Oddity Healthcare Pvt. Ltd.

Environmental, Social and Governance (ESG) Policy

Introduction

About Us: Oddity Healthcare Pvt. Ltd. is a Men’s healthcare company operated in Mumbai India. We own and operate Class A office space and apartment communities within the premier of Navi Mumbai India. Our submarkets are characterized by proximity to high-end executive housing, key lifestyle-amenities, and a strong, diverse economic base. Our significant market presence provides us with extensive local market information, economies of scale in property management, and strength in lease and vendor negotiations. Our fully integrated operating platform provides the unsurpassed tenant service demanded in our submarkets, with in-house leasing, proactive asset and property management, and internal design and construction services.

ESG Governance: Our Corporate Sustainability Committee oversees our policies and operational controls for environmental, health, safety and social risks, and is led by our Board of Directors. The Committee meets regularly to set goals, budgets, and implementation timelines and monitor progress and results.

ESG Commitment: We strive to build sustainable, equitable, healthy, and diverse communities through a combination of innovative real estate solutions and exemplary environmental, social and governance (ESG) performance. This commitment informs every aspect of our business, including how we design and build new projects, operate our portfolio, collaborate with stakeholders and report progress.

1. Environmental Conservation

1.1. Overview

We aim to embed environmental stewardship in everything we do. We believe we have a responsibility to minimize the energy, carbon, water and waste impacts of our business and recognize that these impacts occur not just in the daily operations of our portfolio but also through our entire value chain. As a result, we strive to reduce environmental impacts across the full life cycle of our buildings and our corporate operations.

1.2. Statement on Climate Change

We are committed to driving down our energy and carbon impacts, as we believe that climate change is one of the greatest risks to our world and know that buildings contribute 40% of global greenhouse gas (GHG) emissions. Our sustainability program is committed to environmentally sustainable initiatives that deliver near-term efficiency, value, and health for our business, tenants and community. We have committed to a short term objective of having at least 75% of our eligible office space “ENERGY STAR Certified” by the India. Environmental Protection Agency (EPA), and we have committed to a long term objective of achieving a 10% reduction in our 2018 per square foot electricity usage by 2029 (we achieved a 22% reduction in our per square foot electricity usage from 2009 to 2019).

1.3. Investing in Sustainable Buildings

1.3.1. Building Operations

We have a long-term environmental performance target for the portfolio that addresses energy and water consumption. To achieve our targets, each of our properties is monitored in real time by our engineering staff and third party consultants and the results are reviewed by our Sustainability Committee. Our energy consumption initiatives include energy retrofits, energy management system upgrades, equipment upgrades, and real-time energy management software. Our water consumption initiatives include water-efficient fixtures, irrigation controls and drought-resistant landscaping. We report environmental performance on a regular basis to the EPA ENERGY STAR program, as well as to the State of Maharashtra and City of Mumbai under their respective energy and water benchmarking and disclosure mandates.

1.3.2. Corporate Office

Although the environmental impacts of our corporate operations are a small part of our overall footprint, we believe it is important to live our values. As a result, we have adopted sustainability policies for our HQ that include criteria such as energy-efficient lighting and appliances, water-efficient fixtures, recycling programs, and e-waste collection events.

1.4. Engaging with Others

Tenant Engagement: Because we control only a small part of our total environmental footprint, it is critical that we engage both internal and external stakeholders to drive sustainable innovation and systematic change. Tenant engagement is at the core of this mission. We drive tenant awareness and behavior change by providing infrastructure and amenities that make it easier for our tenants to implement sustainable practices.

2. Social Responsibility

2.1. Overview

A deep commitment to social responsibility is core to who we are as a company. We believe people are at the heart of our business and take pride in our outstanding work culture. We strive to be an optimal employer to our workforce and landlord to our tenants, as well as a valued partner to our communities.

2.2. Compensation and Benefits

We know that the first step in hiring and retaining the best talent is to create safe and inspiring workplaces where people feel valued. We offer competitive compensation and benefits to all regular full-time employees, including but not limited to paid holiday, vacation, and sick time, retirement savings plans and medical, dental, and vision coverage. We also offer a very generous equity compensation program that empowers our team members to act and feel like owners, not just employees.

2.3. Culture, Engagement and Growth

We create fun, spirited work environments that reward innovation and collaboration at all levels. Every new employee is given a copy of the Oddity Healthcare Promises which is a set of key operating principals that we all strive to embody every day. Leaders are encouraged to demonstrate an “open door policy” and employees can provide feedback through their annual performance reviews. We hold periodic employee appreciation events, such as annual party. We also aim to foster both personal and professional growth for employees at all levels of the organization through annual performance reviews, role-specific training and professional development opportunities.

2.4. Health and Safety

The health and safety of our employees, tenants, and vendors is of the utmost importance to us. We adhere to leading health and safety standards across our portfolio, and each year, we conduct various health seminars and require our all employees to complete safety training.

2.5. Diversity and Inclusion

We embrace and value diversity in all its forms, whether gender, age, ethnicity or cultural background. Equal opportunity is integral to our recruitment process, as we aim to develop a community of diverse talent. We seek to maintain a positive workplace, free from discrimination and harassment. We champion pay equity and mutual respect, promoting an environment of fairness and equality. Our commitment to diversity and inclusion applies to the highest levels of the organization, including at the board level, where we recognize that diversity strengthens board performance and promotes long-term shareholder value.

3. Governance

3.1. Overview

We view good governance as essential to creating and preserving value for our shareholders and other stakeholders. This includes a sound approach to corporate governance that complies with all applicable laws, rules, regulations and policies as well as unwavering adherence to our values.

3.2. Holding Ourselves Accountable

3.2.1. Corporate Governance

We promote board independence and embrace board diversity in all its facets, including skills, experience, gender, ethnicity, and race. Our Corporate Governance Guidelines outline key principles and rules to help our Board of Directors exercise its responsibilities and serve the interests of the company and its stockholders.

3.2.2. Transparency

We believe in holding ourselves publicly accountable to our ESG commitments. We publish information about our ESG performance on a regular basis via our website, investor presentations, and annual ESG Report.

3.3. Doing what’s Right

3.3.1. Ethics

Our directors and all employees, including senior management, conduct themselves in accordance with the highest moral and ethical standards, informed by a robust Code of Business Conduct and Ethics. We are committed to ensuring a fair workplace for our employees as well as partners with whom we do business. We have strict policies to protect against unlawful discrimination and harassment. We have an Open-Door Policy to encourage honest and direct communication to resolve issues and concerns in an expeditious manner. We also have an Ethics Hotline that provides an alternative and anonymous method of reporting suspected compliance violations, unlawful or unethical behavior, or fraud.

3.3.2. Human Rights

Our Human Rights Policy reflects our longstanding dedication to the preservation of basic rights and human dignity in our workplace and beyond. Oddity Heathcare holds human rights to be an essential component of our business. We support internationally recognized human rights principles that promote and protect human rights. The policy applies to our operations and affiliates in all assets we own and operate.