SANCTIONS POLICY

I. Objective
Aditya Birla Group (‘Group/ABG’) is committed to carrying on business in accordance with the
highest ethical standards. This Policy sets forth the guidelines for conducting business practices
around the world in compliance with export controls and other foreign trade restrictions, as
applicable.

II. Scope & Coverage

ABG is a global conglomerate having presence in several countries. This Policy applies to all the
companies of the Aditya Birla Group. This Policy provides for a minimum standard the Group
companies should comply with in any country in which our Group does business.
In the event this Policy is stricter than the laws that are applicable, including both applicable local
laws and those laws with extra-territorial application, this Policy will prevail. However, if any part
of this Policy conflicts with local laws in any location, the local law of the appropriate jurisdiction
will prevail. The same principle will apply in case this Policy conflicts with sectoral laws, as may be
applicable to certain companies of the Group.
This Policy is applicable to all the employees of the Group including senior managers, officers,
other employees (whether permanent, fixed-term or temporary), consultants, contractors,
trainees, interns, seconded staff, casual workers and agency staff, agents, or any other person
associated with the Company and such other persons, including those acting on behalf of the
Company (collectively for the limited purpose of this Policy referred as ‘Employees’).
This Policy should be read in conjunction with the existing Group’s Code of Conduct, Policies,
Procedures and Guidelines, as issued from time to time.
The words and expressions used herein but not defined in this Policy shall have meaning as
provided under applicable laws.

III. Compliance Officer

Respective group companies shall appoint one of the Senior Manager conversant with the
operations of the Company to be the Compliance officer to ensure compliance with the provisions of
this Policy (“Compliance Officer”). Company Legal team will be responsible to ensure that the right
Governance process is in place for the compliance of this policy. The Compliance Officer should
annually report the status of compliance of this Policy to the Business Review Committee for their

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 respective businesses. Company Legal team will ensure that the right Governance process is in place
for the compliance of this policy.

IV. Trade Restrictions

All the Companies of the Group should comply with Sanctions, as applicable to their activities.
In certain cases, on account of contractual relationship, extra territorial Sanctions may
additionally apply to one or more Group Companies. Before such a contractual relationship is
honoured by any of the other Group Companies which are not subject to the Trade Sanctions,
Business should seek counsel from the Legal & Compliance team. Generally, any such
circumvention of the Trade Sanctions is also be covered by the Trade Sanctions Laws. All queries
related to Group wide exposure should be referred to the Group Legal & Compliance of the
Aditya Birla Group.

For the purpose of this Policy, “Sanctions” shall mean the trade control, sanctions, embargoes,
prohibitions or restrictions as may be imposed by the host country of our operations or those as
may be made applicable to a Company on account of contractual extension of obligations, save
and except those may be permitted as an exception under the applicable Sanction laws.

V. Compliance Process
Every transaction involving operation must be evaluated for compliance with applicable trade
restrictions before proceeding. Trade control laws can restrict:

 export of certain goods, services, and technologies;

 business dealings (including import, export, and investments) with certain countries,
entities, and individuals;
 travel to certain countries;
 exchange of information; and
 dealing in debt/equity instruments of a particular company.

Therefore, before engaging in any commercial relationship or transaction with any person,
particularly those having overseas operations, foreign individuals and entities, the Company
should undertake appropriate screening and due diligence to mitigate the risk of non-
compliance of applicable Sanction laws and restrictions. The level of screening and due diligence
should be linked to the risk profile of the particular relationship or transaction. Compliance

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 Officer along with relevant functional head should undertake enhanced screening and diligence
if the risk is greater.

In the event, a transaction consequent to its execution/implementation is subjected to Trade

Sanctions, it is unlikely to have any bearing under applicable Sanctions. However, if an ongoing
transaction or any series of a particular transaction is subjected to trade sanctions, the
Compliance Officer should look for appropriate transition period under applicable Sanctions,
within which either the future transactions should be discontinued and/or alternate remedies
should be explored, such that the Company is not found in breach of applicable Sanctions.
In case of any query on this Policy or under applicable Sanctions, you may reach out to the
Compliance Officer of the Company.
Few examples of transactions requiring higher scrutiny along with Employees responsibilities
may be referred from Annexure-I & II.

VI. Non-Compliance
Any violation of this Policy may be subject to disciplinary action under the Group’s Corporate
Principles & Code of Conduct.

VII. Breach
Any breach of this policy should be immediately notified to the General Counsel of the Company
and the Group General Counsel.

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 ANNEXURE-I: Transactions Requiring Higher Scrutiny
The Employees should be careful about the following transactions or situations which, when
appearing together or individually, should raise a ‘red flag’:
1. A transaction with an internationally recognised individual or business that are subject to
Sanctions, or are located in high-risk jurisdictions;
2. A lack of information as to the identity of the end-client involved parties and/or the reluctance of
a party to provide such information;
3. Domestic transactions involving payments in foreign exchange/currency and any transactions
with institutions dealing in foreign exchange/currency.
4. Client:
 actively avoiding personal contact and the Employee perceives that there may be concerns
with respect to their goodwill;
 refuses to provide information, data, and the necessary documents or provides fake
documents;
 uses suspicious domain address or an email address;
 a partner associated or known or known to a person involved in or suspected of terrorist or
terrorist financing activities.
5. Unusual invoicing requests, request for favourable payment terms or request to make unusual
exceptions without proper rationale;
6. Any suspicion or evidence to suggest the possible involvement of a restricted territory or restricted
party or parties or that their representatives are located in a high-risk country;
7. The transaction is inconsistent with the individual's or entity’s economic/business profile;
8. The person who directs the operation is not one of the official parties of the transaction or its
representatives;
9. There is increased complexity in the transaction, or the ownership structures used, resulting in
higher taxes and fees than necessary;
10. The customer requests shipment or labelling of goods that are inconsistent with usual shipping
and labelling practices as well as the shipping route is abnormal for the product and destination;
11. The customer/client or his address is similar to one of the parties listed in the sanctioned list issued
by various applicable authorities;
12. The transaction collateral is located in a high-risk country;

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 13. A client is financed by a lender who is not a credit institution to do business with the Company,
with no logical explanation;
14. There are no documents to support the customer's proposal, previous transactions, or company
activities;
15. Equipment or machinery if any is to be installed in an area under strict security control or in a
suspicious or unusual location;
16. An investment is proposed to be made in immovable property from an entity belonging to a
sanctioned country;
17. The client is relatively a newly incorporated entity which has received huge capital investment
from unknown sources, the identity of which cannot be traced;
18. A transaction is unusual for many reasons, such as its size, nature, frequency, or the suggested
manner of execution.
It is generally assumed to be safe to deal with the Government Agencies, however transaction with
the government of certain countries may be restricted, for example transactions with Government
of North Korea or Cuba or Iran. Such proposals should always be vetted by the Compliance Officer.

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 ANNEXURE-II: Employees Responsibilities
1. Each Employee shall ensure that he/she reads, understands and complies with this Policy. They
should at all times, avoid any activity that might lead to, or suggest, a breach of this Policy. The
prevention, detection and reporting of breach of Sanctions and any other violation of this Policy
are the responsibility of each Employee.

2. Employees shall:
 Understand and meet their Sanctions obligations as a citizen of a particular country or as a
result of their presence in a particular country or those applicable to the Company they are
employed with as a result of contractual obligation or otherwise;
 Basis the risk profile, screen and perform due diligence on each prospective customer,
suppliers and other business partner/counterparties including their Ultimate Beneficial
Owners (UBO’s). If there is any doubt whether screening and due diligence has been
conducted with respect to any such person or entity, the legal department of the respective
Company must be contacted immediately.
 Ensure that the third party with whom Company has a contract,
- as part of due-diligence or conditions precedent seek disclosure with respect to the
following:
i) representing that the third party is not itself a Specially Designated Nationals
(“SDN”) or otherwise subject to Sanctions;
ii) requiring compliance with U.S., U.N. and E.U. or any other Sanctions laws as
applicable.
- In Contract clauses pls get the following understanding reflected:
i) that they are not owned or controlled by a sanctioned person or persons;
ii) That they will not directly or indirectly engage in or facilitate any business
activity that would lead to breach of any applicable Sanctions obligations or this
Policy;
iii) permitting the Company to exit the contract, if the third party during the term
of the contract becomes an SDN or otherwise are found in breach of applicable
Sanction laws.
- is mandated to promptly disclose to the Company if they are subject to Sanctions.
 If a transaction is proposed to be undertaken with a previously screened party, a prior written
confirmation that such party is not subject to any Sanctions should be undertaken.
 Immediately report to the General Counsel of the Company, if they are contacted by anyone

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 outside of Company, including law enforcement officials or government agencies concerning
a potential violation of Sanctions or this Policy.
3. Employees shall not:
 Advise customers, or others as to how transactions may be structured or presented to evade
applicable Sanctions or this Policy. This includes, but is not limited to, advising customers, and
others to amend any information or documents to include false or misleading information, to
omit accurate information, or changing, removing or omitting information from a transaction
or any business record that would otherwise lead to detection of a Sanctions issue.
 Engage in any commercial relationship or transaction that directly or indirectly involve:
i) countries that are subjects or targets of Sanctions such as the list issued by United
Nations from time to time, to the extent applicable; or
ii) nationals of sanctioned countries; unless the contemplated commercial relationship
or transaction has been screened and cleared for action in accordance with the
applicable sanction screening systems, processes and procedures that are
implemented by the Company from time to time.