Introduction

As a part of our Quantum Growth journey at Godrej Properties, ‘Driving Agility’ is a critical
component of our success. In order to promote agility, we are empowering the zonal, regional &
site-level teams through Project Simplify to make timely decisions that benefit our customers
and the organization.

While we continue to promote de-centralization and empower our regional and site-level teams
with more decision-making authority, we must remember that higher authority comes with
stronger personal and professional accountability. We must ensure strict adherence to
Governance mechanisms to maintain Accountability, Transparency, and Consistency in our
decision making. “Trust” is a GPL Value that we must continue to nurture in all our ways and the
expectation to drive this even more strongly is at the Leadership level at all levels, especially
where decision making authority rests.

As we encourage our employees to take ownership and initiative, we also maintain a Zero-
tolerance policy for fraud and unethical behavior. We believe that maintaining the highest
standards of ethical conduct is crucial to the success of our company and the well -being of our
employees and stakeholders.

In order to ensure Agility, combined with high levels of integrity in all our business dealings, we
are formally communicating our zero-tolerance approach towards any individual who commits
theft, fraud, forgery, breach of trust, etc. Any such incident will be directly overseen by senior
leadership of the organization. We encourage all of you to go through the policy document
prescribed by the organization towards a Zero-tolerance policy for fraud and unethical behavior.

Effective today our approach and policy towards this will be the following:

a. Anyone found guilty of code of conduct violation and fraud upon investigation will
be immediately terminated from the rolls of the organization
b. An FIR will be lodged at the local police station and the fraudulent amount will be
recovered
c. The names of the individuals will be published in an internal communication to all
employees in GPL stating that the individual has been terminated for fraud
d. We will choose to publish the name of the person in the local newspapers informing
people externally too of the discontinuation of our association with the individual(s) along
with the details, as necessary

We will continue to leverage the law enforcement authorities to go after anyone who attempts
to cheat or commit fraud against the organization. Committing fraud will have serious
consequences far more than someone just losing their job.
We wish to reiterate that should you come across or hear of any such instances, you are duty-
bound to bring it to the notice of your manager, HR or any of the senior leaders of the
organization.

Last but not the least, there will not be any leniency in our approach and no consideration will be
given to any such culprit. Let us continue to work together to make GPL an organization rooted
in and guided by the Godrej values.
 Violation of Code of Conduct – Course of Action

Objective

This document has been prepared for and notified at the Company to:

a) list down the course of action and steps followed at Godrej Properties Ltd in case of
violation or breach of code of conduct
b) prevent, deter and prohibit the occurrence or commission of any violation of Code of
Conduct or Unethical practices at the Workplace

Applicability & Duty to Report

This is applicable to all Employees - permanent, temporary, ad hoc, consultant, probationer,

trainee or intern whether employed as full time, part time or daily wage basis, whether working
on a voluntary basis or otherwise.

It is a responsibility of each employee to report any breach directly or indirectly to the manager
or Business Head or HR or whistleblowing officer.

Course of Action in cases of violation

Steps Process Responsibility

Step 1 Complaint Received
Step 2 Investigation initiated by intimating the
Internal Audit Team
Step 3 Investigation conducted by Internal Audit Internal Audit
team
Step 4 Termination of employee from the rolls of Business HR & Manger / HOD
the organization if found guilty and recovery
of fraudulent amount
Step 5 Legal action and /or FIR lodged GPL Legal team
Step 6 Details of the case to the published to all GPL GPL HR team
employees
Step 7 Publishing in the local news papers for GPL HR team
discontinuation of association with these
employees

Through the process the following members of the GPL Leadership Team will be kept informed
and they will take the necessary decisions and actions as required:
1. Zonal Head & Zonal HR of the respective GPL Zones
2. Functional Heads at Head Office
3. Chief Financial Officer, GPL
 4. Chief Legal Officer, GPL
5. Chief Human Resource Officer, GPL

How to make a complaint?

Should you wish to raise concerns about improper or unethical practices being followed in the
Company, you may raise it to your line manager/HOD/HR Lead.

Should you wish to raise it without necessarily informing your manager, you can lodge a
complaint with the Whistleblowing Officer or the Audit Committee.

You will be protected against any resultant adverse repercussions and/ or discrimination (such
as intimidating you or your employment) provided it is justified and made in good faith.

Whistleblowing Officer

Mr. V. Swaminathan has been appointed the Whistleblowing Officer, with effect from May 1,
2010.

He can be contacted at:

 Postal Address: Godrej One, Pirojshanagar, Eastern Express Highway, Vikhroli East,
Mumbai - 400079, Maharashtra, India

• Telephone Number: 91-022-25194403/ 91-9819825526

 Email Address: ve.swaminathan@godrejinds.com

You can also make complaints via the following mechanism:

1. Web portal: https://www.godrejspeakup.com
2. Email: ethicsindia@godrejinds.com
3. Toll free number: 1800 22 5548

Should you need any clarification, refer to the GILAC Code of Conduct and reach out to your
Business HR Lead

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