Mukka Proteins Ltd

Dear Shareholders,

Your Directors have immense pleasure in presenting the 14th (Fourteenth) Annual Report on the business and operations of the Company together with the Audited Standalone and Consolidated Financial Statements for the financial year ended 31st March 2024. This being the first annual report after the Initial Public Offering (“IPO”) and listing of the equity shares of the Company on BSE Limited (“BSE”) and National Stock Exchange of India Limited (“NSE”), the Board welcomes all the public shareholders and looks forward to your faith and support in times to come.

1. FINANCIAL PERFORMANCE:

The Audited Financial Statements of your Company as on 31st March 2024, are prepared in accordance with the applicable Indian Accounting Standards (“Ind AS”) and Regulation 33 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI Listing Regulations”) and the provisions of the Companies Act, 2013 (“Act”).

Your Company's performance during the financial year as compared to the previous financial year is summarized as below:

2. STATE OF COMPANY'S AFFAIRS:

As a manufacturer of Fish Protein products, we manufacture and supply fish meal, fish oil and fish soluble paste which is an essential ingredient in the manufacturing of aqua feed (for fish and shrimp), poultry feed (for broiler and layer) and pet food (dog and cat food). Further, fish oil also finds its application in pharmaceutical products (additionally, Omega-3 pills and related products derived from fish oil are gaining importance as high nutrient and

healthy dietary supplements), soap manufacturing, leather tanneries & paint industries. We sell our products domestically and also export them to over 10 countries, including Bahrain, Bangladesh, Chile, Indonesia, Malaysia, Myanmar, Philippines, China, Saudi Arabia, South Korea, Oman, Taiwan and Vietnam. We are also amongst the first few Indian companies to have commercialised insect meal and insect oil (collectively “Insect Protein”) as an ingredient for aqua feed, animal feed and pet food.

The revenue from operations on standalone basis for FY 2023-24 stood at Rs 12,685.43 million as against Rs 10,663.98 million for FY 2022-23, registering a growth of 18.96%. Whereas the profits after tax for FY 2023-24 stood at Rs 627.56 million as against Rs 394.23 million for FY 2022-23.

The revenue from operations on consolidated basis for FY 2023-24 stood at Rs 13,798.29 million as against Rs 11,771.22 million for FY 2022-23, registering a growth of 17.22%. Whereas the profit after tax for FY 202324 stood at Rs 743.05 million as against Rs 475.25 million for FY 2022-23.

During the year under review, there is no change in nature of the business of the Company. The affairs of the Company are conducted in accordance with the accepted business practices and within the purview of the applicable legislations.

3. DIVIDEND:

Pursuant to Regulation 43A of the SEBI Listing Regulations, the Board of Directors have formulated the Dividend Distribution Policy, setting out the broad principles for guiding the Board and the management in matters relating to declaration and distribution of dividend. The Dividend Distribution Policy, in terms of Regulation 43A of the Listing Regulations, can be accessed on the Company's website at https://www.mukkaproteins.com/images/Dividend-Distribution-Policy.pdf. To strengthen the financial position of the Company and to augment working capital the Board does not recommend any dividend for the FY 2023-24.

4. TRANSFER TO RESERVES:

During the period under review, no amount has been transferred to the General Reserve of the Company.

5. TRANSFER OF UNCLAIMED DIVIDEND TO INVESTOR EDUCATION AND PROTECTION FUND:

During the financial year under review, no amount was required to be transferred to the Investor Education and Protection Fund by the Company.

6. CHANGES IN THE NATURE OF BUSINESS:

During the financial year under review there was no change in the nature of business of the Company.

7. INITIAL PUBLIC OFFERING AND LISTING:

During the period under review, the Company successfully completed its Initial Public Offering (IPO) of 8,00,00,000 equity shares of face value of Rs 1/- each for cash at an issue price of Rs 28/- per equity share (including share premium of Rs 27/- per equity share) aggregating to Rs 2,24,00,00,000 (“the issue”) and got listed on BSE Limited (“BSE”) and National Stock Exchange of India Limited (“NSE”) on 7th March 2024. The proceeds from the issue have been earmarked for funding working capital requirements of our Company, investment in our Associate, viz. Ento Proteins Private Limited, for funding its working capital requirements and other general corporate purposes. The IPO proceeds have bolstered an already strong capital structure even further, significantly enhanced the Company's financial flexibility, and accelerated the Company's ambitious growth plans.

The issue was open to the public from 29th February 2024 and closed on 4th March 2024 and received an overwhelming response, was over-subscribed by 135.78 times (overall). The Anchor Investors Bid/Issue period was one working day prior to the Bid/Issue Opening Date, i.e. 28th February 2024. The allotment was finalized on 5th March 2024. The equity shares of the Company were listed on BSE Limited (“BSE”) and National Stock Exchange of India Limited (“NSE”) w.e.f. 7th March 2024.

Cameo Corporate Services Limited is the Registrar and Share Transfer Agent of the Company.

The annual listing fees for the financial year 2023-24 have been paid to the Stock Exchanges.

8. MATERIAL CHANGES AND COMMITMENTS:

There have been no material changes and commitments, which affect the financial position of the Company which have occurred between the end of the financial year to which the financial statements relate and the date of this annual report.

9. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION, FOREIGN EXCHANGE EARNINGS AND OUTGO:

The information on conservation of energy, technology absorption and foreign exchange earnings and outgo stipulated under Section 134(3)(m) of the Act, read along with Rule 8(3) of the Companies (Accounts) Rules, 2014, is annexed as Annexure-A to this report.

10. PARTICULARS OF EMPLOYEES AND RELATED DISCLOSURES:

Your Company had 331 employees (on a standalone basis) as of 31st March 2024.

The disclosure pertaining to remuneration and other details as required under Section 197(12) of the Act read with Rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 is annexed as Annexure-B to this Report.

The disclosure under Rules 5(2) and 5(3) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 forms a part of this Report. However, as per first proviso to Section 136(1) of the Act and second proviso of Rule 5(3) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 the Report and Financial Statements are being sent to the Members of the Company excluding the said statement. Any Member interested in obtaining a copy of the said statement may write to the Company Secretary at the Registered Office of the Company.

11. DIRECTORS' RESPONSIBILITY STATEMENT:

Pursuant to the provisions of Section 134(5) of the Act, the Board, to the best of their knowledge and based on the information and explanations received from the management of your Company, confirms that:

a.in the preparation of the Annual Financial Statements, the applicable accounting standards have been followed along with proper explanation and there are no material departures;

b.they have selected such accounting policies and applied them consistently and judgements and estimates that are reasonable and prudent so as to give a true and fair view of the state of affairs of the Company at the end of the financial year and of the profit of the Company for that period;

c.proper and sufficient care has been taken for the maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities;

d.the annual financial statements have been prepared on a going concern basis;

e.they have laid down internal financial controls to be followed by the Company and that such internal financial controls are adequate and operating effectively; and

f. proper systems have been devised to ensure compliance with the provisions of all applicable laws and that such systems are adequate and operating effectively.

12. DIRECTORS AND KEY MANAGERIAL PERSONNEL:

As of 31st March 2024, your Company's Board had 8 (Eight) members comprising of 3 (Three) Executive Directors, 2 (Two) Non-Executive Non-Independent Directors including one Woman Director and 3 (Three) NonExecutive Independent Directors. The details of Board and Committee composition, tenure of directors, and other details are available in the Corporate Governance Report, which forms part of this Annual Report.

In the opinion of the Board, all Independent Directors possess requisite qualifications, experience, expertise, proficiency and hold high standards of integrity for the purpose of Rule 8(5)(iiia) of the Companies (Accounts) Rules, 2014. In terms of the requirement of the Listing Regulations, the Board has identified core skills, expertise, and competencies of the Directors in context of your Company's business for effective functioning. The key skills, expertise and core competencies of the Board of Directors are detailed in the Corporate Governance Report, which forms part of this Annual Report.

Appointment/Cessation/Change in Designation of Directors:

During the year under review, following changes took place in the Directorships:

a) Appointment:

During the year under review, there is no change in the composition of the Board of Directors of your Company.

b) Re-appointment of Director(s) retiring by rotation:

In accordance with the provisions of Section 152 of the Act, read with rules made thereunder and Articles of Association of your Company, Mr. Kalandan Mohammad Arif (DIN: 03020564) and Mrs. Umaiyya Banu (DIN: 03051040) are liable to retire by rotation at the ensuing Annual General Meeting (AGM) and being eligible, offers themselves for re-appointment.

The Board recommends the re-appointment of Mr. Kalandan Mohammad Arif (DIN: 03020564) and Mrs. Umaiyya Banu (DIN: 03051040) as Directors, for your approval. Brief details, as required under Secretarial Standard-2 and Regulation 36(3) of SEBI Listing Regulations, are provided in the Notice of the ensuing AGM.

c) Resignation/Cessation:

During the year under review, there has been no cessation or resignation of any Director.

Board Diversity:

Your Company recognises the benefits of having a diverse Board and sees increasing diversity at Board level as an essential element in maintaining a competitive advantage. Your Company believes that a truly diverse Board will leverage differences in thought, perspective, knowledge, skill, regional and industry experience, cultural and geographical background, age, race and gender, which will ensure that the Company retains its competitive advantage.

Your Company believes that a diverse Board contribute towards driving business results, make corporate governance more effective, enhance quality and responsible decision-making capability, ensure sustainable development and enhance the reputation of the Company.

The Policy on Board Diversity adopted by the Board, in compliance with Regulation 19(4) read with Part D of the Schedule II of SEBI Listing Regulations, sets out its approach to diversity. The Policy on Board Diversity is available on the website of the Company at https://www.mukkaproteins.com/images/Policy-on-Board- Diversitv.pdf.

Declaration from Independent Directors:

Your Company has received declarations from all the Independent Directors confirming that they meet the criteria of independence as prescribed under the provisions of Companies Act, 2013 read with the Schedules and Rules issued thereunder as well as SEBI Listing Regulations. The Independent Directors have affirmed compliance to the Code of Conduct for Independent Directors as prescribed in Schedule IV to the Act.

In the opinion of the Board, Independent Directors fulfil the conditions specified in Companies Act, 2013 read with the Schedules and Rules issued thereunder as well as SEBI Listing Regulations and are independent from Management. The Independent Directors are persons of high repute, integrity and possess the relevant expertise and experience (including proficiency in terms of Section 150(1) of the Act and applicable rules thereunder) in their respective fields. The Independent Directors have also confirmed that they have registered their names in the Independent Directors' databank with the Indian Institute of Corporate Affairs.

None of the Directors of the Company are disqualified as per the provisions of Section 164 of the Act. The Directors of the Company have made necessary disclosures under Section 184 and other relevant provisions of the Act.

Key Managerial Personnel (“KMP”):

As on the date of this report, the following are Key Managerial Personnel (“KMP”) of your Company as per Sections 2(51) and 203 of the Act:

13. BOARD EVALUATION:

The annual evaluation process of the Board of Directors, individual Directors and Committees was conducted in accordance with the provision of the Companies Act, 2013 and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

The Board evaluated its performance after seeking inputs from all the Directors on the basis of criteria such as the Board composition and structure, effectiveness of Board processes, information and functioning, etc. The performance of the Committees was evaluated by the Board after seeking inputs from the committee members on the basis of criteria such as the composition of committees, effectiveness of committee meetings, etc. The above criteria are broadly based on the Guidance Note on Board Evaluation issued by the Securities and Exchange Board of India.

In a separate meeting of Independent Directors, performance of Non-Independent Directors and the Board as a whole was evaluated. Additionally, they also evaluated the Chairman of the Board, taking into account the views of Executive and Non-Executive Directors in the aforesaid Meeting. The Board also assessed the quality, quantity and timeliness of flow of information between the Company Management and the Board that is necessary for the Board to effectively and reasonably perform their duties. The above evaluations were then discussed in the Board Meeting and performance evaluation of Independent Directors was done by the entire Board, excluding the Independent Director being evaluated.

14. FAMILIARIZATION PROGRAMME FOR INDEPENDENT DIRECTORS:

The Company has adopted a framework, duly approved by the Board of Directors for Familiarization Programmes for Independent Directors. The objective of the framework is to ensure that the Independent Directors have a greater insight into the business of the Company, enabling them to contribute more effectively to decision making.

The details of Familiarization Programme have been uploaded on the website of the Company at https://www. mukkaproteins .com/ images/F amiliarization-Programme-for-Independent-Directors .pdf.

15. SUBSIDIARIES, ASSOCIATES AND JOINT VENTURES:

As on 31st March 2024, your Company had following subsidiaries, associates and joint ventures:

A. Subsidiaries:

1) Haris Marine Products Private Limited

2) Atlantic Marine Products Private Limited

3) Ocean Aquatic Proteins LLC, Oman (Foreign Subsidiary)

B. Associates:

1) Ento Proteins Private Limited

2) Ocean Proteins Private Limited

3) MSFI (Bangladesh) Limited*

*The Board of Directors in their meeting held on 13th August 2024 have approved the sale of investment held by the Company in MSFI (Bangladesh) Limited. However, the said disinvestment is subject to necessary approvals as required under the Foreign Exchange Management Act, 1999.

C. Joint Ventures: Nil

There has been no change in the nature of business of these subsidiaries and associates. Your Company does not have any material subsidiaries pursuant to the provisions of Regulation 16(1) (c) of the SEBI Listing Regulations.

A report on the performance and financial position of each of the Subsidiaries, Associates and Joint Ventures and their contribution to the overall performance of the company for the financial year ended 31st March 2024 in prescribed Form AOC - 1 as per the Companies Act, 2013 is set out in Annexure- C and forms an integral part of this Report.

Further, pursuant to the provisions of Section 136 of the Act, the financial statements of the Company, consolidated financial statements along with relevant documents and separate audited financial statements in respect of subsidiaries are available on the website of the company at https://www.mukkaproteins.com/Finacials.php.

The Company has formulated a policy for determining material subsidiaries. The said policy is also available on the website of the Company at https://www.mukkaproteins.com/images/Policy-on-Material-Subsidiaries-and- Governance-of-Subsidiaries.pdf.

During the period under review, no Company has become or ceased to be a subsidiary, joint venture or associate of the Company.

Further, below is the brief note on the performance of the Subsidiaries and Associates:

Ocean Aquatic Proteins LLC, Oman: The company has recorded a sales Turnover of Rs 1,280.37 million during the year under review, as against the sales Turnover of Rs 1,159.56 million achieved during the previous year. The company has recorded a Profit After Tax of Rs 78.24 million during the year under review, as against the Profit After Tax of Rs 29.19 million during the previous year.

Haris Marine Products Private Limited: The company has recorded a sales Turnover of Rs 8.01 million during the year under review, as against the sales Turnover of Rs 512.74 million achieved during the previous year. The company has recorded a Profit After Tax of Rs 9.52 million during the year under review, as against the Profit After Tax of Rs 5.66 million during the previous year.

Atlantic Marine Products Private Limited: The company has recorded a sales Turnover of Rs 968.39 million during the year under review, as against the sales Turnover of Rs 961.81 million achieved during the previous year. The company has recorded a Profit After Tax of Rs 26.04 million during the year under review, as against the Profit After Tax of Rs 54.17 million during the previous year.

Ento Proteins Private Limited: The company has recorded a sales Turnover of Rs 64.44 million during the year under review, as against the sales Turnover of Rs 47.22 million achieved during the previous year. The company has recorded a Profit After Tax of Rs 9.93 million during the year under review, as against the Profit After Tax of Rs 6.98 million during the previous year.

Ocean Proteins Private Limited: The company has recorded a sales Turnover ofRs 282.35 million during the year under review, as against the sales Turnover of Rs 267.47 million achieved during the previous year. The company has recorded a Net Loss ofRs 15.77 million during the year under review, as against the Net Loss ofRs 57.04 million during the previous year.

MSFI (Bangladesh) Limited: MSFI (Bangladesh) Limited is not actively engaged in any business operations over the past few years and accordingly, the Board of Directors in their meeting held on 13th August 2024 have approved the sale of investment held by the Company in MSFI (Bangladesh) Limited subject to necessary approvals as required under the Foreign Exchange Management Act, 1999.

16. CONSOLIDATED FINANCIAL STATEMENTS:

The Consolidated Financial Statements required pursuant to Section 129(3) of the Companies Act, 2013 read with Rule 6 of the Companies (Accounts) Rule, 2014 have been prepared in accordance with the relevant accounting standards as per the Companies (Indian Accounting Standard) Rules, 2015. The audited consolidated financial statement is provided along with the Standalone Financial Statement.

17. PUBLIC DEPOSITS:

The Company has not accepted any deposits from public and as such, no amount on account of principal or interest on deposits from public was outstanding during the period under review.

18. MEETINGS OF THE BOARD:

The Board met 14 (Fourteen) times during the year under review. The intervening gap between the meetings did not exceed 120 days, as prescribed under the Act and the SEBI Listing Regulations. The details of the Board meetings and the attendance of the Directors are provided in the Corporate Governance Report, which forms part of this Annual Report.

19. INDEPENDENT DIRECTORS' MEETING:

During the year under review a separate meeting of the Independent Directors of the Company was held on 28th March 2024, without the presence of Non-Independent Directors and members of Management. The Independent Directors reviewed the performance of Non-Independent Directors and the Board as a whole, performance of Chairperson of the Company and assessed the quality, quantity and timeliness of flow of information between the Company management and the Board.

20. COMMITTEES OF THE BOARD:

As required under the Act and the SEBI Listing Regulations, your Company has constituted 5 (Five) committees of the Board, namely:

1) Audit Committee;

2) Nomination and Remuneration Committee;

3) Stakeholders' Relationship Committee;

4) Corporate Social Responsibility Committee; and

5) IPO Committee.

A detailed note on the composition of the Board and its committees, including its terms of reference, is provided in the Corporate Governance Report, which forms part of this Annual Report. The composition and terms of reference of all the Statutory Committee(s) of the Board of Directors of the Company is in line with the provisions of the Act and SEBI Listing Regulations.

21. AUDIT COMMITTEE:

The composition of Audit Committee has been detailed in the Corporate Governance Report, forming part of this Annual Report.

All the recommendations made by the Audit Committee were accepted by the Board of Directors of the Company. The Audit Committee of the Company reviews the reports to be submitted with the Board of Directors with respect to auditing and accounting matters. It also supervises the Company's internal control and financial reporting process and vigil mechanism.

During the period under review the Audit Committee met 7 (Seven) times on 1st May 2023, 7th June 2023, 15th June 2023, 29th September 2023, 23rd December 2023, 16th February 2024 and 28th March 2024.

22. PARTICULARS OF LOANS, GUARANTEES AND INVESTMENTS:

The particulars of loans given, investments made and guarantees given and securities provided by the Company under Section 186 of the Act during the financial year 2023-24 are disclosed in the notes to Financial Statements which forms part of this report.

23. PARTICULARS OF CONTRACTS AND ARRANGEMENTS WITH RELATED PARTIES:

The Company has in place a robust process for approval of related party transactions and on dealing with related parties. All transactions with related parties were reviewed and approved by the Audit Committee and are in accordance with the Policy on Related Party Transactions, formulated and adopted by the Board of Directors.

In compliance with the requirements of the Companies Act, 2013 and SEBI Listing Regulations, your Company has formulated a Policy on Related Party Transactions which is also available on Company's website at https://www.mukkaproteins.com/images/Related-Partv-Transactions-Policy.pdf.

The Policy intends to ensure that proper reporting, approval and disclosure processes are in place for all transactions between the Company and its Related Parties. All Related Party Transactions are placed before the Audit Committee for review and approval. Prior omnibus approval is obtained for Related Party Transactions which are of repetitive nature and / or entered in the ordinary course of business and are at arm's length basis.

All related party transactions entered during the year were in ordinary course of the business and at an arm's length basis. No Material Related Party Transaction was entered during the year by your Company. Accordingly, the disclosure of Related Party Transactions as required under Section 134(3) (h) of the Companies Act, 2013 in Form AOC-2 is not applicable.

24. NOMINATION AND REMUNERATION POLICY:

In compliance with the provisions of Section 178 of the Companies Act, 2013, the Board has, framed a policy for selection and appointment of Directors, Key Managerial Personnel, Senior Management and their remuneration.

The salient features of the Policy are:

i. To formulate the criteria for determining qualification, competencies, positive attributes and independence for appointment of Directors (Executive and Non-executive) and persons who may be appointed in Senior Management, Key Managerial positions and recommend to the Board policies relating to the remuneration for the Directors, Key Managerial Personnel, Senior Management and other employees;

ii. To lay down criteria for appointment, removal of Directors, Key Managerial Personnel and Senior Management;

iii. To recommend the remuneration of Directors, Key Managerial Personnel (KMP), and Senior Management of the Company involves a balance between fixed and incentive pay reflecting short and long-term performance objectives appropriate to the working of the Company and its goals; and

iv. To specify the manner for effective evaluation of performance of Board, its committees and individual directors and review its implementation and compliance.

During the year under review, there has been no change to the Policy.

The Nomination and Remuneration Policy of the Company is available on the website of the Company at https://www.mukkaproteins.com/images/Nomination-and-%20-Remuneration-%20Policy.pdf.

25. SUCCESSION PLANNING:

The Company believes that succession planning for the Board members and Senior Management is very important for creating a robust future for the Company. The Nomination and Remuneration Committee plays a pivotal role in identifying successors to the members of the Board, Key Managerial Personnel and Senior Management and invests substantial time with the Managing Director on succession planning.

The Company has a succession planning policy in place which intends to achieve the following:

i. To identify and nominate suitable candidates for the Board's approval to fill the vacancies which arises in the Board of Directors from time to time.

ii. To identify the competency requirements of critical and key positions in the Company, assess potential candidates and develop required competency through planned development and learning initiatives.

iii. To identify the key job incumbents in Senior Managerial positions and recommend whether the concerned individual be granted an extension in term/service or be replaced with an identified internal or external candidate or recruit other suitable candidate(s).

iv. To ensure the systematic and long-term development of individuals in the senior management level to replace the individuals when the need arises due to deaths, disabilities, retirements and other unexpected occurrence.

26. CORPORATE SOCIAL RESPONSIBILITY:

In terms of the provisions of Section 135 of the Act, read with Companies (Corporate Social Responsibility Policy) Rules, 2014, (as amended) the Board has constituted a Corporate Social Responsibility (“CSR”) Committee. The details of the CSR Committee are provided in the Corporate Governance Report, which forms part of this Annual Report. The CSR policy is available on the website of your Company at

https://www.mukkaproteins.com/ima ges/Mukka-CSR-Policy.pdf.

Pursuant to the provisions of Sections 134(3)(a) and 92(3) of the Companies Act, 2013, the draft Annual Return for the financial year ended 31st March 2024, is av ailable on the website of the Company at

The Company has adopted a Code of Conduct to regulate, monitor and report trading by designated persons and their immediate relatives as per the requirements under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015. The Code, inter alia, lays down the procedures to be followed by designated persons while trading/dealing in Company's shares and sharing Unpublished Price Sensitive Information (“UPSI”). The Code covers Company's obligation to maintain a digital database, mechanism for prevention of insider trading and handling of UPSI, and the process to familiarize with the sensitivity of UPSI. Further, it also includes code for practices and procedures for fair disclosure of unpublished price sensitive information which has been made available on the Company's website at https://www.mukkaproteins.com/images/Code-for%20- Fair-Disclosure-of- Unpublished-Price%20-Sensitive-Information.pdf.

The Company is committed to providing a safe and conducive work environment to all its employees and associates. The Company has a policy on Prevention of Sexual Harassment (POSH) at Workplace in place, which is available on the Company's website at https://www.mukkaproteins.com/images/Policy-on%20-Prevention-of- %20Sexual%20-Harassment.pdf. The Company has constituted an Internal Complaints Committee as per the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. During the year under review, no complaint was received under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

The policy ensures that strict confidentiality is maintained whilst dealing with concerns and also that no discrimination is made against any person. The Whistle Blower Policy and Vigil Mechanism is available on the Company's website at https://www.mukkaproteins.com/images/Whistle-Blower-%20Policy.pdf.