CODE OF CONDUCT FOR SUPPLIERS

Code of Conduct for Suppliers

L&T expects suppliers including their personnel (employees or sub-contractors) to support, embrace and enact
the following Code of Conduct (CoC), apart from complying with all national and international regulations and
laws that are applicable at any given time. L&T encourages its suppliers to go beyond compliance and embrace
the principles of sustainability. L&T will support training and capacity-building programmes undertaken by
suppliers, which promote awareness on sustainability and responsible business practices. L&T shall incorporate
regulatory compliance and ESG performance as key criteria based on requirements as stated in the Code during
evaluation of the suppliers.

A. Promote Environmental Sustainability

All suppliers support a precautionary approach to environmental issues and undertake initiatives to promote
better environmental responsibility. To this end, suppliers will

1. Reduce resource consumption and conserve natural resources:

1.1. Conduct all operations, sourcing, manufacture, distribution of products and the supply of services with
the aim of protecting and preserving the environment.
1.2. Use natural resources rationally and work towards reducing resource consumption (water, energy, fuel,
electricity, other materials etc.) and GHG emissions.
1.3. Identify environmental risks and set up appropriate prevention measures.

2. Prevent pollution and reduce waste generation

2.1. Maintain all required official permits, licenses and registrations.
2.2. Prevent contamination, limit waste generation, and avoid or minimise adverse impact on the environment
and biodiversity by facilitating reusing and recycling material.
2.3. Clearly monitor the precautions to be taken during operations & maintenance in case of emission of heat,
vibrations, radioactive rays, noise or similar.
2.4. Use only those chemicals and aerosols with very low or zero ODP (Ozone Depletion Potential), which are
allowed as per the regulatory provisions.
2.5. Ensure that all the chemical and hazardous substances are accompanied by the manufacturer MSDS
(Material Safety Data Sheet) during transport, storage, use and disposal, and that instructions mandated
be strictly followed. No chemical and hazardous substance shall be received without a MSDS document.
All the applicable regulatory guidelines shall be adhered strictly for the procurement, transport, storage,
use and disposal of such harmful and hazardous chemicals.
2.6. Provide written instructions about handling and/or disposal of equipment and product during the life
cycle if special handling is required.

B. Commitment to Human Rights, Labour and the Society

Suppliers shall support, respect and protect human and labour rights and make sure their organisation/entity
is not complicit in any kind of abuses and/or violations. In this regard, the suppliers must:

1. Fair working conditions

1.1. Provide and maintain healthy and safe working conditions and welfare facilities for the employees in its
establishment.
1.2. Ensure that that wages and benefits of their employees and subcontractors are fair and comply with
applicable national and local laws as well as with contractual agreements.
1.3. Provide all workers, both permanent and non-permanent, with employment documents that are freely
agreed to and which respect their legal and contractual rights.

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2. Health & Safety

Ensure that the activities of suppliers do not harm the health and safety of their own employees, suppliers
and subcontractors, local communities/population, and finally the users of its products and services, which is
in accordance with the L&T’s Mission Zero Harm in Health and Safety.

3. Child Labour
3.1. No person below 18 years shall be employed or permitted to work in any occupation or process.
3.2. Zero tolerance for any kind of child labour in their establishments and supply chain.

4. Forced Labour
4.1. Under no circumstance shall suppliers use forced labour1, whether in form of compulsory or trafficked
labour, indentured labour, bonded labour or other forms, through direct or indirect use of force and/or
intimidation.
4.2. Any kind of slavery, mental and physical coercion, human trafficking and debt bondage in the supply chain
shall not be tolerated.

5. Wages and Working hours

5.1. Ensure that all applicable regulations related to wages, overtime compensation and other legally
mandated benefits of their employees and subcontractors are fair and comply with applicable national
and local laws as well as with contractual agreements.
5.2. Ensure that maximum working hours laid down in the respective country are adhered to.

6. Freedom of Association and Collective Bargaining

6.1. Recognise and respect the rights of workers to freedom of association and collective bargaining. Workers
are not intimidated or harassed in the exercise of their right to join or refrain from joining any organisation.
6.2. Ensure that all employees can communicate with the management regarding working conditions.

7. Non-Discrimination and Equal opportunity

7.1. Commit, within the scope of prevailing laws and statutes, to oppose all forms of discrimination2.
7.2. Maintain a work environment free from any form of discrimination and harassment.
7.3. Refrain from discrimination in hiring and employment practices on grounds of skin colour, age, caste,
gender, race, ethnicity, nationality, socio‐economic background, physical or mental disability, religion,
sexual orientation, marital status, pregnancy, dependants, political or religious opinion, ideology, union
membership and personal or social circumstances. Special attention must be paid to the rights of workers
most vulnerable to discrimination.

8. Zero Tolerance towards Harassment

8.1. Treat all employees with respect and dignity and furthermore ensure that their own suppliers treat their
employees in the same manner.
8.2. No tolerance towards unacceptable treatment of employees, such as physical punishment or torture,
sexual harassment3, or abuse, mental or physical coercion or verbal abuse, or the threat of any such
treatment.

1
‘Forced Labour’ or ‘Involuntary Labour’ refers to all work or service that is extracted under the menace of penalty. It also includes terms
such as, bonded labour and modern slavery. It also includes any labour for which the worker receives less than the government stipulated
minimum wage, refer to https://www.ilo.org/global/topics/forced-labour/definition/lang--en/index.htm
2
‘Discrimination’ refers to unjust or prejudicial treatment of people, especially on the grounds of, but not limited to, caste, creed, gender,
race, ethnicity, age, colour, religion, disability, socio-economic status or sexual orientation.
3
‘Sexual Harassment’ includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication) namely: a)
physical contact and advances b) a demand or request for sexual favours c) making sexually coloured remarks d) showing pornography e)
any other unwelcome physical, verbal or non-verbal conduct of sexual nature https://legislative.gov.in/sites/default/files/A2013-14.pdf

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8.3. No worker should be subjected to any physical, sexual, psychological, or verbal harassment, abuse or other
form of intimidation.

C. Ethical Integrity and Legality

Suppliers shall demonstrate the highest standard of integrity, ethics, and business conduct.

1. Compliance with Applicable laws and regulations:

1.1. All activities must be carried out in compliance with the legislation that is applicable in the countries in
which the suppliers operate.
1.2. All other applicable international laws and regulations must be complied with, including those relating to
international trade (such as those relating to sanctions, export controls and reporting obligations), data
protection and antitrust/ competition laws.
1.3. Avoid any conduct that could tarnish or damage the reputation of L&T.

2. Anti-Corruption & Anti Bribery

2.1. All forms of bribery and corruption are prohibited
2.2. Adequate measures and procedures should be in place to prevent bribery in all commercial dealings.
2.3. Maintain a policy of ‘Zero Tolerance’ of any practice that may be deemed to be corruption, either active
or passive.
2.4. No tolerance for unacceptable conduct, which includes, but not limited to, non-compliance with anti-
corruption laws and, directly or indirectly offering, promising, hiring or authorising payments in cash or in
kind to any L&T employee, public official or any other person or entity, with intention of a) obtaining or
retaining business b) Influencing business decisions; and/or c) securing an unfair advantage.

3. Conflict of Interest
3.1. All and any conflict of interest in any business dealings with L&T, of which the suppliers are aware, should
be declared to L&T so that appropriate action can be taken.
3.2. Avoid a situation where there is a real or potential conflict of interest with L&T employees, or with their
family or closely associated persons, that could affect the independence or objectivity of their professional
actions or decisions. If avoidance is not possible, the suppliers should inform L&T of the situation so that
appropriate action can be taken.

4. Insider Trading and Other Economic Crimes

4.1. Ensure that all business and commercial dealings are transparently performed and accurately recorded in
the books and records.
4.2. Comply with applicable anti-money laundering laws, conduct business only with ethically responsible
partners and receive funds only from legitimate sources.
4.3. Avoid actual or attempted participation in economic offences4, such as (but not limited to) money
laundering, criminal breach of trust, counterfeiting, criminal misappropriation of properties, forgery,
cheating, extortion, embezzlement and fraud.
4.4. Refrain from insider trading. No confidential information regarding L&T is used to either engage, facilitate
or support insider trading in L&T’s shares. During their association with L&T, if a supplier is in possession
of any price-sensitive unpublished information on L&T, the supplier will desist from trading in L&T’s shares
until such price sensitive-information is published or known to public at large.
4.5. Take necessary measures to detect and prevent any illicit or suspicious forms of payment and inform
and/or report through established channels if it has any suspicion or concern in this regard.

4
https://ncrb.gov.in/sites/default/files/crime_in_india_table_additional_table_chapter_reports/Chapter%209-15.11.16_2015.pdf

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5. Gifts5 & Hospitality

5.1. Any business entertaining/hospitality with L&T should be modest in value, appropriate, and compliant
with the law and company policies, entirely for the purpose of maintaining good business relations and
not intended to influence in any way L&T’s decisions on future business relationship.
5.2. Only gifts/honorarium of nominal value accepted or offered on festivals, at conferences, etc. will be
permitted. Such gifts should comply with local laws and customs (including cultural and religious festivals)
and should not be prohibited under applicable law and should not include cash or cash equivalents, gold
or other precious metals, gems or stones.
5.3. Neither receive nor offer or make, directly or indirectly, any illegal payments, remunerations, gifts,
donations or comparable benefits that are intended, or perceived, to obtain uncompetitive favours for the
conduct of its business with L&T.
5.4. Neither directly or indirectly offer any gift, entertainment, trip, discount, service, or other benefit to any
official of L&T or his/her close relations which would or be capable of compromising, influencing, liable
to corrupt the integrity and objectivity of that person.

6. Competition, Confidentiality and Data Privacy

6.1. All market survey/other entities information must be obtained and used legitimately and in compliance
with all applicable laws and regulations.
6.2. No attempt should be made to divulge to L&T any information about any other entity in violation of any
law or agreement.
6.3. Likewise, L&T’s confidential information must not be shared with any Supplier unless expressly permitted
by L&T in writing by authorised signatory under the respective purchase order or agreement, as the case
may be.

7. Transparency and Ethics

7.1 Fair competition
Avoid any action that may constitute an illegal practice of unfair competition and ensure compliance with
applicable competition laws.

7.2 Corporate image and reputation

Suppliers must NOT:
• Make false statements or provide any misleading information regarding its products/services.
• Give the impression of representing or being the spokesperson of L&T while getting associated with any
religious/political party or for activities in their personal capacity.

8. Protection of Intellectual Property and No Misuse or Improper use of L&T’s assets/ property
8.1. Respect and protect all confidential information and intellectual property of L&T.
8.2. Do not misuse and share assets of L&T and employ them only for the purpose of conducting the business
for which they are duly authorised by L&T. These include tangible assets such as equipment and
machinery, systems, facilities, materials, and resources and intangible assets such as intellectual property
rights, processes, know how & technology, proprietary information, etc.
8.3. Safeguard, secure, and protect L&T’s assets and information technology from theft, destruction,
misappropriation, wastage, and abuse.

5
A gift is anything of value and would encompass any gratuitous monetary or non-monetary benefit. It includes tangible items such as cash,
precious metals, stones, jewellery, art and any of their equivalents, but also intangible items such as discounts, services, loans, favours,
special privileges, advantages, benefits and rights that are not available to the public. A “gift” also includes meals, entertainment, hospitality,
vacations, trips, use of vacation homes, tickets to sporting or music events, outings, vendor familiarisation trips and use of recreational
facilities.

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 CODE OF CONDUCT FOR SUPPLIERS

8.4. Promptly report loss, theft or destruction of any intellectual property and data of the Company or that of
any Supplier.

9. Financial Records and Accuracy in Books

9.1. Have accounting practices in place to ensure accuracy of its financial books and records.
9.2. Ensure accurate accounting and proper reporting of information pertaining to the business and financial
results in accordance with applicable Accounting Standards [Generally Accepted Accounting Principles
(GAAP)].
9.3. Ensure compliance to applicable laws and regulations with respect to accounting and taxation and timely
discharge of tax liability.

10. Sanction Laws

10.1 Do not engage in any dealings or transactions with any person, or in any country or territory that are
subject to global / regional sanctions as mentioned herein below in clause 10.2. L&T is vigilant of its
suppliers who may be on a sanctions list or have a related company in a country subject to global/regional
sanctions. In case of any concerns, the supplier should immediately report to L&T.
10.2 Do not be subject to or the target of any economic or financial sanctions or trade embargoes imposed,
administered or enforced by the U.S. Government including without limitation by the World Bank or by
the United Nations Security Council, the European Union, the United Kingdom including by Her Majesty’s
Treasury or the Department of Business, Innovation and Skills, a relevant regulatory authority or the
Minister of Foreign Affairs of Canada under the Special Economic Measures Act or the United Nations Act
or legislation or regulations with similar purpose or effect or any other relevant sanctions authority of any
other country (collectively, ‘Sanctions Laws’) nor is the Company or any of its subsidiaries / affiliates
located, organised or resident in a country or territory that is the subject of the target of Sanctions Laws
10.3 Do not take any action which places or is likely to place L&T in violation of Sanctions Laws and/ or breaches
affecting the reputation and/ or business interests of L&T

11. Responsible Sourcing

Ensure that goods and materials are not sourced in a suspicious or illegal way and implement measures for
sustainable procurement practices6 to ensure compliance with laws and regulations

12. Quality of Product and Services

Products and services should meet the specifications, quality, safety and environmental criteria specified in
the relevant contract documents and required by applicable laws

13. Corporate Citizenship

Suppliers shall be committed to be good corporate citizens, not only in compliance with all relevant laws and
regulations, but also by assisting and supporting initiatives to improve the quality of life of local
communities/regions in which it operates. The activities may be, but not limited to, community health and
family welfare, vocational training, education and literacy and employment.

6
Sustainable procurement is the process of making purchasing decisions that meet an organisation’s needs for goods and services in a way
that benefits not only the organisation but society, while minimising its impact on the environment. This is achieved by ensuring that the
working conditions of its suppliers’ employees are decent, the products or services purchased are sustainable, where possible, and that socio-
economic issues, such as inequality and poverty, are addressed

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 (To be printed on Supplier's letterhead)

Declaration of Compliance to L8T Code of Conduct

To,
The Head Procurement
Iasen & Touhro Limited
Address

Sub: Declaration of Compliance to L&T Code of Conduct

1. T7We hereby confirm that I/ We have read and understood L&T Code of Conduct for Suppliers and undertake to
comply with same and all applicable laws / statutes / directives or requlations. I/ We undertake to comply with the
Code of Conduct in letter and in spirit.
2. 1/We agree that these clauses / provisions or amendment, if any, form an intearated part of any or all L&Ts purchase
order or Work order or agreement /contract. I/ We confirm and uphold similar values as enshrined in this Coc and
accordingly conduct my / our business operations.
3. T7We shall promptly notify an actual or potential breach and provide all information in this regard as per the
provisions of CoC. !/ We shall promptlytake all remedial actions as required to comply with CoC. In the event of
any failure to notify such breach or take such remedial measures, L&T willbe entitled to take appropriate action,
inciuding termination of existing contractual relationship / agreement / purchase order / work order / agreement /
contract, if any or any other business transactions without any liability or obligation for cost, expenses or damages
of any kind as a result of exercising its right as mentioned. herein above towards me/us and L&T in its sole discretion,
may remove / suspend me /us as supplier.
4. We also authorise L&T to conduct due diligence / audit / inspection and assure cooperation in the process.
5. I/We state that none of our activities are / have been conducted in violation of the Code of Conduct except the
following:
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Namé of Comipáriy/ Eniy.

IMNWANT TEC HNOLOY LLPI
Name of Authorised Signatory': Designation:
DEVEMHETAMB AAT MIs TRy PARTNERS
Place: AMEDABAD
Date: (ddmmvw) >o32o24 LUP
Signature: Seal: TECTNOGY
INNWANT
PARTNERS
FOR,

From: Defence, Larsen & Toubro Limited

Name & Designation of Buyer from L&T:
Supplier's Registration Number (Vendor Code): |-|-|-| Version 30

'AllPartners for Partnership Fim, Managing Director/ Head of Procurement for Company, Proprietor for Proprietorship fim, et.

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