10.11.2022

To our stakeholders:

I am pleased to confirm that Lochan & Co 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 share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Sharad Agarwal
Partner

Lochan & Co (LC) is committed to respecting the human rights and dignity of individuals in our operations, supply chain, and the communities in which we operate. We are dedicated to maintaining a corporate culture that upholds the principles of promoting, protecting, and guarding all internationally recognized human rights. We recognise our obligation to uphold human rights and avoid culpability in human rights violations. At LC every business transaction is conducted in accordance with the National/International conventions, treaties, and policies (UNHCR, ILO etc.)
The LC commitment to human rights applies to all persons/stakeholders involved in the firm activities, including but not limited to company employees, managers, directors, leased employees, suppliers, vendors, and customers. In circumstances when LC does not have total control over activities, we take reasonable steps to ensure that all parties involved observe human rights values identical to those described below.

In accordance with relevant laws and regulations, we are committed and practice policies related to the following:
1. We treat people with respect and dignity and recruit individuals ethically.
2. We strive for and foster a workplace free of harassment and discrimination in accordance with Indian laws .
3. We promote equal opportunity, inclusivity and diversity at workplace and provide fair wages and benefits.
4. We strictly prohibit forced, bonded, trafficked and child labour and work as per guidelines outlined by the Child Labour (Prohibition and Regulation) Amendment act .
5. We follow uptight code of conduct to proactively check ethical and professional values of our people.
6. We promote and protect health and safety at the workplace and follows preamble, principles and action programme as delineated by Ministry of labour and Employment .
7. We prohibit practices that impede the possession of unrestricted access to personal documents.
8. We practice healthy lifestyle and prohibits use of Illegal Drugs and follows No-Smoking Policy at workplace.
Furthermore, LC exercises due diligence to avoid involvement in human rights violations and avoid causing or contributing to detrimental human rights impacts through business activities and relationships.

When human rights violations occur, LC endeavour to provide and/or cooperate in the provision of effective resolution. The organisation strives for continual improvement and is dedicated to increasing its capacity to recognise and respond to issues.
Where applicable law contradicts our Policy, LC maintains legal compliance while also attempting to raise awareness of best practises within the circles of influence in which we work. We regularly provide human rights training and awareness-raising initiatives to our personnel. We use this to monitor and report on our human rights commitments and initiatives.

Lochan & Co (LC) recognise the business duty to protect human rights, including labour rights, and to comply with all applicable laws and regulations. The firm labour policy establishes controls to ensure compliance and human rights protection with all applicable labour laws and regulations, forced labour, and human trafficking, as well as to ensure LC stakeholders conduct business in a socially responsible and ethical manner.
LC commitment to human rights is emphasised by support for the 'Protect, Respect, and Remedy' framework, which includes the UN Human Rights Council-endorsed guiding principles on Business and Human Rights. Furthermore, the firm complies with Indian labour law and rights legislation. The International Bill of Human Rights, which includes the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social, and Cultural Rights, is respected by LC. The firm also adheres to the principles and rights outlined in the ILO Core Conventions.

The LC management is solely responsible for implementing and ensuring compliance with these worker rights. The policy is conveyed to all workers in an appropriate and meaningful manner, and policy compliance is reviewed and evaluated on a regular basis.

LC commitment to conduct business activities are based on respecting the following Labour rights:
1. Freedom of association - In accordance with existing laws and regulations, LC respects employees' rights to freely associate, organise, and bargain collectively.
2. No forced/bonded or child labour - LC does not condone the hiring of child labour under any circumstances and follows Indian child rights legislation. Any kind of forced labour, including bonded labour, indentured labour, and slave labour, as well as human trafficking, is not tolerated by the firm.
3. Diversity and Equal labour - LC ensures that there is no discrimination in recruiting and employment practises based on race, religion, gender, age, physical ability, political opinion, social or ethnic origin, or sexual orientation.
4. Safe and Healthy workplace - LC offers and maintains a safe and healthy work environment for all employees and people involved with the firm.
5. Fair Employment Practice - LC abides by applicable laws and industry standards on employee pay, work hours, and conditions. The firm offers employees fair and competitive salary appropriate with their job.
6. Human rights and labour due diligence - The firm ensures that all human and labour rights are fully respected in all company activities by undertaking due diligence evaluations as needed and establishing corrective actions based on the findings.
7. No Harassment - The firm provides a harassment-free workplace, including verbal, physical, mental, emotional, and visual harassment.
8. Open dialogue and resolving concerns - Encourage employees to raise their concerns directly with management and foster an environment in which open dialogue is the preferred method of problem resolution. Provide a mechanism for employees, on-site contractors, and service providers to report concerns confidentially, anonymously, and without fear of retaliation, in accordance with applicable company procedures.

Lochan & Co, by the very nature of its activities and the services provided to its clients at both at national and international level, is aware of the need to protect, conserve and enhance the environment. We regard climate change mitigation and environmental improvement as essential features of our sustainable business philosophy. We make concerted efforts through our services to help clients improve their environmental performance toward their sustainability objectives.

On-Site Emergency Plan
Emergency planning is an integral part of the environment and safety management of an organization. Emergency may arise due to manmade reasons resulting in, fire, explosion, failure of critical control system or unsafe acts and natural causes like
earthquake, flood, cyclone, excessive rain, etc.
At Lochan & Co, we are committed to the safety of our employees. We have made arrangements to prevent accidents and losses by technical and organizational measures. We have:
• Identified local authorities like civil defense, fire-fighting services, police -their addresses and communication links.
• Humanitarian arrangements like transport, evacuation plan, first aid, ambulance and nearest hospital

We intend to keep up our environmental commitments through the following actions:
• Improve resource efficiency in operations, especially for key resources such as energy and water.
• Reduce consumption of electricity, gas, and water by instilling green practices in ourselves and our consultants.
• Our policy is to promote recycling and the use of recycled materials whilst reducing consumption of materials. Our aim is to reduce our impact on the environment through conservation, efficient use and careful planning of resources and activities.
• Apply the "3-R" (reduce, reuse, and recycle) philosophy for all types of wastes toward prevention of pollution and dispose of "inevitable" wastes, especially electronic waste, in line with regulatory requirements or industry best practices
• Promote green procurement to the maximum extent possible
• Consider stakeholder expectations on our environmental performance in rendering services, operations, and processes to the extent feasible
• Set, monitor, and review objectives and targets on an ongoing basis toward achieving continuous improvement in environmental performance and the overall environmental management system
• Remain committed to complying with all the applicable environmental and related legal and other requirements and, wherever feasible, enhance the prescribed standards in all the countries that we operate out of
• Continue public reporting of our environmental performance and our contribution to climate change-related issues through appropriate communication channels
• Communicate the environmental policy to all employees, business associates and clients.
• Strive to support various voluntary national and international protocols, conventions and agreements on environment protection and proactively engage with governmental and other agencies in driving future environmental policy and regulation

Our commitment to Environmental Sustainability
At Lochan & Co, we are committed to integrating sustainability into our day-to-day activities and our longer-term planning to enable us to play an active role in meeting the sustainability challenge and in improving the well-being of our clients and our employees.

• We will actively seek to reduce our consumption of natural resources and, where operationally feasible, buy sustainable products and services for our clients while continuing to promote a value for money culture.
• We will advise clients on ways to reduce environment impact in building design, construction, and maintenance, and we will seek to continuously improve energy and water efficiency to minimize waste and pollution.
• We will seek to maximize sustainability measures in our workplaces by promoting the reduction of water and energy use, reducing material waste, and maximizing recycling.
• We will reduce the environmental impact of employees and sub-contractors going about their day-to-day business by promoting sustainable methods of transport and the use of teleconferencing and video conferencing facilities.
• We will operate every aspect of our business in compliance with all applicable environmental legislation, Government policies and approved codes of practice.

We have worked on numerous environmental sustainability and climate change projects across many different countries, assisting our corporate clients in robust solutions with environmental issues. Our endeavor for sustainability extends to our efforts with non-profit sector clients.
We are ISO 14001:2015 Environmental Management System (EMS) certified. We implement and maintain an internationally accepted environmental management system in our operations and new projects. Our environmental policies are actively monitored to ensure they remain effective as per the needs of our organization.

Lochan & Co (LC) is dedicated to conducting business with integrity, honesty, trustworthiness, and accountability. Since our foundation in 1987, this has been a cornerstone of our 30+ year tradition and serves as the backbone of our code of corporate conduct and ethics. We abide by all legal laws in the countries where we conduct business.
The LC's Anti-Corruption Policy (the 'Policy') was developed in accordance with the code of conduct, charters, policies, rules, and regulations adopted by the LC, as well as the legal and statutory framework of anti-corruption legislation prescribed by Indian jurisdiction and international conventions.

This policy applies to all individuals working at all levels and grades, including Directors, senior managers, officers, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual workers and agency staff, volunteers, interns, agents, sponsors, business partners, and third-party representatives anywhere in the world, or any other person associated with us, wherever located who may be acting on behalf of LC.
Recognising the harmful potential of integrity violations, LC provides an avenue for all employees of LC, members of the public and stakeholders to disclose any improper conduct within the firm. All disclosures of improper conduct within the established LC’s whistleblowing Policy.

The goal of LC's anti-corruption policy is to set up controls to ensure compliance with all applicable anti-bribery and corruption regulations, as well as to ensure that the firm's business is conducted in a socially responsible, honest, and ethical manner, with a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all of our business dealings and relationships everywhere we operate, as well as to creating and enforcing effective processes to prevent integrity infractions. The LC policy seeks to achieve the following goals:
1. To initiate the steps to reduce the bribery and corruption risks to the business of the organisation by setting out clear guidelines,
2. To encourage all employees to be vigilant and to act diligently in good faith.
3. To monitor and investigate instances of alleged corruption.
4. To take firm and vigorous action against any individual(s) involved in corruption.
5. To minimize the risk of involvement of all employees and Directors in corruption related activities;
6. To form a common understanding for all stakeholders that LC prevents corruption in any form;
7. To set responsibility for the employees of LC to know and comply with the principles and requirements of the Policy, the key rules of the applicable anti-corruption laws, as well as adequate procedures to prevent corruption.
To uptight the ethics and integrity of our firm, the policy covers integrity violations which includes but not limited to bribes, gifts and hospitality , facilitation payments , political contributions , charitable contributions for concealment , and red flag instances .