Citta Communication Policy

Short description:

Citta places considerable importance on effective communication.

Scope

Relevant to all employees of the Citta Group, including its subsidiaries and affiliates worldwide. The policy covers all forms of communication – written, electronic and verbal.

Need:

The Citta Communication Policy establishes a set of principles to ensure that communication across Citta is effective and appropriate and responds to the diverse information needs of all our stakeholders. The purpose of this policy is to help preserve and enhance the Company’s reputation, both internally and externally, and to help ensure that relevant information reaches the targeted audience in the right format and at the right time. It is key for every Citta employee to understand the value of effective communication. Accurate and timely communication with stakeholders is integral to a business’ risk management process.

1. Background

1.1 Overview :

The Company is committed to effective communication with its customers, shareholders, market participants, employees, suppliers, financiers, creditors, other stakeholders and the wider community. The Company will ensure that all stakeholders, market participants and the wider community are informed of its activities and performance. The Company will endeavor to make publicly available all information to ensure that trading in its shares takes place in an efficient, competitive and informed market.

1.2 Purpose :

This Communications Policy contains the Company's approach and commitment to communication.

The Policy is designed to ensure that the Company:

(a) provides timely and accurate information equally to all shareholders and market participants regarding the Company including its sales process, financial situation, performance, ownership, strategies, activities and governance; and

(b) adopts channels for disseminating information that are fair, timely and cost-efficient. In addition to those policies and processes contained in the Continuous Disclosure Policy, the Company has implemented a number of processes to ensure achievement of these goals.

2. Confidentiality

Information that the Company considers private and that is not generally available outside the Company (Confidential Information) and information that the Company owns, develops, pays to have developed or to which it has an exclusive right (Proprietary Information) must be treated by the Company and all

employees as follows:

(a) the Company and all employees must ensure that they do not disclose any Confidential Information or Proprietary Information to any third party or other employees who does not have a valid business reason for receiving that information.

(b) if Confidential Information or Proprietary Information is required to be provided to third parties or other employees for valid business purposes, the Company and its employees must:

(i) take adequate precautions to ensure that information is only used for those purposes for which it is provided and is not misused or disseminated to the Company's detriment; and

(ii) ensure that the information is returned or destroyed when the purpose is complete. Such precautions include obtaining a confidentiality agreement or other undertaking. Advice about these measures can be obtained from the Company Secretary or Other Defined Upper Management Personality.

Any information concerning the Company which is not generally available and which may have a material effect on the price or value of the Company securities may need to be disclosed in Disclosure Policy and in section 3 of this Communications Policy

3. Communications with clients, stakeholders, employees and the market

3.1 Information on the website

The Company's website is one of the cornerstones of the Company's Communication Policy with stakeholders and the market. All information released for the updation of policy will be posted on the Company's website as soon as practicable.

3.2 Briefings

The Company recognizes the importance of the relationship between the Company and its clients, business partners, institutional investors, brokers and analysts. The Company may from time to time conduct briefings to these groups. In these cases, the following protocols will apply:

(a) material information which is required to be disclosed under the Continuous Disclosure Policy will not be disclosed at these briefings unless it has been previously, or is simultaneously, released in the Proposal or other such documents

(b) questions at briefings that deal with material information that has not previously been disclosed will not be answered; and Company would not be liable to answer those queries.

3.3 Communication with Clients

The Company recognizes the importance of the relationship between the Company and its clients, business partners, institutional investors, brokers and analysts. The Company may from time to time conduct briefings to these groups. In these cases, the following protocols will apply

(a) MOM for each briefings with clients are mandatory which need to be shared with all the required authorities in the process

(b) Only MAIL Communication are consider valid at the time of analysis of situation.

(c) All other means of communication (except mail) can be used but in order to formalize that communication a reference mail is need to be done.

(d) Each meeting or formal discussion should be concluded with MOM in predefined format with concern persons in mail.

(e) Each mail communication is responsibility of Sender to make sure Receiver has received it.

(f) Acknowledgement to a mail should be done in 1 working hour.

(g) Try to make all the communication with one stakeholder with one defined mail id.

3.4 Communication with employees

The Company recognises that its employees are central to the Company's success. In order to enable staff to fulfil their role to the high standards required and to promote employee satisfaction, the Company aims to ensure effective ccommunication with employees. Effective communication with employees starts with their direct manager and with accessibility to senior Management.

3.5 Employee briefings

The Company will from time to time conduct employee briefings so that all staff are aware of activities within the Company. These briefings may be conducted by the Managing Director or an appropriate manager.

3.6 Employee Organisational Communication

Written Communication

● Only MAIL Communication are consider valid at the time of analysis of situation.

● All other means of communication (except mail) can be used but in order to formalize that communication a reference mail is need to be done.

● Each meeting or formal discussion should be concluded with MOM in predefined format.

● All mails should be CC to concern personalities as defined by your RM/TL.

● Task Allocation, Reporting & Task Completion should be done on mail in defined format & process.

● Each mail communication is responsibility of Sender to make sure Receiver has received it.

● Acknowledgement to a mail should be done in 1 working hour and in case of any delay in dead line, delay should be acknowledge.

● Each mail should have a Close End Communication

Verbal Communication

● Employee is expected to maintain the decorum of office premises with his tone & volume of voice.

● Each meeting need to be concluded in meeting room.

● Respect is must in verbal communication across all the hierarchical communication.

● All defined parameters for Video Conference need to be followed.

● Citta believes in clear communication both within & outside the organisation.

3.7 Electronic communication

The Company recognises that it is often efficient to communicate electronically and accordingly:

(a) shareholders will be given the option to receive communications from, and send communications to, the Company and its share registry electronically; and

(b) the Company's email system allows staff and stakeholders to communicate simply and easily with management and staff of the Company. Employees and other stakeholders have access to this system and are encouraged to use it to improve the flow of information and communication generally. The Company will use email to ensure a continued flow of information and to communicate effectively with staff. Staff should feel free to communicate with any member of management by email.

3.8 Website

The Company's website is an important communication tool for employees and external stakeholders, including customers, suppliers, financiers and investors. The Company's website contains a range of information of relevance to stakeholders including relevant corporate governance policies and codes, media and market announcements and presentations to shareholders and institutional investors (see section 4.3 below). Stakeholders are encouraged to view the website on a regular basis so that they can keep up to date with information concerning the Company.

4. Other communications

4.1 Communications with the media

All communication with the media will be through the Chairman, Managing Director or persons authorized or appointed by the Board.

4.2 Communications with other stakeholders

The Company is committed to ensuring that all stakeholders regularly receive information about the Company and its activities. While individual briefings may be held with key stakeholders, such as financiers, the principal means of ensuring that stakeholders to have access to information will be through the Company's website.

4.3 Website

The Company's website is the primary means to provide information to all stakeholders. It has been designed to enable information to be accessed in a clear and readily accessible manner. The following information will be available on the Company's website:

(a) all announcements

(b) copies of presentations to shareholders, institutional investors, brokers and analysts where possible;

(c) any media or other releases;

(d) all notices of meetings and explanatory material;

(e) a copy of the Company's most recent annual report as well as previous annual, half yearly and quarterly reports;

(f) all of the Company' codes, policies and charters; and

(g) any other relevant information concerning non-confidential activities of the Company including business developments.

5. Other matters

5.1 Questions

If you have any questions arising from the Company's Communications Policy, please contact the Company Secretary or Concern Authority

5.2 Amendment of policy

This Policy can only be amended with the approval of the Management.

Communication at Citta is guided by the following principles:

1.Authorised spokespersons: Communication with stakeholders, media and financial markets must be aligned with the Company’s official stance and strategy and must only be done by duly authorised Company spokespersons. Any person not authorised to speak or write on behalf of the Company, asked by the media, shareholders (internal or external) or market analysts, or other stakeholders must decline to comment and refer them to the Corporate or local communications team. Any employee who does not follow this rule may be held personally liable for his/her actions.

2.Responsible individual behaviour: All Citta employees should, in their daily work, behave as if they were representatives and ambassadors of the Company. Therefore, each employee should be committed to preserving and enhancing Citta’s reputation. Any illegal or offensive behaviour or statement, including via social media accounts, which could cause damage to the Company should be avoided. The core values of Sustainability, Quality and Leadership that underpin the Citta brand should be reflected in everything we say or do. Inside information may only be disseminated through an authorised channel (Company press releases). Each employee should keep any inside information about Citta strictly confidential and not trade in Citta securities while in the possession of inside information in line with the Insider Dealing Regulations.

3.Transparency: Citta is committed to providing the public with clear, accurate and reliable information at all times. We seek to establish close relationships with our stakeholders, both internal and external, through regular communication, integrity and transparency.

4.Two-way communication: Citta believes in clear, accurate and reliable top-down and bottom-up communication through all levels of the organisation. Efficient two-way channels of communication ensure that employees understand, are aligned with and help the Company achieve its business objectives. The communication with all stakeholders, internal and external, must proceed in line with the Company’s official stance and strategy.

5.Presenting at conferences: When speaking at conferences, the presentation should be checked with Corporate Communications, Legal and Investor Relations in advance.

6.Official language: Citta recognises the rich linguistic diversity within the Group. However, English has been identified as the official language of the Group, and the learning and use of this language should be promoted.

7. Fair and prompt disclosure: Citta recognises the value of communicating company-related information in a timely and nonselective manner. Publicly available information on company related matters should be released to all internal & external stakeholders and to the public simultaneously.

8.Confidentiality: All Citta documentation, correspondence and company-related information, unless and until publicly available must be treated as confidential. Non-public information from or concerning suppliers, customers, employees, agents, consultants and other parties must also be protected in accordance with legal and contractual requirements, including the Citta Data Protection Procedure, when applicable.

9.Compliance: This policy should be read in conjunction with the Citta Code of Business Conduct. Citta is committed to complying with all applicable laws and stock exchange rules on the disclosure of financial and other information about the Company. Furthermore Citta fully respects the legal rights of the employees in all countries. In case of contradiction between this policy and applicable laws, applicable laws shall prevail.

10.CMMI (Capability Maturity Model Integration) Process - CMMI process improvement model is been followed for the best practice in the organization processes & communication methodology. The entire model act as a guideline for process improvement on any project or a department or even the entire organization. Citta has applied for CMMI Certification.