Code of Conduct

1.Purpose

This Code of Conduct establishes the standards of ethical and professional behaviour expected at Thotnr Consulting Pvt. Ltd. It supports the Company’s ESG commitments and is intended to guide employees, management and relevant third parties in conducting business with integrity, transparency, accountability and respect.

2.Scope

This Code applies to all employees, including full-time, part-time, contractual employees and interns, and to senior management and leadership. Relevant consultants, vendors, agents, service providers and business partners are expected to uphold applicable principles when acting for or on behalf of the Company.

3.Core Principles

• Act lawfully, honestly and ethically.
• Treat colleagues, candidates, customers, suppliers and other stakeholders with dignity and respect.
• Protect Company, client and stakeholder information and assets.
• Avoid conflicts between personal interests and Company responsibilities.
• Maintain accurate and truthful business records and communications.
• Speak up about suspected misconduct and cooperate with legitimate investigations.

4.Respect for Human Rights & Fair Employment

• The Company respects human rights and fair labour practices.
• Child labour, forced or compulsory labour and human trafficking are prohibited.
• Employment decisions should support equal opportunity and non-discrimination.
• Harassment, bullying, intimidation and retaliation are not tolerated.
• The Company respects applicable rights relating to freedom of association and collective bargaining.
• Employees should receive wages, benefits, working hours, leave and rest in accordance with applicable law and Company terms.

5.Health, Safety & Well-Being

Everyone has a responsibility to support a safe and healthy working environment. Employees must follow applicable safety requirements, report hazards or incidents promptly and avoid conduct that could unnecessarily put others at risk.

6.Anti-Bribery & Anti-Corruption

The Company maintains a zero-tolerance approach to bribery and corruption. Employees and relevant third parties must comply with the Company’s Anti-Bribery and Anti-Corruption Policy and applicable laws.

• Do not offer, promise, give, request or accept improper payments or benefits.
• Facilitation or ‘speed’ payments are prohibited.
• Gifts, hospitality and entertainment must not improperly influence business decisions and must comply with Company requirements.
• Conflicts of interest must be disclosed and appropriately managed.
• Charitable donations and sponsorships must be lawful, transparent and not used to obtain an improper advantage.

7.Conflicts of Interest

Employees must avoid situations where personal, family, financial or other interests could improperly influence their business judgment. Actual, potential or perceived conflicts should be disclosed promptly through appropriate internal channels.

8.Fair & Responsible Business

• Deal fairly and professionally with customers, suppliers, candidates, employees and business partners.
• Do not knowingly misrepresent the Company’s capabilities, services, records or commitments.
• Respect applicable competition and procurement requirements.
• Do not use confidential or non-public information for improper personal or commercial advantage.

9.Confidentiality, Data Protection & Information Security

• Protect confidential Company, employee, candidate, client and supplier information.
• Use information only for legitimate business purposes and in accordance with applicable requirements.
• Follow Company information-security, privacy and access-control procedures.
• Promptly report suspected loss, unauthorised access, disclosure or misuse of information.

10.Company Assets & Intellectual Property

Company assets, systems, equipment, software, intellectual property and resources must be used responsibly and for legitimate business purposes. Employees must respect third-party intellectual property and applicable licensing requirements.

11.Accurate Records & Communications

Business records, financial information, timesheets, expenses, invoices, procurement records and other documentation must be accurate, complete and maintained appropriately. Employees must not knowingly falsify or conceal material information.

12.Responsible Supply Chain

The Company expects suppliers, contractors, recruitment agencies and other relevant third parties to conduct business ethically and comply with applicable laws, labour and human rights requirements, environmental expectations and contractual obligations.

13.Environmental Responsibility

Employees and relevant business partners are encouraged to support the Company’s environmental commitments, including responsible use of resources, reduction of paper use, responsible e-waste disposal and environmentally responsible procurement where practicable.

14.Speaking Up, Grievances & Whistleblower Protection

Concerns about misconduct, policy violations, harassment, discrimination, labour-rights issues, corruption, safety or other serious concerns should be raised through the Company’s designated channels. The Company maintains a Grievance Redressal Framework and supports good-faith reporting without retaliation.

The existing grievance framework provides for confidential reporting, investigation, resolution, appeals, anonymous complaints where sufficient information is available, and protection against retaliation.

15.Compliance & Investigations

• Employees are expected to understand and comply with this Code and relevant Company policies.
• Suspected violations may be reviewed or investigated through appropriate internal processes.
• Employees are expected to cooperate honestly with authorised investigations.
• Violations may result in appropriate disciplinary or contractual action, subject to applicable law and Company procedures.

16.Training & Communication

The Company may provide training, onboarding, internal communications or other awareness activities on the Code and related policies. Relevant third parties may also be informed of applicable standards.

17.Governance & Review

Management, HR and designated governance/ESG responsibilities will support implementation of this Code. The Code will be reviewed at least annually or when significant legal, operational or organisational changes occur.

18.Related Policies

• Human Rights & Labour Standards Policy
• Anti-Bribery & Anti-Corruption Policy
• Grievance Redressal Framework
• ESG Policy
• Modern Slavery Statement
• Applicable information security, privacy and HR policies

Agreement