Integrated Annual Report 2025-26 118 New joiners are mandatorily required to undertake eLearning modules on the Code, POSH and ABAC. In addition to this, an Annual Compliance Declaration Module is mandated for the employees where the employees provide their affirmation on clauses of the Code and appropriate disclosure wherever applicable. In order to achieve regular reinforcement of the Code and policies across the Company, the Company has an Ethics Counsellors community with over 170 Ethics Counsellors. They are the flag bearers and drivers to enhance awareness about the policies and procedures, amplify the values which the Company stands for and facilitate regular conversations and awareness with their cohorts. The Ethics Counsellors are trained by subject matter experts (internal/ external) on ethics and policies throughout the year. During the year, they have trained more than approximately 4,000 employees across various geographies on the Code and policies related to ABAC, G&E, POSH and WB including appropriate real life case studies (while maintaining confidentiality), examples and respective disciplinary actions taken. Further, the Company has driven sensitisation on various aspects of its ethical policies and procedures vide guidelines, emailers, videos, standees and posters across locations. Your Company’s Vigil mechanism process is clearly defined for identifying, investigation and decision making by respective Group Ethics and Governance Committee (‘GEGC’) or Business Ethics and Governance Committee (‘BEGC’) to appropriately resolve the violations of applicable Company policy and relevant law. It is regularly communicated throughout the Company vide the ‘Speak Up campaign’. Overall details pertaining to such violations is reviewed by the Corporate Governance Council and the Audit Committee on quarterly basis which helps in identification of vulnerable areas, policy development, any review of policies, process improvement, training and awareness initiatives. The Corporate Governance Council ensures that the Ethics and Governance framework is executed effectively. The GEGC and BEGC help to ensure decisions on substantiated cases are taken in a fair, just and consistent manner across various functions of that business. In addition to the laid down processes, the Company has also strengthened the Data Leakage Protection (DLP) process, to ensure minimisation of any loss/ leakage and protection of Company’s sensitive/ confidential data. Vigil Mechanism The Vigil Mechanism as envisaged in the Companies Act, 2013, read with the Rules prescribed thereunder, and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 is implemented through the Company’s Whistle-Blower Policy. The Whistle-Blower Policy of your Company is uploaded on the Company’s website and can be accessed at the Web-link: https://www.mahindra.com/Whistle-blower-Policy.pdf It enables the Directors, employees and all stakeholders of the Company to report genuine concerns (about unethical behaviour, actual or suspected fraud, or violation of the Code) and provides for adequate safeguards against victimisation of persons who use such mechanism and makes provision for direct access to the Chairman of the Audit Committee. A quarterly report on the whistle-blower complaints, as received, is placed before the Audit Committee for its review. All complaints are tracked and monitored on timely basis. During the year, the Company received 208 whistle-blower complaints, out of which 165 complaints were investigated, and appropriate actions were taken and investigations are underway for the remaining 43 complaints. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 Your Company believes in providing a safe, non-hostile and harassment-free work environment at all its workplaces. The Company has zero tolerance towards sexual harassment at the workplace. A detailed Prevention of Sexual Harassment (‘POSH’) Policy is in place as per the requirements of The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (‘the Act’). The POSH Policy of the Company is available on the Company’s website and can be accessed in the Governance section at the Web-link: https://www.mahindra.com/policiesand-documents The POSH Policy is also available in 8 vernacular languages. The POSH Policy covers the Company and its subsidiaries, all employees (permanent, contractual, temporary, trainees) irrespective of their sexual orientation/ preferences and all persons associated with/ visiting the Company at any of its locations. The POSH Policy is gender inclusive and the framework ensures complete anonymity and confidentiality. Internal Complaints Committees (‘IC’) have been constituted to timely redress complaints of sexual harassment and the Company has complied with the provisions relating to the
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