1.0 OBJECTIVE

This policy sets out the rules regarding the receipt of gifts, entertainment, and hospitality to ensure ethical business conduct and prevent actual or perceived conflicts of interest, bribery, or undue influence.

2.0 SCOPE

This policy applies to:

· All employees, officers, and directors of Geeken

· Contractors, consultants, agents, or anyone acting on behalf of the company

3.0 RESPONSIBILIT

IMS Coordinator and Head Operations

4.0 POLICY STATEMENT

Geeken prohibits the receipt of gifts or hospitality that could:

· Influence (or appear to influence) business decisions

· Create a conflict of interest

· Violate laws or internal policies

Employees must exercise sound judgment and maintain high ethical standards in all interactions with clients, suppliers, and stakeholders.

5.0 ACCEPTABLE GIFTS AND HOSPITALITY

Gifts or hospitality may be accepted only if they are:

· Nominal in value (e.g., under Rs. 2000 or as defined by the company)

· Infrequent and not part of a pattern

· Customary and reasonable in the business context

· Not in the form of cash or cash equivalents (e.g., gift cards, loans)

· Not tied to any expected or actual favor, influence, or business outcome

· Fully disclosed and approved where required

6.0 BREACH OF POLICY

Violations of this policy may result in:

· Disciplinary action, including termination

· Referral to authorities in cases of suspected bribery or corruption

· Reputational damage to the company

1.0 OBJECTIVE

The purpose of this Corporate Ethics Policy is to promote a culture of integrity, accountability, and legal compliance at Geeken. It outlines the ethical principles and behavioral expectations that guide our decisions and actions.

2.0 RESPONSIBILITY

IMS Coordinator and Head Operations

3.0 CORE ETHICS PRINCIPLES

At Geeken, we commit to the following principles:

· Integrity: Be honest, fair, and trustworthy in all dealings.

· Respect: Treat colleagues, customers, partners, and stakeholders with dignity and professionalism.

· Accountability: Take responsibility for actions and decisions.

· Compliance: Follow all applicable laws, regulations, and internal policies.

· Transparency: Communicate openly and truthfully, avoiding misleading or deceptive practices.

4.0 STANDARDS OF CONDUCT

a. Compliance with Laws

All employees must comply with:

· Local, national, and international laws

· Industry regulations

· Anti-corruption, anti-bribery, and anti-money laundering laws

b. Conflicts of Interest

Employees must avoid situations where personal interests conflict with the interests of Geeken. Any actual or potential conflict must be disclosed to management or HR immediately.

c. Confidentiality and Data Protection

Protect confidential company, employee, and client information. Do not share or misuse proprietary or personal data.

d. Gifts and Hospitality

Gifts, entertainment, or hospitality must never influence — or appear to influence — business decisions. When in doubt, consult the Gifts & Hospitality Policy or seek guidance from compliance.

e. Use of Company Assets

Use company property, resources, and systems responsibly and only for legitimate business purposes.

f. Fair Dealing

Deal fairly with clients, suppliers, competitors, and employees. Do not manipulate, conceal, or misrepresent information to gain unfair advantage.

5.0 WORKPLACE CONDUCT

We maintain a professional and inclusive workplace. This means:

· No discrimination, harassment, or retaliation of any kind

· Promotion of diversity, equity, and respectful collaboration

· Support for employee well-being and safety

6.0 REPORTING MISCONDUCT

Employees are encouraged and expected to report any suspected violations of this policy. Reports can be made to:

· A supervisor or manager

· The HR or Legal Department

Retaliation against whistleblowers is strictly prohibited.

1.0 OBJECTIVE

The purpose of this Insider Trading Policy is to ensure compliance with applicable securities laws and to prevent the misuse of material, nonpublic information ("inside information") when trading in the securities of Geeken or any other publicly traded company.

2.0 SCOPE

This policy applies to all employees, officers, directors, contractors, consultants, and any third parties who may have access to inside information concerning Geeken or other publicly traded companies through their work.

3.0 DEFINITIONS

· Material Information: Any information that a reasonable investor would consider important in making a decision to buy, sell, or hold securities. This includes financial results, mergers or acquisitions, changes in senior management, major contracts, or regulatory developments.

· Nonpublic Information: Information that has not been disclosed to the public and is not generally available.

· Insider Trading: Buying, selling, or recommending securities based on material, nonpublic information.

· Tipping: Disclosing material, nonpublic information to another person who then trades on that information.

4.0 RESPONSIBILITY

IMS Coordinator and Head Operations

5.0 INSIDER TRADING POLICY

Insider trading refers to the buying or selling of a publicly traded company's stock by someone who has material, nonpublic information about that stock. It is considered illegal when the trading is done based on confidential information in violation of a duty to withhold it — whether the duty is to the company, shareholders, or another party.

5.1 PROHIBITED ACTIVITIES

You may not:

· Buy or sell [Company Name] securities (or any other company’s securities) while in possession of material, nonpublic information.

· Disclose inside information to others ("tipping"), including friends, family, or colleagues, unless required for legitimate business purposes and subject to confidentiality obligations.

· Recommend or suggest that anyone else trade based on inside information.

5.2 TRADING WINDOWS & BLACKOUT PERIODS

· Regular trading by directors, officers, and designated employees is limited to open trading windows (usually beginning 48 hours after public earnings release and ending before the quarter’s end).

· Blackout periods may be imposed around earnings releases or significant events.

· Pre-clearance of trades may be required for certain individuals.

5.3 REPORTING AND COMPLIANCE

· All questions about this policy or its application must be directed to the [Compliance Officer / Legal Department].

· Violations of this policy may result in disciplinary action, including termination of employment, and may also expose the individual to civil or criminal liability under applicable laws.

1.0 OBJECTIVE

The purpose of this Fair Hiring Policy is to establish clear, consistent, and equitable hiring practices at Geeken, ensuring that all applicants are treated fairly and without discrimination throughout the recruitment and selection process.

2.0 RESPONSIBILITY

IMS Coordinator and Head Operations

3.0 POLICY DETAILS

Geeken is an equal opportunity employer. We are committed to creating a diverse and inclusive workforce and do not discriminate against any applicant or employee based on:

· Race, color, or ethnicity

· Religion or belief

· National origin or citizenship

· Gender, gender identity, or expression

· Sexual orientation

· Age

· Disability or medical condition

· Marital or family status

· Military or veteran status

· Genetic information

· Any other status protected by applicable law

3.1 RECRUITMENT PRINCIPLES

To ensure fair hiring, Geeken will:

· Advertise all open positions internally and externally to reach a broad and diverse pool of applicants.

· Write job descriptions that are accurate, clear, and focused on essential functions and qualifications.

· Base hiring decisions strictly on merit, qualifications, experience, and alignment with the job requirements.

· Ensure hiring managers are trained on bias awareness and inclusive hiring practices.

· Provide reasonable accommodations to applicants with disabilities as required by law.

3.2 INTERVIEW & SELECTION PROCESS

· All candidates will be evaluated using the same criteria relevant to the position.

· Structured interviews or assessments will be used where appropriate to minimize bias.

· Notes and decisions from interviews will be documented to ensure transparency and accountability.

· Candidates not selected will be notified in a timely and respectful manner.

3.3 RECORDKEEPING AND DATA PRIVACY

· All application materials and interview records will be kept confidential and stored securely in compliance with data protection laws.

· Personal data will be used only for recruitment purposes and retained only as long as legally required.

GEEKEN SEATING COLLECTION PVT LTD

Policy Against Sexual Harassment

A. PURPOSE:

GEEKEN SEATING COLLECTION PRIVATE LIMITED (--) (hereinafter “Company”) commits to create and maintain work environment in which the dignity of employees is respected. The Company recognizes that sexual harassment violates fundamental rights of gender equality, right to life, liberty and right to work with human dignity as guaranteed by the Constitution of India. The work environment shall be free of notion of sexual harassment as per the guidelines laid down by the Apex Court for prevention of sexual harassment which has now been superseded by the “Sexual Harassment of Women at Work Place (Prevention, Prohibition & Redressal) Act, 2013” (“Act”). The victims, if any, should not feel that their grievances are either ignored or trivialized or they suffer from fear of reprisals. Further the purpose is to achieve the following objectives:

a) To fulfill, comply and adhere in letter and spirit the law as contained in the Act or any other such laws as may be applicable in this regard.

b) To eliminate sexual harassment in the workplace so that employees can work without any inhibition and contribute their best without any fear or favor.

c) To provide appropriate mechanism to deal with the problem and prevent occurrence of sexual harassment where all respect one another’s dignity, privacy and right to equity in the workplace.

d) To ensure that sexual harassment is solved in a sensitive, efficient, effective and confidential manner.

e) To ensure that victims of sexual harassment are exposed to alternative remedies, when they feel unable to confront the perpetrators or turn to colleagues for support.

B. SCOPE:

It applies to all employees working inside the premises of the Company including full time directors, in-house consultants, advisors, expatriates, employees on contract and any other person covered by the definition of employee as provided in this policy.

“Sexual Harassment” amounts to serious misconduct in employment, under the code of conduct/ disciplinary policy governing employment. The Company employees,

customers, vendors, consultants and anyone else doing business on the Company premises, as well as those involved in activities in which our name is associated must comply with this policy.

This policy on Sexual Harassment applies to men and women; to like and opposite gender relationships; to relationships between supervisors and sub-ordinates and peer relationships.

C. DEFINITION:

I. “Sexual Harassment" includes any one or more of the following unwelcome acts or behavior (whether directly or by implication) namely:

a. physical contact and advances; or

b. a demand or request for sexual favors; or

c. making sexually colored remarks; or

d. showing pornography; or

e. any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

II. The following circumstances, if it occurs or is present in relation to or connected with any act/behavior of Sexual Harassment may amount to sexual harassment:

a. implied or explicit promise of preferential treatment in her employment; or

b. implied or explicit threat of detrimental treatment in her employment: or

c. implied or explicit threat about her present or future employment status; or

d. interference with her work or creating an intimidating or offensive or hostile work environment for her; or

e. humiliating treatment likely to affect her health or safety.

III. “Aggrieved Woman" means in relation to a workplace, a woman, of any age whether employed or not with the Company, who alleges to have been subjected to any act of Sexual Harassment by the respondent in the workplace.

IV. “Aggrieved Person” means any person of any age whether employed with the Company or not who alleges to have been subjected to any act of Sexual Harassment by the respondent in the workplace.

V. Employee" means a person employed at a workplace for any work:

a. on regular, temporary, ad hoc or daily wage basis,

b. either directly or through an agent, including a contractor, with or, without the knowledge of the principal employer, whether for remuneration or not,

c. or working on a voluntary basis or otherwise,

d. whether the terms of employment are express or implied and includes a co-worker, a contract worker, probationer, trainee, apprentice or called by any other such name.

VI. “Employer" means:

a. Head of any department, organization, office etc.;

b. Person responsible for the management, supervision & control of any other workplace;

c. Person discharging contractual obligations with respect to his or her employees, with respect to workplaces covered above.

VII. “Respondent” means a person against whom the Aggrieved Woman/ person has made a complaint of Sexual Harassment.

VIII. "Workplace" means all locations where business of the Company is conducted or any activity is conducted in partnership with the Company or social events are sponsored by the Company or any place visited by the Employee arising out of or during the course of employment, including transportation provided by the Company for undertaking such journey.

IX. “Internal Complaints Committee" means an Internal Complaints Committee constituted by the Company to deal with the complaints of Sexual Harassment at workplace.

D. ORGANIZATIONAL COMMITMENT TO PREVENT SEXUAL HARASSMENT: The Company will:

a. Create appropriate rules and procedure to provide a safe working environment at the workplace.

b. Organize workshops and awareness programs at regular intervals for sensitizing Employees and provide necessary training/ orientation program for the members of the Internal Complaints Committee.

c. Provide necessary facilities to the Internal Complaints Committee for dealing with the complaint and conducting an enquiry.

d. Assist in securing the attendance of the Respondent and witness before the Internal Complaints Committee.

e. Make available the information to the Internal Complaints Committee having regard to the complaint made.

f. Company will ensure that the victim or witness are not victimized or discriminated against while dealing with the complaints of Sexual Harassment.

g. Provide assistance to the woman if she chooses to file a complaint in relation to the offence under the Indian Penal Code (“IPC”) or any other law for the time being in force.

h. Cause to initiate action under the IPC or any other law against the perpetrator or if the Aggrieved Woman so desires, where the perpetrator is not an Employee, in the work place where the incident of Sexual Harassment took place.

i. Treat Sexual Harassment as misconduct under the service rules and initiate action for such misconduct.

j. Maintain confidentiality about the Aggrieved Woman, witness, enquiry proceedings, etc.

k. Display the policy against the Sexual Harassment and its penal consequences in its intranet portal for information and compliance by employees.

l. Monitor the timely submission of reports by the Internal Complaints Committee.

E. CONSTITUTION OF COMMITTEE:

A five-member Internal Complaint Committee (“ICC”) is herewith constituted to consider and redress the complaints of Sexual Harassment shall function under the Chairperson who shall act on behalf of the Employer. The committee shall consist of employees (3 Females & 2 Males) and their names shall be communicated through separate communication by the HR Head.

The ICC shall consist of the following members:

a. A Presiding officer who shall be a senior level woman employee;

b. Not less than two members from among Employees, preferably committed to the cause of women or who have had experience in social work or have legal knowledge;

c. One member from among Non-Governmental Organizations or associations committed to the cause of women or a person familiar with the issues relating to Sexual Harassment;

d. At least one half of the total members nominated shall be woman;

e. The Presiding Officer and every member shall be on the ICC for a period not exceeding 3 years from the date of their nomination, as specified by the Company;

f. The member appointed from the NGOs or associations shall be paid fees or allowance for participating in the proceedings of the ICC as prescribed from time to time;

g. The constitution and appointment of members shall be in accordance with this policy and subject to the stipulation as provided under the Act. The details of the location specific ICC constituted for the present in this regard is at Annexure-I.

A member of ICC can be removed if he/she:

a. contravenes the provisions relating to prohibition of publication/making known contents of complaint/proceedings; or

b. has been convicted for an offence or an inquiry into an offence is pending against him/her; or

c. he/she has been found guilty in any disciplinary proceedings or a disciplinary proceeding is pending against him; or

d. has so abused his position as to render his continuance in office prejudicial to the public interest.

In case of such termination or any casual vacancy, the vacancy to be filled up as per the procedure provided.

F. POLICY & PROCEDURE

I. Making a Complaint:

1. An Aggrieved Woman can make a complaint to the ICC in writing:

a. within 3 (Three) months from the date of incident; or

b. in case of a series of incidents, within 3 months of the date of last incident.

2. If complaint cannot be made in writing, reasonable assistance to be provided by presiding officer/member to the Employee making the complaint to reduce the same in writing.

3. Time limit extendable by another 3 (Three) months if ICC is satisfied that circumstances prevented making a complaint.

4. If the Aggrieved Woman is dead/physically or mentally incapable then legal heir/prescribed persons can file complaint on her behalf.

5. If the complaint is against the employer himself, then Aggrieved Woman can make complaint to local complaints committee.

II. Conciliation:

A. ICC can settle the matter between an Aggrieved Woman and the Respondent:

1. Before an inquiry is initiated by ICC; If request is made by Aggrieved Woman;

2. No monetary settlement can be made the basis of settlement.

B. If settlement is concluded, ICC shall:

1. Record the settlement;

2. Forward the same to the employer to take recommended action;

3. Provide a copy of settlement to the Aggrieved Woman & Respondent;

4. Not proceed with any further inquiry.

5. ICC can proceed with inquiry if Aggrieved Woman informs that settlement is not being complied with by the Respondent.

III. Inquiry in to Complaint / Report:

ICC shall make inquiry as follows:

1. ICC shall make inquiry as per service rules applicable to Respondent;

2. Copy of findings to be given to both parties;

3. ICC is vested with powers of civil court under Code of Civil Procedure for:

a. Summoning & enforcing attendance

b. Examination on oath

c. Requiring discovery & production of documents

d. Any other matter

Enquiry shall have to be completed within 90 (Ninety) days. Based on the findings of the ICC, the management will initiate action, commensurate with the degree of offence

ICC shall submit report to employer:

4. If allegation is not proved, ICC shall recommend no action;

5. If allegation is proved, ICC shall recommend:

a. to take action as a misconduct in accordance with the service rules, or in absence thereof

b. To take action including written apology, warning, reprimand or censure, withholding of promotion, withholding of pay rise/increments, termination from service, undergoing counseling or community service

c. to deduct from the Respondent’s salary/ make Respondent to pay such appropriate sum to compensate the Aggrieved Woman.

6. The compensation shall be computed having regard to:

a. the mental trauma, pain, suffering and emotional distress caused to the Aggrieved Woman;

b. the loss in career opportunity due to the incident of Sexual Harassment;

c. medical expenses incurred by the victim for physical or psychiatric treatment;

d. the income and financial status of the Respondent;

e. feasibility of such payment in lump sum or in installments.

7. If Respondent fails to pay the compensation, ICC can order for recovery as an arrear of land revenue.

ICC can, pending inquiry, recommend to employer on application by Aggrieved Woman:

a. transfer the Aggrieved Woman or the Respondent to any other workplace;

b. grant additional leave to the Aggrieved Woman up to a period of Three months;

c. Restrain Respondent from reporting on Aggrieved Woman’s work/writing her confidential report

Employer shall implement ICC’s recommendations & send report to ICC.

Further, the ICC will maintain details like complaint register/soft copy, record of all complaints received, date when the process began, procedure followed and date of closure.

8. Procedure & Time Line:

A. ICC can terminate inquiry / pass ex parte decision (advance written notice of 15 days) if either party does not appear for 3 consecutive hearings.

B. ICC can terminate inquiry / pass ex parte decision (advance written notice of 15 days) if either party does not appear for 3 consecutive hearings.

C. Parties not allowed to bring any legal practitioner.

D. Appeal to be made to court / tribunal as per service rules or to appellate authority under Industrial Employment (Standing Orders Act. 1946).

9. Prohibition on Disclosure

I. The following shall not be published, communicated or made known to the public, press and media in any manner:

a. contents of the complaint;

b. identity and addresses of the Aggrieved Woman, Respondent and Witnesses;

c. any information relating to conciliation and inquiry proceedings;

d. recommendations of the ICC; and

e. action taken by the Employer.

II. Information may be disseminated regarding the justice secured without disclosing information which can identify the Aggrieved Woman and Witnesses.

III. Contravention

a. Penalty in accordance with the service rules applicable to the offender; or

b. Where no such rules exist, INR 5000 to be recovered by employer from offender.

G. Frivolous or False Complaints:

I. If ICC concludes that:

1. allegation against Respondent is malicious; or

2. aggrieved woman has made a false complaint;

3. any other person making the complaint has produced forged/misleading document,

II. It can recommend to the Employer/District Officer:

1. to take action as per service rules; or in absence thereof

2. to take action including written apology, warning, reprimand or censure, withholding of promotion, withholding of pay rise/increments, termination from service, undergoing counseling or community service.

III. Inability to substantiate complaint/provide adequate proof does not attract this provision.

IV. If ICC concludes that any witness:

a. has given false evidence

b. produced any forged or misleading document

c. It can recommend to the employer/District Officer to take action as per service rules; or in absence thereof to take action including written apology, warning, reprimand or censure, withholding of promotion, withholding of pay rise/increments, termination from service, undergoing counseling or community service

H. Annual Reporting:

1. ICC to prepare & submit to Employer and the District Officer (District Officer shall be the District Magistrate or the Collector or Deputy Collector) an annual report for each calendar year:

a. Number of complaints received in the year;

b. Number of complaints disposed of in the year;

c. Number of cases pending more than 90 days;

d. Number of workshops or awareness programs carried out;

e. Nature of action taken by employer.

2. Employer to include the following in its annual report:

a. Number of cases filed;

b. Disposal of such cases.

ANNEXURE – A

INTERNAL COMPLAINTS COMMITTEE MEMBERS

Please note: Presiding officer is a Senior Female working in the organization.

Other Two members can be males.

1. OBJECTIVE

To prohibit the engagement of children in certain employments and to regulate the conditions of work of children in certain other employments. Be it enacted by Law “Child Labour (Prohibition and Regulation) Act, 1986”.

Prohibition of employment of CHILDREN in certain occupations and processes. No child shall be employed or permitted to work in any of the occupations set forth in Part A (Child Labour Act) of the Schedule or in any workshop wherein any of the processes set forth in Part B (Child Labour Act) of the Schedule is carried on: Provided that nothing in this section shall apply to any workshop wherein any process is carried on by the occupier with the aid of his family or to any school established by, or receiving assistance or recognition from, Government.

2. AGE AND CONTEXTS

"Child' means a person who has not completed Eighteen years of age; if any question arises between an Member / occupier as to the age of any child who is employed or is permitted to work by him in an establishment, the question shall, in the absence of the certificate as to the age of such child granted by the prescribed medical authority, be referred by the Member / Occupier for decision to the prescribed medical authority.

(i) “Child' means a person who has not completed Eighteen year of age;

(ii) "Day" means period of twenty four hours beginning at mid-night;

(iii) "Establishment" includes a ship, commercial establishment, work-shop, farms,

(iv) Residential hotel, restaurant, eating house, theatre or other place of public

Amusement or entertainment;

(v) "Family", in relation to an occupier, means the individual, the wife or husband, as the case may be, of such individual, and their children, brother or sister of such individual;

(vi) "Occupier", in relation to an establishment or a workshop, means the person who has the ultimate control over the affairs of the establishment or workshop;

(vii) "Port authority" means any authority administering a port;

(viii) "Prescribed" means prescribed by rules made under section 18 of the act;

(ix) “Week" means a period of seven days beginning at midnight on Saturday night or such other night as may be approved in writing for a particular area by the Inspector;

(x) "Workshop" means any premises (including the precincts thereof) wherein any industrial process is carried on, but does not include any premises to which the provisions of section 67 of the Factories Act, 1948 (63 of 1948), for the time being, apply.

3. CHILD LABOUR

3.1 Geeken Furniture. does not employ Child Labour nor does it encourage appointment and use of Child Labour.

3.2 The minimum age for recruitment for all levels of employees shall be 18 years and above.

3.3 Geeken Furniture. shall establish, document, maintain, and effectively communicate to personnel and other interested parties, the policies and written procedures for remediation of children found to be working in situations which fit in the above definition of child labour , and shall provide adequate financial and other support to enable such children to attend and remain in school until no longer a child as defined above.

3.4 Geeken Furniture. shall not expose children or young workers to any situations – in or outside of the workplace – that are hazardous or unsafe their physical and mental health and development.

3.5 A person with specific responsibility to communicate, deploy, monitor and maintain the process and procedures aimed towards ensuring that the company does not employ or use child labour has been designated.

3.6 It is ensured that contractual employees engaged through contractors and working in .Geeken Furniture shall also be above the minimum age set by Geeken Furniture.

3.7 At the time of employment it is ensured that all employees are above or at least of minimum age as set by Geeken Furniture. This is ensured by checking the age of all employees from age records as evidenced by birth certificates, school records, and certificate of age proof from a certified Dental surgeon.

3.8 Pavilions & Interiors India Pvt Ltd. retains a copy of the document submitted by the employee as proof of age, after mandatory verification, in the personnel file.

3.9 At the time of employment, Pavilions & Interiors India Pvt Ltd. also obtains signed application forms from the employee stating among other things his/her age and date of birth.

3.10 Periodic review of the performance of the process and procedures aimed at prohibiting child labour implemented in Geeken Furniture. is carried during which the documents in support of age are also reviewed.

3.11 If there are any cases of violation concerning issues related to child labour, such cases shall be investigated and suitable remedial action shall be initiated.

3.12 If children are found to be employed in Geeken Furniture., the remediation shall be as per the Child labour remediation procedure

4. CHILD LABOUR ADVISORY COMMITTEE

4.1 The Committee shall consist of a Chairman and such other members not exceeding ten, both from Management and Workers side in that two representations from Women personnel.

4.2 The Committee shall meet as often as it may consider necessary and shall have power to regulate its own procedure.

4.3 The committee may, if deems it necessary to do so, constitute one or more sub committees and may appoint any such sub-committee, whether generally or for the consideration of any particular matter, any person who is not a member of the committee.

5. VERIFICATION OF AGE

This can be done through an audit. They can be asked to provide proof of age, if possible. Sometimes there are no birth certificates to verify age (and falsified documents may be easy to obtain from the black market). Techniques to verify age include the following:

5.1 Medical examination prior to employment

5.2 Multiple written documents and affidavits

5.3 Interviews (that are culturally adjusted)with employees and applicants who appear to be too young

5.4 School enrolment certificate.

We, GEEKEN SEATING COLLECTION PVT. LTD. are involved Designing, Manufacturing and Service Provider for various Medical device products and are committed to:

1. To provide our customers competitive solutions with quality products and services by working closely with our customers and other relevant interested parties to meet customer requirement with applicable statutory & regulatory requirements.

2. To gain the long-term confidence and satisfaction of our customers through continual improvement in our day-to-day activities while operating in a transparent and professional manner.

3. To continually improve MD-QMS processes through applying strategic directions against identified process risks with respect to the identified external and internal issues related to the Medical device quality Management systems.

4. To ensure participation of our stakeholders including employees, suppliers and customers.

5. To communicate its policy to all personnel within the organization and interested parties including public.

The purpose of this policy is to reduce employees and staff exposure to chemical hazards from hazardous chemicals used or kept at the Organization. By selecting products with lesser hazards, and by properly using these products, there will be a reduced risk of exposure to these products.

The superintendent will be responsible for the implementation and enforcement of this policy.

Inventory

Each year, corporation personnel as assigned by the superintendent or designee shall conduct a corporation-wide chemical inventory. During the inventory, expired and unwanted chemicals are to be identified for proper disposal.

Purchasing

Chemical purchases shall adhere to the following protocol.

1. This Organization has identified the following procedures and guidelines for purchasing chemicals in an effort to minimize employees and staff exposure to chemical hazards:

a. All Purchases of chemicals shall be approved by the organization administration.

b. Donated items such as hand sanitizers and any products employees want to bring into the organization must be approved by organization administration.

2. First in first out method will be followed. Over purchasing and stock piling are not permitted.

3. The least toxic chemical that is still effective for the job is to be selected. Material Safety Data Sheets should be reviewed to make this determination. This includes selection of cleaning supplies as well as working tools for process. Micro and green chemistry are encouraged.

4. Chemicals listed on the Banned Chemical List shall not be purchased.

Material Safety Data Sheets (MSDS) will be available at the corporate office and in any rooms/ area where chemicals are stored. The MSDS books are to be updated annually and as new chemicals are purchased or disposed of.

Use

1. Chemicals will be mixed and used according to manufacturer’s directions. Measuring devices or direct mixing systems are to be used. Any warnings, especially requirements for ventilation are to be followed.

2. When possible, use of cleaning products should be performed when Employees are not present.

3. Areas where chemicals are being used will be properly ventilated, including process and laboratories.

4. Only properly trained staff may use hazardous chemicals. Staff will receive annual training and when required, certification (i.e. pesticide applicators).

5. Required notification procedures will be followed (i.e. pesticide notifications)

Storage

1. Secondary containers will not be used to store chemicals unless they are properly labeled and approved for such use.

2. Storage areas will be properly ventilated.

3. Storage areas will be compatible with the chemicals being stored in them.

4. Reactive chemicals will not be stored near each other.

5. Hazardous chemicals will be stored in locked areas at all times.

6. All original containers will be labeled with the date received

Disposal

1. Unwanted, unused, and outdated chemicals should be identified on a regular basis but at least annually. These identified chemicals should be marked for disposal.

2. Disposal will follow state regulations. Pouring down the drain or throwing in the trash is not acceptable or proper disposal in most instances.

Spills, Chemical Explosions, and Accidents (including inhalation, ingestion, or direct contact)

1. Notify the building administrator.

2. Follow guidelines outlined in Hazardous Materials section of Crisis Response Plan.

LEGAL REFERENCE: 410 I.A.C. 33-4-8

Objective: - The primary objective of this policy is to promote equitable and unbiased practices across the organization. We aim to eliminate unlawful or unethical discrimination and treat everyone with respect and dignity. Through this approach, we strive towards fostering healthy relationships amongst everyone regardless of their background or identity.

Scope and Applicability: -

This policy binds Geeken employees together and fosters a healthy workplace which ensures respect and dignity for everyone. It covers everyone nationally (including contract workers, interns, trainees and others with any other kind of work engagement with the organization) regardless of their backgrounds, experiences, or hierarchies.

Policy Statement: - Geeken is committed to fostering, cultivating and preserving a culture of equity and inclusion.

Our human capital is the most valuable asset we have. The collective sum of the individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities and talent that our employees invest in their work represents a significant part of not only our culture, but our reputation and company’s achievement as well.

We embrace and encourage our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status and other characteristics that make our employees unique.

Geeken initiatives are applicable – but not limited – to our practices and policies on recruitment and selection; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; layoffs; terminations; and the ongoing development of a work environment built on the premise of gender and diversity equity that encourages and enforces:

• Respectful communication and cooperation between all employees.

• Teamwork and employee participation, permitting the representation of all groups and employee perspectives.

• Work/life balance through flexible work schedules to accommodate employees’ varying needs.

All employees of Geeken have a responsibility to treat others with dignity and respect at all time. All employees are expected to exhibit conduct that reflects inclusion during work, at work functions on or off the work site, and at all other company-sponsored and participative events. All employees are also required to attend and complete annual diversity awareness training to enhance their knowledge to fulfill this responsibility.

Any employee found to have exhibited any inappropriate conduct or behavior against others may be subject to disciplinary action.

Employees who believe that have been subjected to any kind of discrimination that conflicts with the company’s diversity policy and initiatives should seek assistance from a supervisor or an HR representative.

Corporate Social Responsibility

Background

“Geeken” is a leading diversified business with interests in design, manufacture, marketing and distribution of value-added products of Modular Office Furniture, Seating Systems, Institutional Furniture, Healthcare Furniture and AV Solutions in India.

The “Geeken” takes pride not only in bringing world-class technology to its customers; but also in discharging its responsibility of creating an environment of inclusive growth in the country. We believe that our success in executing and operating plants is critically dependent on following a participatory development-oriented approach that strengthen our bond with the local population.

“Geeken” has undertaken and shall continue to undertake appropriate Corporate Social Responsibility (CSR) measures having direct, measureable and positive economic, social and environmental impact on the community with particular emphasis on the local area and areas around where it operates.

Our Belief : Reaching Beyond - “A little push in right direction can make a big difference”

CSR Vision: “Enriching lives to create a healthier and happier world”

CSR Mission: 

• To be a responsible organization.

• To provide access to healthcare through Blood donation and other health initiatives/projects for the less privileged.

• To support advancement of education.

• Women Empowerment

• Temple Construction

• To support improvement of infrastructure and environment.

• To encourage employee volunteering across all our locations.

The CSR Policy

Applicability: This CSR Policy is framed as per Sec. 135 of the Companies Act,2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended time to time.

Focus Area: CSR areas targets inclusive growth of all stakeholders under 12 (twelve) categories, mentioned under Schedule-VII of the Companies Act-2013.

The CSR activities of the Company will have the following thrust areas:

1. Eradicating hunger, poverty and malnutrition, [‘‘promoting health care including preventive health care’’] and sanitation

2. Promoting education, including special education and employment enhancing vocation skills

3. Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age

homes, day care centers and such other facilities for senior citizens

4. ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water

5. protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works

of art; setting up public libraries; promotion and development of traditional art and handicrafts

6. Measures for the benefit of armed forces veterans, war widows and their dependents

7. Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic

8. Contribution to the prime minister's national relief fund [or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund)] or any other fund set up by the central govt.

9. (a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and

(b) Contributions to Public Funded Universities; like IITs, DAE, DBT, DST, Department of Pharmaceuticals, AYUSH, Ministry of Electronics and Information Technology and other bodies, namely DRDO, ICAR, ICMR and CSIR, engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs)

10. Rural development projects

11. Slum Area Development

12. Disaster management, including relief, rehabilitation and reconstruction activities

Governance Structure A three-tier governance structure is responsible for implementing CSR activities at “Geeken” . These include the

1. CSR Apex Committee

2. CSR Central Committee

3. CSR Regional Committee

Budget & Allocation For achieving the CSR objectives, the Company will, on yearly basis, allocate at least 2% of the average net profits of the company made during the three immediately preceding financial years, as its annual CSR Budget Guidelines for Allocation

• 1/3rd of the total amount to local area needs or requirements.

• 1/3rd of the total amount to initiatives supported by our key stakeholders (Customers, Suppliers, bankers etc.)

• 1/3rd of the total amount to support the vision of the Foundation in India.

CSR Implementation The CSR Activities can be implemented in two ways:

1. Directly by the CSR team of the Company.

2. Indirectly through NGO’s or Local CSR partners or in collaboration with the CSR team of other Companies working in the local areas.

Governance Structure – CSR Committee

CSR Apex Committee “Geeken” Company will have their own CSR Committee. The CSR Apex Committee comprises of.

As per the provisions of Section 135 of the Companies Act, the Companies having:

1. Net profit : Rs. 5 Cr or more; or

2. Turnover : Rs. 1000 Cr or more; or

3. Net Worth: Rs. 500 Cr or more; are required to spend 2% of ‘average net profits during last 3 financial years’ towards CSR. The CSR Committee shall finalize the CSR activities among those recommended by the CSR Central Committee within the CSR Policy of the company, and recommend to the Board for approval.

CSR Central Committee:

Mr. R P Shukla

Mr. B P Tiwari

Mr. Adesh kumar

Mr. Kamal kumar

Mr. Jitendra kumar

Mr. N Das Gupta

Roles & Responsibilities

The Scope of the CSR Central Committee includes:

1. Identify and priorities the CSR activities from the activities recommended by the CSR Regional Committee within the CSR policy approved by the Board.

2. Prepare the budget for each identified CSR activities.

3. Identify, negotiate with the CSR partners and devise the implementation strategy.

4. Coordinate with the CSR Regional Committees and the CSR implementation partners:

5. Recommend the CSR Activities and Implementation agencies to the CSR Committee of the respective Companies.

6. Monitor and supervise the CSR Activities at the regional level and report to CSR Committee on periodic basis.

7. Prepare the CSR annual Report and submit to the CSR Committee.

CSR Regional Committee

1. Management

2. Plant Head

3. Finance Head

4. HR Head

5. Sales Head

Roles and Responsibilities

The Scope of the CSR Regional Committee includes:

1. Identify the CSR activities and locations

2. Identify the local CSR implementation partners/NGOs’

3. Prepare the budget for each identified CSR activities.

4. Recommend CSR activities and particulars of the local CSR partners / NGOs’ to the CSR Central Committee.

5. Coordinate with the local NGOs for implementation of the CSR activities carried out at the regional level/local areas.

6. Monitor the implementation of the CSR activities and give report to the CSR Central

Committee on a periodic basis.

Monitoring & Feedback

• To ensure effective implementation of the CSR programmes undertaken at each location, a monitoring mechanism will be put in place by the respective regional head.

• The central CSR Committee will conduct impact studies on a periodic basis, through independent professional third parties / professional institutions , especially on the strategic and high value programmes.

• Central office will also try to obtain feedback from beneficiaries about the programme.

Few suggested CSR Activities :

1. To create/enhance infrastructure facilities in any school/orphanage and to be name in the name of the promoter.

2. To establish a training center in association with a NGO to impart vocational training free of cost to the needy.

3. To create a corpus for the benefits of poor and meritorious students in any school and to support Book/Uniform/Fee etc. out of the profits/interest of the corpus.

4. To adopt any park/road/locality for improvement and maintenance.

5. To develop infrastructure like Public Convenience/Transport for use under “Swachh Bharat Mission.

6. Organizing Health Camps / Sponsoring Mid-day meals etc.

To encourage employee volunteering

Hearts of Gold Award

To encourage employees to volunteer in CSR activities, Company Name would like to introduce, Hearts of Gold Award.

The objective of this award will be to recognize and celebrate the extraordinary achievements of individuals and teams who never forget that, as “Geeken” colleagues, we are all part of

a wider community. Eligible projects for Hearts of Gold could range from those that have been in place for several years to newly launched initiatives, or even short-term responses to community crises.

We, at Geeken Furniture are committed to fulfill our social obligations to provide a fair environment to persons contributing to our products and services.

For achieving above, the company is committed to: -

o To lead our business in labor law, health and safety requirements and the environment according to applicable legal national and international documents and standards;

o Not to use and not to support the use of children, forced or compulsory labor;

o To ensure equal opportunities and freedom of association by encouraging the development of each person;

o To prohibit any form of discrimination at the workplace (due to age, race, gender, nationality, religion and belief);

o To act against the use of corporal punishment, physical or mental coercion, verbal harassment, etc.;

o To observe and to follow the applicable regulatory requirements and industry standards for working hours. To aspire to a decent wage, satisfying basic needs of the personnel;

o To provide healthy and safe working conditions for all employed in the company by improving the working environment, buying modern production equipment and continuous striving to prevent injuries and subsequent disease;

o To review the policy of social accountability periodically in order to improve it in accordance with the changes of requirements and good practice of social management;

o To provide conditions for the effective implementation, maintenance and communication of this policy;

o To make this policy available to the engaged staff for its implementation;

o To allow this policy to be publicly accessible and effective in form and manner to the concerned parties.

Energy Policy

Top management has established an energy policy that:

· Adopting Energy Efficient methods and technologies.

· Reviewing energy usages & new opportunities for Energy Performance Improvement.

· Complying with all applicable and legal and other requirements.

· Ensuring availability of information and all necessary resources to achieve objectives and targets.

· Supporting the procurement of Energy Efficient products, services and design for energy performance improvements.

· Creating awareness among Employees and Suppliers about Energy Efficiency.

Design for Environment (DfE) Policy

Review Frequency-Once/Year - Review Date-21.03.2024

Policy Statement

At GeeKen, we are committed to advancing sustainability in the design and manufacturing of our furniture. In alignment with BIFMA Level certification, our Design for Environment (DfE) Policy integrates key environmental considerations, including the use of renewable, recycled, and recyclable materials, effective end-of-life management strategies, and the reduction of energy and water usage. By focusing on these core areas, we aim to minimize the environmental impact of our products throughout their lifecycle—from raw material sourcing to disposal.

1. Sustainable Material Selection

In our commitment to creating environmentally responsible products, we will ensure that our materials align with BIFMA’s standards for sustainability:

· Renewable Materials: We will prioritize the use of materials derived from renewable sources, such as FSC-certified wood and rapidly renewable resources (e.g., bamboo, cork, and natural fibers), to reduce dependency on finite resources.

· Recycled Materials: We are committed to incorporating recycled materials into our products. We will increase the use of post-consumer and post-industrial recycled materials, such as recycled wood, metal, and plastic, ensuring that these materials are safely incorporated into our furniture designs.

· Recyclable and Biodegradable Materials: We will design products with materials that are recyclable or biodegradable at the end of their life. This includes selecting materials like metals, wood, and certain plastics that can be easily separated and recycled. Biodegradable components will be prioritized where appropriate, ensuring minimal environmental impact after product use.

2. End-of-Life Management

We will implement comprehensive strategies for managing the environmental impact of our products once they reach the end of their usable life:

· Product Take-Back and Recycling Programs: We will offer product take-back or recycling programs to ensure that our furniture is either reused, repurposed, or properly recycled. Products will be designed to facilitate easy disassembly, enabling the recovery and recycling of materials.

· Waste Reduction at End-of-Life: We will provide clear guidance to customers on how to responsibly dispose of or recycle our products. By designing furniture with minimal complex components, we aim to make it easier for end users to separate materials and reduce landfill waste.

3. Energy Efficiency in Manufacturing

We recognize the significant role of energy consumption in manufacturing processes and are committed to reducing our energy footprint:

· Energy Efficient Production Processes: We will invest in energy-efficient technologies and production methods that minimize energy use throughout the manufacturing process. This includes optimizing machinery, reducing waste in production, and employing lean manufacturing principles to ensure energy is used efficiently.

· Renewable Energy Sources: Wherever feasible, we will integrate renewable energy sources, such as solar or wind power, into our production facilities to reduce greenhouse gas emissions associated with the manufacturing of our products.

4. Water Management

Water is a precious resource, and we are dedicated to reducing our water usage throughout the production process:

· Water Conservation in Manufacturing: We will adopt water-saving technologies and processes to minimize water consumption. This includes optimizing water use in cleaning, cooling, and manufacturing processes, and recycling water where possible.

· Efficient Water Use in Product Finishing: In product finishing and coating processes, we will use water-based and non-toxic finishes that minimize water waste and reduce the environmental impact of volatile organic compounds (VOCs).

5. Product Design for Durability and Longevity

In addition to the environmental impacts of material use, we will ensure that our products are designed to last:

· Durability and Repairability: We will design products to be durable, with materials and components that are built to last. This includes designing products that can be easily repaired or refurbished, extending their useful life and reducing the need for frequent replacement.

· Modular Design: Where applicable, we will design modular furniture that can be easily reconfigured, allowing customers to adapt the product to changing needs without requiring a full replacement.

6. Continuous Improvement and Compliance

We are committed to ongoing improvements in sustainability and environmental performance:

· Compliance with BIFMA and Environmental Regulations: All products will meet or exceed BIFMA’s Level certification standards, ensuring that they comply with environmental regulations and best practices. We will stay current with changes in sustainability standards and regulations, ensuring compliance with all relevant laws governing materials, emissions, and waste management.

· Monitoring and Goal Setting: We will continually assess our environmental performance through regular monitoring and reporting. Sustainability targets will be set, and we will identify areas for improvement to ensure that we meet our environmental goals.

7. Transparency and Stakeholder Engagement

We believe in maintaining open communication with our customers, suppliers, and other stakeholders regarding our sustainability practices:

· Supplier Partnerships: We will work closely with our suppliers to ensure that the materials and components we source adhere to our sustainability goals. This includes selecting suppliers who share our commitment to environmental responsibility and ethical manufacturing practices.

· Customer Education: We will educate our customers on the environmental benefits of our products and encourage responsible usage, recycling, and disposal practices. This includes providing clear product information and guidance on how to maintain and dispose of our furniture sustainably.

8. Conclusion

At GeeKen, sustainability is a core value that drives our design, manufacturing, and operational processes. Through the implementation of this Design for Environment (DfE) Policy, we are taking measurable steps to reduce our environmental impact. We remain committed to incorporating renewable, recycled, and recyclable materials, improving energy efficiency, optimizing water use, and implementing effective end-of-life management strategies to ensure that our products contribute to a sustainable future.

Approval and Implementation

This policy will be reviewed annually and updated as necessary to ensure continuous improvement in our environmental performance. All employees and suppliers will be trained on the policy and expected to contribute to its implementation.

As per ISO 14001

ENVIRONMENT, HEALTH AND SAFETY POLICY

A responsible and forward-looking approach to environmental issues is an important factor in Design, Development, Production and Marketing of Furniture inclusive of show room, production areas, and logistics and management offices. We recognize the mutual benefits of incorporating sustainability into our business strategies and of dealing appropriately with any impact on the environment caused by our operations.

We at Geeken recognize the impact that our activities can have on people and the environment, and run our company according to a moral philosophy that strikes a well-reasoned balance between economic, social and environmental needs. Safety, health and protection of the environment form an integral part of our planning and decision-making.

We are committed to:

- Implement internationally recognized safety, health and environmental systems.

- Benchmark the best safety, health and environmental practices.

- Provide healthy and safe working condition for the prevention of work related injuries and ill health.

- Consultation & participation of workers and where they exist workers representative.

- Prevention of pollution.

- Continually improve our safety, health and environmental performance.

- Use natural resources responsibly.

- Reducing energy use and its impact on climate change, and whilst energy forms part of our environmental policy.

- Trainand educate all employees and contractors on safety, health and environmental matters.

- Complying, as a minimum, with all applicable legal and other requirements.

- Operate our business with respect for people and the environment.

- Provide appropriate resources to implement the above.

Review this policy as and when required for continual improvement and effectiveness.

Quality Policy:

We, at Geeken Seating Collection Private Limited are committed to Customer Delight by supplying the Quality Furniture products and services through continually improving our employee skills and activities with latest technology.

Ergonomic, Safe, Durable, and Aesthetically Elegant look and feel, are the hall marks of Geeken brand of office furniture. We also create an environment of joy and partnering with all our Stakeholders to become a Top Leader in the Indian Furniture Industry.

We, at Geeken Seating Collection Private Limited are committed to comply with all applicable requirements.