Whistleblower Policy (Internal) v1.

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(Approved by the Board at its meeting held on 21 January 2021)

Kisetsu Saison Finance (India) Private Limited

Sl No Particulars Details
1 Document title Whistleblower Policy
2 Date of preparation January 2021
3 Date of Modification NA
4 Validity / Next review Post Board Approval
5 Document Owner Sakshi Goyal

Approval details
Name & Designation Date
Approved by KSF Board 21 Jan 2021
Presha Paragash
Prepared and Owned by Sakshi Goyal

Change Log
Version Material Changes
1.0

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Table of Contents

1. Introduction.................................................................................................................... 4
2. Definitions ...................................................................................................................... 4
3. Objective ........................................................................................................................ 5
4. Eligibility ........................................................................................................................ 5
5. Who is a Whistle Blower? ............................................................................................... 5
6. Disqualifications ............................................................................................................. 5
7. Applicability / Types of protected disclosures .................................................................. 6
8. Protection....................................................................................................................... 6
9. Process ........................................................................................................................... 7
10. Confidentiality .......................................................................................................... 11
11. Retention .................................................................................................................. 12
12. Modification ............................................................................................................. 12
13. Disclosure ................................................................................................................. 12
Annexure 1- Employee Consent ............................................................................................ 13

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1. Introduction
Kisetsu Saison Finance India Private Limited believes in the conduct of business and affairs
in a fair and transparent manner with utmost integrity and commitment while addressing
the reporting of and resolving violations, abuse of company policies, adverse work
conditions, fraud etc. Any actual or perceived as potential violation of the company
policies would be taken seriously and addressed as per this policy and process.

2. Definitions
Disciplinary Action: Includes any action that can be taken on the completion of
investigation process including but not limiting to a warning, financial fine, suspension
from the official duties, termination or any such action as is deemed to be fit considering
the seriousness of the incident / violation
Employee: Means every employee of the Company, both full time and contract, working
in India or abroad, including the expatriates working in India
Whistle Blower: Means an employee initiating a Protected Disclosure under this Policy.
This whistle-blower has come to the decision to make a disclosure or express a genuine
concern/grievance/allegation, after due diligence
Company: Kisetsu Saison Finance India Private Limited
Protected Disclosure: A genuine concern raised by an official communication made in
good faith disclosing information around actual or potential unethical and / or improper
activity. Protected Disclosures should be factual, as detailed as possible, specific but not
speculative or ambiguous in nature
Ethics Officer / Investigator: Persons authorized, appointed, consulted or approached by
the Chairman of the Audit Committee and includes the Statutory and/or Internal Auditors
of the Company and the Law Enforcement officers
Subject: A person against or in connection with the Protected Disclosure where
accusation of violations are made or evidence gathered during the investigation process
The access to the Whistle-blower information will be restricted to the HR, Exec Director,
parent company (Credit Saison Co., Ltd.). The case will then be referred to an internal
team or an external agency for a detailed investigation, if required.

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 Failure to co- operate or providing incorrect / false information can lead to disciplinary
action.

3. Objective
This policy and process document covers scope of activities which are covered. Its
process, purpose, communication, committee among other details necessary for
employees to be aware of their obligation and medium to report any misconduct and
violations involved across the levels in the company. The policy promotes whistle blowing
of violations and encourages whistle blower to report information and associated
incidents through suggested medium.

4. Eligibility
The policy is applicable to all the employees of Kisetsu Saison Finance India Private
Limited across levels, bands including Directors of the company. The whistle blower policy
and action on reporting to be conducted as a neutral fact‐finding process without
presumption of guilt.

5. Who is a Whistle Blower?

An employee who discloses or demonstrates an evidence of unethical activity or any
conduct that may lead to breach of the Company’s code of conduct, ethics, process and
policies or its values.

6. Disqualifications
- Whistle blowers are protected from any biased or unfair treatment as a repercussion to
reporting violations to the committee. However, any abuse of the policy will attract
strict disciplinary action
- Protection under this policy does not include protection from disciplinary action arising
from false and baseless allegations made by whistle blower knowing it to be false or
with mala fide intention
- Disciplinary action against employees misusing the policy would be taken only after
duly evaluating the case and after providing reasonable opportunity to the employee
to be heard

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 - Whistle blowers, who make any Protected Disclosures, which have been found to be
malicious or mala fide for two or more Protected Disclosures, reported otherwise than
in good faith, will be disqualified from reporting further Protected Disclosures for a
period of 12 months

7. Applicability / Types of protected disclosures

The policy is applicable to all the employees of Kisetsu Saison Finance India Private
Limited for any events described below or potential events but not limited to are:
- Abuse of authority for personal gain
- Breach of contract
- Negligence causing substantial and specific danger to public health and safety
- Manipulation / unauthorized usage and stealing of company data
- Financial irregularities including Fraud and suspected fraud
- Acquiring confidential/propriety information
- Criminal offence
- Intentional violation of law
- Misuse of company funds
- Unethical events
Abetment of any of the above mentioned acts
This policy should not be used for any personal grievances, such as promotion or
appraisal. This policy should not be misused for raising malicious or baseless allegations
against colleagues with ulterior motive.

8. Protection
- No unfair or biased treatment of any kind will be meted out to a Complainant for
reporting a Protected Disclosure under this Policy
- The company does not promote any kind of discrimination, harassment or victimization
of the Whistle Blower and provides complete protection against retaliation, threat,
suspension or termination, refusal of promotion, lack of fair opportunities or use of
authority obstructing Whistle Blower's right to perform their duties including sharing
additional details related to the current or future Protected Disclosure
- The identity of the Whistle Blower will be kept confidential as much as possible and
allowed by the law

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 - The protection is also extended to any other employee / s who would be assisting the
Whistle Blower in investigation and reporting

9. Process

An overseas hotline has been set up for executives and employees of Credit Saison.

The Setup and Purpose of the Whistleblower System

The purpose of this system is to contribute to the reinforcement of compliance-oriented

management by preventing, detecting, and correcting misconduct at an early stage by
establishing a system for the appropriate handling of the whistleblowing and the
consultation about systematic or individual misconduct from officers and employees
concerning organizational or personal misconduct, so-called whistleblowing system.

About the Overseas Hotline

If the Company becomes aware of any of the following type of misconduct, you may
report it to your supervisor in the workplace or a member of the Company's board of
directors or audit & supervisory board member, and in addition to these, you may also
report it through a hotline established on the website (the "Overseas Hotline").

When you use the Overseas Hotline, your report will be forwarded directly to the
reporting office of the parent company, Credit Saison Co., Ltd.

The Overseas Hotline is operated by the Reporting Support Center Co., Ltd.

1. Overseas Hotline Users

Anyone who was a director, audit & supervisory board member, executive officer, employee,
or associate of our company

Employees are defined in the Rules of Employment and dispatched workers defined in the
Worker Dispatch Law who is engaged in our business.

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 2. The Department in charge of Contact

A compliance consultation desk is set up in the department that has jurisdiction over
compliance at our parent company, Credit Saison Co., Ltd...

3. Eligible Activities available on the Overseas Hotline

(1) Bribery Reporting

(2) Reporting Accounting Fraud

(3) Reporting of harassment and other misconduct

(4) Other violations of laws and regulations in the course of business and violations of company
rules

4. Acts not covered by the Overseas Hotline

(1) Reporting on Human Resources Policies, Personnel Systems, and Personnel Evaluation

(2) False allegations, slanderous allegations against others, or allegations made for other
improper purposes.

(3) Reporting of dissatisfaction regarding personal evaluation and treatment

(4) Reports on religious and political matters

(5) Information that cannot be transferred overseas (state secrets, commercial secrets, privacy,
etc.) as defined by laws and regulations

Whistle Blowers can make Protected Disclosure to the committee as soon as possible
after being aware of violations, preferably within 30 consecutive days. However, Protected
Disclosures submitted after 30 days would also be investigated by the committee. The

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 Protected Disclosure should be based on facts with as much specific information as
possible avoiding any ambiguity.

The Whistleblowers may enter the Web-based Overseas Hotline system of the Center and
agree to the Terms and Conditions of Use of the Center before proceeding to the next
step of the whistleblowing process.

a. WEB reporting page: https://whistle.jp/tsuho/

b. Password: To be announced by KSF HR

The procedures for using the Overseas Hotline of the Center will be as follows:

I. Input password; choose workplace (country/area) and language

II. Agree with Overseas Hotline Terms of Use (which will appear at this stage)

III. Register the Basic Information (The Whistleblowers’ company and Contact E-mail
Address)

IV. Confirm whether the Whistleblowers wish to delete the Signature Information (signature
in the e-mail and the e-mail address) stating the contents of the whistleblowing when the
Center provides the Compliance Office of the parent company with the contents of the
whistleblowing.

Note that even if the Signature Information is deleted, if there is information that can
identify the Whistleblowers included in the Whistleblowers’ report, the Compliance
Office of the parent company or its subsidiaries/affiliated companies may still be able to
identify the Whistleblowers.

5. Compliance with the Rules and Regulations

When using the Overseas Hotline, you must comply with the "Whistleblowing Rules" and
"Whistleblowing Guidelines" set forth by our company and the "Terms of Use for the Overseas
Hotline" set forth by the Overseas Whistleblowing Support Center.

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6. Points to keep in mind

Our parent company, Credit Saison Co., Ltd. outsources the operations of the Overseas
Hotline to TSUHO Support Center Co., Ltd... All whistleblowing to the Overseas Hotline will be
made to Japan from Kisetsu Saison Finance India Private Limited.

Because whistleblowing to such a point of contact is not primarily directed to us, but to our
parent company, which is a separate legal entity from us, the laws and regulations of India
and the contracts and rules that we or you enter into or are bound by may prohibit or restrict
the provision of information overseas or to our parent company. You may be required to
report the incident to your supervisor at work or our directors or audit & supervisory board
member. In this case, you are required to report the incident to your supervisor at work or
one of our directors or audit & supervisory board member...

7. Deletion of Signature Information (Anonymous Whistleblowing)

When using the Overseas Hotline, upon request, the Overseas Whistleblowing Support Center
will remove the signature and e-mail address ("Signature Information") from the e-mail
containing the content of the report. If you wish, you can make whistleblowing anonymously
to the parent company after deleting the signature and e-mail address (hereinafter referred to
as "Signature Information") from the e-mail that contains the content of the whistleblowing.
However, please note that the information on the whistleblowing other than the signature
information will be provided by the Overseas Whistleblowing Support Center to the parent
company, Credit Saison Co., Ltd...

8. Handling of personal information of our officers and employees

(1) Purpose of Use of Personal Information

The personal information of our executives and employees will be used to the extent
necessary for the whistleblowing system.

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 (2) Prior consent for the transfer, use, and storage of personal information

The personal information of our officers and employees will be transferred to our company
and to our parent company (in Japan, where the company is based) for use and storage.
Please refer to Annex 1 for the consent format.

(3) Appropriate Management of Personal Information for Whistleblowing

ⅰ） Information obtained through whistleblowing handling services shall be shared only with
those who are engaged in whistleblowing handling services.

ⅱ） Those who engage in the Whistleblower Management Service are required to consider

not identifying the whistleblower when receiving or investigating a whistleblower.

ⅲ） The confidential or personal information of the whistleblower or any other information

obtained through the whistleblowing handling process will not be disclosed without the
whistleblower's consent or other legitimate reasons.

9. Protection of the whistleblower

Please be assured that we will not treat you adversely by whistleblowing through our overseas
hotline.

10. Confidentiality
- The Whistle Blower, Investigator, Audit Committee and all the members involved in
the Protected Disclosure and investigation process should strictly comply:
- Maintaining complete confidentiality of the matter
- Not discussing the matter with any other individual other than required in the
investigation
- Not leaving any confidential paper unattended and secure with locks in safe places
- Protecting documents and electronic material with passwords
Anyone not complying to above mentioned secrecy guidelines shall be held liable for
appropriate disciplinary action as considered fit

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11. Retention
All Protected Disclosures documented along with result of investigation and related
process, shall be retained for a minimum of 5 years or such period as required by the
law, whichever is higher

12. Modification
The company has right to review the policy from time to time to amend, include
necessary changes as required at any stage with concurrence of Audit committee. The
amendments made to policy shall not be contradicting to any act, rule or regulation
issued by the Government. The amendments will be shared by KSF HR.

13. Disclosure
- All the Protected Disclosure cases along with findings and results to be submitted by
investigators to Audit Committee on a quarterly basis
- Audit Committee shall report the investigations and results to the Chairman of Board
on a regular basis

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 Annexure 1- Employee Consent
Whistleblowing system for executives and employees of Credit Saison Group overseas
offices
The Setup and Purpose of the Whistleblower System
The purpose of this system is to contribute to the reinforcement of compliance-oriented management
by preventing, detecting, and correcting misconduct at an early stage by establishing a system for
the appropriate handling of the whistleblowing and the consultation about systematic or individual
misconduct from officers and employees concerning organizational or personal misconduct, so-called
whistleblowing system.

About the Overseas Hotline

If the Company becomes aware of any of the following type of misconduct, you may report it to your
supervisor in the workplace or a member of the Company's board of directors or audit & supervisory
board member, and in addition to these, you may also report it through a hotline established on the
website (the "Overseas Hotline").
When you use the Overseas Hotline, your report will be forwarded directly to the reporting office of
the parent company, Credit Saison Co., Ltd...
The Overseas Hotline is operated by the Reporting Support Center Co., Ltd...

Notes
1. Overseas Hotline Users
Anyone who was a director, audit & supervisory board member, executive officer, employee, or
associate of our company
Employees are defined in the Rules of Employment and dispatched workers defined in the
Worker Dispatch Law who is engaged in our business.

2. The Department in charge of Contact

A compliance consultation desk is set up in the department that has jurisdiction over compliance
at our parent company, Credit Saison Co., Ltd...

3. Eligible Activities available on the Overseas Hotline

(1) Bribery Reporting
(2) Reporting Accounting Fraud
(3) Reporting of harassment and other misconduct
(4) Other violations of laws and regulations in the course of business and violations of company rules

4. Acts not covered by the Overseas Hotline

(1) Reporting on Human Resources Policies, Personnel Systems, and Personnel Evaluation
(2) False allegations, slanderous allegations against others, or allegations made for other improper
purposes.
(3) Reporting of dissatisfaction regarding personal evaluation and treatment
(4) Reports on religious and political matters
(5) Information that cannot be transferred overseas (state secrets, commercial secrets, privacy, etc.)
as defined by laws and regulations

5. Overseas Hotline
To make a report via the Overseas Hotline, please visit the following website
Overseas Whistleblowing Support Center
Website: https://whistle.jp/tsuho/
Password: To be announced by KSF HR

6. Compliance with the Rules and Regulations

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 When using the Overseas Hotline, you must comply with the "Whistleblowing Rules" and
"Whistleblowing Guidelines" set forth by our company and the "Terms of Use for the Overseas
Hotline" set forth by the Overseas Whistleblowing Support Center.

7. Points to keep in mind

Our parent company, Credit Saison Co., Ltd. outsources the operations of the Overseas Hotline to
TSUHO Support Center Co., Ltd... All whistleblowing to the Overseas Hotline will be made to
Japan from India.
Because whistleblowing to such a point of contact is not primarily directed to us, but to our
parent company, which is a separate legal entity from us, the laws and regulations of India.and
the contracts and rules that we or you enter into or are bound by may prohibit or restrict the
provision of information overseas or to our parent company. You may be required to report the
incident to your supervisor at work or our directors or audit & supervisory board member. In this
case, you are required to report the incident to your supervisor at work or one of our directors or
audit & supervisory board member...

8. Deletion of Signature Information (Anonymous Whistleblowing)

When using the Overseas Hotline, upon request, the Overseas Whistleblowing Support Center
will remove the signature and e-mail address ("Signature Information") from the e-mail
containing the content of the report. If you wish, you can make whistleblowing anonymously to
the parent company after deleting the signature and e-mail address (hereinafter referred to as
"Signature Information") from the e-mail that contains the content of the whistleblowing.
However, please note that the information on the whistleblowing other than the signature
information will be provided by the Overseas Whistleblowing Support Center to the parent
company, Credit Saison Co., Ltd...

9. Handling of personal information of our officers and employees

(1) Purpose of Use of Personal Information
The personal information of our executives and employees will be used to the extent necessary for
the whistleblowing system.
(2) Prior consent for the transfer, use, and storage of personal information
The personal information of our officers and employees will be transferred to our company and to
our parent company (in Japan, where the company is based) for use and storage.
(3) Appropriate Management of Personal Information for Whistleblowing
ⅰ） Information obtained through whistleblowing handling services shall be shared only with
those who are engaged in whistleblowing handling services.
ⅱ） Those who engage in the Whistleblower Management Service are required to consider not
identifying the whistleblower when receiving or investigating a whistleblower.
ⅲ） The confidential or personal information of the whistleblower or any other information
obtained through the whistleblowing handling process will not be disclosed without the
whistleblower's consent or other legitimate reasons.

10. Protection of the whistleblower

Please be assured that we will not treat you adversely by whistleblowing through our overseas
hotline.
…………………………………………………………………………………………………………………………
Consent form
I understand the above and agree to the processing of my personal information.

Date of the acceptance(DMY) -

Signature -

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