1.Overview

This Code of Conduct (“Code”) outlines the expectations Absolute Veritas places on its employees, partners, consultants, advisors, contractors, vendors, suppliers, and all third-party representatives (collectively referred to as “Suppliers”), both in India and abroad. It sets the standard for ethical business practices, legal compliance, workplace behavior, and the overall professional conduct expected while engaging with or working on behalf of Absolute Veritas.

Suppliers are required to adhere to all relevant laws, regulations, contractual obligations, and AV procurement guidelines. This Code aims to foster an ethical, professional, and positive work environment.

2. Ethical Business Practices

Absolute Veritas is committed to integrity and fairness in all its operations. We expect our Suppliers to uphold and reflect this commitment in their business practices.

1. Business Integrity: Bribery, kickbacks, facilitation payments, and improper exchanges of value are strictly prohibited. Gifts or entertainment should be modest, occasional, legally permissible, and must not be given with the intent to influence business decisions. Cash or cash equivalents (e.g., gift cards) are not permitted.

2. Compliance with Government Regulations: Absolute Veritas adheres to the directives of the Government of India, including CVC and GFR guidelines, and expects Suppliers to do the same.

3. Political Lobbying: Suppliers are expected to be aware of and comply with applicable local laws related to lobbying activities. Lobbying includes attempts to influence laws, policies, or regulations, and may extend to procurement and business development activities.

4. Accountability: Suppliers are expected to maintain high professional standards, meet their contractual commitments, and perform their services for Absolute Veritas with diligence and expertise.

5. Unfair Competitive Practices: Absolute Veritas does not engage in or support unfair competition or deceptive business practices.

6. Financial Records: Suppliers must maintain accurate and transparent financial records related to dealings with Absolute Veritas, in compliance with applicable accounting standards.

7. Fraud: Any form of deception, theft, or fraudulent activity is prohibited.

8. Insider Trading: Suppliers must protect confidential, non-public information and not use it for securities trading or other personal gain.

9. Political Donations: Suppliers must not offer company funds or assets as donations to government bodies or officials to gain favorable treatment.

10. Conflict of Interest: Suppliers must steer clear of any situations that could lead to, or be perceived as, a conflict of interest. Any potential conflict must be promptly disclosed to Absolute Veritas.

11. Data Privacy & Security: Suppliers must protect personal data and comply with relevant data protection laws and agreements with Absolute Veritas.

12. Confidential Information: Suppliers must safeguard Absolute Veritas confidential information and intellectual property, using it only for authorized purposes and under appropriate agreements.

13. Fair Competition: Suppliers must comply with antitrust and competition laws applicable in India and other jurisdictions.

14. Trade Compliance: Suppliers must follow trade laws, including sanctions, embargoes, and export/import regulations.

15. Anti-Money Laundering: Absolute Veritas prohibits all forms of money laundering. Suppliers must take steps to prevent involvement in such practices.

16. Responsible Sourcing: Suppliers must ensure materials are sourced responsibly and, where required, demonstrate efforts to avoid conflict minerals.

3. Respectful Workplace Practices

1. Anti-Harassment & Anti-Discrimination: Absolute Verita maintains a zero-tolerance policy toward any form of discrimination or harassment based on race, gender, religion, age, disability, or any other legally protected status. Suppliers must create and uphold a workplace free from abusive, offensive, or hostile behavior.

2. Labor and Human Rights: -Child labor, forced labor, and human trafficking are strictly prohibited.
   -Workers must have control over their own documents and freedom of movement.
   -Suppliers must verify the legal working age and respect all applicable employment laws.

3. Working Hours and Compensation: Working hours must comply with legal limits. Wages must meet or exceed minimum wage laws and be sufficient to meet basic needs where no such law exists.

4. Freedom of Association: Suppliers must respect workers’ rights to unionize, bargain collectively, and raise concerns without fear of retaliation.

4. Health, Safety, and Environmental Responsibility

1. Safety and Quality: Suppliers must ensure a safe and healthy workplace, comply with safety regulations, and meet all quality standards required by Absolute Veritas and applicable law.

2. Environmental Protection: Suppliers must minimize their environmental impact and comply with environmental laws concerning emissions, waste management, and hazardous substances.

5. Reporting Violations

Suppliers are required to report any suspected breaches of this Code, including those involving Absolute Veritas personnel. Reports may be submitted anonymously where allowed by law, via direct contact with the business representative or via AV official communication channels.

Violations may lead to review and possible termination of the business relationship, subject to contractual and legal provisions

Employee Conduct for AV Visitors

Employees, consultants, and other associates of Absolute Veritas are expected to uphold professional standards at all times, both on- and off-premises.

7. Disciplinary Procedure

1. Informal Action: Used for minor misconduct. Managers may counsel the employee in a one-on-one discussion to encourage improvement.

2. Formal Action: Triggered by allegations of serious misconduct. The process includes:
   -Written complaint.
   -Preliminary investigation.
   -Appointment of an adjudicating officer.
   -Prior notice and a fair opportunity for the employee to present their response.
   -Collection of evidence and witness statements.
   -Final report and penalty recommendation based on findings.
   The employee has the right to appeal within 30 days of the decision.

3. Possible Penalties: -Censure.
   -Withholding salary increments.
   -Recovery of financial losses.
   -Demotion.
   -Suspension.
   -Termination.

4. Grounds for Immediate Suspension: -Possession of dangerous items.
   -Intoxication.
   -Criminal charges involving moral turpitude.
   -Threat to workplace safety.

Suspension during investigation is not considered disciplinary punishment.