reviewed periodically.

Explanation of the policy:

HR department will be the sole authority to interpret the content of this policy. NB: Management reserves the right to exercise its discretion in special cases based on organizational values.

Authorized Signatory,

Saubhik Bhattacharya, Head – HR