September 26, 2022

Hi everyone,

I am pleased to confirm that SirionLabs reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment, and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture, and daily operations. We also commit to sharing this information with you using our internal communication tools.

Sincerely yours,
Ajay Agrawal
Director

SirionLabs’ Code of Conduct applies to all employees and sets expectations for SirionLabs and its subsidiaries (referred to collectively as ‘SirionLabs’ or ‘Company’) as well as our non-employee members of the Board of Directors regarding their SirionLabs-related activities. The code of conduct also applies to independent contractors, consultants, suppliers, and others who do business with SirionLabs.
One of our core values is to conduct business with uncompromising integrity and professionalism. We
put this value into practice by:
• Communicating clearly, respectfully, and professionally in business,
• Treating customers, suppliers, distributors, and others fairly,
• Acting as a responsible corporate citizen, respecting human rights, and managing the impact of our
business on the world around us, and
• Keeping accurate financial and other books and records.

One of our core values is to work as a team with respect and trust for each other. We strive to uphold open and honest communication and to protect employees from discrimination, harassment, or unsafe practices.

Open and Honest Communication
We value the free flow of thoughts, ideas, questions, and concerns. We encourage employees to raise work-related issues or concerns through our established processes as soon as issues or concerns arise.

Equal Employment Opportunities and Discrimination
We value diversity in our workforce, as well as in our customers, suppliers, and others. We provide equal employment opportunities for all applicants and employees. We do not discriminate on the basis of race, color, religion, sex, national origin, ancestry, age, disability, medical condition, genetic information, military and veteran status, marital status, pregnancy, gender, gender expression, gender identity, sexual orientation, or any other characteristic protected by local law, regulation, or
ordinance. We also make reasonable accommodations for disabled employees and applicants, as required by law.
We follow these principles in all areas of employment including recruitment, hiring, training, promotion, compensation, benefits, transfer, and social and recreational programs.

Anti-Harassment
We are committed to providing a workplace free of harassment based on personal characteristics such as race, color, religion, sex, national origin, ancestry, age, disability, medical condition, genetic information, military and veteran status, marital status, pregnancy, gender, gender expression, gender identity, sexual orientation, or any other characteristic protected by local law, regulation, or ordinance. We strongly disapprove of and do not tolerate harassment of employees by managers or co-workers. We must treat co-workers, customers, and suppliers with dignity and respect.

Human Trafficking, Child and Forced Labor
We believe human trafficking, forced, debt bonded, indentured, and slave labor are unacceptable, and we are committed to preventing these practices in our operations and supply chain. SirionLabs’ Code and policies prohibit harsh or inhumane treatment, including corporal punishment or the threat of
corporal punishment; additionally, our policies prohibit the employment of anyone under the age of16 in any position, and workers under the age of 18 are not to perform hazardous work. We expect our suppliers to meet these expectations.

Safety
SirionLabs is committed to providing a safe workplace for employees, customers, vendors, contractors, and others on SirionLab's property. We comply with the safety laws, standards, and guidelines that apply to our business. Sound safety practices are important in all of our workplaces.

Workplace Violence
In keeping with our commitment to safety, SirionLabs will not tolerate threats of any kind, whether explicit or implicit, threatening behavior, stalking, or acts of violence. We take all reports of threatening behavior or violence seriously, look into the matter, and take appropriate action.

All Human Resources policies have already been implemented in the company and the entire staff is obligated to adhere to such policies. The company ensures that we hold periodic training sessions for all our existing and new staff.

We monitor the Human Rights Policies via our grievance redressal procedure and so far no human rights violation has been reported.

As a global company, SirionLabs complies with the laws of the many countries in which it does business. In addition to compliance with applicable legislation, SirionLabs meets the following requirements at all of its locations:
- No employment of children under 18 years of age (ILO conventions 79, 138,142,182 and recommendation 146 apply);
- No forced labour, no physical punishment or physical/psychological compulsory measures (ILO conventions 29 and 105 apply);
- Freedom of association (ILO conventions 87, 98, 135, 154 apply);
- Compliance with regulations governing working hours (ILO conventions 1 and 14 apply);
- Compliance with regulations governing occupational safety and health, and the observance of minimum standards for workplaces and sanitary facilities (ILO convention 155 and recommendations 164, 190 apply);
- No discrimination on the basis of ethnicity, origin, race, gender, age, language, religious or political convictions (ILO conventions 100, 111, 143, 158, 159 apply);
- Provision of wages that meet or exceed the legal minimum and /or industry standards for all employment positions within our company (ILO conventions 26, 131 apply).

SirionLabs' code of conduct outlines the standard of behavior expected from employees, contractors, and service providers of SirionLabs. It is designed to assist staff to understand their responsibilities and obligations and provide guidance on expected behavior in the workplace, or if faced with an ethical dilemma or conflict of interest in their work involving colleagues, contractors, and third parties.
The code of conduct provides a set of principles to guide staff on acceptable and unacceptable behavior. Our entire staff is trained on our code of conduct and follows its principles, which comprise antitrust, bribery and anti-corruption, environmental, health and safety management and compliance, privacy, treating each other fairly, open and honest communication, equal employment opportunities and discrimination, anti-harassment, human trafficking, child and forced labor, safety, workplace violence, act in the best interests of SirionLabs and avoid/handling conflicts of interest.

As an employer, we understand the content of the national Labour Code and other laws that relate to child labor. We do perform checks as mentioned below:
1. Review national laws regarding child labor
2. Refer to our client’s compliance requirements
3. We do not hire a candidate without proof of age.

All Labor Law policies have already been implemented in the company and the entire staff is obligated to adhere to such policies. The company ensures that we hold periodic training sessions for all our existing and new staff.

We monitor the Labor Law Policies via our grievance redressal procedure and so far no forced labor case has been reported.

SirionLabs provide guidelines in addressing issues that are central to our business, including environmental impact and being an eco-friendly organization in its Environment Policy. The policy applies to all SirionLabs employees, contractors, and third-party resources.
The primary objective of this policy is to
Reduce the carbon footprint generated through our business activities.
Manage the waste generated through our business operations by applying the principles of reduction, reuse, and recycling.
Effectively communicating the importance of environmental issues to our people and motivating them to embed environmental responsibility in our work culture.
Continuously improving our environmental performance in the areas of energy, waste, transportation, and employee engagement.

Principle 8 - Undertake initiatives to promote greater environmental responsibility
SirionLabs operates environmentally and sustainably by providing a responsible workplace to employees and ensuring that ethical practices are uniformly upheld. Furthermore, we are committed to working with business partners who share these values. The use of eco-friendly papers/diaries, recycling the water, providing recyclable joining kits to employees, and minimizing the use of plastic in the company are a few of the initiatives that we have taken to strengthen our commitment towards environmental preservation.

Principle 9 - Encourage the development and diffusion of environmentally friendly technologies

Water Sustainability - SirionLabs is based in a corporate tower where water runoff is being managed by a well-designed rainwater harvesting system and stormwater management plan. We have implemented water system assessments and management by working with employees and educating them about water conservation, regularly assessing water-consuming systems: Checking for leaks and studying utility bills to see if there have been any spikes in water usage and consulting with a plumber on a regular basis. Additionally, simple yet regular checks have been implemented: Check for leaks, efficiently operate water-intensive machinery, Shut off cooling units, High-efficiency bathroom fixtures, etc.

Energy - Our corporate tower functions on Voltage source converters (VSCs) which are commonly used with converter-based power sources and loads. Differing from synchronous generators, VSCs enables full control of electric power, and thus the control dynamics of VSCs play a critical role in the grid–converter interactions. To improve energy efficiency SirionLabs measure the current energy usage of fossil fuels, electricity, water, etc and has educated staff to reduce energy consumption. To achieve desired goals, we have invested in monitoring systems like meters and implemented a periodic maintenance and repair program to maintain the energy efficiency of the equipment.

Environmental Stewardship - We reduce, reuse, and recycle. Consume less, carry reusable grocery bags and water bottles, and check what materials are recyclable in our city. Educating employees on water and energy management and using recyclable materials are a few of the environmentally friendly practices we follow in the company.

Green Industry - Being a technology company our IT department created a specific power management system that efficiently controls all of their computers so that our employees can make greener choices and reduce their own carbon footprints. SirionLabs instituted a policy that allows for working from home and also provides commuting incentives.

We have instituted an environmental policy that all the employees, our vendor partners, clients, and contractors abide by. The policy addresses issues that are central to our business, including environmental impact and being an eco-friendly organization.

We monitor our environmental policies and ensure a healthy environment for our staff. No environmental hazard/accident has been reported so far.

SirionLabs complies with all anti-corruption laws and accurately reflects all transactions in SirionLabs’ books and records. SirionLabs makes every effort to comply with customer and third-party applicable Anti-Bribery policy.
Our Anti-Bribery policy prohibits normal and appropriate hospitality (given and received) to or from third parties. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable and not linked in any way to an improper act. The intention behind the gift should always
be considered. Giving or receiving gifts or hospitality is often an important part of maintaining and developing business relationships. However, all gifts and hospitality should be for a genuine purpose and reason.

Anti-corruption is one of the principles of the code of conduct at SirionLabs. We ensure that our existing and new staff is periodically trained and adhere to the code of conduct.

No corruption incident has been reported so far within the company.