Disability Policy

1. Preamble

Biome Laboratories Private Limited (‘the Company’) is committed to fostering an inclusive, equitable, and
respectful work environment for all individuals, including Persons with Disabilities (PwD"). The Company
firmly believes that diversity in its workforce, including the inclusion of persons with disabilities, strengthens its organisational culture and contributes to its overall growth.

This Equal Opportunity Policy (‘Policy’) has been formulated in accordance with Section 21 read with Rule 8 of the Rights of Persons with Disabilities (RPwD) Act, 2016 and the Rights of Persons with Disabilities Rules, 2017, to ensure that Persons with Disabilities are afforded equal opportunities in all aspects of employment with the Company.

2. Objectives

The objectives of this Policy are to:

• Ensure non-discrimination against persons with disabilities in all employment matters.
• Provide reasonable accommodation to enable PwD employees to perform their duties effectively.
• Create a safe, accessible, and supportive work environment for persons with disabilities.
• Create a safe, accessible, and supportive work environment for persons with disabilities.
• Establish a transparent grievance redressal mechanism for PwD-related concerns.
• Comply with the provisions of the Rights of Persons with Disabilities Act, 2016.

3. Scope and Applicability

This Policy applies to:

• All employees of Biome Laboratories Private Limited — whether permanent, contractual, temporary, or intern.

• All job applicants seeking employment with the Company.

• All locations and offices of the Company, including the registered office at 501 Link Rose Building, Linking Road. Santacruz. Mumbai. Maharashtra — 400054.

This Policy covers all employment-related matters including recruitment, selection, appointment, promotion, training. transfer. remuneration, and separation.

4. Definition of Disability

For the purposes of this Policv. 'Disability’ and 'Person with Disability’ shall have the meanings assigned to them under the Rights of Persons with Disabilities Act, 2016.

The Act recognise the following 21 specified disabilities:

• Blindness

• Low Vision

• Leprosy Cured Persons

• Hearing Impairment (Deaf and Hard of Hearing) Locomotor Disability

• Dwarfism

• Intellectual Disability

• Mental Illness

• Autism Spectrum Disorder

• Cerebral Palsy

• Muscular Dystrophy

• Chronic Neurological Conditions

• Specific Learning Disabilities

• Multiple Sclerosis

• Speech and Language Disability

• Thalassemia

• Hemophilia

• Sickle Cell Disease

• Multiple Disabilities including Deaf-Blindness

• Acid Attack Victims

• Parkinson's Disease

A 'Person with Benchmark Disability' means a person with not less than forty percent (40%) of a specified disability as certified by the competent authority.

5. Non-Discrimination Policy

Biome Laboratories Private Limited shall not discriminate against any person on the basis of disability in respect of:

• Recruitment, selection, and appointment to any post.

• Promotion, increment, or career advancement.

• Access to training. learning. and development programmes.

• Terms, conditions, and benefits of employment.

• Transfer or posting decisions.

• Retrenchment. termination. or separation.

Any form of harassment, intimidation, or victimization directed at a person on account of their disability shall be treated as a serious misconduct and shall be subject to disciplinary action under the Company's applicable policies.

6. Recruitment and Employment

The Company shall ensure that its recruitment process is inclusive and accessible to persons with disabilities. Specifically:

• Job advertisements shall be drafted in a manner that does not discourage PwD candidates from applying.

• Interview venues and processes shall be accessible, and reasonable adjustments (such as additional time, accessible formats, or assistive support) shall be provided to PwD candidates upon request.

• Selection decisions shall be made solely on the basis of merit. qualification. and suitability for the role. without any adverse inference being drawn from the candidate's disability.

Given the nature and scale of the Company's current operations, no specific posts have been separately earmarked for PwD candidates at this stage. However. the Company shall evaluate all roles for their suitability for PwD candidates and update this section accordingly as the organization grows.

No incentive or preferential quota scheme is currently in force. The Company shall review this position annually and introduce affirmative measures as deemed appropriate.

7. Reasonable Accommodation

The Company is committed to providing reasonable accommodation to PwD employees to enable them to perform the essential functions of their job. Reasonable accommodation may include, but shall not be limited to:

7.1 Physical Accessibility

• Ensuring that workplace entrances, workstations, restrooms, and common areas are accessible to persons with mobility-related disabilities to the extent practicable within the existing premises.

• Making structural modifications or adaptations as required and feasible, including ramps, accessible seating arrangements, and appropriate signage.

• Providing reserved and accessible parking for PwD employees upon request.

7.2 Assistive Technology and Devices

• Providing or facilitating access to screen readers, magnification software, text-to-speech tools, or other assistive technologies required by visually impaired employees.

• Providing hearing loop systems, captioning. or other audio-assistive devices for employees with hearing impairment, where feasible.

• Making available ergonomic furniture, modified keyboards, or other adaptive equipment as required for employees with locomotor disabilities.

• Bearing reasonable costs associated with the provision of such assistive devices or technology.

7.3 Flexible Working Arrangements

• Permitting Work From Home ('WFH') arrangements for PwD employees where the nature of the work permits and the employee's condition warrants such flexibility.

• Allowing flexible working hours, adjusted shift timings, or modified work schedules on a case-by- case basis for PwD employees.

• Enabling part-time working or phased return-to-work arrangements following a disability-related absence.

All requests for reasonable accommodation shall be considered promptly and in consultation with the employee. The Company shall not deny a request for accommodation without genuine justification. Where full accommodation is not feasible. the Company shall endeavour to provide the closest practicable alternative.

8. Leave and Benefits

All PwD employees shall be entitled to the same leave and benefit entitlements as other employees under applicable Coir}iany policies and statutory provisions.

Where a PwD employee requires additional leave for medical treatment, rehabilitation, fitting or adjustment of assistive devices. or therapeutic purposes related to their disability, the Company shall consider such requests sympathetically on a case-by-case basis. Such leave shall be processed in accordance with the applicable leave policy and statutory provisions.

At present, the Company does not offer a separate medical benefits scheme specifically for disability-related conditions beyond applicable statutory entitlements. The Company shall review this position on an annual basis.

9. Training and Career Development

The Companv shall ensure that:

• All training programmes, workshops, and learning materials are made accessible to PwD employees in appropriate formats (large print, audio, digital, or other suitable formats) upon request.

• Training venues are physically accessible or, where not feasible, alternative delivery modes (such as virtual or one-on-one training) are arranged for PwD employees.

• PwD employees are provided equal access to career development opportunities, mentoring, and skills enhancement programmes.

• Sensitization programmes on disability inclusion and the provisions of the RPwD Act, 2016 are conducted periodically for all managers, HR personnel, and employees.

10. Liaison Officer

In accordance with Rule 8f1) of the Rights of Persons with Disabilities Rules. 2017. the Company hereby‘ designates the following person as the Liaison Officer for the purposes of this Policy:

Name                        Ms. Tanvi Pandit

Designation              Liaison Officer — Equal Opportunity (Disability)

Organisation            Biome Laboratories Private Limited

Address                    501 Link Rose Building, Linking Road, Santacruz, Mumbai,                                                      Maharashtra - 400054

The Liaison Officer shall be responsible for:

• Receiving, registering, and processing complaints or representations made by or on behalf of PwD employees.

• Maintaining records of PwD employees as required under Rule 8(3) of the RPwD Rules, 2017.

• Coordinating with the relevant department heads to facilitate reasonable accommodation.

• Serving as the primary point of contact for PwD-related matters with govcrnment authorities.

• Ensuring timely updating and display of this Policy as required by law.

11. Grievance Redressal Mechanism

Any employee or applicant who believes they have been subjected to discriminations, harassment. or denial of reasonable accommodation on the grounds of disability may raise a grievance as follows:

Step 1 — Informal Resolution

The aggrieved person may first bring the matter to the attention of the Liaison Officer verbally or in writing. The Liaison Officer shall attempt to resolve the grievance informally within 7 (seven) working days of receiving the complaint.

Step 2 — Formal Complaint

If the matter is not resolved informally, the aggrieved person may file a formal written complaint with the Liaison Officer. The Liaison Officer shall acknowledge receipt within 3 (three) working days and shall investigate and respond within 15 (fifteen) working days of receipt of the formal complaint.

Step 3 — Escalation

If the grievance is not resolved to the satisfaction of the aggrieved person at Step 2, the matter may be escalated to the Director (Ms. Rhea Ravi Goenka) for final resolution. The Director shall consider the matter and communicate a final decision within 15 (fifteen) working days of escalation.

The Company shall ensure that:

• All complaints are treated with strict confidentiality.

• No employee shall be victimised, penalised, or retaliated against for raising a genuine grievance under this Policy.

• The identity of the complainant shall not be disclosed without their consent.

12. Record Keeping

In accordance with Rule 8f3) of the Rights of Persons with Disabilities Rules. 2017. the Company shall maintain a register containing the following details in respect of PwD employees:

• Name of the employee

• Gender

• Address

• Nature and percentage of disability (as per disability certificate)

• Desipqnation and department

• Date of appointment

This register shall be maintained at the registered office of the Company and shall be made available for inspection by any competent authority upon request.

13.Publication and Communication o( Policy

In accordance with Rule 8f2) of the Rights of Persons with Disabilities Rules. 201 7:

• This Policy shall be published on the official website of Biome Laboratories Private Limited, if applicable.

• A copy of this Policy shall be dismayed at the registered office premises at a prominent and easily accessible location.

• This Policy shall be made available to all employees as part of the onboarding documentation and shall be communicated to all existing employees via internal communication.

• The Policy shall be available in accessible formats upon request by any PwD employee or applicant.

14. Review and Amendment

This Policy shall be reviewed  annually  by the Liasion Officer in Officer in consultation with the Director. Amendments may also be made at any time in response to:

• Changes in applicable law or regulations.

• Recommendations arising from grievance redressal proceedings.

• Changes in the Company's operations, size, or structure.

Any material amendment to this Policy shall be communicated to all employees and, where required, re- submitted to the appropriate government authority.

15. Statutory Compliance

This Policy is framed in compliance with:

• The Rights of Persons with Disabilities Act, 2016 (Act No. 49 of 2016)

• The Rights of Persons with Disabilities Rules, 2017

• Any other applicable central or state legislation relating to persons with disabilities

In the event of any conflict between this Policy and the provisions of applicable law, the provisions of the law shall prevail.

Declaration by the Authorised Signatory

I, Mrs. Rhea Ravi Goenka the undersigned being the duly authorised signatory of Biome Laboratories Private Limited, hereby confirm that this Equal Opportunity Policy for Persons with Disabilities has been approved and adopted by the Company and shall be implemented and upheld in letter and spirit.