Familiarization Program for Independent Directors

1. OBJECTIVE

   Anupam Rasayan India Limited (“Company”) believes that a board well informed and having proper familiarization with the Company will contribute positively to the Company. The familiarization programs which may be conducted for Independent Directors from time to time, would aim to provide overall understanding about the Company’s business model, operations, strategies, industry in which the Company operates and other aspects of the business along with roles, responsibilities of the Independent Directors.

2. FAMILIARIZATION PROCESS

   At the time of joining new Independent Directors are provided with the overview of the Company’s business model, operations, infrastructure, strategies, organizational structure, industry it operates in etc. by the senior management in the form of presentations and discussions. Roles and responsibilities are explained to the Independent Directors. Formal appointment letters outlining roles and responsibilities of Independent Director are provided. Apart from the appointment letters, Independent Directors are provided with policies of the Company such as:

   • • Code of conduct for Independent Directors
     • Code of conduct for board and senior management team
     • Memorandum and Articles of the Company
     • Code or practices & procedures for fair disclosure of UPSI
     • Code of Conduct-Regulate, Monitor & Report Trading-Designated Persons, Immediate Relatives
     • Copy of Directors and officers’ liability and Company insurance policy

   The Company keeps all its directors updated about the operations and key developments inside the Company which may have impacts on the operations of the Company. The Company follows the practice of recommending appointment of Independent Directors to the Company on basis of their experience, expertise, understanding and knowledge of the industry, management, corporate governance, corporate laws etc.

   To keep the directors updated about the business, the Company will provide opportunities to visit the facilities of the Company.

3. DISCLOSURE AND REVIEW OF THE PROGRAM

   This policy shall be uploaded on the website of the Company. The board of directors of the Company may review this program and may make changes as maybe required.