Pratiti Technologies Pvt. Ltd.

Confidential

Business Integrity@Pratiti Technologies

Objective – Pratiti Technologies operates in Information Technology domain and is committed to
the highest standards of ethics and integrity in its business conduct. Infusing ethical values into our
day to day activities is essential to preserve the trust of both of clients and vendors, to safeguard our
image and reputation and to protect the rights of our internal employees. To sustain our
commitment, we have implemented a sustainable business integrity framework.

Our Business integrity framework ensures that how we do business and conduct ourselves in public
is fully aligned to our values and applicable laws and regulations of the region where we operate.

Applicability - The policies, procedures and operating practices provided are applicable to all
permanent and contract employees of Pratiti Technologies, Pratiti vendors and clients across all the
locations.

Interpretation of Policy - The interpretation of the policy guidelines rests exclusively with the
Company. For any queries on interpretation of the policies contact the designated Director (Prashant
Anaskure) who is the sole and final deciding authority for resolving any conflicts that may arise from
the interpretation of this document. Words used in any gender include other genders.

The contents of this manual including but not limited to the policies, procedures and operating
practices stated therein may be changed by the Company, at its sole discretion, from time to time.
The Company may change / suspend any policy for a temporary period under exceptional
circumstances and the same will be communicated to all employees through organization
announcements.

Review of the Policies – The process and policies mentioned in this document will be reviewed at
the end of every financial year by the management team comprising of the Directors of the
company.

Code of Ethics and Expected Behavioral Standards of Fellow Pratitians

1. Respect and Protection of people and Environment – Pratiti takes utmost care to define the
standards of ethical behaviour that all Pratitians are expected to follow when conducting
Pratiti business. All Pratitians are expected to exhibit respect for individual while dealing
with fellow Pratitians and external clients and vendors. This essentially means people should
be treated with dignity , honesty and fairness in all dealings with fellow colleagues , clients
and vendors.

2. Integrity in managing company information – Pratitians are expected to protect

confidential and sensitive company information. Employees are discouraged to upload any
confidential and sensitive information that might compromise the company or any of its
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client business. Adequate steps are also taken in safeguarding the interest of the company
while using social media

3. Integrity in Business practices – Pratiti always maintains transparency in its offerings and
products and believes in fair competition. Wherever there is a conflict of interest whether
with the internal employees, client or with vendors, Pratiti always resorts to fair and
mutually accepted means to resolve the conflict.

4. Countering corruption and anti-bribery – One of Pratiti’s commitment in doing business

with integrity requires zero tolerance approach towards bribery and corruption. Pratiti does
not (directly or indirectly) offer, pay, seek or accept a payment, gift or favor to improperly
influence a business outcome.

5. Adherence to company values - At Pratiti we have identified four core value that defines
our culture and our value system throughout our dealings internally and to the community
at large. These values, namely – Passion for Technology, taking Pride in what we do ,
Integrity in our dealings and Customers success forms the backbone of our value chain, from
innovation through to our customers. Every Pratitians needs to demonstrate these values
while engaging with others externally and also while dealing internally.

6. Code of Business Conduct - People represent Pratiti’s greatest value and create the richness
of the organization. We believe that all of us must make our best efforts to contribute to an
environment that builds confidence and empowers people through personal and
professional growth. We grow through collaborative working, skills development, and
knowledge sharing and learning from each other.

All employees are expected to read and understand this Code of Conduct, uphold these
standards in day-to-day activities, comply with all applicable policies and procedures.

Responsibility to Our Colleagues : We respect the dignity of our colleagues. We will treat
each other with respect and fairness at all times. We will value the difference of diverse
individuals from around the world. Employment decisions, such as, hiring, training,
promotions are based on qualifications, talent, achievements and will comply with local and
national employment laws. We provide equal opportunity to all. We are committed to
providing a work environment free from unlawful discrimination, harassment and
intimidations of any nature. We strictly prohibit harassment and discrimination based on
gender, religion, age, national origin and other such characteristics. We are all responsible
for maintaining a safe workplace by following safety and health rules and practices. We
comply with the applicable laws and regulations regarding health and safety, and are
responsible for immediately reporting accidents, injuries, unsafe equipment or any possible
threat to safety.
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Responsibility to the Company : We believe integrity is a value which cannot be

compromised. We expect all employees to be ethical in all their interactions with the
Company, its customers, partners and other employees. This would include honesty in all
transactions, conformance with the Company’s code of conduct and conformance with all
laws of the land. When participating in an external event, meeting, or conference we should
keep in mind that we represent our Company and are all contributing to its reputation. We
should pay attention to carry a positive image of the Company, its values, teams and
management, and to act with integrity and seriousness in any professional circumstances.

Responsibility to Our Customers And Partners: We respect and exist to satisfy our customers
and partners. Our lasting relationships with our customers, suppliers and business partners
are built upon honesty, fair play and integrity. Our communications are accurate, truthful
and do not deliberately omit important facts or mislead. We respect the privacy of our
partners and treat their information with care in accordance with our agreements.

Responsibility to Our Competitors: We compete aggressively but with integrity at the same
time We compete aggressively, legally and ethically; we “play hard” but fairly, in compliance
with the laws in the countries in which we do business. We collect competitive information
appropriately: through public communications, public filings, trade shows, industry surveys,
and appropriate interactions with customers

Responsibility to the Regulatory Bodies: It is our obligation to obey the law. In terms of
financial reporting, we ensure the accuracy and integrity of our records and financial
reporting critical to maintaining the confidence of our shareholders, customers, partners
and colleagues.

Safeguarding Company Assets: Protecting our assets is vital to our operations, regardless of
whether the asset is tangible or intangible. The use of the Company’s assets for illegal or
non-ethical business purposes is strictly prohibited. Assets include but are not limited to:
• Intellectual property
• Confidential and proprietary information
• Employee data
• Products
• Computers
• Programs and codes
• Customer lists and information

How Business Integrity is Governed and Managed

Our Directors set an unequivocal tone from the top , communicating regularly through various
forums such as town halls, focus group discussion to all the employees on business integrity , making
it clear that adhering to our code of conduct is non negotiable. Many other members of our
leadership team are also value champions, they regularly share their perspective of business
integrity with their team.
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The code of ethics and business integrity listed in this document are published to all the existing
Pratitians. All new joiners are oriented about the policy via the company orientation session.

For the purpose of enforcement, there is a grievance committee formed that looks into any
complaint raised via the whistle blower policy.

Whistle Blower Policy - The possibility of malpractices occurring in an organization’s operations can
never be ruled out and ignorance of this possibility demonstrates poor corporate governance with
potentially disastrous consequences. The existence of malpractices in an organization can be known
only when a person having knowledge of the same reports it to the appropriate authorities. Such a
person is known as a whistleblower. However, fear of retaliation and ignorance of where to report
malpractices usually discourage a potential whistleblower from reporting the malpractice.
Therefore, one of the cornerstones of good corporate governance is the existence of a mechanism
to investigate complaints of malpractices with fairness and protect whistleblowers against any
retaliatory action.

This policy applies to the Company’s activities throughout its location including but not limited to
client site. Anyone associated with the Company’s activities or dealing with the Company may
submit a Complaint. This includes directors, shareholders, customers, employees and suppliers.

Pratiti’s Commitments

(1) The Company will provide and maintain an appropriate mechanism for receiving and dealing with
Complaints.

(2) The Company will protect a Whistleblower against any harassment, victimization or any other
form of retaliation (whether active or passive).

(3) If the Whistleblower requests anonymity, the Company will not disclose the identity of the
Whistleblower unless legally required or when anonymity is impractical for the purposes of
dealing with the Complaint.

(4) The Company will not disclose the existence or contents of a Complaint to anyone other than the
Audit Committee and those persons who are required to know for the purpose of dealing with
the Complaint or any action required to be taken pursuant thereto. The commitment of
confidentiality will not apply when the relevant information is legally required to be disclosed.

(5) The Company will appoint from time to time, one or more full-time senior employees, who are
respected for their fairness, independence and integrity, to be part of the grievance redressal
committee that can be formed under this policy.

(6) The Company will make a copy of this policy (together with its Annexures) easily available to its
shareholders, customers, employees and suppliers and issue appropriate communications to
ensure that the existence of this policy is known to the aforesaid stakeholders.
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Implementation of the Policy

The Company may, from time to time, frame and maintain appropriate procedures to fulfill the
objectives and commitments of this policy. All involved parties (be it a Whistleblower, Respondent
or grievance committee members) shall adhere to such procedures and maintain confidentiality with
regard to a Complaint. This policy, if used appropriately, can help support the best corporate
governance practices in the Company.

This policy is intended to encourage and enable fearless reporting of Malpractices. It is however not
intended to question financial or business decisions taken by the Company. Here are some
important Dos and Don’ts that must be followed.

Do’s:

1. Bring any Malpractice to the attention of the Company as soon as you become aware of the same.
Delay in reporting may lead to loss of evidence and also financial loss for the Company.

2. Ensure you have sufficient basis for making a Complaint.

3. Avoid unnecessary anonymity when making a Complaint.

4. Follow the procedures prescribed in this policy for making a Complaint

5. Co-operate with the investigating authorities.

6. Maintain confidentiality of the subject matter of the Complaint and the identity of the persons
involved in the alleged Malpractice.

Don’t’s:

1. Make allegations that are petty, false, malicious or without substance. Such allegations
undermine the purpose of this policy viz. to unearth serious and genuine issues. It may also invite
disciplinary action at the discretion of the grievance committee.

2. Publicly discuss the subject matter of the Complaint or details of the persons involved in the
alleged Malpractice. It may forewarn the Respondent and important evidence is likely to be
destroyed.

Consequences

When investigations under this policy or proceedings under a due process of law establish that any
person/persons have committed a Malpractice or violation of this policy, the Company will adopt
appropriate disciplinary action against such persons (including their accomplices in the Malpractice).
Such disciplinary action may include (but not be limited to) termination of services, denial of
increments and debarring from doing business with the Company.

Reports

The Grievance Committee shall send a report to the Company’s CEO at the end of every financial
year, listing the complaints received and/or closed during the year, the status of open Complaints
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and brief findings with actions taken on Complaints closed during the financial year. The report may
also contain recommendations for improvement in the procedures or amendments to this policy.

Current Members of Grievance Committee

1. Name – Prashant Anaskure

Email ID – [email protected]

2. Name – Nisha Motwani

Email – [email protected]