Preamble

Green Edge Compliance Group Private Limited stands committed to the social and economic development of the communities in which it operates. The company’s commitment towards this includes contributing to Institutions which are engaged in activities aligned to the activities forming part of its CSR policies.

Purpose

The key purpose of this policy is to:

• » Define what CSR means to us and the approach adopted to achieve our CSR goals
• » Define the kind of projects that will come under the ambit of CSR
• » Identify broad areas of intervention in which the company will undertake projects
• » Serve as a guiding document to help execute and monitor CSR projects
• » Establish criteria for partner implementation agencies

Policy Statement

The CSR Policy of Green Edge Compliance Group Private Limited focuses on addressing critical social, environmental and economic needs of the underprivileged and downtrodden sections of the society. Grecom adopts an approach that integrates the solutions to these problems into the strategies of the company to benefit the communities at large and create social and environmental impact. The policy includes contributing or adopting projects in the following areas of intervention defined in Schedule VII of the Companies Act:

• » Livelihood enhancement projects
• » Ensuring environmental sustainability
• » Promoting education
• » Other activities defined in Schedule VII as may be identified in future by the CSR Committe.

Scope of CSR activities

Grecom classifies only those projects which are not forming part of the normal course of business of the company. All CSR projects will be reviewed and updated by the CSR committee of the Board of directors Green Edge Compliance Group Private Limited.

Governance Structure

The company has constituted a CSR committee consisting of three Directors from the Board of Directors including the Managing Director and two independent Directors to oversee the implementation of the CSR policy of the company in accordance with the requirements of Section 135 of the Companies Act.

The Committee, which will report to the Board, consists of the following Directors:

• » Mr. J.P Mishra, Chairman
• » Ms. Princey Aggwral, Member

The responsibilities of the CSR committee include:

• » The CSR Committee shall indicate the activities to be undertaken by the company.
• » The CSR Committee shall recommend the amount of expenditure to be incurred every financial year at least two percent of the average net profits of the company calculated under section 198 of the Act, made during the three immediately preceding financial years; from the day, this applicable to us.
• » Any other executive of the company associated with the CSR activities of the company will report to the CSR committee for all CSR projects undertaken

Budget

The total budget for the CSR projects will be decided by the CSR Committee.

Green Edge Compliance Group Private Limited requires that companies Employees, Sustainability Compliance Monitoring Organizations and other representatives acting on Green Edge Compliance Group Private Limited’s behalf as Green Edge Compliance Group Private Limited representative(s) adhere to the same standards. These standards strictly prohibit the solicitation, offer or acceptance of anything of value from any person or company that may impair or be presumed to impair the exercise by any Green Edge Compliance Group Private Limited representative of independent judgment and unbiased assessment.

Furthermore, no individual or company may offer anything of value including, but not limited to, any cash, gratuity, benefit, discount, special privilege, loan, lodging or other favour, or any meals and travel other than as reasonably necessary and incidental to a Green Edge Compliance Group Private Limited representative’s work intended, or which may reasonably appear intended, to influence any Green Edge Compliance Group Private Limited representative. Any individual or company doing so is subject to having its contract to manufacture Green Edge Compliance Group Private Limited -branded products terminated immediately.
If you have any concerns or questions regarding the behaviour of any Green Edge Compliance Group Private Limited representative or to report a violation of Green Edge Compliance Group Private Limited’s ethics policy, please immediately Contact the Green Edge Compliance Group Private Limited Hotline in your region at the number listed below:

The above mentioned numbers may be called any time, day or night, as it is available 24 hours a day, 365 days a year. Green Edge Compliance Group Private Limited strictly prohibits any form of retaliation against anyone who reports any suspected wrongful conduct to Green Edge Compliance Group Private Limited. Reports are also accepted anonymously. Green Edge Compliance Group Private Limited will use reasonable efforts to maintain the confidentiality of any report, although it must retain the right to make disclosures that it deems required by law or otherwise necessary for the protection of the Green Edge Compliance Group Private Limited Sustainability Program or other Green Edge Compliance Group Private Limited rights and interests.

Green Edge Compliance Group Private Limited’s Social Accountability policy is to promote a positive culture of social compliance, which respects human rights. Company’s upmost priority is to continually improve in providing a healthy and productive working environment. Grecom identifies, evaluate and manage all elements of our operations that impact on social accountability.

Grecom’s Social Accountability Principles include

Grecom operates to prevent the use of child labour, forced labour, improve health & safety, support freedom of association, prevention of discrimination& harassment, grant freedom of association to workers of organization, manage compensation and working hours as per local law and international standards and norms. Grecom provides awareness training on social accountability health and safety, freedom of association for employees and encourage suppliers and sub- contractors to support our principles and commitment on social accountability.

Green Edge Compliance Group Private Limited ( Grecom) as an responsible company towards society and nation at large, would never support, promote and do any activities which lead towards bribery or corruption in any of following forms:-

• » Influence-pending of public officials or political or Government.
• » Offering or receiving improper gifts, gratuities, favours or commissions by company employees.
• » Bribery to avoid liability for taxes or other costs.
• » Bribery in support of fraud.
• » Bribery in support of unfair competition for benefits or resources.
• » Bribery for making contracts for goods or services may be bribed to ensure that contracts are made with the party that is paying the bribe and on favourable terms.
• » Private sector bribery like banking and finance officials to approve loans.
• » Bribery to obtain confidential or “inside” information.

No member of Company management or Staff shall derive any personal profit or gain, directly or indirectly, by reason of his or her participation with Company . This shall also include the member’s business or other non-profit affiliations, family and/or significant other, employer, or close associates who may stand to receive a benefit or gain. Each individual shall disclose to the management any personal interests which he or she may have in any matter pending before the organization and shall refrain from participation in any discussion or decision on such matter.
In addition, any member of Company management or Staff shall refrain from obtaining any list of clients or donors for personal or private solicitation purposes at any time during the term of their affiliation.
Any new member of the Board of Directors and employees shall be given this policy at the time of their election onto the management and the policy will be reviewed annually by the management at a regularly scheduled meeting.
Grecom understands that the purposes of this policy are to protect the integrity of Company and the organization’s decision-making process as well as to enable our constituencies to have confidence in the integrity, intentions and actions of the officers, staff and management.

Green Edge Compliance Group Private Limited is accountable for keeping the environmental clean and do not do anything which will harm the environmental. The company is bound to follow legal requirement of the land under environmental laws & rules of the country. The policy shall be well communicated to the workers and all.

Green Edge Compliance Group Pvt Ltd constantly strives to deliver services with consistent quality, continually improving & exceeding the expectations of all our customers. Top Management insures that quality policy is communicated from Top to Bottom & displayed at appropriate places. Company reviews suitability of its quality policy, achievements of its quality objectives and implementation of its quality management system on pre-defined intervals in a planned way. Company is also committed to provide adequate resources in terms of documents and information needed to continually improve effectiveness of its quality management system.

Green Edge Compliance Group Pvt. Ltd. believes to provide independent services to its clients’ to operate in a more sustainable manner by improving compliance, integrity, quality, safety, productivity, increasing speed to market and reduce risk. Integrity is crucial for long-term partnership with our customers. GRECOM is committed to maintaining the total confidence of its customers and its shareholders. GRECOM’s maintains high standard for integrity, confidentiality and open and transparent communication.

Green Edge Compliance Group Pvt. Ltd. has Zero Tolerance regarding breaches of its compliance policy. Grecom regards a facilitator, a receiver and a giver of a bribe or benefit equally guilty through association of such transaction.

Green Edge Compliance Group Pvt. Ltd. Integrity basics demonstrate high standards of Integrity. The below steps are taken to maintain integrity of the organization, staff, associates and sub-contractors.

• » Conducts Recruitment check, background screening, Check previous employer and industry network for Integrity.
• » Provide Integrity Induction Training to all staff, sub-contractors and associates
• » Ensures that Code of Conduct signed by all employees, sub-contractors and associates.
• » Maintains Zero Tolerance policy.
• » Any compliance issues are reported directly to Director.
• » Independent & Rotational based on Skills and Competency matrix, as and when required.
• » To ensure that all findings MUST have objective evidence.
• » Factories are able to challenge results.

Green Edge Compliance Group Pvt. Ltd. shall not support or employee any Child labour, who has not completed 14 years of age (who is termed as Child Labour). The company ensures the below:

• » Birth certificate or any other age proof like Adhaar card etc. is obtained.
• » In case not available, Medical examination by a doctor /Dentist is carried out to ascertain age.
• » Written and verbal communication to suppliers and subcontractors of products and services, new staff and workers
• » Display the policy of ‘no child labour’ at the gate
• » Spread the awareness regarding national and international laws on no child labour through training
• » In case of apprehension or possible ‘border line case’ and an accidental case by contractors, co will undertake specific actions such as:
• » Establish and make a note of such incidence of child labour and necessary remedial action.
• » Study the causes by enquiry and verification with the respective department and persons responsible
• » Adequate measures so those similar incidences do not recur
• » Written & verbal communication to the concerned dept., party, contractor that such incidences should not take place again

Ref: The Child Labour (Prohibition and Regulation) Act, 1986 (Act No. 61 of 1986),
The Factories Act, 1 948 (Act No. 63 of 1948)
The Constitution of India, Fundamental Rights, Article 23 & 24

(a) Clients

Green Edge Compliance Group Private Limited has its policy to maintained confidentiality of all the information about its clients and committed to not share the same with anyone. Green Edge Compliance Group Private Limited will hold confidentially any and all knowledge or information that Green Edge Compliance Group Private Limited may obtain in the course of business of Green Edge Compliance Group Private Limited’s clients and with respect to the secret processes, formulae, machinery, plans, sensitive or personal information etc. used by Green Edge Compliance Group Private Limited or Green Edge Compliance Group Private Limited’s clients in delivering its services. Green Edge Compliance Group Private Limited will keep confidential information so long as that information remains confidential and is not otherwise available in the public domain.

(b) Subcontractors

Each Green Edge Compliance Group Private Limited’s subcontractors signs our non-disclosure policy/agreement.

A copy is included below and states:

“I agree that I will hold confidentially of any and all knowledge or information that I may obtain in the course of my employment with Green Edge Compliance Group Private Limited or from working with Green Edge Compliance Group Private Limited plans, sensitive or personal information etc. used by Green Edge Compliance Group Private Limited or Green Edge Compliance Group Private Limited’s clients in delivering its services.
I will keep confidential information so long as that information remains confidential and is not otherwise available in the public domain.
I will not engage as employer, employee, principal, agent, or otherwise, directly, in any matching business within one calendar year of terminating my contract with Green Edge Compliance Group Private Limited.
I will not impart the knowledge specifically acquired through this employment with Green Edge Compliance Group Private Limited to anybody and if I at any time leave the employ of Green Edge Compliance Group Private Limited, I agree not to enter into the employ or service or otherwise act in aid of the business of any rival company or concern or individual engaged in matching lines of business for a period of one year.
If I do so in violation Green Edge Compliances Group Private Limited will be entitled to compensation by any competent court enjoining and restraining me and every other person concerned from continuance of employment, services or other acts in aid of the business of the rival company or concern. Nothing will prevent me, upon the termination of the employment, in engaging in any occupation in which the confidential or personal data, proprietary processes, formulas, and other secrets of the employer will not be directly involved”.
If you have any concerns, about confidentiality or non-disclosure, Contact Green Edge Compliance Group Private Limited’s policy to Mr. S.S. Mishra, Director, at email ss.mishra@grecom.in.”