Aditya Birla Sun Life Asset Management Co Ltd

The ultimate stewardship responsibility will be discharged by the Aditya Birla Health Insurance Co. Limited. The company will be responsible for ongoing monitoring of the investee companies and will also be responsible for engaging with the managements of the investee companies. The investment team will seek guidance and approvals from the Investment Committee with respect to the engagement and intervention with the investee companies. Appropriate operating guidelines shall be put in place for such monitoring on ongoing basis. [...] The Company will manage conflicts of interest by requiring Investment Committee members and other personnel involved in implementing the stewardship code. [...] Frequency and process to monitor the activities of Investee Company shall be annually. The Investment team will be accountable for monitoring all the companies in which the Company invests in. [...] Investment Front Office shall decide the engagement strategy based on internal research and institutional advisory services. The final decision should be documented by Investment Front Office and approved by Investment Mid Office and subsequently presented in IC for noting. [...] First level of escalation will be internally to investment head or committee, where further course of action will be decided which may include decision to divest or escalate the matter to regulatory authorities or collaboration with other investors, [...] The Company shall furnish a report on an annual basis to the Authority as per Annexure A, on the status of compliance with the Stewardship Code. The status report, approved by the Board shall be endorsed by the Compliance Officer and should be submitted on or before 30[th] June.

ABSLAMC will ensure that the stewardship policy is comprehensive and will be followed in true spirit. Policy Review: The Stewardship Policy will be reviewed and updated once every year and will be disclosed on the website of ABSLAMC. [...] To manage the above conflicts of interest, the Company ensures that: 1. The employees in the investment teams shall comply with the policy for Prevention of Insider Trading in compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015 and the Code of Conduct policy which includes provisions for identifying and managing Conflict of interest. 2. Rationale for voting on each shareholder resolution shall be recorded by the Company. 3. Rationale behind a new investment decision shall be recorded. [...] Frequency and process to monitor the activities of Investee Company shall be annual. Investment team will be accountable for monitoring all the companies in which ABSLAMC invests. [...] First step: Interaction: The meeting(s) with investee companies are to be conducted in a confidential manner with a view to resolve the issue constructively. If dissatisfied with the response of the investee company, ABSLAMC will proceed to escalate the matter further. Next step: Escalation First level of escalation will be internally to investment head or committee, where further course of action will be decided which may include decision to divest or escalate the matter to regulatory authorities or collaboration with other investors, In case there is no progress despite re-iteration through multiple interactions, the matter will be discussed at the Investment Committee of ABSLAMC for further escalation to the Board of Directors of the investee company. If the Investment Committee decides to escalate, the communication to the Board of the investee company should elaborate on the concerns. Final step: Reporting to regulators/authorities Despite escalation if there is no response or action taken by Investee Company, the Investment Committee may decide to report to the relevant regulator, authority or any Government body as may be required. In all cases of engagement with the management and / or the Board of Directors of the investee company, all communications and discussions are to be conducted in private and confidential manner. [...] Effective oversight on the stewardship activities is to be reviewed by Board for compliance with corporate governance code. ABSLAMC shall furnish a report on an annual basis as per Annexure A, on the status of compliance with the Stewardship Code. The status report shall be placed before the Board of ABSLAMC should be uploaded on the website on or before 30th June every year. The reporting should be done under the principle of "comply or explain", the reasons for deviation or non- compliance with the Stewardship Principles should be provided in the report. The report shall also be sent as a part of annual communication to its investors.