Policies

  1. Objective

    SILA Solutions Private Limited and its subsidiaries (the “Group”) strongly believes in and is committed to do business in a fair, honest, and ethical manner, abiding by all laws applicable to the business of the Group, and taking every possible step for prevention of corrupt and unethical business practices.

  2. Purpose, Scope and Applicability

    1. The Group is committed, and continuously strives, to follow the doctrine of ‘Zero- Tolerance to Corruption and Bribery’, in all its businesses and functions in line with its ‘Values and Beliefs’. Every employee or personnel associated with the Group is bound to exhibit honest and ethical conduct in his/her official/business dealings and relationships.

    2. The Company is dedicated to ensuring compliance with all applicable laws, regulations, and contractual obligations with the highest order of governance and ethics, including those relating to bribery and corruption, to protect its image and reputation.

    3. This Anti-Bribery and Anti-Corruption Policy (this “Policy”) applies to all employees and members of the Board of Directors of the Company and its subsidiaries and it also applies to individuals who serve the Company and / or its subsidiaries on contract, subcontract, retainer, consultant or any other such basis. (“Company Personnel”)

    4. This Policy also applies to any individual or organization who has business dealings with the Company and / or its subsidiaries and includes actual and potential business associates, customers, distributors, suppliers, business contacts, agents and government bodies and officials or any other person associated with or acting on behalf of the Company / its subsidiaries (“Third party”).

    5. This Policy also applies to all other individuals, working for the Company or any of its subsidiaries, individuals acting as agents, appointed by the company, or acting on the company’s behalf in negotiating with Third Parties, etc.

  3. Definitions

    In the context of this Policy, certain relevant terms are defined as below:

    Anti-Corruption Laws: means all anti-corruption Laws of India including Prevention of Corruption Act, 1988, and all applicable anti-bribery and anti-corruption regulations and codes of practice;

    Anti-Money Laundering Laws: means the Prevention of Money Laundering Act, 2002 and any other applicable law of any relevant jurisdiction having the force of law and relating to anti-money laundering, as each such law may be amended from time to time.

    Bribery: Bribe is the form of inducement offered or promised or provided to any person in authority (private or public) for obtaining undue advantage i.e., either (i) to obtain or retain business for self or connected commercial organization, or (ii) obtain or retain advantage in the conduct of ongoing business of self or connected commercial organization. Bribe could be monetary or any other undue advantage in the form of gifts, favour, travel and entertainment expenses, facilitation payments, kickbacks, donation, offering employment, hospitality, entertainment, employment for nominees, education expenses of self/dependents, etc.

    Corruption: Corruption includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral, or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery.

    Undue advantage: means an unfair advantage, i.e., any gratification which is considered unreasonable or excessive and it includes expensive club memberships, lavish hospitality, etc.

    Gratification: Doing/receiving a favour - and it is not limited to pecuniary gratification or to gratifications estimable in money.

    Facilitation and Kickback Payments: Such type of payments are small unofficial payments made to public servants, generally in order to expedite or secure the performance of routine governmental actions.

  4. Governing Legislations

    The Company dedicates itself to uphold all the relevant laws to prevent/counter acts of bribery and corruption in the conduct of its business across jurisdictions as per the relevant Applicable Law(s)including Anti-Corruption and Anti-Money Laundering Laws that may be valid and/or enforced from time to time.

  5. Principles and Guidelines

    1. Gifts: Except in connection with and specifically pursuant to programs officially authorized by the Company, no Company Personnel shall give or accept, directly or indirectly, take or offer any money, objects of value, or favors / discounts from any person or company or entity that has or is doing or seeking business with the Company / its subsidiaries.

      Political Contributions: The Group upholds its commitment to not support any specific political party or have any political affiliation. No political contributions shall be made on behalf of the Company / its subsidiaries either directly or indirectly to any political party or for any political purpose without the prior approval of the Board of Directors. No Company Personnel shall use his job title or Company / Group affiliation in connection with political activities.

      Charitable Contributions and Sponsorships: The Company shall ensure that charitable contributions and sponsorships are not used as a vehicle for bribery. We shall publicly disclose all our charitable contributions and sponsorships and ensure that all such transactions are legal and ethical under local laws and practices.

      Facilitation Payments and Kickbacks: The Group prohibits facilitation or grease payments or kickbacks of any kind, regardless of whether such payments are permitted under applicable law. It is also our policy that we work to ensure that our agents and other intermediaries, joint ventures and consortia, contractors and suppliers do not make facilitation payments or kickbacks on our behalf.

      Offering Employment: The Company would not give any preference during recruitment to any associate or relative of a Third Party.

  6. Specific Acts Strictly Prohibited under this Policy

    No Company Personnel or any other person to whom this Policy applies, shall directly or indirectly:

    1. give, promise to give, or offer, a thing of value with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

    2. give, promise to give, or offer, a thing of value to a government official, agent or employee to facilitate or expedite a routine procedure;

    3. accept payment from a third party that you know, or suspect is offered with the expectation that it will obtain a business advantage for them;

    4. accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

    5. threaten or retaliate against another employee who has refused to commit a bribery offense or who has raised concerns under this Policy; or

    6. engage in any activity that might lead to a breach of this Policy.

    The above mentioned points are only illustrative in nature and in no way limit applicability of this Policy.

  7. Third Party Management

    To minimize the risk of doing business with a corrupt third party, the Company shall assess the third party and confirm that it is a legitimate business with a reputation for integrity. Before engagement, the Company / its subsidiaries shall subject each third party to a vetting / due diligence process.

    All Red Flags with respect to a third party that signify a heightened risk to the Company must be reported. Please refer to Annexure I.

  8. Record Keeping

    1. The Group companies shall keep financial records and have appropriate internal controls in place, which shall evidence the business reason for making payments to third parties.

    2. The Company shall declare and keep a written record of all gifts and hospitality accepted or offered, which shall be subject to managerial review.

    3. The Company shall ensure all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted and specifically record the identity of any third parties and the reason for the expenditure.

    4. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, shall be prepared and maintained with strict accuracy and completeness. No accounts shall be kept off-book to facilitate or conceal improper payments.

  9. Audit Procedures to Verify Compliance

    In line with the policy, the Group will get audits conducted by internal compliance team or through external auditors, from time to time to inter alia assure that they are effectively countering bribery and corruption.

  10. Governance

    The respective business heads or corporate function heads have overall responsibility for ensuring that their business unit or function complies with its legal and ethical obligations.

  11. Reporting of Concerns and Violations

    Every person to whom this policy applies, is encouraged to raise valid concern(s) about any bribery or corruption issue or suspicion of malpractice at the earliest possible stage. Every employee / personnel should raise concern(s) on any violation of Company’s policies with the Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) (official email addresses ([email protected] and [email protected])).

  12. Penalties for Violations

    1. Violation of this Policy by any employee of the Company shall entail appropriate action as per the relevant disciplinary policy.

    2. Commercial parties such as consultants, vendors and service providers who violate this policy are liable to be dealt with suitably under the relevant Codes/Contracts, law(s) as applicable.

  13. Business Relationship

    1. Every Company Personnel must ensure that he/she has read and understood all the terms and conditions of this Policy and shall ensure compliance thereof.

    2. In case of any doubt, employee or company personnel may obtain necessary clarification/guidance from the human resource (HR) or compliance team.

    3. Prevention, detection and reporting of bribery/corruption is the responsibility of each person working for the Company or on its behalf or under its control. Every Company Personnel is bound to ensure against commission of any act that might lead to or suggest a breach of this Policy.

    4. Every Company Personnel shall ensure that every Third Party within its work area is provided a copy of this policy and has made a formal commitment to abide by it and that any fees and commissions agreed to will be appropriate and justifiable remuneration for legitimate services rendered.

    5. In the event of any doubt on the integrity of a Third Party, it is the duty and responsibility of every Company Personnel to act and/ or notify to the Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) (official email addresses: [email protected] and [email protected]) who will in turn report the same to the Chief Executive Officer who can discuss appropriate course of action with the Board of Directors.

  14. Who is Responsible for the Policy

    The Board of Directors and/or Chief Executive Officer’s and/or their duly authorized Company Personnel/ shall have the overall responsibility for ensuring that all the provisions of this Policy are complied with by the Company and all its personnel.

    Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) or any other person duly authorized by the Board is the process owner of this Policy.

  15. Periodic Review and Evaluation

    The Company’s HR team and compliance team shall monitor the effectiveness and review the implementation of this Policy, regularly considering its suitability, adequacy and effectiveness.

  16. Waiver and Amendment of this Policy

    The Company is committed to continuously review and update its policies and procedures based on the learning. This Document is subject to appropriate modification, as and when so required. The Policy will be reviewed and amended from time to time.

  17. Annexure I – Red Flags

    The following is a list of possible red flags that may arise during the course of business dealings with third parties and which may raise concerns under various applicable anti-bribery and Anti-Corruption Laws. In such cases, the Company Personnel / employee shall report them promptly to the Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) at their official email addresses ([email protected] and [email protected]) who will in turn report the same to the Chief Executive Officer who can discuss appropriate course of action with the Board of Directors. The list below is not intended to be exhaustive and is for illustrative purposes only:

    Reputational Risk

    • The transaction or the third party is in a country known for widespread corruption, as measured by the Transparency International Corruption Perceptions Index or other similar indices.
    • The third party has a history of improper payment practices, such as prior or ongoing formal or informal investigations by law enforcement authorities or prior convictions.
    • The third party has been subject to criminal enforcement actions or civil actions for acts suggesting illegal, improper or unethical conduct.
    • The third party has a poor business reputation.
    • Allegations that the third party has made or has a propensity to make prohibited payments or facilitation payments to officials.
    • Allegations related to integrity, such as a reputation for illegal, improper, or unethical conduct.
    • The third party does not have in place an adequate compliance program or code of conduct or refuses to adopt one.
    • Other companies have terminated the third party for improper conduct.
    • Information provided about the third party or its services of principals is not verifiable by data, only anecdotally.


    Government Relationships

    • The third party has a family relationship with a foreign official or government agency.
    • The third party has a business relationship or association with a foreign official or government agency.
    • The third party previously worked in the government at a high level, or in an agency relevant to the work he/she will be performing.
    • The third party is a company with an owner, major shareholder or executive manager who is an official.
    • There is a rumour or other information that the third party has an undisclosed beneficial owner.
    • A government official suggests, requests, urges, insists, or demands that a particular party, company, or individual be selected or engaged, particularly if the official has discretionary authority over the business at issue.
    • The third party makes large or frequent political contributions.
    • The third party conducts private meetings with government officials.
    • The third party provides lavish gifts, paid travel, or hospitality to government officials.
    • The third party insists on dealing with government officials without the participation of the company.


    Insufficient Capabilities

    • The third party is in a different line of business than that for which it has been engaged.
    • The third party lacks experience or a “track record” with the product, service, field, or industry.
    • he third party does not have offices or a staff, or lacks adequate facilities or staff, to perform the work.
    • The third party has an unusual or non-existent corporate structure.
    • The address of the third party’s business is a mail drop location, virtual office, or small private office that could not hold a business the size that is claimed.
    • The third party is not expected to perform substantial work.
    • The third party has not been in business for very long or was only recently incorporated.
    • The third party has poor financial statements or credit.
    • The third party’s plan for performing the work is vague and/or suggests a reliance on contacts or relationships.


    Type and Method of Compensation

    • The third party requests an unusual advance payment.
    • The fee, commission, or volume discount provided to the third party is unusually high compared to the market rate.
    • The compensation arrangement is based on a success fee or bonus.
    • The third party offers to submit or submits inflated, inaccurate, or suspicious invoices.
    • The third party requests an invoice to reflect a higher amount than the actual price of goods provided.
    • The third party’s invoice vaguely describes the services provided.
    • The third party requests cash, cash equivalent, or bearer instrument payments.
    • The third party requests payment in a jurisdiction outside its home country that has no relationship to the transaction or the entities involved in the transaction – especially if the country is an offshore financial center.
    • The third party requests that payment be made to another third party or intermediary.
    • The third party proposes the use of shell companies.
    • The third party requests that payments be made to two or more accounts.
    • The third party shares compensation with others whose identities are not disclosed.
    • The third party requests an after-award services contract that it does not have the capacity to perform.
    • The third party requests that a donation be made to a charity.
    • The third party refuses to properly document expenses.
    • The third party pressures the company to make the payments urgently or ahead of schedule.
    • The third party requests a large up-front payment.
    • The third-party requests payment arrangements that raise local law issues, such as payment in another country’s currency.
    • The third party requests an increase in the contractually agreed upon form of payment (commission, etc.) and links the need for higher payments to the ability to successfully secure business.
  1. Objective

    SILA Solutions Private Limited (the “Company”) and its subsidiaries (collectively, “Group”) is committed to conduct its business in accordance with applicable laws, rules, regulations, highest standards of business ethics, honesty, integrity, and ethical conduct. Accordingly, we expect that our Suppliers will share and embrace the letter and spirit of our commitment to integrity.

  2. Purpose, Scope and Applicability

    1. The Group expects all Suppliers and their employees, agents and subcontractors (their representatives) to adhere to the Company’s Code of Business Conduct and Ethics while they are conducting business with and/or on behalf of the Company. All Suppliers should educate their representatives to ensure they understand and comply with this Supplier Code of Conduct (“Code”).

    2. This Code sets forth the basic requirements that the Suppliers are required to respect and adhere to when conducting business with the Group companies.

    3. This Code is applicable to all ‘Suppliers’. ‘Supplier’ here refers to firm or individual suppliers/ service providers/ vendors/ traders / agents/ consultants/ contractors/ joint venture partners/ third parties including their employees, agents, and other representatives, who have a business relationship with and provide, sell, seek to sell, any kinds of goods or services directly or indirectly to the Company or any of its subsidiaries, affiliates, divisions, or any of its clients.

  3. Legal and Regulatory Compliance

    Suppliers shall conduct their business activities in full compliance with the applicable laws and regulations while conducting business with and/or behalf of the Group companies. In addition to any obligations under the Suppliers agreement with the Company, all suppliers shall without limitation:

    1. Comply with all anti-corruption and anti-money laundering laws of India including the Prevention of Corruption Act, 1988, the Prevention of Money Laundering Act, 2002, and not make any illegal direct or indirect payments or promises of payments to any government officials for the purpose of inducing the individual to misuse his or her position to obtain or retain business;

    2. Shall not offer any gift, hospitality or entertainment for the purpose of obtaining any advantage, order or undue favour;

    3. Shall desist from any unfair or anti-competitive trade practices.

  4. Business Practice

    1. The Supplier shall take appropriate steps to safeguard and not infringe any confidential and proprietary information/intellectual property/ technology of the Group company, which comes to its knowledge during the course of its business relationship/ dealings with the Company / subsidiaries. In case of sub-contracting, sharing of confidential information should be made with the consent of the Company.

    2. Provide their services in compliance with their own applicable professional standards, including requirements established by any organizations that regulate their activities.

    3. Honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy.

    4. Create, retain and dispose of business records in full compliance with all applicable legal and regulatory requirements

    5. Avoid the appearance of or actual improprieties or conflicts of interests.

    6. Suppliers or their representatives shall not deal directly with any employee of the Group Companies whose spouse, domestic partner or other family member or relative holds a significant financial interest in the Suppliers business.

  5. Health, Safety, Environment and Sustainability

    1. Supplier shall provide its employees with a safe and healthy working environment and comply with all applicable laws and regulations regarding working conditions.

    2. Supplier shall follow all Environmental, Health and Safety and other operational policies of the Company or the controller of the facilities / premises of the relevant site while executing any work or contract at the company site.

    3. Supplier shall follow all laws of the land including laws on Environment sustainability and protection while executing any work for any of the Group companies.

  6. Employment and Human Rights

    1. The Group expects its Suppliers to share its commitment to human rights and equal opportunity in the workplace.

    2. Suppliers shall ensure that all its employees are provided equal employment opportunities, an environment conducive to their growth, free from any form of discrimination and harassment.

    3. Suppliers shall ensure compliance with minimum working hours and minimum wages prescribed by applicable laws and regulations.

    4. Supplier shall comply with all applicable local, state and national laws related to Labour and Human rights.

    5. Suppliers shall ensure that all their employees are hired on their own free will and guarantee that all their operations are free from forced, bonded, compulsory, indentured, prison labour or any other form of compulsory labour and child labour.

  7. Compliance with the Company’s Code of Business Conduct and Ethics

    1. It is the responsibility of the Supplier to ensure that its representatives understand and comply with the Company’s Code of Business Conduct and Ethics and to inform the Company (or the head of the HR or compliance function) if any situation develops that causes the Supplier to operate in violation of the Code.

    2. In addition to any other rights the Company may have under its agreement with Supplier, the Company may request the immediate removal of any representative who behaves in a manner that is unlawful or inconsistent with the Code of Business Conduct and Ethics, this Suppliers Code of Conduct or any Company policy.

  8. Third Party Representation

    The Suppliers shall not be authorized to represent the Company / Group or to use its brands without the written permission of the Company. Further, this Code of Conduct does not confer, nor shall be deemed to confer, any rights on the part of third-parties, including any third-party beneficiary rights.

  9. Cooperation with Investigations

    Suppliers are expected to cooperate with us in any investigation conducted by the Company into an allegation of inappropriate or unethical behavior involving either an employee of the Company or an employee of the Supplier where the allegation involves the Company.

  10. Reporting of an Unethical Behavior or a Violation

    Any Supplier willing to report an unethical behavior or a violation of this Code can send an email to [email protected] or [email protected].

    Send a representation in writing in a sealed envelope marked “Private and Confidential” to “Attention: Head of HR / Compliance” at below mentioned address:

    SILA Solutions Private Limited
    A-301, Floor-3rd, Plot no-249, A, Neelam
    Centre Baburao Pendharkar Marg, Glaxo,
    Worli Colony, Mumbai – 400030

    We would urge you to inform all your employees, consultants, contractors and personnel about the terms of this Code and we encourage reporting of unethical behavior in terms of the above.

  11. Suppliers Compliance Commitment

    1. The Group expects the Supplier to adhere to all applicable laws and regulations and comply with this Code in letter and spirit. It is the Supplier’s responsibility to read and understand the contents of this Code and the Company’s Code of Business Conduct and Ethics and other applicable policies.

    2. The Supplier shall maintain adequate documentation to demonstrate compliance with the principles of this Code and allow access to the Company to check compliance upon request with reasonable notice.

  12. Who is Responsible for the Policy

    The Board of Directors and/or Chief Executive Officer’s and/or their duly authorized Company Personnel/ shall have the overall responsibility for ensuring that all the provisions of this Policy are complied with by the Company and all its personnel.

    Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) or any other person duly authorized by the Board is the process owner of this Policy.

  13. Waiver and Amendment of this Policy

    The Company is committed to continuously review and update its policies and procedures based on the learning. This Document is subject to appropriate modification, as and when so required. The Policy will be reviewed from time to time.

  1. Objective

    SILA Solutions Private Limited (the “Company”) and its subsidiaries (collectively, “Group”) strongly believes in and is committed to do business in a fair, honest, and ethical manner, abiding by all laws applicable to the business of the Group. The Code of Business Conduct and Ethics (this “Code”) contains the ethics policies that everyone who does business on behalf of our Company / any Group companies must understand and follow.

  2. Purpose, Scope and Applicability

    1. The Group is committed to conducting business in an ethical manner and to act with integrity in dealing with our customers, suppliers, partners, competitors, employees, and other stakeholders.

    2. The Group is dedicated to ensuring compliance with all applicable laws, regulations, and contractual obligations with the highest order of governance and ethics.

    3. This Code applies to all employees and members of the Board of Directors of the Group companies and it also applies to individuals who serve the Group companies on contract, subcontract, retainer, consultant or any other such basis (“Company Personnel”).

    4. This Code also applies to any individual or organisation who has business dealings with the Group companies and includes actual and potential business associates, customers, distributors, suppliers, business contacts, agents and any other person associated with or acting on behalf of the Group companies. (“Third party”)

  3. Honest and Ethical Conduct

    This Code is absolute in principle, but it cannot cover every situation which may arise involving an ethical question or decision. Every Person to whom this Code applies should constantly ensure that his or her conduct is compliant with the principles and the details of this Code. In any situation where there is a doubt, the Person should discuss the situation with his/her supervisor, senior personnel or even a director until he or she is satisfied that all the relevant facts are known and have been considered and that the conduct chosen to be followed in that situation is the conduct prescribed by this Code.

    Every person to whom this Code applies owes a duty towards the Group to act at all times ethically and with the highest degree of honesty and integrity. Competitive advantage or profit must not be sought through unlawful, dishonest, or unethical business practices.

  4. Conflict of Interest

    1. Personal involvement including financial interests or dealings with competitors, clients, managers, subordinate employees or peers of SILA that has the potential to affect the employee’s ability to exercise good judgment for SILA creates an actual or potential conflict of interest. The conflicting interest need not necessarily be limited to mean financial gains and could include personal benefits like professional advancement or favours for colleagues.

    2. Every person to whom this Code applies is expected to use good judgment and avoid situations that can lead to even the appearance of a conflict. Conflicts of interest can undermine the trust others place in us and damage our reputation.

    3. As a general rule, employees must avoid conducting any Sila business with a relative (which includes a “significant other”) or a business in which a relative is associated in a key role. If such a related-party transaction is unavoidable, the employee must fully disclose the nature of the related-party transaction to his/her HR manager.

    4. While it is not the intent of the Company to unduly restrict the activities of employees on their own time, employees may not work for or receive payments for services from any business that does or seeks to do business with or is in competition with the Company.

    5. Every Person to whom this Code applies must immediately bring to the notice of Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) (official email addresses: [email protected] and [email protected]) who will in turn advise the chief executive officer of any material transaction or relationship that reasonably could be expected to give rise to a conflict of interest and the Company will not take any action to proceed with that transaction or relationship unless and until that action has been approved by the chief executive officer or the Board of Directors, if so required by the chief executive officer.

  5. Gifts, entertainment, and business courtesies

    We do not accept or provide gifts, favours, or entertainment if the intent is to influence a business decision. Except in connection with and specifically pursuant to programs officially authorized by the Company, no Company Personnel shall give or accept, directly or indirectly, take or offer any money, objects of value, or favors / discounts from any person or company or entity that has or is doing or seeking business with the Company.

    In any event, and for greater certainty, the offer, acceptance or permitting of cash gifts by any Person is prohibited.

  6. Record Keeping

    The Group companies will maintain accurate and complete financial, accounting and documentary records. Further, the Company will keep proper financial records and have appropriate internal controls in place which will evidence the business reason for making payments to, and receiving payments from, Third Parties.

  7. Confidential Information

    One of our most valuable assets is information. The unauthorized release of confidential information can cause the Company to lose a critical competitive advantage, embarrass the Company, and damage our relationships with customers and others. For these reasons, confidential information must be accessed, stored, and transmitted in a manner consistent with the Company’s policies and procedures.

    Every person to whom this Code applies must be vigilant to safeguard the Company’s confidential information as well a third parties’ confidential information that is entrusted to us. We must keep it secure, limit access to those who have a need to know in order to do their job and avoid discussion of confidential information in public areas. The obligation to preserve the confidentiality of non-public information continues even after employment ends.

  8. Protection and Proper Use of Assets

    We must act in a manner which protects the assets and resources of the Group and ensures their responsible and efficient use. All assets and resources of the Group must be used for legitimate business purposes (incidental and non-material personal usage is considered a legitimate business purpose).

    The obligation to protect the assets of the Group includes its proprietary information. Proprietary information includes, without limitation, intellectual property, such as trade secrets, patents, trademarks and copyrights, business marketing and service plans, manufacturing or service ideas, designs, databases, records, remuneration information, and any unpublished financial data and reports. Unauthorized use or distribution of this information is a violation of this Code. It may also be illegal and may result in civil or criminal penalties.

  9. Fair Dealing

    We must deal honestly, ethically, fairly and in good faith with the customers, suppliers, competitors, employees, advisors and regulators. The Company seeks competitive advantage through superior performance, but never through unlawful, dishonest or unethical business practices. The Company prohibits people from taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.

  10. Governance

    The respective business heads or corporate function heads have overall responsibility for ensuring that their business unit or corporate function complies with its legal and ethical obligations.

  11. Reporting of Concerns and Violations

    Every person to whom this policy applies, is encouraged to raise valid concern(s) about any violation of this Code to the Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) (official email addresses: [email protected] and [email protected]group.co.in)

  12. Penalties for Violations

    1. Violation of this Code by any employee of the Company shall entail appropriate action as per the relevant disciplinary policy.

    2. Commercial parties such as consultants, vendors and service providers who violate this Code are liable to be dealt with suitably under the relevant contracts, law(s) as applicable.

  13. Business Relationship

    1. Every Company Personnel must ensure that he/she has read and understood all the terms and conditions of this Code and shall ensure compliance thereof.

    2. In case of any doubt, employee or Company Personnel may obtain necessary clarification/guidance from the respective human resource department.

    3. Every Company Personnel shall ensure that every Third Party within its work area is provided a copy of this Code and have made a formal commitment to abide by it and that any fees and commissions agreed to will be appropriate and justifiable remuneration for legitimate services rendered.

    4. In the event of any doubt on the integrity of a Third Party, it is the duty and responsibility of every Company Personnel to report or discuss the same promptly with the relevant immediate reporting senior / manager, if applicable or Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) (official email addresses: [email protected] and [email protected]).

  14. Who is Responsible for this Code

    The Board of Directors and/or Chief Executive Officer’s and/or their duly authorized Company Personnel shall have the overall responsibility for ensuring that all the provisions of this Policy are complied with by the Company and all its personnel.

    Head of the HR function (Payal Sondhi) and/or the Head of the compliance function (Shivang Kagzi) or any other person duly authorized by the Board is the process owner of this Policy.

  15. Periodic Review and Evaluation

    The Company’s HR and compliance team shall monitor the effectiveness and review the implementation of this Code, regularly considering its suitability, adequacy and effectiveness.

  16. Waiver and Amendment of this Code

    The Company is committed to continuously review and update its codes, policies and procedures based on the learning. This Document is subject to appropriate modification, as and when so required. The Code will be reviewed from time to time.