Code of Conduct

The Code of Conduct is equally applicable to the Board of Directors as well as all the employees of the Company. The salient features of the Code of Conduct are as follows:

A. BUSINESS ETHICS

1. The company's policy is to conduct its business with honesty and integrity and
be ethical in its dealings, showing respect for the interest of all stakeholders
including its shareholders, employees, customers, suppliers and the society.
2. The company is dedicated to providing a safe and non-discriminatory
working environment for all employees.
3. The company does not support any political party or contributes funds to
groups whose activities promote political interests.
4. The company is committed to provide valuable quality IT services to its clients.
5. The Board of Directors and the Management are committed that the
company is a responsible corporate citizen and the business shall be carried
out in sustainable manner.
6. The operations shall be carried out with minimum adverse effect on the
environment and producing quality products in a healthy and safe working
environment.
7. We, as a responsible corporate citizen shall promote our role towards
betterment of the society in health and education sectors.

B. CONFLICTS OF INTEREST

1. Every employee should conduct his / her personal and business affairs in a
manner such that neither a conflict, nor the appearance of a conflict, arises
between those interests and the interests of the company.
2. The company is dedicated to providing a safe and non-discriminatory
working environment for all employees.
3. An employee should avoid any situation in which he or she, or a family
member, might profit personally (directly or indirectly), from the company’s
facilities, its products, or company’s relationships with its vendors or customers.
4. An employee should not permit himself / herself (or members of his / her
family) to be obligated (other than in the course of normal banking
relationships) to any organization or individual with whom the company has a
business relationship. However, business lunches, dinners or social invitations,
and attendance at conferences and seminars would not be considered a
violation of this Code.
5. In case an employee is offered or receives something of value which he / she
believe may be impermissible under this Code, he / she should disclose the
matter.
6. Conflict of interest shall be avoided and promptly disclosed where they exist
and guidance should be sought from superiors.

C. ACCOUNTING RECORDS, CONTROLS & STATEMENTS

1. All books, records, accounts and statements should conform to generally
accepted and applicable accounting principles and to all applicable laws
and regulations and should be maintained accurately.
2. Employees are expected to sign only documents or records which they
believe to be accurate and truthful.

D. ENVIRONMENT

1. The company is committed to carry its business in an environmentally sound
and sustainable manner and promote preservation and sustainability of the
environment.
2. All employees are required to adhere strictly to all applicable environmental
laws and regulations that impact the company’s operations.
E. REGULATORY COMPLIANCE
1. Where an employee is privy to the information, which is generally referred to
as “material inside information”, the same must be held in the strictest
confidence by the employee involved until it is publicly released.
2. The employees shall abide by the appropriate Competition Laws and shall
not enter into understandings, arrangements or agreements with competitors
which have the effect of fixing or controlling prices, dividing and allocating
markets or territories, or boycotting suppliers or customers.

F. PERSONAL CONDUCT

1. All employees should conduct themselves with the highest degree of integrity
and professionalism in the workplace or any other location while on company
business.
2. The employees shall be careful while dealing with personal or business
associates and not disclose, divulge or provide any information regarding the
company to anyone except where the same is used as a part of his / her
official obligations and as required for official purpose and shall abide by the
Closed period announced by the company from time to time and also sign a
Non- Disclosure Agreement if the need arises.

3. All employees should avoid any kind of bribery, extortion and all other forms
of corruption.
4. Employees should always be cognizant of the need to adhere strictly to all
safety policies and regulations.
5. Any legally prohibited or controlled substances if found in the possession of
any employee will be confiscated and where appropriate, turned over to the
authorities.

G. MISCELLANEOUS

1. All employees are required to comply with this code of conduct and are
personally responsible for doing so. Employees must comply with any rules set
out in this code of conduct. Breach of any principles within the code may
result in disciplinary action, such as if any employee is found to be in wanton
abuse of the code and their action cause reputational risk or damage or
financial loss to the business, may amount to gross misconduct which may
result in summary dismissal. Further, the company reserves the right to seek
redress and damages from such individuals.
2. Employees at all levels will be required to certify annually that they
understand the code and that they are in full compliance with this code. On
an annual basis, the Board monitors the findings of this certification.
3. The Company has in place a confidential “Speak Up” policy and process to
encourage the reporting of any non-compliance with this code of conduct.