Wipro Ltd

Wipro has a corporation-wide Code of Business Conduct (COBC) that provides broad direction as well as specific guidelines for all business transactions. The COBC applies to all business practices and employees, contractor employees and consultants. It covers critical aspects like customer relations, protecting customer information, supplier selection, conflicts of interest, gifts, entertainment and business courtesies, communicating with the public, confidential information, intellectual property, competitive/business intelligence, protecting the privacy of employee and personal information, business records and internal controls, safeguarding company assets, insider trading; anti-trust and fair competition, anti-corruption, political involvement/lobbying, global trade; human rights, diversity and non-discrimination, harassment-free workplace; safe and healthy work environment, and sustainability and corporate citizenship. [...] Wipro's compliance processes are overseen by the Board of Directors, the Audit Committee, and the Corporate Compliance Committee. The latter focuses on matters related to the Code of Business Conduct, grievance redressal, and statutory issues. [...] We have an effective framework for monitoring legal compliance, including a Global Statutory Compliance Policy approved by the Board. We've also implemented an online compliance management system to track and report compliance status to senior management and the Board regularly. The Audit, Risk, and Compliance Committee, along with the Board, regularly monitors compliance with applicable laws.

Our code of conduct and the supplier code of conduct cover requirements of FCPA (Foreign corrupt practices act) and the UK anti-bribery act. High risk functions assessed are procurement, Talent Acquisition, CMF, Human Resources, Facility Management Group, Sales and the geographies selected are based on the relative ranking in Transparency International ranking of countries we operate in. [...] Your Company has adopted an Ombuds process as a channel for receiving and redressing complaints from employees and directors, as per the provisions of Section 177(9) and (10) of the Companies Act, 2013, Regulation 22 of the Listing Regulations and Regulation 9A of Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015. [...] Under this policy, your Company encourages its employees to report any incidence of fraudulent financial or other information to the stakeholders, reporting of instance(s) of leak or suspected leak of unpublished price sensitive information, and any conduct that results in violation of the Company's code of business conduct, to the management (on an anonymous basis, if employees so desire). Further, your Company has prohibited discrimination, retaliation or harassment of any kind against any employee who reports under the Vigil Mechanism or participates in the investigation. [...] Awareness of policies is created by, inter alia, sending group mailers highlighting actions taken by the Company against errant employees. Mechanism followed under the Ombuds process has been displayed on the Company's intranet and website at https://www.wipro.com/investors/corporate-governance/#Wipr osOmbudsProcess. [...] All complaints received through the Ombuds process and investigative findings are reviewed and approved by the Chief Ombuds person. All employees and stakeholders can also register their concerns either by sending an email to ombuds.person@wipro.com or through web-based portal at https://www.wipro.com/investors/corporate-governance/ #WiprosOmbudsProcess. Following an investigation of the concerns received, a decision is made by the appropriate authority on the action to be taken on the basis of the investigation's findings. In case the complainant is non-responsive for more than 15 days, the concern may be closed without further action.

### 6. Governance

#### 6.1 Policy Owner

CEO and Managing Director

#### 6.2 Cadence

Wipro is dedicated to conducting annual reviews of its environment policy to ensure its relevance, effectiveness, and adherence within the organization and to international standards and best practices. The outcomes of these reviews will be documented, and any essential amendments or enhancements to the policy will be promptly implemented.

#### 6.3 Catalyst

Chief Sustainability Officer, Group Executive Council and the Board of Directors. These individuals are responsible for creating awareness, understanding, and compliance with the policy throughout the organization.

The Board Governance, Nomination and Compensation Committee is headed by an independent director and acts as the CSR Committee - an apex body that oversees Wipro's sustainability policy and programs. The Committee comprising entirely independent directors is responsible for reviewing the Company's policies on Corporate Social Responsibility, including public issues significant to Wipro and its stakeholders. This committee and the Chairman will discuss and sign off the goals and objectives along with the budgets of CSR programs at the beginning of every year. Subsequently, the sustainability team's leadership will allocate the budgets in line with the defined priorities and goals. The sustainability team also presents a quarterly report to the Chairman and the Board CSR Committee. [...] Wipro's sustainability program is governed by the Nomination and Remuneration Committee comprising of independent directors. This is followed by the Wipro Executive Committee, including the Chairman and CEO. The Chief Human Resources Officer also acts as the Chief Sustainability Officer, and reports to the Wipro Executive Committee. Their collective vision shapes Wipro's sustainability strategy, ensuring alignment with global best practices and emerging trends. We recognize that sustainable governance is not an isolated function but a collaborative effort across hierarchies and functions. This is not possible without the collaborative efforts of different cross-functional teams. [...] The Global Operations Team – architecting sustainable processes, strategies and mitigation measures. The People Function – nurturing diversity, well-being, talent and managing the workforce. Investor Relations – engaging with investors, weaving sustainability into financial narratives. The Legal Team – ensuring compliance, ethical conduct, and safeguarding commitment to responsible business.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]We have an overarching "Ecological Sustainability" policy that lays the overall scope and activity alignment (https://www.wipro.com/content/dam/nexus/en/sustainability/pdf/ecological-sustainability-policy.pdf ). This is signed by our CEO and Managing Director.

Excerpts are here:
"The crisis of climate change poses one of the biggest threats to humanity the impacts of which will be global
with vulnerable communities being hit the hardest. As a responsible corporation, we are committed to minimizing our impact and have set for ourselves the goal of Net Zero greenhouse gas emissions for Scopes 1,2 and 3 by the year 2040 in line with the Paris agreement with clearly defined intermediate targets. A basic principle underlying our efforts will
be a predominant focus on direct decarbonization with deferment of offsets to the target year.

"Global standards: As a global leader in sustainability, we will constantly benchmark with leading practices from across the
world and meet and exceed those standards. As part of this, we will actively engage with globally accepted frameworks and calibrate our environmental policies and programs accordingly e.g. on climate change, we are aligned with Science Based Targets Initiative (SBTi) for our goal setting and with the guidelines of the Taskforce for Climate-related Financial Disclosures (TCFD) for our climate reporting. "

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes