Adani Wilmar Limited

Supplier Code of Conduct

1. Introduction

Adani Wilmar Limited (AWL) is committed to responsible and ethical business practices
in the areas of human rights, labour practices, environment, anti-corruption, and other
governance related areas.

AWL considers suppliers as business partners. This Code of Conduct is aimed at

collaborating with our suppliers in the promotion of lawful, professional, and fair
business practices that integrates respect of human rights, business ethics and
environment.

2. Applicability

This Supplier Code of Conduct is applicable to all Suppliers globally. Here, “Supplier”
refers to material suppliers/ service providers/ vendors/ traders/ agents/ consultants/
contractors / third parties including their employees, agents and other representatives,
who have a business relationship with and provide, sell, seek to sell, any kinds of goods
or services to AWL or any of its subsidiaries and associated entities.

The Supplier shall communicate the code to related entities and subcontractors who
support them in delivering materials or services and ensure adherence from all related
entities and subcontractors.

3. Guidelines on Code

 Regulatory Compliance: The Supplier shall ensure to comply with all applicable laws
and regulations in all the territories it operates.

 Human Resources:
 Freely Chosen Employment: The Supplier shall ensure to hire all their employees
on their own free will; and all their operations are free from child, forced, and
bonded labour or any other form of compulsory labour or slavery.
 Equal Opportunity: The Supplier shall ensure to provide equal employment
opportunities and conducive environment to all its employees for their growth
without any discrimination and harassment.
 Working Hours, Wages and Benefits: The Supplier shall comply with all applicable
laws and regulations with respect to working hours, minimum wages, employing
labour, including those pertaining to women and children. The Supplier shall treat
their employees with respect and dignity.
 Human Trafficking: The Supplier shall ensure the compliance with all anti-human
trafficking laws internally and across their supply chains.
 Freedom of Association: The Supplier shall be committed to an open and
constructive dialogue with their employees and worker’s representatives, in
accordance with local law.

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 Adani Wilmar Limited
Supplier Code of Conduct

 Health and Safety:

 The Supplier shall ensure provision of safe and healthy working environment to its
employees/ workers.
 The Supplier shall ensure necessary precautionary safety measures and shall
design processes to protect against potential accidents and occupational
hazards.
 The Supplier shall ensure that general principles of health and safety risk
prevention are met in the process of delivery of products and services. General
principles include identifying, minimizing and preventing hazards using
competent and trained professionals; maintaining safe equipment and tools;
providing personal protective equipment as required.
 The Suppliers shall ensure that adequate training is provided for all employees,
workers/ contractors on health and safety issues.
 The Supplier shall ensure provision of safe, clean and secure accommodations to
their employees, if applicable.

 Environment Management:

 Natural resource conservation: The Supplier shall ensure that optimal processes
exist for conservation of natural resources and minimization of the release of
harmful emissions to the environment.
 Efficient systems and process: The Supplier shall ensure ongoing initiatives to
promote environmental responsibilities and encourage environment-friendly
processes and technologies to mitigate climate change effects.
 Pollution prevention: The Supplier shall ensure compliance with all laws
pertaining to sustainability, pollution, environment protection etc. as applicable.
 Waste management: The Supplier shall ensure management of wastes of any form
– hazardous, non-hazardous, industrial, solid/ liquid/ gaseous as per the prevailing
laws and recommended guidelines.

 Governance:

 Adherence with Company Policy: The Supplier shall follow all contract conditions
and other applicable policies of the Company while executing any work at AWL
sites.
 Bribery or Corruption: The Supplier shall not offer or accept bribes or other
unlawful incentives to/from their business partners.
 Conflict of Interest: The Supplier shall not take advantage of any family/ social/
political connections to obtain favourable treatment that creates any actual or
potential conflict of interest.
 Grievance Redressal: The Supplier shall ensure that any worker/ employee, acting
individually or with other workers, can submit grievance and an effective
grievance procedure should be established for its redressal.
 Reporting of Unethical Practices: The Suppliers shall report any unethical activity
or discrimination if practiced by any of AWL employee/ other suppliers as per the
whistle-blower policy.

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Supplier Code of Conduct

 The policy is uploaded on the Company website.

(https://www.adaniwilmar.com/investors).
 Intellectual Property: The Supplier shall ensure that all employees' and business
partners’ privacy and intellectual property rights which includes protection
against disclosures, patents, copyrights and trademarks are protected.
 Third Party Representation: The Suppliers shall not be authorized to represent
AWL or to use its brands without written permission from AWL. Third parties and
their employees who are authorized to represent AWL are expected to abide by
provision in the non-disclosure agreement to be signed by them.
 Prohibition on Insider Trading: The Suppliers and their personnel shall not use any
material or non-publicly disclosed information for trading of AWL businesses
securities or enabling others for the same.

 Subcontracting:
 The Supplier shall not use any subcontractor in connection with any AWL
business unless subcontractor abides by the same conditions as put forth by
AWL. The Supplier shall submit declaration with list of subcontractors to AWL
prior to commencement of work. AWL BUs must be notified immediately in case
of any changes in subcontracting.

4. Supplier Evaluation: AWL has set specific supplier expectation regarding supplier
performance with the Code. AWL will continue to evaluate the Suppliers taking into
consideration the ability to meet the objective and expectations of this Code.

5. Continuous Improvement: Where applicable, AWL will support Suppliers in the

establishment of best practices to meet and exceed the standards outlined in the Code.

6. Acceptance: By signing the purchase order/ contract/ agreement copy the Supplier
acknowledges having read, understood, and accepted the guidelines as described in
the Supplier Code of Conduct. The Suppliers are expected to fulfil the aforementioned
key elements of this policy by incorporating them in their own business practices.

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