BALAJI INDUSTRIES has created this Escalation Policy (“Policy”) to assist Associates with their reporting requirements under the various BALAJI INDUSTRIES Policies and to ensure proper evaluation and escalation of identified incidents or violations. For external or internal incidents or violations that are not contemplated by existing policy, procedure or guidance, BALAJI INDUSTRIES Conflicts Committee (“Committee”) has been charged with the responsibility of addressing these other issues. Upon an issue being reported, the Committee will perform a brief assessment to determine the appropriate channel and resources for further evaluation, management and remediation. Once that determination has been made, the Committee will coordinate remediation of the issue, with all relevant information, to the appropriate parties. Issues escalated according to this Policy will be treated as sensitive and will be discussed on a need-to-know basis with business unit management and BALAJI INDUSTRIES Compliance, Legal and Human Resources Departments, as appropriate.