Heritage Foods Limited | 31st Annual Report 2022-23

In addition to its Code of Conduct and Ethics, key policies that have been adopted by the Company are as follows: Name of the policy Brief description Web link Whistle-blower Policy (Policy on vigil mechanism) The Company has adopted the whistle-blower mechanism for directors and employees to report concerns about unethical behavior, actual or suspected fraud, or violation of the Company’s code of conduct and ethics. It also provides for adequate safeguards against victimization of employees who availed the mechanism and also provides for direct access to the Chairperson of the Audit Committee. Insider Trading Policy and Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information The Company has adopted a Code of Conduct to Regulate, Monitor & Report Trading by Insiders and Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information as per the SEBI (Prohibition of Insider Trading) Regulation 2015, with a view to regulate trading in securities by the Directors and Designated Persons while in possession of unpublished price sensitive information in relation to the Company and during the period when the Trading Window is closed and other certain situations. All Board of Directors and the designated employees have confirmed compliance with the Code. Policy and procedure of inquiry in case of leak or suspected leak of unpublished price sensitive information (“upsi”) The Policy aims to provide a framework for inquiry in case of leak or suspected leak of Unpublished Price Sensitive Information. Nomination and Remuneration Policy This policy formulates the criteria for determining qualifications, competencies, positive attributes and independence for the appointment of a director (executive / non-executive) and also the criteria for determining the remuneration of the directors, key managerial personnel and senior management of the Company. https://www.heritagefoods.in/policy Corporate Social Responsibility Policy The policy outlines the Company’s strategy to bring about a positive impact on Society through programs relating to hunger, poverty, education, healthcare, environment, relief, disaster management etc., as per the provisions of the Companies Act, 2013. Policy for Determining Material Subsidiaries The policy is used to determine the material subsidiaries and material non-listed Indian subsidiaries of the Company and to provide the governance framework for them. Related Party Transaction Policy The policy regulates all transactions between the Company and its related parties Policy on Preservation of Documents The policy deals with the preservation of corporate records of the Company. Archival Policy The policy deals with the retention and archival of corporate records of the Company. Business Responsibility Policy This Policy endorses the Company’s commitment to follow principles and core elements, in conducting its business, as laid down in the National Voluntary Guidelines on Social, Environmental and Economic responsibilities of Business. Dividend Distribution Policy This Policy is to ensure the right balance between the quantum of Dividend paid and amount of profits retained in the business for various purposes Policy on Determination of Materiality of Events The Policy is to determine materiality of events or information relating to the Company and to ensure timely and accurate disclosure on all material matters concerning the Company. Risk Management Policy This policy sets out the objectives and accountabilities for the management of risk within the Company such that it is structured, consistent and effective Anti-Sexual Harassment – Safe work environment policy The policy aims at providing a safe work environment for women at workplace Code of Conduct to Regulate, Monitor & Report Trading by Insiders This code Regulates any kind of Insider Trading by designated persons Heritage Foods Limited | 31st Annual report 2022-23 80

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