3. Professional Conduct

All employees must maintain high standards of professionalism in all work-related activities. Examples of unprofessional behavior include but are not limited to:

• Consumption of alcohol or illegal substances during work hours.
• Gambling, fighting, or disruptive conduct.
• Use of profane, offensive, or discriminatory language.
• Inappropriate displays, postings, or use of workplace materials (physical or digital).
• Misuse of Company property, such as unauthorized use of computers or tools.

4. Equal Opportunity, Diversity, and Anti-Harassment

The Company promotes an inclusive and diverse work environment. Discrimination, harassment, or retaliation based on race, gender, religion, disability, age, sexual orientation, or any other protected characteristic is strictly prohibited.

Sexual harassment includes, but is not limited to:

• Unwelcome sexual advances or requests.
• Inappropriate touching, comments, or jokes.
• Displaying sexually explicit or suggestive materials.
• Storing or posting offensive content in the workspace or on devices.

Violations will lead to disciplinary action, including possible termination.

5. Employment Practices and Welfare

• Compensation and Benefits: The Company adheres to and often exceeds minimum wage and employment standards. Employees enjoy competitive remuneration, health coverage, flexible work hours, and well-being initiatives.
• Workplace Safety: Everyone is responsible for adhering to safety protocols and reporting hazards.
• Work-Life Balance: Flexible schedules and mental wellness programs are provided to promote a healthy work-life balance.

6. Conflicts of Interest

Employees must avoid situations where personal interests interfere with the interests of the Company. This includes:

• Ownership in competitors, vendors, or clients.
• Personal relationships that may affect objectivity.
• Outside employment that interferes with job responsibilities.

All potential conflicts must be promptly disclosed to HR or management.

7. External Engagements and Civic Activities

The Company encourages involvement in civic, religious, and charitable activities, provided they do not:

• Interfere with job duties.
• Present a conflict of interest.
• Involve unauthorized use of Company resources or name.

8. Relationships with Clients, Vendors, and Partners

All business relationships must be conducted impartially, fairly, and ethically. Employees must avoid:

• Receiving or offering gifts that may influence decisions.
• Favoritism or preferential treatment.
• Investing in or engaging with vendors where personal benefit is involved.

9. Gifts, Hospitality, and Entertainment

Acceptable:

• Nominal gifts that are customary in business relationships.
• Nominal gifts that are customary in business relationships.

Unacceptable:

• Lavish gifts or entertainment.
• Anything offered with expectation of favor or preferential treatment.

All non-trivial gifts must be disclosed to management.

10. Bribery, Kickbacks, and Corruption

• Strict prohibition on giving or accepting bribes, kickbacks, or unlawful payments.
• No facilitation payments or secret commissions.

• Compliance with anti-corruption laws including FCPA and local equivalents.

Violations may result in immediate termination and legal consequences.

11. Use of Company Resources

• Use Company resources (funds, tools, vehicles, software) only for authorized purposes.
• Protect against waste, misuse, loss, or theft.

• Do not loan, donate, or sell Company assets without written approval.
• Ensure data security and system access policies are followed.
• Personal use of Company assets (e.g., laptops, internet) must be minimal and not interfere with business operations.

12. Financial Integrity and Reporting

• Ensure accuracy and completeness in all accounting records.
• No falsification of time sheets, expense reports, or financial statements.

• Cooperate fully with internal and external audits.

13. Communication and Representation

• Speak on behalf of the Company only if authorized.
• Avoid use of Company assets, stationery, or branding for personal or political purposes.

• All official communications must be respectful, accurate, and lawful.

14. Data Privacy and Confidentiality

• Collect, store, and use personal data lawfully and responsibly.
• Limit data access to authorized personnel.

• Ensure physical and digital safeguards are in place.
• Confidentiality obligations extend to information covered by NDAs and contracts.
• Do not disclose confidential information unless legally required or contractually permitted.

Comply with applicable data protection regulations (e.g., GDPR, IT Act, DPDP Bill).

15. Digital Conduct and Cybersecurity

• Use Company systems responsibly and only for professional use.
• Do not download unauthorized software or content.

• Report cyber threats, data breaches, or phishing attempts immediately.
• Avoid storing or transmitting inappropriate, offensive, or non-business-related materials on Company systems.
• Social media behavior should reflect Company values and must not disclose sensitive information.

16. International Compliance

Employees engaged in cross-border operations must comply with:

• Trade controls and sanctions.
• Export/import laws.

• Anti-money laundering regulations.
• Local labor, data protection, and environmental laws where applicable.

17. Environmental and Social Responsibility

The Company is committed to sustainability and ethical sourcing. Employees are expected to:

• Minimize waste and energy consumption.
• Support green initiatives.

• Treat communities and stakeholders with respect.

18. Reporting Violations and Whistleblower Protection

• Report any suspected violations to HR, Legal, or the designated Ethics Committee.
• Anonymous reporting mechanisms may be provided.

• Retaliation against whistleblowers is strictly prohibited.

All concerns will be investigated confidentially and objectively.

19. Enforcement and Disciplinary Action

Violations of this Code may result in:

• Verbal or written warnings.
• Suspension or demotion.

• Termination.
• Referral to law enforcement where appropriate.

20. Administration and Acknowledgment

This Code is administered by the Compliance and HR departments. It is reviewed annually and updated as necessary.