Whistle Blower Policy

1.Background:

Kia India Private Limited (the “Company”) believes in a fair, ethical and professional work environment, and endeavours to conduct its operations and daily business affairs in a fair and transparent manner by adopting the highest standards of professionalism, integrity, honesty, and ethics, being also applicable in dealings with its Employees, customers, suppliers, vendors and society at large.

With this approach, Kia India intends to implement this Whistle-Blower Policy / vigil mechanism (“Policy”) that defines the expectations of the Company from its Employees and Stakeholders (“You”), in terms of your integrity and professional conduct.

This Whistle-Blower Policy defines the procedure / process / mechanism for reporting any and all deviations from the Company set standards defined in this Policy and any other Company policy.

This Policy shall be called ‘The Kia India Whistle-Blower Policy, 2026.’

Linkable Table of Contents

1. 2. Objective
2. 3. Coverage and Scope
3. 4. Definitions
4. 5. Guiding Principles
5. 6. Procedure for Reporting
6. 7. Investigation Procedure
7. 8. Protection to the Whistle-Blower
8. 9. Retention of Documents
9. 10. Reports
10. 11. No Obligation / Objection / Claims
11. 12. Amendment

2. Objective

The objective of this Policy is to help detect and address any unacceptable conduct, relating to the activities mentioned in head titled “Unethical Practice” herein and to make the Employees and Stakeholders aware that, such unacceptable conduct can be reported in good faith to the Company via the set reporting channel(s) of the Company’s vigil mechanism and without any fear of retaliation.

The intent is to inculcate among the Employees and Stakeholders, a culture where:

• Wrong doings are voiced;
• Discipline and ethical conduct is encouraged; and
• Transparency and accountability is aimed for.

Without an iota of doubt, prevention of wrongdoings in the Company is crucial for maintaining a strong brand reputation and fostering a positive work environment.

The purpose of this Policy is to make sure that,

• You understand that you can report any genuine wrongdoing (“Unethical Practice”) within and/or in relation to the Company and/or with/by its stakeholders safely, securely, and with confidence. It is assured that you will be protected and supported by the Company for your effort to bring the Unethical Practice to the Company’s notice.
• You are not subjected to any form of reprisal, repercussion, or victimisation because of reporting or disclosing the Unethical Practice.
• All disclosures (be it of any severity) are dealt with by the Company appropriately and on a timely basis.
• The Company remains transparent about its framework for receiving, handling, and investigating any Unethical Practice and related disclosures in a fair and timely manner.
• The Company and its Employees make an effort towards preventing of any wrongdoing, but at the same time highlight any such Unethical Practice to the Company.

3. Coverage and Scope

This Policy is equally applicable to all Stakeholders, Employees, collectively referred to as the “Participant(s)”. The definition of Participant(s) and the Policy shall also cover and include any ex-Participants, or any other third party or personnel for the purpose of reporting any Unethical Practice.

Any of the Participants can disclose / report any event of wrongdoing in relation to any Participant(s). That said, any Participant can report and be reported.

This Policy applies to all the Participants working at and/or associated with the Company’s manufacturing plant, corporate office, all regional offices, satellite offices, and any other Company offices, across India.

4. Definitions

• i) “Action Taken Report” means the report to be submitted by the Audit Team to the Managing Director of the Company on the Disciplinary Action taken against the Respondent along with the procedure to be implemented in preventing recurrence of unethical misconduct.
• ii) “Audit Team” refers to the team responsible for managing the entire internal audit function of the Company.
• iii) “Disciplinary Action” means any action decided or taken by the Company including but not limited to a warning, reduction or withholding of increments, reduction in grade, designation suspension or dismissal, or as the Company deems fit.
• iv) “Disclosure” means any and all communications made by You in good faith that discloses or demonstrates concrete information that may be treated as evidence of an unethical or improper activity. The disclosure should be factual truth and not be speculative in nature.
• iv) “Employee” means every employee of the Company (irrespective of them being permanent, temporary, in-probation), expats, board of directors, personnels’ of the Company.
• v) “Investigators” means all those persons / committee(s), be it internal or external, being authorised, appointed, consulted or approached by the Company and/or any authority established by law for any investigation of any Disclosure made under this Policy.
• vi) “Respondent” means an Employee against or in relation to whom a Disclosure is made i.e. the Alleged Wrongdoer, by the Whistle Blower.
• vii) “Stakeholders” means and includes value-chain partners like suppliers, service providers, sales representatives, contractors, channel partners (including dealers), consultants, trainees, apprentices, interns, agents, vendors, auditors, advisors, technicians, joint venture partners; and lenders, business associates, trainees, employees of other agencies deployed for the Company’s activities, whether working at any of the Company’s offices or any other location, customers of the Company and any other person or entity with whom the Company has any financial or commercial dealings.
• viii) “Unethical Practice(s)” means and includes, but is not limited to, the following activities:
  • Abuse / Misuse of Authority.
  • Breach of Contract.
  • Bribery, Corruption, Embezzlement of assets / money, in any manner.
  • Breach / Violations of Information Technology (IT) Security & Data Privacy rules.
  • Deliberate Violation of Statutory Laws, Rules and Regulations.
  • Financial Irregularities, including Fraud or alleged Fraud, any dishonest / unethical conduct.
  • Falsification of Records in any manner and to any extent (for example, information relating to employment, expense claims etc.).
  • Conflict of Interest.
  • Anti-Competitive Practices.
  • Misuse or Misappropriation of Company’s Assets / Funds.
  • Manipulation of Company’s data / records / accounts.
  • Misuse of Social Media.
  • Misuse of Company’s Information.
  • Negligence / Non-Compliance of any kind resulting in loss to the Company including monetary, brand image, etc. and specific danger to employees, public property, health and safety.
  • Revelation of any confidential / proprietary information of the Company to any unauthorized persons, or third party.
  • Any Unlawful act whether of a civil or criminal activity / nature.
  • Any issue of human right(s) violation.
  • Violation of the Company’s policy - Ethics and Code of Conduct and any other related Company’s policies.
  • Theft / Misuse of Company’s Property.
  • Retaliation against a Whistleblower.
  • Unfair and Unlawful practices in procurement, supplier dealings, contract management.
  • Any other unlawful activity, fraud, misconduct, wrongdoing which impacts the interests of the Company.
  • Any act which directly or indirectly relates to the Participant making or receiving an offer, promise, solicitation, acceptance, gratification, gift, undue advantage, hospitality, which may lead or leads to influencing of any Company specific decision or the Participant securing of any benefit (in whole or part).
  • Any act which harms and/or is likely to harm the interests of the Company, and not covered under the specific head above and/or any deliberate concealment of the above instances.
• ix) “Vigilance Officer” means the person(s) duly nominated / appointed by the Company and/or any authorised representative of the Company and/or the Audit Team, to conduct detailed investigation against the Respondent on the disclosure made by the Whistle-Blower and recommend Disciplinary Action against the Respondent.
• x) “Whistle-Blower”means any person (including a Participant) who makes a Disclosure in relation to Unethical Practice(s) (defined / described below) to the Company under this Policy.
• ix) “Whistle Blower Investigation Committee (WIC)” means one member nominated internally within the Company by each of the audit, legal, employee relations and human resources departments.

5. Guiding Principles

• i) Good Faith Reporting: Concerns, if any, must be raised honestly.
• ii) Non-Retaliation: Efforts are to be taken by the Company to keep the identity of the Whistle-Blower discreet. However, retaliation of any kind against a Whistle-Blower shall invite strict disciplinary action and be viewed as a serious misconduct.
• (iii) Fair Treatment: Every Disclosure shall be considered, treated and investigated in all fairness.
• (iv) Zero Abuse: False, frivolous, or malicious complaints, if identified by the Company, may lead to disciplinary action against the complainant.

6. Procedure for Reporting

It is recommended that, any individual who wishes to make a Disclosure under this Policy, may do so after gathering adequate, relevant facts and information to substantiate the complaint.

Any Employee or a Stakeholder can make a Disclosure by way of different modes as below:

• Through E-Mail: Disclosure can be made through, to the Company’s email id: whistleblower@kiaindia.net.
• Through the Company’s Web Portal: Disclosure can be made through Company’s web link
• Submit a Document to the Address: Disclosure can be made by sending the complaint and relevant documents having facts to the – Audit Head duly addressed to the below contact by legally accepted means of communication:

  To,
  Head - Audit Department,
  Kia India Private Limited,
  Erramanchi, Penukonda Mandal, Sri Satya Sai District,
  Andhra Pradesh – 515 164

• Through the Complaint Box: Disclosure can be made by dropping a letter in the complaint box. Any ‘Anonymous Disclosures’** without any personal motive may also be made.
• **Anonymous Disclosures Any Disclosure of this nature, being anonymous shall only be considered by the Company, only if such disclosures have sufficient details to proceed for an investigation. Any Disclosure with partial details, not supported by documents / evidence are bound to be not entertained by the Company.

The following types of complaints will ordinarily not be considered and taken up by the Company:

• Trivial, frivolous and malicious complaints;
• Matters that are pending before any Court of Law or any other Regulatory Authorities in India;
• Matters relating to service matters or personal grievance (such as increment, promotion, appraisal etc.);
• Customer / product grievances; and
• Complaints pertaining to sexual harassment at workplace.

The Whistle-Blower must address the following issues, while reporting Disclosures to the Company, under this Policy:

1. i) The Disclosure made should bring out a clear understanding of the issue being raised (e.g., names of individuals, names of entities, date / time of Unethical Practice, place of Unethical Practice, document reference numbers like invoice number, PO number, etc.)
2. (ii) The Disclosure made should be factual, and not speculative in nature.
3. (iii) The Disclosure can be made in any language, as per the Whistle-Blower’s comfort. However, the investigation and related findings / reports by the Company shall be in English language.

The Whistle-Blower is expressly prohibited from initiating or conducting any form of independent investigation in relation to the Disclosure(s). Compliance with this restriction is mandatory, and no exceptions shall be permitted by the Company.

6.1 Respondents

1. i) No allegation of wrongdoing against a Respondent shall be considered as maintainable, unless there is reasonable evidence in support of the allegation.
2. ii) Respondents may be informed about the Disclosure(s) made against them at the commencement of the investigation process, at the discretion of the Audit Team, unless there are compelling reasons to not inform them of the same. The Company reserves the right to refrain from disclosing the contents of any complaint / Unethical Practice reported.
3. iii) The Respondent shall be provided an opportunity for submitting his/her explanation and being heard, during the Company’s investigation process.
4. iv) The Respondent shall not, in any manner, destroy or tamper with any and shall have a duty to fully co-operate with the Vigilance Officer in the investigation process.

7. Investigation Procedure

• i) The Vigilance Officer(s) and/or the WIC are duly authorized to investigate any Disclosure reported under this Policy.
• ii) Disclosure(s) made under this Policy shall be recorded and duly actioned.
• iii) The Vigilance Officer and/or the WIC shall investigate and shall have the right to call for any and additional records, evidence, information, etc. from the Whistle-Blower to substantiate the Disclosure wherever possible.
• iv) The Vigilance Officer and/or the WIC shall have the right to call for any kind of records (including personal details), evidence, information, etc. from the Respondent if the Vigilance Officer or the WIC anticipates or concludes that there is a prima facie case existing against the Respondent.
• v) The Respondent shall provide records, evidence, information, etc. called for by the Vigilance Officer and/or the WIC immediately or within the time frame as suggested by the Vigilance Officer and/or the WIC, but not later than 5 (five) working days, from the date of such request / instruction.
• vi) In the event of the Respondent’s refusal or the Respondent exercising any delay tactics in providing the above records, evidence, information, etc. to the Vigilance Officer or the WIC, the Vigilance Officer and/or the WIC shall have the absolute right to carry out the investigation based on the records, evidences, information, etc. available and recommend action or close investigation, as he/they may deem fit. The Action Taken Report will be submitted, thereafter.
• vii) Confidentiality of the Whistle-Blower shall be maintained during the investigation process. Any other Employee serving as witness or assisting in the said investigation would also be protected to the same extent as the Whistle-Blower.
• viii) Any investigation conducted against any Respondent shall not be construed by itself as an act of accusation and shall be carried out as a neutral fact-finding process, without presumption or assumption of any guilt.
• ix) Depending on the prevailing circumstances, availability of data and other factors relevant to the Disclosure made, attempt will be made to complete the investigation within 90 working days from the date of receipt of concern (80 working days for completion of investigation and 10 working days for report preparation).
• x) The investigation shall be conducted in a fair manner, and the Vigilance Officer and/or WIC shall provide an equal opportunity to the Respondent for presenting his / her response to the allegation(s).
• xi) The Whistle-Blower, Respondent, Investigators, WIC, witnesses and everyone involved in the investigation process shall maintain complete confidentiality of the case and its contents, during and after the completion of the same.
• xii) A report of the findings, post the investigations shall be discussed by the Audit Team with the WIC. The WIC shall be actively consulted (for advising on workplace violations, legal risk exposure/violations, Company policies respectively) by the Audit Team and recommendations / suggestions shall be sought from them, prior to finalising any decision and/or sharing the recommendations of the investigation with the Managing Director in relation to the findings / investigation.
  The Audit Team will share the findings / recommendations (as discussed and recommended by the above mentioned three teams) to Managing Director of the Company along with its recommendation for action within 10 (ten) working days of conclusion of the investigation.
• xiii) The Audit Team shall post receiving approved recommendations by the Managing Director of the Company, forward all such recommendations to the Employee Relations (“ER”) team of the Company for initiating appropriate Disciplinary Action against the Respondent in accordance with the Disciplinary Action policy of the Company.

  Upon investigation if it is proved that the Whistle-Blower has knowingly made a complaint that is frivolous, malicious or made with ulterior intent/motive, appropriate disciplinary or legal action will be taken against the concerned Whistle-Blower based on the recommendations made by the Audit Team, the WIC. In any event, the Employees or any third party will not be exempted from accountability for their involvement in the wrongdoing or the consequences of their own misconduct or inadequate performance, and self-reporting of such issues will be dealt with at the discretion of the management of the Company.

  Also, it is advised that the Whistle-Blower reports the Unethical Practice to the Company, first. The Whistle-Blower is strongly advised against reaching out to external sources / agencies / forum / social platforms, without prior written consent of the Company. Publicity of any Unethical Practice (reported or un-reported), in any manner is strictly prohibited.

  The Company may, as a consequence of the Disclosure or suo moto, conduct any internal checks, investigations, inspection, scrutiny, review, audit (“Action”) of any of the Company’s departments, processes, procedures. All Participants shall be expected to cooperate fully with the Company in relation to the Action taken.

  The decision of the Company on any Disciplinary Action in relation to any Unethical Practice(s) shall be final and binding on the Participant(s).

8. Protection to the Whistle-Blower

The Company encourages openness and supports anyone who raises a genuine concern / complaint in good faith under this Policy, even if they turn out to be mistake.

The identity of the Whistle-Blower shall be always kept confidential, except where such identity is required (as per law, rule, regulation) or if requested by any regulatory, governmental, statutory, judicial authority or body, where a Disclosure is required to be filed and the same shall be disclosed only upon prior intimation to the Whistle-Blower.

The Company will take steps to minimize difficulties, which the Whistle-Blower may experience because of making the Disclosure. If the Whistle-Blower is required to give evidence in any criminal or disciplinary proceedings, the Company will arrange for the Whistle-Blower to receive guidance about the procedure.

The Company, from a policy standpoint, strongly condemns any kind of discrimination, harassment or any other unfair employment practice being adopted against the Whistle-Blowers for Disclosures made under this Policy. No unfair treatment, under any circumstances shall be meted out towards the Whistle-Blower by virtue of his/her having reported a Disclosure under this Policy and the Company shall ensure that full protection is granted to him/her against: .

• Unfair employment practices like retaliation, threat or intimidation or termination/suspension of services, sidelining / isolation among colleagues etc.
• Disciplinary action including transfer, demotion, refusal of promotion, etc.
• Direct or indirect abuse of authority to obstruct the Whistle-Blowers’ right to continue performance of his/her duties.
• Smooth functioning and delivery of duties during routine daily operations, including encouraging for making further Disclosures under this Policy.

However, any such protection if granted or waiting to be granted shall be subject to the discretion of the Company management.

The Whistle-Blower shall not receive such protection as stated above as a matter of right or entitlement. The protection may also be offered by the Company as a departmental / location transfer, which shall be at absolute discretion of the Company.

The Company may decline any request for protection by the Whistle-Blower, without substantiating any reasons, thereof.

If the Whistle-Blower’s negligence or error is found in relation to the disclosure made, then the disciplinary penalty may be reduced against the Respondent, under the discretion of the Company’s management.

9. Retention of Documents

All Disclosures including the investigation proceedings, recommendations and Action Taken Reports shall be retained by the Vigilance Officer / Audit Team for a minimum period of 8 (Eight) years.

10. Reports

A Report with number of Disclosures received by the Company under the Policy along with the outcome shall be submitted to Managing Director of the Company on an annual basis, or as directed by the Company management from time to time.

11. No Obligation / Objection / Claims

The Company shall under no circumstances, be obligated to acknowledge or reward / incentivise the Whistle Blower for any Disclosure made, in any manner, irrespective of the outcome of investigation. Also, the Company reserves the right to not disclose the outcome of the investigation to the Whistle Blower, for any reason whatsoever.

The Company’s decision in relation to the Disciplinary Action shall be final and binding on the Respondent. Neither the Respondent, nor the individuals associated with the Respondent shall raise any claims against the Company in relation to the outcome(s) of the investigation or for any other purpose / reason.

No Respondent or the Whistle-Blower or any other person related to the Respondent or Whistle-Blower shall have any right to contest, appeal, challenge the decision of the Company with respect to the Disclosure, under any forum.

12. Amendment

The Company reserves its right to solely, at its own discretion, review and amend, modify or supplement this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the Employees and Stakeholders unless the same is notified to the Employees in writing and displayed on the website in case of Stakeholders.

This Policy, in entirety, supersedes the existing Whistle-Blower Policy of the Company.

Policy Revision Year	Details	Version
2019	Policy Introduced	Introduction of the Policy
2026	Policy Revised	Ver. 2-2026 Effective from [15-06-2026]