VIGIL MECHANISM POLICY

Policy Objectives
The Vigil Mechanism aims to provide a channel to the Directors and employees to report genuine concerns about unethical behavior, actual or suspected fraud or violation of the Codes of Conduct or policy. The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations and in order to maintain these standards, the Company encourages its employees who have genuine concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment.

Definitions
“Protected Disclosure” means a written communication of a concern made in good faith, which discloses or demonstrates information that may evidence an unethical or improper activity under the title
“SCOPE OF THE POLICY” with respect to the Company. It should be factual and not speculative and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern.

“Subject” means a person or group of persons against or in relation to whom a Protected Disclosure is made or evidence gathered during the course of an investigation.
“Vigilance Officer/Vigilance Committee or Committee” is a person or Committee of persons, nominated/appointed to receive protected disclosures , maintaining records thereof, placing the same before the Audit Committee for its disposal and informing the person disclosing the result thereof.

o Breach of Business Integrity and Ethics
o Breach of terms and conditions of employment and rules thereof
o Intentional Financial irregularities, including fraud, or suspected fraud
o Deliberate violation of laws/regulations
o Gross or Wilful Negligence causing substantial and specific danger to health, safety and environment
o Manipulation of company data/records
o Pilferation of confidential/propriety information
o Gross Wastage/misappropriation of Company funds/assets

The Policy should not be used as a route for raising malicious or unfounded allegations against colleagues

The contact details of the Vigilance Officer are as under or contact the Chairman of the Audit Committee in case the issue is not solved by the vigilance officer:-

Name and Address – Avinash Agarwalla (Whole Time Director) Captain Steel India Limited
Address: 21A, Shakespeare Sarani 10th Floor, Flat No 10A Kolkata WB 700017 Email: avinash.agarwalla@bmaind.com

On receipt of the protected disclosure the Vigilance Officer shall process the Protected Disclosure.

Investigation
All Protected Disclosures under this policy will be recorded and thoroughly investigated. The Vigilance Officer will carry out an investigation either himself/herself or by involving any other Officer of the Company/ Committee constituted for the same /an outside agency before referring the matter to the Audit Committee of the Company. The Audit Committee, if deems fit, may call for further information or particulars from the complainant and at its discretion, consider involving any other/additional Officer of the Company and/or Committee and/ or an outside agency for the purpose of investigation. The investigation by itself would not tantamount to an accusation and is to be treated as a neutral fact finding process.

Decision And Reporting
If an investigation leads to a conclusion that an improper or unethical act has been committed, the Chairman of the Audit Committee shall recommend to the Board of Directors of the Company to take such disciplinary or corrective action as it may deem fit. Any disciplinary or corrective action initiated against the Subject as a result of the findings of an investigation pursuant to this Policy shall adhere to the applicable personnel or staff conduct and disciplinary procedures. A complainant who makes false allegations of unethical & improper practices or about alleged wrongful conduct of the Subject to the Vigilance Officer or the Audit Committee shall be subject to appropriate disciplinary action in accordance with the rules, procedures and policies of the Company.

Disqualifications
While it will be ensured that genuine complainants are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action. Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a complainant knowing it to be false or bogus or with a mala fide intention. Complainants, who make any Protected Disclosures, which have been subsequently found to be mala fide, frivolous or malicious, shall be liable to be prosecuted.

The Company reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the Directors and employees unless the same is not communicated in the manner described as above. The relevant law, rule, regulation or standard will take precedent over this policy.