Ethical Standards

At Sysfora Technologies Private Limited (Sysfora), we're committed to building an open, honest, inclusive and supportive professional environment in which everyone is treated fairly and with dignity, in line with our values of respect and tolerance.

We also take seriously our responsibility to uphold the values of integrity and responsibility by conducting our business in an ethical way and actively addressing important social issues, linked to our core principles of authenticity, integrity and the highest ethical standards in our business dealings.

Our Code of Conduct sets out the standards and principles that apply to everyone at Sysfora. Whatever our role in the Company, whether as Board members, managers, or colleagues, our actions and behaviours can significantly impact the Company’s reputation. These standards also extend to freelancers, consultants, and contractors who work with us.

We are rightly proud of our mission to create a purely software services business which disrupts analogue models. We have created this Code to support us in building a reputation of which we can be equally proud, both inside and outside of our Company.

Scope

The Code of Conduct (the 'Code') applies to Sysfora and to all subsidiaries in which it holds, directly or indirectly, a majority shareholding or exercises effective control, collectively called the 'Company'.

The Code sets the minimum standards of behaviour we require of all individuals working full time or part time at all levels within the Company, as well as those performing work for the Company such as contractors, self-employed contractors, part-time and fixed-term employees, interns, collectively referred to as our 'Colleagues'.

Detailed policies and procedures support a number of the areas covered in this Code; these are referenced in individual sections.

Areas Covered

The following areas are covered in the Code:

Accurate Record Keeping

Sysfora seeks to comply with the law and applicable technical and professional standards and prepares financial and other records in a timely manner, representing the facts faithfully and completely.

We maintain accurate records of the Company's dealings, and this includes all transactions between our business and external individuals and organizations, and all expenditure and labour charges.

We aim to maintain a rigorous system of financial, operational and compliance controls and an effective system of risk management.

Conflicts of Interest

We are committed to act in the best interests of Sysfora. We all have an obligation to conduct business in a way that avoids actual or potential conflicts of interest, either within Sysfora or with our clients or suppliers. A 'conflict of interest' occurs where our personal interests do not align with those of Sysfora. For example, where a relative is given a supplier contract with Sysfora, even if they are not the best choice. Or giving a job to a friend's family member where they are not the best candidate.

This means you should only use your position at Sysfora, as well as the Company's property, both physical and intellectual, for proper and legitimate business purposes. For example you should not use the Company's software, digital assets, concepts etc. for your own business purposes. Further you should always make decisions independent of financial or other personal interests which could potentially compromise your judgement or independence. This includes not providing preferential treatment to any third party with whom you have an interest - including family, friends or other contacts.

You should avoid any relationship that may create or give the appearance of a conflict and disclose promptly any personal or professional interests that might reasonably be perceived to conflict with the best interests of Sysfora. This includes anything that may create an appearance of impropriety or affects your judgment in carrying out your role.

You should also avoid external positions, engagements or activities that might interfere with your responsibilities or harm Sysfora's reputation.

You must immediately disclose any potential conflict of interest, including personal relationships with clients, vendors, or other employees of the company, particularly if there is a relationship of authority, to your manager.

Data

Communications
All of Sysfora communications should be professional, transparent, relevant and focused on our mission.
Both traditional and modern forms of communications including social media must be used responsibly. Inappropriate communication or unauthorized sharing of information (e.g. images, comments, links or other data) could cause legal or reputational damage to you, your colleagues, Sysfora, our clients, customers or others. This also includes statements made on social media or elsewhere that are maliciously untrue, discriminatory or violate the Company's anti-harassment policies. Furthermore, we must not make unauthorized statements on behalf of Sysfora or that could be considered as the Company's position.
Intellectual Property and Confidential Information
Information produced and stored on Sysfora's information systems, intellectual property and confidential information are our most valuable assets.
These include our brands, trademarks, know-how, inventions, patents, content and other copyrighted materials, trade secrets, strategies, computer programmes and media properties, including websites and apps. This also includes financial and commercial information about the Company, its clients and any other information protected under applicable Non-Disclosure Agreements.
Safeguarding the Company's intellectual property, proprietary and confidential information against unauthorized use or dissemination is critical to our success, whether in any of our offices, while working outside our offices or while travelling. Please keep track of information, in whatever format it exists. When discussing confidential information, do not speak where you can be overheard, and do not disclose any information to anyone unless you have a proper business purpose. This obligation to keep confidential our information continues, even if you are no longer employed with Sysfora.
You must not accept confidential information from a third party unless you have permission to do so and you have agreed to receive it under a prior written agreement. We also respect the intellectual property rights and confidential information of others and recognize that doing so is vital to maintaining our business and reputation.
Data Privacy and Digital Ethics
At Sysfora, we respect the privacy rights of our staff, customers, suppliers and business partners and are committed to collect, use, store, handle, transfer and disclose personal data in a professional, lawful and ethical way in line with local, national and international rules and regulations.
We may only process personal data for specific, defined, legitimate purposes and the data must be accurate and relevant for the purpose for which it was collected, as well as properly protected from inappropriate access or misuse. When it is to be transferred to third parties, it must be appropriately safeguarded.
Information and technology security
Sysfora provides you with the technology and software to do your job effectively, and you should treat this equipment with respect. The access and use of information technology and all our associated systems such as email, software/applications, networks, the internet as well as social media might be subject to cyberattacks, 'insider' threats or similar risks.
We therefore use our technology responsibly, only for legitimate business purposes and we must ensure that any use does not cause any harm to the Company, even inadvertently. Limited personal use of Sysfora's information technology assets is permissible in accordance with applicable policies, provided such use does not pose a conflict of interest risk. Our IT systems and devices should not be used for any improper purpose, or ways which could affect their operation or integrity.

Environment and Human Rights

Sysfora comply with the environmental laws and regulations in the countries where we do business. Our commitment goes beyond existing laws and regulations by promoting sustainable development. We seek to manage our environmental footprint transparently and ethically in the interests of our stakeholders, including our customers, Colleagues, investors and the communities in which we operate.

Child labour and modern slavery

At Sysfora, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain.

We comply with applicable laws and regulations, including the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organization.

Working with our external stakeholders, we seek the overall wellbeing of our communities.

Fair employment, diversity & inclusion

Harassment
We will not tolerate any action, conduct or behaviour which is humiliating, intimidating or hostile. We are all afforded an employment environment that is free from physical, psychological, sexual and verbal harassment, intimidation and other abusive conduct or threats of such treatment. Feedback, criticism and challenge must always be delivered in an appropriate and respectful manner, whilst considering cultural sensitivities.
Diversity and Inclusion
We offer equal opportunities to everyone, as this helps us ensure we always draw on the widest possible talent pool and attract the very best people.
We value diversity and shall never, at any stage of employment, discriminate against any individual on the basis of race, national origin, religion, ethnicity, disability, age, sexual orientation, political affiliation, union membership, gender or gender identity, marital status or any other classification protected by applicable laws and regulations.
Training
As part of our comprehensive compliance programme, we provide our Colleagues with training on ethical issues and policies related to this Code and expect everyone to comply with their assigned training responsibilities.
In particular, our training emphasizes our Colleagues' obligations within their Employment Contract.
Working hours
We operate in compliance with both International Labour Organization standards and local laws and regulations in relation to working, resting hours, maximum consecutive days of work and annual leave. Hours worked beyond the normal work week shall be voluntary.
Employment is freely chosen, and anyone may terminate their employment or engagement with reasonable notice in compliance with employment contracts, applicable laws and regulations.
Freedom of association and collective bargaining
We recognize the rights of individuals to exercise their right to freedom of association and collective bargaining in accordance with applicable laws and regulations, collective bargaining agreements and local customs.
Disciplinary and grievance mechanism
We have a transparent and fair disciplinary process in place to address concerns regarding any of our Colleagues' work, conduct or absence.
Migrant workers
The term 'migrant worker' refers to a person who is to be engaged, is engaged or has been engaged in a remunerated activity in a State of which that person is not a national. Sysfora ensures that migrant workers are employed in full compliance with the immigration and labour laws of the host country.
Health & safety
Sysfora strives for the highest standards of occupational health and safety. We comply with all applicable occupational health and safety regulations and provide a work environment that is safe, conducive to good health, and which helps prevent accidents, injuries, and work-related illnesses.
Political activity
Sysfora does not make payments or other contributions to support political campaigns or political activities.
As an individual you have the right to personally participate in lawful political activity, with any political views being clearly expressed as personal ones, and not those of Sysfora.

Prevention of Financial Crime

Anti-Bribery and Corruption
Sysfora has zero tolerance for any form of bribery or influence peddling. We comply with the anti-bribery and corruption laws of the countries where we operate, as well as those that apply across borders.
We do not offer, pay, or accept bribes or kickbacks for any purpose, either directly or through a third party. We do not make facilitation payments or permit others to make them on our behalf.
Gifts and Hospitality
We occasionally use hospitality and promotional opportunities to present our services, establish relationships or attract new clients and customers. Modest gifts, entertainment and hospitality can help build a good working relationships with clients, customers, suppliers and stakeholders.
However, gifts, entertainment and hospitality should not be offered or accepted if these can be viewed as improperly influencing a business decision.
Before offering or accepting any gifts or hospitality, we must ensure that the value is reasonable and allowed under Sysfora internal policies and standards.
Sponsorship & Donations
Sysfora supports local community organizations through voluntary contributions. We also use sponsorships as part of our marketing activities.
Charitable contributions, donations and sponsorship arrangements must be appropriate, reasonable in terms of value and frequency and approved in advance in line with Sysfora internal policies and standards. We must not use such arrangements to influence business decisions, disguise political payments or for any other improper purpose.
Third Parties
The nature of our work requires us to interact frequently with third parties. These third parties may include clients, customers, suppliers, distributors, resellers, lobbyists, consultants and any other person or entity that is not a Sysfora company or Colleague.
Since the third parties often control decisions or processes that can affect our business success, we must hold ourselves to the highest ethical standards when working with team.
Fraud
Sysfora does not tolerate any form of fraud by attempting to obtain any improper benefit through deception, making false claims or acting fraudulently. This includes the misuse of Sysfora's intellectual property and proprietary information.
Sanctions
Sysfora complies with all trade laws and restrictions within the countries in which we operate. This may include sanctions and trade restrictions which stop us working in certain countries, or with individuals or entities.
We aim to ensure regulatory compliance by establishing an internal framework that minimizes the risk of trade sanctions, breaches and abuse of our products and services for money laundering purposes.
Anti-Trust
Sysfora believes in free and open competition. We work hard to win against the competition by providing better products and services, not by unethical or illegal business methods. We never willingly undertake actions which would restrict free and fair competition, such as working with competitors to rig bids, exchange sensitive commercial information, fix prices or share markets.
Insider Trading
Sysfora complies with national and international laws on insider dealing.
We do not use or communicate material non-public information about Sysfora or any other company for personal financial gain or advantage. Such information may be obtained in a wide range of ordinary business situations which if disclosed, might influence a person's decision to buy, sell or hold a company's securities/shares.
Tax Evasion
Sysfora strives to comply with all local tax legislation in the countries where we operate and pay the right amount of tax for those activities. We have a zero-tolerance approach to tax evasion and always manage our tax affairs ethically. We also ensure we don't facilitate tax evasion by other parties, even accidentally.

This Code of Conduct reflects our core values of respect, integrity, authenticity, and responsibility, and serves as a guide for how we act individually and collectively in our professional roles. By adhering to these standards, we not only protect the reputation and success of our Company but also contribute to a culture of trust, fairness, and accountability.

Each of us plays a vital role in upholding these principles. We share the responsibility to speak up if we see something that does not align with our values, to support one another in doing the right thing, and to continuously strive for excellence in both our work and our conduct.

Together, we can ensure that Sysfora remains a company we are proud to be part of, one that leads with integrity, respects the rights and dignity of all individuals, and makes a positive impact on the clients we serve. We must remain committed to these ethical standards today and every day.