Introduction

Meiden T&D (India) Limited ("MTD") enforces a strong commitment to ethical conduct through its Anti-Bribery Secondary Rules (LCS-036-2022-2023), effective from April 1, 2023. These Rules supplement the Meiden Group Anti-Bribery Policy and work together to prevent bribery and corruption within the company.

Compliance

All directors and employees (collectively, "Employees") must comply with these Rules and the Group Policy. Offering or receiving financial or non-financial benefits requires prior approval, and the timing will be essence during the exchanges so to avoid suspicion of corruption (e.g., avoid during negotiations).

Restricted Practices

These Rules strictly prohibit, but are not limited to, the following:

• Dishonest misappropriation of property or money.
• Bribery (offering or receiving).
• Improper charitable donations intended to gain commercial advantage.
• Accepting or giving gifts exceeding specified limits or not compliant with these Rules.

Approval Process

To ensure adherence, a defined approval process is in place. Employees must submit a request form for any offering or receiving of benefits. The approval level depends on the recipient category (government official, client, etc.) and value of the offering. MTD encourages reporting of suspected violations and strictly prohibits retaliation against such reports.

Responsibility

Finally, the Board of Directors and all employees are individually responsible for upholding these, Rules. These Rules will be reviewed annually to ensure they remain aligned with evolving business practices.

With this framework, MTD strives for a work environment built on ethical conduct and legal compliance.