Code of Business Conduct and Ethics

1. Introduction

This Code of Business Conduct and Ethics (this "Code") is intended to help ensure compliance with legal requirements and our standards of business conduct. All officers, directors and employees of VT Netzwelt Pvt Ltd, or its subsidiaries (collectively the "Company") are expected to read and understand this Code, uphold these standards in day-to-day activities, comply with all applicable policies and procedures, and ensure that all agents, contractors and consultants doing business with the Company are aware of, understand and adhere to these standards.

Because the principles described in this Code are general in nature, you also should review all applicable Company policies and procedures for more specific instruction and contact the Human Resources department or the Company’s Chief Officers if you have any questions.

Nothing in this Code, in any Company policies and procedures, or in other related communications (verbal or written) creates or implies an employment contract or term of employment.

We are committed to continuously reviewing and updating our policies and procedures. This Code, therefore, is subject to modification. This Code supersedes all other such codes, policies, procedures, instructions, practices, rules or written or verbal representations to the extent they are inconsistent.

Please sign the acknowledgment form at the end of this Code and return the form to the Human Resources Department indicating that you have received, read, understand and agree to comply with this Code. The signed acknowledgment form will be located in your personnel file.

2. Compliance is everyone's business

Ethical business conduct is critical to our business. As an officer, director and/or employee, your responsibility is to respect and adhere to these practices. Many of these practices reflect legal or regulatory requirements. Violations of these laws and regulations can create significant liability for you, the Company, its officers, directors and employees.

Part of your job and/or ethical responsibility is to help enforce this Code. You should be alert to possible violations and promptly report possible violations to the Human Resources Department or to a member of Senior Management. You must cooperate in any internal or external investigations of possible violations. Reprisal, threats, retribution or retaliation against any person who has in good faith reported a violation or a suspected violation of law, this Code or other Company policies, or against any person who is assisting in any investigation or process with respect to such a violation, is prohibited.

Violations of law, this Code, or other Company policies or procedures should be promptly reported to the Human Resources Department or a member of Senior Management.

Violations of law, this Code or other Company policies or procedures can lead to disciplinary action, up to and including termination.

In all cases, if you are unsure about the appropriateness of an event or action, please seek assistance by contacting a member of Senior Management.

3. General Employee Conduct

The Organization expects its employees to conduct themselves in a businesslike manner. In addition to complying with all applicable laws, rules and regulations, any unprofessional activities including but not limited to drinking, gambling, fighting, swearing, and similar are strictly prohibited while on the job.

The company has zero tolerance on discrimination or harassment: All employees must be treated with utmost respect and dignity. All employees are equal - irrespective of gender, age, religion or creed, sexual orientation, disability or ethnic origins. Harassment and discrimination of any kind will not be tolerated.

Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer.

4. Wages, working hours, health & safety and employee welfare

The Organization takes great pride in offering a state-of-the-art workplace and working environment for its employees. Among others, employees benefit from subsidized insurances, flexible working hours, perks such as food tokens / free taxi conveyance, paid overtime (or convert to leaves) and a remuneration that by far exceeds any minimum wage legislation. The organization abides to all other statutory legislation requirements.

Furthermore, the safety of people at the workplace is a primary concern of the Company. Each of us must comply with all applicable health and safety policies.

5. Conflicts of Interest

The Organization expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the Organization. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.

6. Outside Activities, Employment, and Directorships

All employees share a serious responsibility for the Organization’s good public relations, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to the Organization and is encouraged. Employees must, however, avoid acquiring any business interest or participating in any other activity outside the Organization that would, or would appear to:

  • Create an excessive demand upon their time and attention, thus depriving the Organization of their best efforts on the job.
  • Create a conflict of interest - an obligation, interest, or distraction - that may interfere with the independent exercise of judgment in the Organization’s best interest.
7. Relationships with Clients and Suppliers

Employees should avoid investing in or acquiring a financial interest for their own accounts in any business organization that has a contractual relationship with the Organization, or that provides goods or services, or both, to the Organization if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of the Organization.

8. Gifts, Entertainment, and Favors

Employees must not accept entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or organization with whom or with which the Organization has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with the Organization might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.

9. Kickbacks and Secret Commissions

Regarding the Organization’s business activities, employees may not receive payment or compensation of any kind, except as authorized under the Organization’s payroll policies. In particular, the Organization strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law.

10. Organization Funds and Other Assets

Employees who have access to Organization funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in the Organization’s policies and procedures or other explanatory materials, or both. The Organization imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that the Organization can promptly investigate further.

When an employee’s position requires spending Organization funds or incurring any reimbursable personal expenses, that individual must use good judgment on the Organization’s behalf to ensure that good value is received for every expenditure.

Organization funds and all other assets of the Organization are purposed for the Organization only and not for personal benefit. This includes the personal use of organizational assets, such as computers. Care should be taken to ensure that assets are not misappropriated, loaned to others, or sold or donated, without appropriate authorization. You are responsible for the proper use of Company assets, and must safeguard such assets against loss, damage, misuse or theft.

11. Organization Records and Communications

Accurate and reliable records of many kinds are necessary to meet the Organization’s legal and financial obligations and to manage the affairs of the Organization. The Organization’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:

  • False expense, attendance, production, financial, or similar reports and statements
  • False advertising, deceptive marketing practices, or other misleading representations
12. Dealing With Outside People and Organizations

Employees must take care to separate their personal roles from their Organization positions when communicating on matters not involving Organization business. Employees must not use organization identification, stationery, supplies, and equipment for personal or political matters.

When communicating publicly on matters that involve Organization business, employees must not presume to speak for the Organization on any topic, unless they are certain that the views they express are those of the Organization, and it is the Organization’s desire that such views be publicly disseminated.

When dealing with anyone outside the Organization, including public officials, employees must take care not to compromise the integrity or damage the reputation of either the Organization, or any outside individual, business, or government body.

13. Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the public and others in the Organization, all employees must make every effort to achieve complete, accurate, and timely communications - responding promptly and courteously to all proper requests for information and to all complaints.

14. Privacy and Confidentiality

In addition to any rules implied by an individual NDA agreements, when handling financial and personal information about customers or others with whom the Organization has dealings, observe the following principles:

  • Collect, use, and retain only the personal information necessary for the Organization’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
  • Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
  • Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.