Ethics and Compliance Policy for ENH iSecure

  1. Introduction

    ENH iSecure ("the Company") is committed to conducting its business with the highest standards of ethics, integrity, and compliance with all applicable laws and regulations. EnH iSecure Private Limited (the” Company”) expects that all its employees shall, without exception, observe and exhibit high degree of professional ethics, fairness & transparency in conducting themselves in discharge of their duties and responsibilities in line with the Company’s Code of Conduct including all other organizational policies, codes and the laws in force in this regard. We must understand that we must always act with integrity to ensure we are trusted by our business partners, customers and our stakeholders. It is always expected that the employee acts with a high degree of integrity to ensure that trust is maintained by the business partners, customers and the Company’s stakeholders.

    This Ethics and Compliance Policy outlines the principles and guidelines that all employees, contractors, consultants, agents, and representatives of the Company must adhere to in their duties.

    The Code of Conduct (the” Code”) is a central policy document that outlines standards of professional and interpersonal conduct that all employees must comply with and uphold. The Code provides a basis for all employees to maintain a working environment that is productive, positive, enjoyable, safe, and free from harassment and discrimination. This policy, as amended sometimes, shall be available at the HR portal.

  2. Ethical Conduct

    a. Integrity: All employees must act with honesty, integrity, and fairness in all aspects of their work and interactions with others.
    b. Respect: Employees must treat all individuals with respect, dignity, and fairness, regardless of their background, position, or beliefs.
    c. Confidentiality: Employees must maintain the confidentiality of sensitive information entrusted to them by the Company, customers, or other stakeholders.

  3. Responsibility Matrix

    It shall be the responsibility of the Heads of the Departments, to ensure the following: a. Strict implementation of the Code for their team so as to be a role model for Strict adherence to the Code b. All the team members are familiar with the Code and that they follow it by letter and spirit c. Hold such team members accountable for any breach of Code. Any incidence of non-compliance shall be reported to the Head of Human Resources (‘HR’) immediately.

  4. Control Group

    The Control Group shall consist of (i) Board of Operations and (ii) Head of Board. The email to the Control Group shall be grievance.redressal@enhisecure.com.

    For any meeting of the Control Group that is required to be conducted, all the members mentioned above need to be present.

    The Control Group shall be responsible for ensuring that the official’s personnel files containing confidential information are kept in the manner as prescribed under the law along with such security mechanisms and logical controls as prescribed by the Chief Information Security Officer (‘CISO’).

  5. Dealing with External Entities

    Interaction with the Regulatory authorities: Interaction with any Regulatory Authorities shall be done only by the Head of Businesses concerned and/or CEO.
    Contact with the Electronic and Print Media: No employee, other than the person authorized by the Board, shall discuss the affairs of the Company or its subsidiaries with the media and/or post anything on social media. In the absence of any such person so appointed, such person by default shall be the CEO.

  6. Compliance with Laws and Regulations

    a. Legal Compliance: All employees must comply with all applicable laws, regulations, and Company policies in the countries and jurisdictions where the Company operates.
    b. Anti-Bribery and Corruption: The Company prohibits bribery, corruption, kickbacks, and other unethical practices in all its business dealings. Employees must not offer, give, receive, or solicit anything of value to improperly influence business decisions or gain an unfair advantage.
    c. Data Privacy: Employees must respect and protect the privacy rights of individuals and comply with all applicable data protection laws and regulations when handling personal information.

  7. Conflicts of Interest

    a. Disclosure: Employees must promptly disclose any actual or potential conflicts of interest to their supervisor, manager, or the Compliance Officer.
    b. Avoidance: Employees must avoid situations where their personal interests conflict with the interests of the Company or could create the appearance of impropriety.

  8. Gifts, Entertainment, and Hospitality

    a. Guidelines: Employees may accept or offer gifts, entertainment, or hospitality in the ordinary course of business, provided that they are of nominal value, given or received in good faith, and do not create a conflict of interest or the appearance of impropriety.
    b. Approval: Any gifts, entertainment, or hospitality exceeding nominal value must be approved in advance by the employee's supervisor or the Compliance Officer.

  9. Reporting and Whistleblowing

    a. Reporting Violations: Employees are encouraged to report any violations of this policy or other unethical behavior promptly. Reports can be made to the employee's supervisor, manager, Human Resources, Legal Department, or anonymously through the Company's whistleblowing hotline or reporting mechanism.
    b. Non-Retaliation: The Company prohibits retaliation against individuals who make good faith reports of suspected violations of this policy or cooperate in investigations.

  10. Records Management

    a. Employees must be aware of their record-keeping responsibilities and adhere to proper records management practices and procedures.
    b. All employees must ensure that Company’s documents are placed in line with proper records management procedures as prescribed under Information Security Policy/ or respective departmental Standard Operating Procedures (“SOP”).
    c. Employees may remove or replace any control documents from official files only with proper authorization and approval(s). These are checked records and must always be complete and up to date with the capability of providing organizational accountability when officially scrutinized.
    d. Employees must not damage, dispose of, or interfere with official documents or files. The destruction of records shall be duly approved by the head of the department and shall be conducted as per the purging procedures which have been provided under the Information Security Policy.

  11. Countering Bribery and Corruption

    No employee shall be involved in giving or offering to give undue advantage with the intention to:
    (a) Induce a public servant to perform a public duty improperly; or
    (b) Reward such public servant for the improper performance of public duty.

    No employee shall be involved in making or offering to make payments of bribes to public servants in order to:
    (a) Obtain or retain business for the Company; or
    (b) Obtain or retain an advantage in the conduct of business for the Company.
    No employee shall give or receive undue advantage or payments of bribe to any person(s) (including a corporate person) with the expectation of any favor in return.

  12. Dual Employment, Directorships and Vested Interest

    a. No employee shall be permitted dual employment or directorship, unless permitted by the Head of Human Resources and Head of Legal due to any exceptional circumstances.
    b. No employee shall join the competitors or the client of the Company during the subsistence of their employment with the Company.
    c. Employees shall voluntarily disclose if they have any relative working in the Company.
    d. Employees shall disclose whether they hold any shares in the competitors or the clients of the companies to the Head of Human Resources.

  13. Dealing with Clients

    An employee who receives any complaint from any Client or Customer shall acknowledge the receipt within 2 (two) working days and shall resolve the complaint within 14 working days. If the redressal of the complaint requires more time, the same shall be communicated to the complainant duly acknowledging the receipt of the complaint within 2 (two) working days.
    All replies being sent to the Client or Customer shall be duly approved and/or authorized by the Head of Department concerned.

  14. Training and Awareness

    The Company will provide regular training and awareness programs to employees to ensure understanding of this policy and compliance with ethical standards and legal requirements.

  15. Attendance & Punctuality

    The Company relies on all employees to contribute productively to its success and profitability.
    a. Regular attendance and punctuality are expected of all employees. When tardiness or absence is unavoidable, an employee must notify his or her direct manager prior to the normal start time, or in the case of an emergency, as soon as reasonably possible.
    b. An employee who is absent without getting due approval either from the reporting line manager or the HR for a continuous period of five (5) days would automatically be moved out of HRIS/HR system. Re-login shall be permitted only upon due authorization from the reporting line manager.

  16. Hours of Work

    The work timings are from 09:00 AM to 06:00 PM, and a normal work week consists of forty-eight (48) hours of work.

  17. Consequences of Non-Compliance

    Violations of this policy may result in disciplinary action, up to and including termination of employment or business relationship, as well as civil or criminal penalties for individuals involved in unethical or illegal behavior.

  18. Prevention of Sexual Harassment

    The Company believes that all employees should:
    (a) Can work in an environment free from sexual harassment,
    (b) Complement each other as equals, and
    (c) Have the right to be treated with utmost respect and dignity (Kindly refer to POSH Policy for more information).

    a. The employee aggrieved due to sexual harassment may file a Complaint with Internal Complaints.
    b. Committee (‘ICC’) by writing to Grievance.Redressal@enhisecure.com.
    c. The Disciplinary Action for Sexual Harassment may, amongst other things, include dismissal from employment with the Company.
    d. In case of third-party sexual harassment at the workplace, the Company will actively assist and provide all its resources to the complainant in pursuing the complaint and ensure their safety at the workplace.

  19. Alcohol and Un-Prescribed Drugs

    Consumption, possession or illegal trafficking of alcohol, psychotropic drugs is strictly prohibited under the law during employment.
    Any employee coming across any such breach of discipline shall immediately report the matter to the HR Department. The Company reserves the right to take any appropriate disciplinary action, which may include immediate termination of employment.

  20. Smoking

    Smoking is strictly prohibited within the premises of the Company.

  21. Conclusion

    All employees, contractors, consultants, agents, and representatives of ENH iSecure are expected to familiarize themselves with this Ethics and Compliance Policy and adhere to its principles and guidelines in their day-to-day activities.