1. Investor Relations Policy

1.1 Purpose and Scope

This Investor Relations Policy ("Policy") of 7Sindhu Private Limited (CIN: U58202KA2026PTC216654) ("Company," "we," "us," or "our") establishes the framework for communication with shareholders, potential investors, financial analysts, and other stakeholders. This Policy ensures compliance with applicable laws, regulations, and best practices in corporate governance.

1.2 Principles of Communication

• Transparency: All material information shall be disclosed in a timely, accurate, and comprehensive manner.
• Consistency: Information shall be disseminated uniformly to all stakeholders simultaneously.
• Compliance: All communications shall comply with the Companies Act, 2013, SEBI regulations (if applicable), and other relevant laws.
• Confidentiality: Unpublished price-sensitive information shall be handled with strict confidentiality.
• Accessibility: Information shall be made available through multiple channels including the Company website, email, and official communications.

1.3 Authorized Spokespersons

Only the following individuals are authorized to communicate with investors and analysts on behalf of the Company:

• Managing Director / Chief Executive Officer
• Chief Financial Officer
• Investor Relations Officer
• Company Secretary (for regulatory and compliance matters)
• Any other person specifically authorized by the Board of Directors

2. Disclosure and Materiality Policy

2.1 Material Information

Material information includes any information that could reasonably be expected to affect the investment decisions of shareholders or the market price of the Company's securities. Examples include but are not limited to:

• Financial results, forecasts, and material changes in financial condition
• Mergers, acquisitions, divestitures, or joint ventures
• Changes in capital structure or dividend policy
• Material contracts, agreements, or partnerships
• Changes in senior management or Board composition
• Regulatory actions, litigation, or legal proceedings
• Material changes in business operations or strategy
• Significant technological developments or intellectual property matters

2.2 Disclosure Timeline

Material information shall be disclosed promptly, and in no event later than 24 hours from the occurrence of the event or decision by the Board of Directors, whichever is earlier, unless otherwise specified by applicable regulations.

2.3 Quiet Period

The Company observes a "quiet period" commencing two weeks prior to the end of each financial quarter until 48 hours after the public release of quarterly financial results. During this period, the Company will not comment on financial performance, guidance, or market expectations.

3. Code of Conduct for Prevention of Insider Trading

3.1 Prohibition on Insider Trading

No director, officer, employee, or connected person shall trade in the securities of the Company while in possession of unpublished price-sensitive information (UPSI). This prohibition extends to communicating, providing, or allowing access to UPSI to any person who may trade on the basis of such information.

3.2 Trading Window

Trading in the Company's securities by designated persons shall be permitted only during "trading windows." The trading window shall be closed:

• From the end of each financial quarter until 48 hours after declaration of financial results
• When the Compliance Officer determines that a material event has occurred
• During any other period as may be specified by the Company

3.3 Pre-clearance Requirements

Designated persons must obtain pre-clearance from the Compliance Officer before trading in the Company's securities when the value of proposed trades exceeds INR 10,00,000 (Ten Lakhs) in a calendar quarter. Pre-clearance approval shall be valid for 7 trading days from the date of approval.

3.4 Disclosure Requirements

Designated persons shall disclose their holdings and trading in the Company's securities within 2 working days of such transaction. Annual disclosures shall be made within 30 days of the end of each financial year.

4. Related Party Transaction Policy

4.1 Definition of Related Party

Related parties include directors, key managerial personnel, their relatives, entities in which they have significant influence or control, and any other party as defined under Section 2(76) of the Companies Act, 2013 and applicable accounting standards.

4.2 Approval Requirements

• Audit Committee: All material related party transactions require prior approval of the Audit Committee.
• Board of Directors: Transactions exceeding specified thresholds require Board approval.
• Shareholders: Material transactions as defined under applicable law require shareholder approval through special resolution.

4.3 Arm's Length Principle

All related party transactions shall be conducted on an arm's length basis and in the ordinary course of business. The Company shall maintain documentation supporting the arm's length nature of such transactions.

4.4 Disclosure

Related party transactions shall be disclosed in the financial statements, Board reports, and other statutory filings as required under applicable laws and accounting standards.

5. Dividend Distribution Policy

5.1 Dividend Philosophy

The Company is committed to creating sustainable shareholder value through a balanced approach of growth investments and dividend distributions. The Board shall consider dividend declarations based on the Company's financial performance, cash flows, capital requirements, and growth opportunities.

5.2 Factors Affecting Dividend Decisions

• Profits available for distribution as per applicable laws
• Cash flow position and working capital requirements
• Capital expenditure plans and expansion requirements
• Debt obligations and financial covenants
• Economic and business conditions
• Tax implications for the Company and shareholders
• Past dividend trends and shareholder expectations

5.3 Dividend Payment

Dividends, when declared, shall be paid within 30 days from the date of declaration. Interim dividends may be declared by the Board, while final dividends require shareholder approval at the Annual General Meeting.

6. Risk Management Policy

6.1 Risk Management Framework

The Company has established a comprehensive risk management framework to identify, assess, monitor, and mitigate risks that could impact business objectives, financial performance, or stakeholder interests.

6.2 Key Risk Categories

• Strategic Risks: Market competition, business model changes, technological disruption
• Operational Risks: Process failures, supply chain disruptions, human resource challenges
• Financial Risks: Credit risk, liquidity risk, foreign exchange risk, interest rate risk
• Compliance Risks: Regulatory changes, legal proceedings, tax matters
• Reputational Risks: Brand damage, stakeholder relations, media coverage
• Cybersecurity Risks: Data breaches, system failures, cyber attacks

6.3 Risk Governance

The Board of Directors has overall responsibility for risk oversight. The Audit Committee reviews the risk management framework quarterly. Business units are responsible for day-to-day risk management within their areas.

7. Vigil Mechanism / Whistle Blower Policy

7.1 Purpose

The Company has established a Vigil Mechanism to provide a channel for directors, employees, and stakeholders to report genuine concerns about unethical behavior, actual or suspected fraud, or violation of the Company's code of conduct.

7.2 Reportable Matters

• Financial irregularities, fraud, or misappropriation of assets
• Breach of code of conduct or ethics policy
• Conflict of interest situations
• Abuse of authority or misuse of Company resources
• Violation of legal or regulatory requirements
• Discrimination, harassment, or unsafe working conditions

7.3 Protection of Whistle Blowers

The Company is committed to protecting whistle blowers from retaliation, discrimination, or adverse employment consequences. The identity of whistle blowers shall be kept confidential to the extent possible. Anonymous complaints will be investigated to the extent feasible.

7.4 Reporting Channels

Concerns may be reported to:

• Audit Committee Chairman: audit@7sindhu.com
• Company Secretary: compliance@7sindhu.com

8. Document Retention and Archival Policy

8.1 Retention Requirements

The Company shall maintain and preserve documents in accordance with applicable laws and regulations. Key retention periods include:

• Financial Records: 8 years from the end of the relevant financial year
• Statutory Registers: Permanently
• Board and Committee Minutes: Permanently
• Contracts and Agreements: 8 years after expiry or termination
• Tax Records: As per Income Tax Act and GST Act requirements
• Employee Records: 3 years after separation

8.2 Document Destruction

Documents shall be destroyed only after the expiry of the retention period and with proper authorization. No documents shall be destroyed if they are subject to litigation, investigation, or audit.

9. Investor Grievance Redressal Policy

9.1 Grievance Mechanism

The Company has established a mechanism for prompt and effective resolution of investor grievances. All complaints shall be acknowledged within 48 hours and resolved within 30 days, wherever possible.

9.2 Types of Grievances

• Non-receipt of dividend, interest, or redemption proceeds
• Non-receipt of annual reports or notices
• Issues related to share transfers or transmissions
• Discrepancies in shareholder records
• Requests for information or clarification
• Any other investor-related concerns

9.3 Contact Information

Investor grievances may be submitted to:

10. General Provisions

10.1 Amendment

These policies may be amended, modified, or supplemented by the Board of Directors from time to time. Material amendments shall be disclosed on the Company website and through appropriate channels.

10.2 Interpretation

In case of any conflict between these policies and applicable laws or regulations, the provisions of such laws or regulations shall prevail. The Board of Directors shall have the authority to interpret these policies.

10.3 Governing Law

These policies shall be governed by and construed in accordance with the laws of India. Any disputes arising from these policies shall be subject to the exclusive jurisdiction of courts in Karnataka, India.

10.4 Disclaimer

The information contained in these policies is for general guidance only and does not constitute legal, financial, or investment advice. Investors should consult their own advisors before making investment decisions. The Company does not guarantee the accuracy or completeness of information and shall not be liable for any errors or omissions.

11. Acknowledgment and Compliance

All directors, officers, employees, and relevant stakeholders are required to read, understand, and comply with these policies. Violations may result in disciplinary action, including termination of employment or directorship, and may also result in civil or criminal liability.

By accessing this information, you acknowledge that you have read and understood these policies and agree to be bound by their terms.