The purpose of this Code of Business Conduct and Ethics outline the ethical principles that govern decisions and behavior at Geca InnoTech Private Limited and all its subsidiaries, hithertho referred to as Company. In this policy, Company‘s employees will find clear guidelines on how to conduct themselves professionally, as well as specific guidance for handling issues like harassment, safety, and conflicts of interest. Integrity, high ethical standards of business conduct and responsibility form the basis of Company’s operations.

• This Code requires the Directors and Employees of the Company to act honestly, fairly, ethically and with integrity, conduct themselves in a professional, courteous and respectful manner and not allow their independent judgment to be subordinated.
• Directors and Employees are expected to act in a manner to enhance and maintain the reputation of the Company.
• Each Director and Employee must comply with the letter and spirit of this Code.
• Violations of this Policy may lead to disciplinary action, up to and including termination of employment.

• Directors and Employees of the Company must respect and comply with all laws, rules and regulations of India and other countries in which the Company conducts its business.
• They should strive to keep themselves updated concerning the laws/statutory compliances applicable to their scope of work.

Directors and Employees of the Company must help to create and maintain a culture of high ethical and professional standards. They are also expected to:

• Conduct business operations in compliance with competition laws and principles of fair market competition.
• Not to conduct own selves in a manner as may bring disrepute to the office or tarnish the reputation and image of the Company.

Directors and each Employee of the Company should endeavour to avoid any conflict of interests with the Company.

• The Directors and each Employee of the Company must not allow personal interest to conflict with the interest of the Company or to come in the way of discharge of duties of the office.
• They should not engage in a business, commercial relationship or commercial activity with anyone who is a party to the transaction(s) with the Company. Similarly, they should not derive a personal benefit or a benefit to any of their relatives by making or influencing decisions relating to any transaction(s).
• The Directors and each Employee of the Company should act in good faith, responsibly, with due care, competence and diligence. They should abstain from discussions, voting or otherwise influencing decisions on any matter that may come before the Board in which they may have a conflict or potential conflict of interest.

• Each Director and Employee of the Company shall endeavour to deal fairly with the Company’s customers, suppliers, dealers, investors and competitors.
• No Director or Employee of the Company should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice.

The Directors and Employees of the Company shall not exploit for their gain, opportunities that are discovered through the use of corporate property, information or position unless the opportunity is disclosed fully in writing to the Company’s Board of Directors and the Board of Directors declines to pursue such opportunity. The Directors and Employees of the Company are prohibited from:

• Taking for themselves any opportunity that particularly belongs to the Company or is discovered through the use of corporate property, information, or position.
• Using corporate property, information, or position for personal gain; and competing with the Company.

The Company provides equal opportunities to all employees and aspirants for employment in the Company irrespective of gender, caste, religion, race or colour, merit being the sole differentiating factor.

• The Directors and each Employee shall maintain a work environment free from sexual harassment, whether physical, verbal or psychological.
• Disciplinary action shall be taken against any Director / Employee found in breach of this Code, which may include civil or criminal prosecution before a competent Court of Law.
• Directors and employees shall in addition to this ‘Code’ also adhere to the Company’s Prevention of Sexual Harassment Policy.

• The Company recognises its social responsibilities and is committed to improving the quality of life of its workforce and their families.
• The Company maintains clear employment, health, and safety practices to support a safe, healthy, and respectful working environment.

• The Company provides email and internet facilities for the Company’s business.
• Posting and disseminating Company’s information and data on the internet or voice mail or on private networks except for business exigencies is prohibited.
• The use of internet facilities for accessing unauthorized, immoral websites from the computers provided by the Company is barred.

The Software used on the Company’s equipment(s) must be licensed and legal software. The use of unlicensed software on the Company’s equipment(s) is prohibited.

All Directors and employees of the Company should protect the Company’s assets from theft, carelessness, and waste which will have a direct impact on the Company’s profitability and ensure their efficient use and restrain from using the Company’s property or position for personal gain.

All Directors and employees of the company should

• Not communicate or divulge to any person, firm, corporation or business entity, either directly or indirectly and to hold in strict confidence for the benefit of the Company, all Confidential Information and Customer Information except that the Employee may disclose such information to persons, firms or corporations who need to know such information during the course and within the scope of the Employee’s employment with the Company.
• Not store, copy, transfer, duplicate, modify, damage, destruct, delete, or amend the Customer Information.
• Agree to return to the Company or delete all the Confidential Information, Customer Information as may be available with the Employee, after the performance, rendering, completion, offering or delivery of Services, or as and when notified by the Company, whichever is earlier, and shall certify to the Company about such return or deletion of all the Confidential Information, Customer Information.
• Agree that in the event of any unauthorized access or theft or loss or damage to the Confidential Information, Customer Information, the Employee shall immediately notify the Company, and the Employee further agrees to take reasonable actions to mitigate such unauthorized access or theft or loss or damage.
• Agree not to use any Confidential Information and Customer Information for any purpose or for the Employee’s personal benefit other than in the course of and within the scope of the Employee’s obligation to the Company under this Agreement.

Agree that any Non-Disclosure and Confidentiality agreements signed by the Company for individual work assignments is also binding on the individual as well.

To ensure that all documents are accurate, timely and properly authorised. Financial records are to be maintained in compliance with applicable accounting and financial reporting standards as applicable to the Company.

All Directors and Employees of the Company should protect the Company’s assets from theft, carelessness, and waste which will have a direct impact on the Company’s profitability and ensure their efficient use and restrain from using the Company’s property or position for personal gain.

The Company shall endeavour to ensure that it:

• Encourages employees to talk to their superiors and other appropriate personnel when in doubt about the best course of action in a particular situation.
• Encourages employees to report a violation of laws, rules, regulations or the Company’s Code of Conduct to appropriate personnel.
• Alternatively, any Employee can make a protected disclosure addressed to the HR of the actual or possible violation of the ‘Code’ with reasonable evidence to conclude that a violation is possible or has taken place with a covering letter which shall bear the identity of the reporting employee.

A Committee compromising the Director and Functional Leads will investigate the matter and prepare a Report for appropriate action.
Assure Employees that the Company will not allow retaliation for reports made in good faith.

Company reserves the right to update this policy from time to time as appropriate.