As approved by the Board pursuant to NSE Circular Ref. No. NSE/INVG/65921 dated 31.12.2024

Date of Implementation: 1st February 2025

1. Objective

The objective of this Whistle Blower Policy ("Policy") is to provide employees, clients, and stakeholders of Abhipra Capital Limited ("the Company") with a secure and transparent mechanism to report genuine concerns regarding unethical behaviour, fraud, violation of company policies, or market abuse, while ensuring adequate safeguards against victimization of those who raise such concerns in good faith.

2. Scope

This Policy applies to all employees, directors, clients, vendors, and other stakeholders.

It covers matters including fraud, unethical conduct, market manipulation, insider trading, breach of SEBI/NSE/BSE regulations, and conflict of interest.

3. Definitions

• Whistle Blower: Any individual who raises a concern in good faith.
• Whistle Blower Committee (WBC): Internal body responsible for handling complaints.
• Whistle Blower Redressal Head (WBRH): Designated person to receive and process complaints.
• Protected Disclosure: Complaint or communication made in writing or email regarding unethical activity.

4. Constitution of Whistle Blower Committee (WBC)

The Whistle Blower Committee (WBC) consists of:

1. Mr.Abhinav Aggarwal- Director
2. Mr. V.D. Aggarwal-Chairman

5. Appointment of Whistle Blower Redressal Head (WBRH)

Mr. Kapil Bansal, Compliance Officer, is appointed as the Whistle Blower Redressal Head responsible for receiving complaints, conducting preliminary reviews, and presenting matters before the Committee.

6. Reporting Mechanism

Complaints can be reported via:

• Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
• Post: Whistle Blower Committee, Abhipra Capital Limited, Abhipra Complex, A-387, G.T. Karnal Road, Azadpur, Delhi - 110033

7. Process Flow / Handling of Complaints

1. Acknowledge complaint within 7 working days.
2. Preliminary assessment by WBRH.
3. Review by WBC and decision on investigation.
4. Complete investigation within 45 working days.
5. Submit report to Board/Audit Committee.
6. Implement corrective actions within 15 working days.

8. Protection of Whistle Blower

Identity of whistle blower shall remain confidential. No retaliation is permitted. Malicious complaints may result in disciplinary action.

9. Reporting to the Audit Committee / Board

Complaints involving Directors, MD, CEO, or Promoters shall go to the Audit Committee. Others handled by WBC.

Quarterly summaries of complaints and their status shall be submitted to the Board.

10. Record Keeping and Confidentiality

All complaint records and findings shall be maintained by Compliance Department for 8 years.

11. Annual Review, Periodic Confirmation & Board Approval

The policy will be reviewed annually by the Board. The WBC shall provide half-yearly reports to the Board.

The Board will confirm the adequacy and effectiveness of the policy annually.

12. SOP for Implementation

• Step 1: Receipt of complaint - WBRH (Immediate)
• Step 2: Acknowledgment - WBRH (7 days)
• Step 3: Preliminary Review - WBRH (10 days)
• Step 4: Review & Decision - WBC (15 days)
• Step 5: Investigation - WBC/Internal Audit (45 days)
• Step 6: Report to Audit Committee/Board (10 days)
• Step 7: Corrective Action - HR/Compliance (15 days)
• Step 8: Record Keeping - Compliance (Ongoing)
• Step 9: Annual Review - Board/Audit Committee (Annually)

13. Effective Date and Approval

This policy was approved by the Board of Directors on 25th January 2025 and is effective from 1st February 2025.