R & D for continuous innovation & customer satisfaction

VIGIL MECHANISM / WHISTLE BLOWER POLICY

The Board of Directors of the Company at its meeting held on 20th February, 2015 has established a Policy on Vigil Mechanism for the Directors and Employees of the Company to report their genuine concerns or grievances relating to unethical behavior, actual or suspected fraud, or violation of the Company's Code of Conduct or Ethics Policy, and any other event which would adversely affect the interests of the business of the Company. Whistle Blowers may send their concerns/complaints to the Vigilance and Ethics Officer/ Chairman of Vigil Mechanism Committee in a sealed envelope marked confidential, for appropriate action.

VIGIL MECHANISM POLICY OF PON PURE CHEMICAL INDIA PRIVATE LIMITED

1. PREFACE:

Section 177 of the Companies Act, 2013 requires every Listed Company and such class or classes of Companies, as may be prescribed to establish a Vigil Mechanism for the directors and employees to report genuine concerns in such manner as may be prescribed. The Company has adopted a Code of Conduct for Directors and Senior Management Executives (“the Code”), which lays down the principles and standards that should govern the actions of the Company and its employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern of the Company. Such a Vigil Mechanism shall provide for adequate safeguards against victimization of persons who use such mechanism and and also make provision for direct access to the Chairperson of the Committee in appropriate or exceptional cases. Here, our Company has set up and adopted the following Vigil Mechanism which lays down the principles and standards governing the management of grievances and concerns of employees and directors of the Company and shall be over seen by the Vigil Mechanism Committee (hereinafter referred to as ‘Committee’) of the Company.

2. POLICY OBJECTIVES:

i. The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment. A Vigil Mechanism provides a channel to the employees and Directors to report to the management concerns about unethical behavior, actual or suspected fraud or violation of codes of conduct or policy. The mechanism provides for adequate safeguards against victimization of employees and Directors to avail of the mechanism.

ii. This neither releases employees from their duty of confidentiality in the course of their work nor can it be used as a route for raising malicious or unfounded allegation against people in authority and / or colleagues in general.

3. SCOPE OF THE POLICY:

The Policy covers malpractices and events which have taken place / suspected to have taken place misuse or abuse of authority, fraud or suspected fraud, violation of Company rules, manipulation, negligence causing danger to public health and safety, misappropriation of monies, and other matters or activity on account of which the interest of the Company is affected.

4. DEFINITIONS:

“Alleged wrongful conduct” shall mean violation of law, Infringement of Company’s rules, misappropriation of monies, actual or suspected fraud, substantial and specific danger to public health safety or abuse of authority.
“Board” means the Board of Directors of the Company.
“Company” means the Pon Pure Chemical India Private Limited (‘Pon Pure’) and all its offices.
“Code” means Code of Conduct for Directors and Senior Management Executives adopted by the Company.
“Committee” means the Vigil Mechanism Committee constituted by the Board for the purpose of Vigil Mechanism.
“Employee” means all the present employees and Directors of the Company.
“Protected Disclosure” means a concern raised by an employee or group of employees of the Company, through a written communication and made in good faith which discloses or demonstrates information about an unethical or improper activity under the title “SCOPE OF THE POLICY” with respect to the Company. It should be factual and not speculative or in the nature of an interpretation / conclusion and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern.
“Subject” means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.
“Vigilance and Ethics Officer” means an officer appointed to receive protected disclosures from whistle blowers, maintaining records thereof, placing the same before the Committee for its disposal and informing the Whistle Blower the result thereof.
“Whistle Blower” is an employee or group of employees who make a Protected Disclosure under this Policy and also referred in this policy as complainant.

5.ELIGIBILTY:

All Directors and Employees of the Company are eligible to make Protected Disclosures under the Policy in relation to matters concerning the Company.

6. RECEIPT AND DISPOSAL OF PROTECTED DISCLOSURES:

All Protected Disclosures should be reported in writing by the complainant as soon as possible after the Whistle Blower becomes aware of the same so as to ensure a clear understanding of the issues raised and should be in the prescribed format.
The Protected Disclosure should be submitted in a closed and secured envelop and should be super scribed as “Protected Disclosure under the Vigil Mechanism Policy”. If the complaint is not super scribed and closed as mentioned above, it will not be possible for the Committee to protect the complainant and the protected disclosure will be dealt with as a normal disclosure. In order to protect identity of the complainant, the Vigilance and Ethics Officer will not issue any acknowledgement to the complainant and they are advised neither to write their name / address on the envelope. The Vigilance and Ethics Officer shall assure that in case any further clarification is required he will get in touch with the complainant.
All Protected Disclosures should be addressed to the Vigilance and Ethics Officer of the Company or to the Chairman of the Committee in exceptional cases.
The contact details of the Vigilance and Ethics Officer is as under:-
Name and Address: Mr.B.Subbiah,
M/s Pon Pure Chemical India Private Limited
32,H-Block 15th Main Road, Anna Nagar,
Chennai – 600040
Email: b.subbiah@pure-chemical.com

The contact detail of the Chairman of the Committee is as under:-
Name and Address: Mr. M. Ponnuswami
M/s Pon Pure Chemical India Private Limited
32,H-Block 15th Main Road, Anna Nagar,
Chennai – 600040
Email: cmd@pure-chemical.com
On receipt of the protected disclosure the Vigilance and Ethics Officer / Chairman of the Committee, as the case may be, shall make a record of the Protected Disclosure and also ascertain from the complainant whether he was the person who made the protected disclosure or not. He shall also carry out initial investigation either himself or by involving any other Officer of the Company or an outside agency before referring the matter to the Committee of the Company for further appropriate investigation and needful action.
The record will include: Brief facts;
Whether the same Protected Disclosure was raised previously by anyone, and if so, the outcome thereof;
Whether the same Protected Disclosure was raised previously on the same subject; Details of actions taken by Vigilance and Ethics Officer / Chairman for processing the complaint
Findings of the Committee
The recommendations of the Committee/ other action(s).

7. INVESTIGATION:

All Protected Disclosures under this Policy will be recorded and thoroughly investigated. The Committee may investigate and may at its discretion consider involving any other Officer of the Company and/ or an outside agency for the purpose of investigation.
The decision to conduct an investigation is by itself not an accusation and is to be treated as a neutral fact finding process.
Subject(s) will normally be informed in writing of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation.
Subject(s) shall have a duty to co-operate with the Committee or any of the Officers appointed by it in this regard.
Subject(s) have a right to consult with a person or persons of their choice, other than the Vigilance and Ethics Officer / Investigators and/or members of the Committee.
Subject(s) have a responsibility not to interfere with the investigation. Evidence shall not be withheld, destroyed or tampered with and witness shall not be influenced, coached, threatened or intimidated by the subject(s).
Unless there are compelling reasons not to do so, subject(s) will be given the opportunity to respond to material findings contained in the investigation report. No allegation of wrong doing against a subject(s) shall be considered as maintainable unless there is good evidence in support of the allegation.
Subject(s) have a right to be informed of the outcome of the investigations. If allegations are not sustained, the Subject should be consulted as to whether public disclosure of the investigation results would be in the best interest of the Subject and the Company.
The investigation shall be completed normally within 90 days of the receipt of the protected disclosure and is extendable by such period as the Committee deems fit.

8. DECISION AND REPORTING:

If an investigation leads the Vigilance and Ethics Officer / Chairman of the Committee to conclude that an improper or unethical act has been committed, the Vigilance and Ethics Officer / Chairman of the Committee shall recommend to the management of the Company to take such disciplinary or corrective action as he may deem fit. It is clarified that any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures.
The Vigilance and Ethics Officer shall submit a report to the Chairman of the Committee on a regular basis about all Protected Disclosures referred to him/her since the last report together with the results of investigations, if any.
In case the Subject is the Chairman of the Committee after examining the Protected Disclosure shall forward the protected disclosure to other members of the Committee if deemed fit. The Committee shall appropriately and expeditiously investigate the Protected Disclosure.
If the report of investigation is not to the satisfaction of the complainant, the complainant has the right to report the event to the appropriate legal or investigating agency.
A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the subject to the Vigilance and Ethics Officer or the Committee shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.

9. PROTECTION:

No unfair treatment will be meted out to a Whistle Blower by virtue of his/ her having reported a Protected Disclosure under this policy. The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistle Blowers. Complete protection will, therefore, be given to Whistle Blowers against any unfair practice like retaliation, threat or intimidation of termination / suspension of service, disciplinary action, transfer, demotion, refusal of promotion or the like including any direct or indirect use of authority to obstruct the Whistle Blower’s right to continue to perform his duties / functions including making further Protected Disclosure. The Company will take steps to minimize difficulties, which the Whistle Blower may experience as a result of making the Protected Disclosure. Thus if the Whistle Blower is required to give evidence in criminal or disciplinary proceedings, the Company will arrange for the Whistle Blower to receive advice about the procedure, etc.
The identity of the Whistle Blower shall be kept confidential to the extent possible and permitted under law. The identity of the complainant will not be revealed unless he himself has made either his details public or disclosed his identity to any other office or authority. In the event of the identity of the complainant being disclosed, the Committee is authorized to initiate appropriate action as per extant regulations against the person or agency making such disclosure. The identity of the Whistle Blower, if known, shall remain confidential to those persons directly involved in applying this policy, unless the issue requires investigation by law enforcement agencies, in which case members of the organization are subject to subpoena.
Provided however that the complainant before making a complaint has reasonable belief that an issue exists and he has acted in good faith. Any complaint not made in good faith as assessed as such by the Committee shall be viewed seriously and the complainant shall be subject to disciplinary action as per the Rules / certified standing orders of the Company. This policy does not protect an employee from an adverse action taken independent of his disclosure of unethical and improper practice etc. unrelated to a disclosure made pursuant to this policy.

10. RETENTION OF DOCUMENTS:

All Protected disclosures in writing or documented along with the results of Investigation relating thereto, shall be retained by the Company for a period of 5 (five) years or such other period as specified by any other law in force, whichever is more.

11. ADMINISTRATION AND REVIEW OF THE POLICY:

The Chairman of the Committee shall be responsible for the administration, interpretation, application and review of this policy. The Chairman of the Committee also shall be empowered to bring about necessary changes to this Policy, if required at any stage with the concurrence of the Committee.

12. AMENDMENT:

The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the Employees and Directors unless the same is notified to them in writing.

FORM FOR VIGIL MECHANISM

Date: ……………………
Name of the Employee/Director: …………………………………………………………………..
E-mail id of the Employee/Director:……………………………………………………………
Communication Address;……………………………………………………………………………
Contact No …………………………………………………………………………………………
Subject matter which is reported:………………………………………………………………..
(Name of the Person / event focused at):
………………………………………………………………
……………………………………………………………………………………………. ……………………………………………………………………………………
Brief about the Concern:
…………………………………………………………………………….
………………………………………………………………………………………………………… ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… …………………………………………………………………………………………………………
Evidence (enclosed, if any):
………………………..………………………….………………………
……………………….………………………………………………………………………………
Signature: ………………………………………………..

Note: The Whistle Blowing shall be submitted atleast within 30 days of the Occurrence of the Concern/event (or) before Occurrence.

POLICY ON CORPORATE SOCIAL RESPONSIBILITY

As an Indian leader in chemical distribution, We Pon Pure are very keen in the protection of the environment and the communities in which we live in. We are committed to conducting ourselves in a socially responsible manner and to keeping our business operations environmentally sound. We follow and adhere to the environmental rules and regulations. The health and safety of our customers, our employees, and the communities in which we operate is the paramount in all we do. Our values are reflected not only in the quality and the reputation of our Company, but also in our dedication to serving the communities where we do business.

Pon Pure will undertake its Corporate Social Responsibility through its Public Charitable Trust “Pon Pure Charities” which was formed by the promoters on 11th February, 2008. Pon Pure Charities helps poor and needy people for their medical treatment and impartment of education.

Pon Pure believes in the concept that corporate success and social welfare are interdependent.

Our vision is – "to actively contribute to the social and economic development of the communities in which we operate. In doing so build a better, sustainable way of life for the weaker sections of society and raise the country's human development index".

CSR Policy

Initiatives in line with the Triple Bottom line

Pon Pure maintains high standards of safety, health and environmental care at all its operating locations, always ensuring that increasing scales of operation have no negative impact on the standards of safety, health and environment and without losing sight of its long term goal of zero occupational injuries, operational incidents and environmental releases. Pon Pure is committed to conducting business with a strong focus on preserving the environment, sustainable development, safe work place & enrichment of the quality of life of employees, customers and the community. Established systems & procedures are constantly revised for continual improvement.

It is Pon Pure policy to direct CSR Programmes, inter alia, towards achieving one or more of the following –

Enhancing environmental and natural capital;
Supporting rural development;
Promoting education;
Providing preventive healthcare,
Prompting preventive health care, sanitation and drinking water facilities;
To develop the required capability and self-reliance of women
To engage in affirmative action interventions such as skill building and vocational training, to enhance employability and generate livelihoods for persons from disadvantaged sections of society in rural and urban India;

Governance

Every year, the CSR Committee will place for the Board's approval, a CSR Plan delineating the CSR Programmes to be carried out during the financial year and the specified budgets thereof. The Board will consider and approve the CSR Plan with any modification that may be deemed necessary.
The CSR Committee will assign the task of implementation of the CSR Plan within specified budgets and time frames to such persons or bodies as it may deem fit.
The persons/bodies to which the implementation is assigned will carry out such CSR Programmes as determined by the Committee within the specified budgets and timeframes and report back to the Committee on the progress thereon at such frequency as may be directed.
The Committee shall review the implementation of the CSR Programmes and issue necessary directions from time to time to ensure orderly and efficient execution of the CSR Programmes in accordance with this Policy.
Once every six months the Committee will provide a status update to the Board on the progress of implementation of the approved CSR Programmes carried out during the six month period. At the end of every financial year, the CSR Committee will submit its report to the Board.

CSR Budget

CSR budget would be as approved by the Board for the specific projects.

CSR Expenditure

CSR expenditure will include all expenditure, direct and indirect, incurred by the Company on CSR Programmes undertaken in accordance with the approved CSR Plan. Moreover, any surplus arising from any CSR Programmes shall be used for CSR. Accordingly, any income arising from CSR Programmes will be netted off from the CSR expenditure and such net amount will be reported as CSR expenditure.

Composition of CSR Committee:

Mr.S.Srinivasan- Chairman

Mr.M.P.Suryaprakas, Member

Mr.M.P.Lakshmipathy, Member

POLICY ON PREVENTION OF SEXUAL HARASSMENT

Dated: 16.12.2020

PREAMBLE

M/s. Pon Pure Chemical India Private limited (the “Company”) is committed to provide a work environment that is safe and conducive environment to its employees. The Company is committed to provide a safe, flexible and respectful environment for staff and clients free from all forms of sexual harassment. All employees are required to treat others with dignity, courtesy and respect.

OBJECTIVE

1. This Policy has been formulated in accordance with the provisions of The Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013 (hereinafter referred to as SHWW Act) and its Rules. The said policy is to define the guidelines and the process to be followed in order to provide protection against sexual harassment of women at workplace and for the prevention and redressal of complaints of sexual harassment in addition to the matters connected therewith or incidental thereto. The provisions of the SHWW Act and Rules, as may be amended from time to time, will be applicable. In case of any discrepancy between the Policy and the Act or Rules, the provisions of the Act or Rules, as the case may be, shall prevail.

DEFINITIONS

“Workplace” includes:

All offices or other premises where the Company’s business is conducted.
All Company-related activities performed at any other site away from the Company’s premises including transportation provided by the employer for undertaking such a journey.
Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.

“Employee” means:

A person employed at a workplace for any work, on regular, temporary, ad hoc or daily wage basis, either directly or through an agent, including a contractor, with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a co-worker, a contract worker, probationer, trainee, apprentice, or called by any other such name.

“Employer” means:

The Head of the organisation or any person who is responsible for the management, supervision and control of the workplace.

Sexual Harassment

Sexual Harassment includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication) namely;-

Physical contact and advances; or
A demand or request for sexual favours; or
Making sexually coloured remarks; or
Showing pornography; or
Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

The following circumstances, among other circumstances, if it occurs or is present in relation to or connected with any act or behaviour of sexual harassment :-

Implied or explicit promise of preferential treatment in her employment; or
Implied or explicit threat of detrimental treatment in her employment; or
Implied or explicit threat about her present or future employment status; or
Interference with her work or creating an intimidating or offensive or hostile work environment for her; or
Humiliating treatment likely to affect her health or safety.

“Respondent”

Against whom the aggrieved has made a complaint

APPLICABILITY

This policy shall applicable to All employees of M/s. Pon Pure Chemical India private limited (P) Ltd., deployed at the workplace who are either on the rolls of the Company or engaged through any service agreement with the Company or in any other way as enumerated in the SHWW Act.

COMPLAINTS MECHANISM

All employees of the Company have a personal responsibility to ensure that their behavior is not contrary to this policy. Whether or not such conduct constitutes an offence under law or a breach of the service rules, an appropriate complaint mechanism in the form of Internal Committee “Complaints Committee” has been created in the Company for time-bound redressal of the complaint made by the victim.

INTERNAL COMMITTEE (IC)

This is a Committee which is being constituted as per section 4 of the SHWW Act read with its Rules. Initially, and till further notice, the Complaints Committee will comprise of the following members:

Mrs.Shaalini Vimal Kumar (Presiding Officer)
Mr.S. Srinivasan (Member)
Mrs.P.Govindanayagi (Member)
V.P. Sengottuvel ( Member )

Every Member of the IC shall hold office for a period not exceeding three years, from the date of their nomination as may be specified by the Management. The Complaints Committee is responsible for:

Investigating every formal written complaint of sexual harassment
Taking appropriate remedial measures to respond to any substantiated allegations of sexual harassment

RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL HARASSMENT:

Formal Complaints:

Any aggrieved woman (as defined in the Act) can file a complaint to the IC within 3 months from the happening of the incident of Sexual Harassment. If it is a series of incidents, then 3 months from the date of happening of the last incident. The Complaint shall be in writing. Six copies of the complaint along with supporting documents and names and addresses of the witnesses should be filed by the aggrieved woman with the IC. However, the Presiding Officer or a member of the IC shall, for justifiable reasons recorded in writing, extend the time limit not exceeding three months. Provided that where such complaint cannot be made in writing, the Presiding Officer or any Member of the IC shall render all reasonable assistance to the aggrieved woman for making the complaint in writing. Where the aggrieved woman is unable to make a complaint on account of her physical or mental incapacity or death or otherwise, her legal heir or such other person specified in the Rules may make a complaint on her behalf.

Conciliation

a. The IC may, before initiating a formal enquiry and at the request of the aggrieved woman make all reasonable efforts to settle the matter between her and the respondent through conciliation as per the provisions of the Act & the rules thereunder. There can be no monetary consideration as the basis of conciliation. Where a settlement is arrived, the IC shall record the same and forward it to the management of the Company and copies of such settlement may be provided to the aggrieved woman and the Respondent.

Enquiry

b.IC may proceed to make enquiry into the complaint in accordance with the provisions of the Standing Orders or Conduct Discipline & Rules, as the case may be applicable to Respondent and shall submit a report of its findings to the management within 10 days from the date of completion of the enquiry in accordance with the Act and the Rules thereunder. The enquiry shall be completed within a period of 90 days.

c. Where the IC arrives at the conclusion that the allegation against the respondent has been proved, it shall recommend to the management, to take action for sexual harassment as misconduct, in accordance with the provisions of the Standing Orders/Conduct Discipline & Rules applicable to the respondent or such other action as may be provided under the Act or Rules.

d. An aggrieved Woman or the Respondent, who is not satisfied with the decision of the IC may prefer an appeal to the Appellate Authority, as prescribed under the provisions of the Act within the time frame provided under the Act.

e. Where the IC arrives at a conclusion that the allegation against the Respondent is false or malicious or the aggrieved woman or any other person making the complaint has produced any forged or misleading document, or any witness has given false evidence or produced any forged or misleading document it may proceed against the complainant, in accordance with the Act read with the Rules thereunder.

f. It is also open to the IC to recommend any compensation in accordance with the applicable law and the recovery and payment will be as per the Act and the Rules thereunder.

g. The management of the Company shall act upon all the recommendations of the IC in terms of the Act and the Rules.

Corrective action may include any of the following:

a. Formal apology

b. Counseling

c. Written warning to the perpetrator and a copy of it maintained in the employee’s dossier

d. Change of work assignment / transfer for either the perpetrator or the victim.

e. Suspension or termination of services of the employee found guilty of the offence

PROTECTION TO COMPLAINANT / VICTIM:

a. The management understands that it is difficult to come forward with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter confidential.

b. To protect the interests of the victim and the accused, confidentiality will be maintained throughout the investigation to the extent practicable and appropriate.

c. All the records of complaints, including contents of meetings, results of investigations and any other relevant material will be kept confidential by the Company except where it should be disclosed in accordance with law.

d. The Company will ensure that victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment. However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action.

e. The Management will provide assistance to the CE if she so chooses to file a police complaint in relation to the offence under the India Penal Code or any other law for the time being in force.

f. The IC will submit an annual report to the Management outlined in the SHWW Act and it is the responsibility of the Management to ensure that the said annual report is also filed with the District Officer as per the format applicable.

Dissemination of the Policy

A copy of this Policy shall be given to all employees and to all new recruits and they shall sign a statement acknowledging that they have received, read, understood and will abide by the Policy.

General

The Company shall ensure to

(i) Provide a safe working environment at the work place, which shall include safety from the persons coming into contact at the workplace;

(ii) Display at any conspicuous place in the work place, the penal consequences of sexual harassment; and the order constituting the ICC and this Policy;

(iii) Organize workshops and awareness programmes at regular intervals for sensitizing the employees with the provisions of the Policy and the orientation programs for the members of the Committee in the manner as may be prescribed;

(iv) Provide necessary facilities to the ICC for dealing with the complaint and conducting an inquiry;

(v) Assist in securing the attendance of respondent and witnesses before the ICC;

(vi) Make available such information to the ICC, as it may require having record to the complaint of sexual harassment;

(vii) Provide assistance to the women if she so chooses to file a complaint in relation to the offence under the Indian penal code or any other law for the time being in force;

(viii) Cause to initiate action, under the Indian penal code or any other law for the time being in force, against the perpetrator, or if the aggrieved women so desires, where the perpetrator is not an employee, in the work place at which the incident of sexual harassment took place;

(ix) Treat sexual harassment as misconduct under the service rules and initiate action for such misconduct;

(x) Monitor the timely submission of reports by the ICC.

Communication

There shall be displayed in the Notice Boards, the Policy, constitution of the ICC, the means of lodging complaint and the penal consequences of sexual harassment.

More information

Any query or information on this Policy, please contact [Mr. Subbiah b.subbiah@purechemical.com (08939978265)

Review

This Policy was adopted on 16.12.2020 and will be reviewed once in [3] years at the discretion of the management of the Company. *********************

Signed for and on behalf of the Board, For Pon Pure Chemical India Private limited
M.PONNUSWAMI
DIN: 00015847
(Managing Director)

+91-7338820509

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