• 8960648508
  • shivambiolumina@gmail.com
  • Gata No.134 Vill- Birnai, Para Kora , Jahanabad Fatehpur-212631

*1. Corporate Governance Policy*

Shivam Biolumina Pvt Ltd is committed to maintaining the highest standards of corporate governance in strict compliance with SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Companies Act, 2013, and global best practices. Our governance framework is designed to ensure transparency, accountability, and sustainable value creation for all stakeholders including shareholders, employees, customers, and the community at large.

 

*1.1 Board Composition and Responsibilities*

  1. The Board shall consist of a balanced mix of Executive, Non-Executive and Independent Directors with appropriate skills and experience to provide effective leadership.
  2. At least 50% of the Board shall comprise Independent Directors as mandated by SEBI LODR Regulations.
  3. The Board shall meet at least four times annually with a maximum gap of 120 days between two meetings. Additional meetings shall be convened for matters requiring urgent attention.
  4. All Directors shall disclose their interest in other companies/entities annually and recuse themselves from discussions where conflicts may arise.

*1.2 Board Committees*

*Audit Committee:*

Comprising majority Independent Directors, this committee oversees financial reporting integrity, internal controls, statutory audits, and compliance. It reviews quarterly results before Board approval.

*Risk Management Committee:*

Identifies key business risks (strategic, operational, financial, compliance)

and ensures appropriate mitigation frameworks

are in place.

*Nomination & Remuneration Committee:*

Responsible for Board composition, director appointments,

and ensuring fair compensation policies

aligned with long-term organizational goals.

*Stakeholders’ Relationship Committee:*

Addresses investor grievances, ensures timely dividend payments,

and maintains effective

communication with shareholders.

*1.3 Ethical Business Practices*

  1. Strict prohibition on insider trading as per SEBI (Prohibition of Insider Trading) Regulations, 2015.
  2. No employee/director shall engage in any transaction that creates conflict between personal interests and company interests.
  3. Compliance with Prevention of Corruption Act, 1988 and foreign anti-bribery laws (FCPA, UKBA) in all business dealings.

*2. Code of Business Conduct & Ethics*

This Code applies to all directors, officers and employees of Shivam Biolumina Pvt Ltd and its subsidiaries.

*2.1 Workplace Conduct*

  1. Equal employment opportunities regardless of caste, creed, gender, religion, disability or sexual orientation.
  2.  Strict prohibition of sexual harassment at workplace as per Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
  3. Professional work environment free from discrimination, bullying or any form of harassment.

*2.2 Anti-Corruption Policy*

  1. No employee shall offer, give, solicit or accept any bribe, kickback or improper advantage.
  2. Gifts/entertainment exceeding ₹5,000 value per instance requires prior written approval from Compliance Officer.
  3. Third-party due diligence mandatory for all vendors/agents under PMLA guidelines.

*2.3 Data Privacy & Confidentiality*

  1. Compliance with Digital Personal Data Protection Act, 2023 for all personal data processing.
  2. Sensitive business information (trade secrets, R&D, financial data) shall be protected through NDAs and access controls.

*3. Risk Management & Internal Controls*

*3.1 Enterprise Risk Management*

  1. Biannual risk assessment covering:
  2. Strategic risks (market competition, M&A integration)
  3. Operational risks (supply chain, IT systems)
  4. Financial risks (currency fluctu…

*3.2 Internal Financial Controls*

  1. Monthly reconciliation of all accounts
  2. Three-level approval system for expenditures above ₹10 lakhs
  3. Quarterly internal audits by independent firm

*4.1 Information Security Framework*

  • Implementation of ISO 27001 standards for information security
  • Role-based access control for all systems
  • Mandatory multi-factor authentication for remote access

*4.2 Data Protection Measures*

  1. Encryption of all sensitive data in transit and at rest
  2. Regular vulnerability assessments and penetration testing
  3. Secure disposal of obsolete hardware/media

*4.3 Incident Response*

  1. 24/7 security operations center monitoring
  2. Breach notification within 72 hours as per DPDPA
  3. Employee cybersecurity training quarterly

*5. Human Resources Policy*

*5.1 Recruitment & Onboarding*

– Merit-based hiring through structured interviews
– Background verification for all hires
– 30-day induction program covering policies, systems and culture

*5.2 Performance Management*

– Bi-annual performance reviews using balanced scorecard
– Career development plans for high-potential employees
– 360-degree feedback for leadership roles

*5.3 Compensation & Benefits*

– Market-linked salary benchmarking annually
– Variable pay tied to individual and company performance
– Comprehensive health insurance for employees and dependents

*5.4 Workplace Safety*

– Compliance with Factories Act and OSHA standards
– Quarterly safety drills and audits
– Ergonomics assessment for all workstations

 

 

 

*6. Whistleblower Policy*

– Anonymous reporting channel via dedicated email/helpline
– Investigation by Ethics Committee within 30 days
– Strict non-retaliation protection for genuine complaints

*7. Policy Review & Compliance*

All policies shall be reviewed annually by the Board. Compliance metrics shall be reported quarterly to the Audit Committee.

 

*Approved by the Board of Directors*
*Shivam Biolumina Pvt Ltd*
*Date: [DD/MM/YYYY]*

*Contact:*
Company Secretary
Email: shivambiolumina@gmail.com
Phone: 8960648508
This comprehensive policy document reflects our commitment to ethical business practices, regulatory compliance and sustainable growth. All employees are required to acknowledge receipt and understanding of these policies.