Grievance Addressing / Vigil Mechanism

Shine is a professionally managed company engaged in the business of Asset Reconstruction under the SARFAESI Act. To ensure compliance with its Vision and
Mission of following the highest standards of business ethics, transparent policies and procedures based on the highest levels of Corporate Governance, Shine is keen to establish a Vigil Mechanism which will inter-alia, protect “whistle-blowers” and encourage stakeholders to report any potential or actual violation of business ethics,
including company policies, code of conduct, actual or suspected fraud, hereinafter referred to as “alleged breach”.

All stakeholders of the Company including Directors will be covered; the first report or disclosure of an alleged breach (“complaint”) will be made in writing to the NodalOfficer and will be made in good faith, i.e. the complainant has strong reason to believe that the complaint is materially correct and is not mala-fide. The Nodal Officer, at his discretion, may decide to investigate anonymous complaints, if the charges are serious and the material available on record is sufficient to warrant a prima-facie inference that the allegations are maintainable and further investigation is justified. The whistle blower will not conduct any investigation; this is the responsibility of the Nodal Officer and his representatives, including the concerned Management personnel.

Any stakeholder, whether employee or otherwise who makes a “complaint” will be considered as a “whistle blower “and will be entitled to protection against any unfair treatment / harassment including threatened or actual disciplinary action by Shine, merely by reason of making such complaint. Such protection will also be available to any other stakeholder who gives evidence or assists in the investigation (witness). The identity of the whistle blower / witnesses will be kept confidential and disclosed only if required under law or where the investigation cannot proceed without such disclosure;Shine will assist the whistleblower / witnesses in any proceedings including court matters, concerning the investigation of the complaint.