CODE OF CONDUCT

Hinduja Group has a Code of Conduct for its employees. As a part of Hinduja Group, you are
expected to strictly adhere to the Code of Conduct. Any breach will be viewed seriously and may
lead to termination on the basis of the conduct.

 Conflict of Interest and Concurrent Employment –

o During your employment tenure, your interests will be focussed on the success of the Group
and its growth only. You will not engage in activities and advance any personal interests at
the expense of the company’s interests.
o You will not let a conflict of interest situation arise during your employment with the
Company.
o You will not (without the requisite officially written approval of the company) undertake or
accept employment or a position or responsibility (such as Director) with any other
Company, nor provide freelance services to anyone, with or without remuneration.
o You will not use the Company’s resources, partnerships and business contacts to make any
personal advancements.
o Neither your spouse nor any family member will use the name of the Group or build
partnerships with parties who are doing business with the Company.
o You will disclose any such activities or personal interests that may lead to conflict of interest
or concurrent employment.

 Maintaining Confidentiality and Information Security -

o Neither you nor your family members will divulge or use or derive any benefit, or assist
others to derive benefit, from access to and possession of, the information about the
Company, its Group companies and/or clients, suppliers, employees that are not in the
public domain, and constitute sensitive insider information.
o You will also respect, observe and ensure integrity and confidentiality related to the other
Companies belonging to Hinduja Group, their patents, intellectual property rights,
trademarks and inventions and strictly observe the practice of non-disclosure.
 Use and Protection of Hinduja Group’s Assets and Resources
o You have access to a variety of assets belonging to Hinduja Group, due to your employment
with the Company. You are requested to use these assets and resources judiciously and
protect them from damage / misplacement. These include all tangible (equipment and
machinery, systems, facilities, materials, etc.) as well as intangible (Information Technology,
systems, proprietary information, intellectual property and relationships with customers and
suppliers etc.) assets.
o You are requested to be alert about any incident related to theft / damage / misplacement /
misuse of the Company’s assets and / or resources. You must report all such incidences
promptly to your Manager and Head of HR.

 Computer, Email, Internet and Intranet Usage

o These are company provided resources for official purpose only. They belong to the
Company and are issued to you, to enable you to deliver results.
o You will at all times protect the computer and the information stored on the computer. You
will not use passwords, access files or retrieve stored communication without prior
authorization. You will require prior approval, for movement of the computer, or installation
of any software on the computer.
o The company purchases and licences the use of various software for business purposes. You
must use the software according to the business requirement only. You are prohibited from
illegally duplicating or installing software or distributing / using unlicensed software.
o You will at all times, follow the IT guidelines to maintain your computer and protect the files,
by taking regular back-ups. Any loss of computers, especially notebooks or handheld devices
including Blackberry, DVDs, USB storage device, must be reported immediately to your
Reporting Head, Head of IT and Head of HR. In case of a major loss which is a serious matter,
the Company reserves the right to recover any losses it may face, due to the loss.
o You will maintain password security and ensure that you do not share / disclose your
passwords. Passwords are intended to protect access, and you will ensure that there are no
incidences of unauthorized access to data / information from your password. Change the
password regularly. Your passwords will be disabled upon your transfer / exit. Also, your
access rights will be changed, based on the change in role. The earlier rights can be revoked
by the company.
o Your email address is mainly for official communication only. You are requested to use your
discretion and professionalism, when writing and receiving emails. Email is a Company Asset,
and any misuse such as carrying/receiving illegal messages; pornography or undesirable
communication etc. will lead to disciplinary action and suspension of the email facility.
o The Internet is provided to you, to facilitate your access for business information. It must be
used judiciously, and you must follow the laws and regulations of the country. Any
downloading, possession, distribution of a copyright work or inappropriate material related
 to sexual content, gambling or anything that advocates intolerance or prohibited sites like
links to extremist groups, is not permitted. You are responsible to ensure that your
information and communication system is appropriate.

 Workplace Security
o You will maintain the workplace security, and not carry any unauthorised or illegal arms or
equipment to the office.
o If you are expecting a visitor, it is your responsibility to inform the reception / security desk.
Always escort the visitor, when in the office premises. Unescorted visitors can pose a threat
to the workplace security, including access to confidential data. It is your responsibility to
protect the workplace from any security lapses.

 Smoking at Work
o No smoking is allowed at any time, on Company premises.

 Substance Abuse
o You will be committed to maintain a substance abuse-free work environment by keeping
away from illegal manufacture, distribution, possession and / or use of such elements. The
founders respect your freedom, but request you to abstain from tobacco, liquor and drugs.
o You will not report to work under possession or influence of liquor or illegal drugs. You will
not be involved in any sale / purchase / transfer of any liquor or illegal drugs, during or
after work time. In case the Management observes the same, it may request you to
undergo tests for substance abuse. The Company reserves the right to inspect and / or
search the Company property you are using, for any unlawful or unauthorized possession
of such substances. You will have to cooperate with the Management.
o In case you observe substance abuse within the organization, you are requested to report
to the Head of HR or Divisional Head immediately.

 Bribes, Gifts and Entertainment

o As a part of this code, you will not make or receive any illegal payments, remuneration, gifts
or donations or comparable gifts / benefits that are intended or perceived to obtain
uncompetitive favours for the conduct of business.
o In case of receipt of such an offer, you are expected to surrender the same to the
Management immediately.
o However, with the Management’s approval and full disclosure, you may accept and offer
nominal customary seasonal gifts, which are commemorative in nature.
 o Gifts in the form of entertainment through free / discounted travel /food / stay for self and /
or family, any gifts for family members from parties conducting business with the Company,
are not permitted under this code of conduct.

 Equal Opportunities Employer; Harassment including sexual harassment

o Hinduja Group believes in equal opportunity employment irrespective of race, caste,
religion, colour, gender, nationality, ancestry, age, ethnic origin, marital status, sexual
orientation or disability. You will comply with the equal opportunity status, and will not
discriminate between people, based on their background.
o You will ensure that the work environment is free of discrimination (by treating everyone
with dignity) and free of all forms of harassment (whether physical, verbal or
psychological).
o Any sexual harassment, through unwelcome sexually oriented conduct including sexual
advances, either verbal or through gestures or through use of sexually suggestive material;
obscene remarks / jokes; comments on appearance; demands for sexual favours; threats;
physical contact (which are avoidable) will be viewed as a serious offence.
o In case you observe such an incident, or are subjected to any such harassment, you are
requested to report the same to the Head of HR immediately, for further action.

 National Interest and Compliance with Law

o Hinduja Group is committed to the benefit of the economic and social development of the
countries in which it operates. You will not undertake any activity / project during the
employment with Hinduja Group, which is detrimental to the wider interests of the nation.
o You will abide by Management practices, business conduct and laws of the land, which will
benefit the country, locality and the community at large. Compliance with the law is of
utmost importance, as a representative of Hinduja Group.
o You will respect diversity in culture, customs, traditions and gender. You are expected to be
a responsible citizen of the country and follow trade procedures, processes and legal
requirements as a part of the nation.

 Political Non-Alignment and Non-Membership of Political Parties / Bodies

o During your employment with the Group, you will be committed to and support the
Constitution and Governance system of the Country. You will not associate yourself with
any specific political party or body of organization. You will not be allowed to be an active
member of any political party, body of organization, or take part in any political activity or
demonstration.
o You will always bear in mind during your employment with Hinduja Group, that you are not
only representing yourself but also your Company. All your dealings, personal conduct and
 practices should reflect the pride you take in being a part of Hinduja Group, and practice its
code of conduct with its fullest intention and sanctity.
o In case you observe anyone violating the code of conduct, it is your moral responsibility to
report such an incidence immediately to your Director/CEO or the Head of HR, as you deem
appropriate.