Core Governance Policies

Code of Business Conduct and Ethics

SDIPL’s expectations and commitment with respect to business ethics and compliance are contained in the Code of Business Conduct and Ethics. It provides guidelines with regard to various aspects of ethical business conduct and the right behaviours expected.

The Company is in the process of adopting the Code of Conduct for Board and Senior Management Personnel pursuant to the requirement of Part D of Schedule V of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Whistle-blower Policy

SDIPL’s Whistle-blower Policy is adopted to ensure that an independent and effective reporting system is available to our employees and third parties to provide open channels of communication and foster a culture of integrity and ethical decision-making. The Policy accommodates anonymous disclosures and prohibits retaliation or intimidation against the Whistle-blower.

The Board has duly adopted a Whistle-blower Policy (“Policy”) which facilitates the stakeholders to have direct access to the management, to report concerns about any unethical behaviour, actual or suspected fraud or violation of the Company’s Code of Business Conduct and Ethics (“Code”).

The Board has also constituted an Ethics Committee pursuant to the said Policy.

Adequate safeguards are provided against victimisation to those who avail of the mechanism and direct access to the Chairperson of the Board is provided to them.

Anti-bribery and Corruption (“ABC”) Policy

This Policy is aimed to provide guidance to understand, analyse and act in situations where there is a potential ABC related risk. It reiterates SDIPL’s commitment of not paying bribes in furtherance of business objectives and also sets the expectation that no one acting for or on behalf of the Company is allowed to either pay or accept bribes.

Code of Conduct for Prohibition of Insider Trading

At SDIPL, we are in compliance with the applicable provisions of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time-to-time and have adopted the Code of Conduct for Prohibition of Insider Trading to monitor the compliances. Your Company has also implemented the Structured Digital Database platform to monitor the sharing of the price sensitive information of the Company in compliance with the aforesaid regulations.

Risk Management Policy

The Company has in place a Risk Management Policy which provides for a robust risk management framework to identify and assess risks such as operational, financial, regulatory and other risks. There is an adequate risk management infrastructure in place, capable of addressing these risks.

Internal Financial Controls

The Company has adequate internal financial controls commensurate with the size of the business and nature of our operations, designed to provide reasonable assurance with regard to the accuracy and completeness of the accounting records and timely preparation and provision of reliable financial statements.

Corporate Social Responsibility (“CSR”) Policy

Pursuant to section 135 of the Companies Act, 2013 (“Act”), the Board of Directors of your Company has approved and adopted a CSR Policy and the same is available on the website of the Company i.e. www.summitdigitel.com. During the period under review, the Board, at its meeting held on February 11, 2022, approved and adopted the amended CSR Policy to include reference of Board in place of the committee, pursuant to the dissolution of the CSR Committee in compliance with the provisions of the Act and circulars issued thereunder.

The purpose of the CSR Policy is to articulate what CSR means to the Company, the kind of projects to be undertaken, the broad areas of intervention, the approach to be adopted to achieve the CSR goals and a monitoring mechanism. This policy is aligned with our Company’s objectives, principles and values, for delineating its responsibility as a socially and environmentally responsible corporate entity. This document is also an attempt to showcase the linkage of our social objectives with business strategy.