Code of Ethics and
Professional Conduct Guide

Code of Ethics and Professional Conduct

This Code of Ethics and Professional Conduct document outlines the ethical principles that govern decisions, acceptable and non-acceptable conduct and behaviour at Pine Labs (the “Company”). This document will be refreshed periodically to ensure that it remains relevant to the times without changing our underlying principles.

This Code of Ethics and Professional Conduct (The “Code of Conduct”) is applicable to every person engaged with Pine Labs – whether as a Director, full-time employee, contract employee, intern, trainee, vendor, 3rd party and is applicable across all Pine Labs’ offices in India and outside, now and in future.

Standards of Conduct

• All are required to comply with all established policies, procedures, rules, regulations and adhere to the terms and conditions mentioned in their contracts.
• Compliance with all local, state, and national laws is an absolute must.
• Compliance with all instructions (reasonable and lawful) given by or on behalf of the Company.
• All must devote their complete attention, time, efforts and skills during the working hours and at other times as might be required to perform their duties.
• Company’s best interests should be kept in mind always.
• Everyone is expected to be honest and fair in their conduct with clients, customers, colleagues, management and the public at large.
• No statements to the media should be given by anyone about the Company’s business, unless expressly authorised to do so by the Corporate Communications team or the management. Requests for media statements should be directed to communications@pinelabs.com.
• We should strive to observe all health and safety rules and responsibilities at the workplace. Refrain from making any discriminatory remarks or exhibit behavior which can be construed as bullying or harassing toward customers, clients, colleagues, management and the public.
• To not make any statements on social media or any other external platform, that may harm the reputation of the company.
• Acceptance of any financial or other benefit from any entity other than the Company, unless acceptance of such benefit is in accordance with the Company’s workplace policies or is otherwise disclosed to the Company and expressly permitted by the Company.
• No employee is allowed to engage in any employment or provide any services to any entity or individual other than the Company; exception only with the Company’s prior written consent.
• Any conduct whether during or after work hours, that causes damage or potential damage to the Company’s property or reputation will be subjected to disciplinary action.
• No one is allowed to discriminate on the basis of personal characteristics including (but not limited to) age, sexual orientation, race, religion, caste, ethnicity, marital status, or any other inherent biases.
• It is important to dress in an appropriate manner and be presentable, clean, neat and tidy while in office premises or during external meetings.
• To maintain complete confidentiality of information, records or other materials acquired during employment.
• Always uphold the Company’s Core Values and reputation of the Company.

Equal Opportunity Employer: We shall recruit and promote employees based on merit and performance only and will not discriminate.

Statutory Laws & Compliance: We shall follow the applicable laws both in letter and spirit set out by the respective governments and will not wilfully engage in any activity that contradicts the law of the land.

Financial Statement & Statutory Disclosure: We shall be sincere and straightforward in so far as our financial statements and statutory disclosures are concerned. We make it our habit to reflect all our company’s financial records and disclosures in an ethical and transparent manner reflective of a responsible business entity that respects fair and accepted reporting standards of businesses. We will strive to set a benchmark in high reporting standards and practices.

Conflict of Interest: We shall always strive to avoid instances of “Conflict of Interest”, where our interests either through our personal associations or direct relation are not in the best interest of the company. If such instances do occur, we shall report to HR and not partake in such decisions. Conflict of interest includes but not limited to:

• Engaging in any business either through personal association or through a family relationship which competes with the business of the organization.
• Conduct personal financial transactions with vendors, partners, customers or contractors.
• Introduce any family member as a vendor, partner or contractor to the organization without disclosing the relationship.
• Exploit for our personal gain any company asset, facility of perquisite received by the organization.
• Share any organization data for any personal or public cause.
• Influence the recruitment process for hiring of any relative in any position with or without remuneration.

Prevention of Corruption: We shall in no way encourage any bribery or indulge in any unfair or corrupt activities while representing the organization during our business. We shall not indulge in any act of corruption such as deception, bribery, forgery, extortion, theft, embezzlement, misappropriation, falsification or collusion.

Cyber Security: We recognize that we use digital media and modern technology platforms. Therefore, we commit to adopt by design, secure cybersecurity practices for the good of the company and for securing our customers’ data and information. We will always strive to be aware and cautious about the potential of cyberattacks to our customers’ networks and digital platforms. When in doubt we will consult the IT team in our organisation.

Safety, Health & Environment: We understand the importance of natural resources and will take necessary steps to reduce our carbon footprint and minimize the impact of our products on the environment. We will also ensure adherence to safe work practices to ensure protection against safety and health hazards.

Representing Pine Labs: We recognize that each of us is an ambassador of Pine Labs to the external world. We will take the utmost care and pay all necessary attention to the way we conduct ourselves both inside and outside our company and premises. We commit to demonstrate our ethics in our professional behaviour outside the company. We will use official communication material and follow our company guidelines and brand rules. We will not make our company’s interests subservient to our opinion and beliefs.

Other Policies

Employees and 3rd party (to the extent applicable) are encouraged to read the below policies in conjunction with other relevant Company policies, including:

• Annexure to Appointment letter applicable only to employees.
• Anti-corruption Compliance policy – Outlines details on established norms as we engage with people outside of the organisation.
• Corporate Values including Integrity - Uploaded on www.pinelabs.com
• Whistle Blower and Disciplinary Policy- We have established a disciplinary committee to address employee concerns and conduct neutral and fair investigation into all complaints.

To report any violation of the Code of Conduct, please write an e-mail to: ethics@pinelabs.com. The identity of the individual shall be kept completely confidential during an internal or external investigation.