Code of Conduct & Ethics Policy

Policy Statement

The Company is committed to conducting its business with integrity, fairness, and accountability. This Code of Conduct & Ethics Policy establishes the standards of professional behavior expected from all employees, directors, and representatives of the Company. The Code serves as a guide to ethical decision-making and promotes compliance with laws, regulations, and internal policies.

Purpose

The purpose of this Code of Conduct & Ethics Policy is to:

• Promote a culture of honesty, transparency, and respect.
• Provide employees with guidance on appropriate workplace behavior.
• Protect the Company's reputation and stakeholder trust.
• Prevent misconduct, conflicts of interest, and unethical practices.

Scope and Applicability

This policy applies to all employees, officers, directors, contractors, consultants, and third parties engaged with the Company It covers behavior at the workplace, during business activities, and in all interactions representing the Company.

Core Values

• Integrity: Conduct all business activities honestly and fairly.
• Accountability: Take responsibility for actions and decisions.
• Respect: Treat colleagues, clients, and stakeholders with dignity.
• Innovation: Strive for excellence and continuous improvement.
• Compliance: Adhere to legal and regulatory requirements at all times.

Professional Conduct

Employees must act in a manner that upholds the reputation and integrity of the Company. Professionalism should be maintained in all communication, decision-making, and interactions with colleagues, clients, and partners.

Compliance with Laws and Regulations

Employees must comply with all applicable local, national, and international laws, including those related to labor, taxation, data protection, anti-bribery, and intellectual property. Ignorance of the law will not be accepted as a defense for misconduct.

Conflict of Interest

Employees must avoid situations where personal interests conflict or appear to conflict with Company interests. Any potential conflicts must be promptly disclosed to the Compliance Department using the Conflict of Interest Declaration Form.

• Engaging in outside employment that competes with the Company.
• Having financial interests in vendors, suppliers, or competitors.
• Using Company property or information for personal gain.
• Favoring relatives or friends in hiring or business decisions.

Confidentiality and Data Protection

All employees are required to protect the confidentiality of Company, client, and employee information. Access to sensitive information should be limited to authorized personnel only. The use, disclosure, or transmission of confidential data without authorization is strictly prohibited and may lead to disciplinary action.

Anti-Discrimination and Equal Opportunity

The Company promotes a workplace free from discrimination, harassment, and retaliation. Employment decisions will be based on merit, competence, and qualifications, without regard to race, religion, gender, age, disability, or any other protected category.

Workplace Behavior and Ethics

• Maintain a safe, respectful, and harassment-free work environment.
• Avoid abusive language, discrimination, or inappropriate behavior.
• Dress and behave in a professional manner consistent with Company standards.
• Respect diversity and foster inclusivity across teams.

Anti-Bribery, Corruption, and Gifts

Employees must comply with the Anti-Bribery & Anti-Corruption (ABAC) Policy. Bribes, facilitation payments, and excessive gifts are prohibited. Any gifts, hospitality, or entertainment must be reasonable, transparent, and approved by the Compliance Department if they exceed approved thresholds.

Use of Company Assets

Employees are responsible for safeguarding Company assets, including physical property, intellectual property, funds, and digital systems. Assets must be used solely for legitimate business purposes and not for personal benefit.

Information Technology and Cybersecurity

Employees must adhere to IT security guidelines and ensure responsible use of Company systems, email, and internet. Unauthorized downloads, access to restricted websites, or sharing of sensitive data are strictly prohibited. Employees should immediately report any cybersecurity incidents or data breaches to the IT Department.

Health, Safety, and Environment

The Company is committed to maintaining a safe and healthy work environment. Employees must comply with all safety protocols, report hazards immediately, and participate in emergency preparedness drills.

Reporting Misconduct and Whistleblower Protection

Employees are encouraged to report any suspected violations of this Code or unethical conduct via the Whistleblower Channel or directly to the Compliance Officer. Reports will be investigated confidentially, and retaliation against whistleblowers is strictly prohibited.

Disciplinary Action

Violations of this Code of Conduct & Ethics Policy may result in disciplinary measures, including warnings, suspension, termination, or legal action, depending on the severity of the offense.

Roles and Responsibilities

• Board of Directors: Provide oversight and ensure ethical leadership.
• Compliance Officer: Enforce the Code, conduct investigations, and provide training.
• Managers: Lead by example and ensure team adherence to ethical standards.
• Employees: Read, understand, and follow the Code at all times.

Training and Awareness

All employees must complete Code of Conduct training at the time of onboarding and periodically thereafter. The training shall cover ethical decision-making, conflict resolution, and compliance obligations.

Policy Review

This policy shall be reviewed annually or as required by regulatory or business changes. Updates will be communicated to all employees through internal communication channels.

Employee Acknowledgment

I acknowledge that I have read and understood the Code of Conduct & Ethics Policy of the Company I agree to comply with the principles, guidelines, and standards set forth in this document.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________