CODE OF ETHICS

EMPLOYEE CODE OF CONDUCT

1. Private Business/ Employment/ Consulting Assignment:

No employee shall engage, either directly or indirectly, in any trade/consultation, with or without remuneration during his/her employment with the organization. Any exception to this needs prior written permission of the management, any such requests should be directed to the concerned HRBP.

2. Confidentiality:

No employee shall be associated in any way with media or external agencies, to reveal business/technical information, unless authorized to do so.

3. Gifts from suppliers/ customers:

No employee shall directly or indirectly accept any gifts in cash or kind, or avail or offer any kind of entertainment, donations, facilitation payments from or to our suppliers or customers and at all times must be guided by our Gift & Hospitality policy.

4. Conflict of interest:

a) No employee shall directly or indirectly be associated with any supply of goods/materials/services to the organization or have any financial dealings with the organization’s customers, agents or suppliers.
b) Situations that include either financial or personal gains of employees or their close affiliates or family members must be avoided. In case the situation should arise, a conflict of interest must be declared to your line manager & HRBP, as outlined under this Code.

5. Financial & Business reporting:

All organizational transactions must be duly recorded in conformity with generally accepted accounting/reporting principles. No false or misleading entries may be made in the books of the Company.

6. POSH :

Time to time employees are appraised by the trainings on the “Prevention of Sexual Harassment” Act. Women employees can register an official complaint as per company’s whistleblower policy on the portal.

How To Register A Complaint On Whistleblower Portal?

• Employees can register their Whistle Blower may report Concerns orally in person/telephonically or in writing (via email) or anonymously. Whistle Blower must give rationale behind defining the incident as an Improper Activity.
• Email ID – compliance@syndrometech.net
• Website :- https://syndrome.integritymatters.in Contact : +91-22-40332201
• The Whistle Blower should provide as much specific information as possible including names, dates, places and events that took place.
• Suspicion of an improper activity/Concern can also be reported in the same manner.
• Anonymous reporting must provide sufficient corroborating evidence(s) to justify an Investigation.

SUPPLIER CODE OF ETHICS

• The Suppliers shall maintain business integrity by – complying with all applicable laws and regulations including laws related to human rights, Anti-Bribery and Anti-corruption; not engaging in any corrupt practices for obtaining or retaining business or gaining improper advantage; adhering to the Company’s Gifts and Hospitality policy while exchanging gifts, etc.
• The Supplier shall respect Company’s confidentiality by – following applicable data privacy laws; abstaining from making any video and/or audio recording during discussions without prior consent, not sharing confidential information without written consent from procurement head with regard to pricing, volume, intellectual property, organization designs/plans, operating systems and technology platforms, etc.
• The Supplier shall disclose all potential sources of conflict of interest – Conflict of interest exists when Supplier’s direct/indirect personal interests are inconsistent with/interfere with best interests of the company. To prevent the same, the Supplier shall disclose all family/ social/ political affiliations with the Company to the Company before entering into such business transaction.
• The Supplier shall engage in fair trade practices and processes by – not taking advantage of social/political connections for favorable treatment in business; not engage in anti-competitive activities like cartelization; ensuring quality assurance of products and/or services, etc.
• The Supplier shall advocate whistle-blower protection by – Escalating any misconduct, unethical or dishonest behavior by any of the company staff by the channels provided (refer Company’s Whistle-Blower policy for more details); Endeavoring to develop mechanisms to expose the Company staff/business associates wrong practices in business dealings; Cooperating with the Company in the investigation of reported misconduct, unethical or dishonest behavior, etc.
• The Supplier shall share this Supplier Code of Ethics with all its employees who may be engaged in conducting business activities with the Company or its subsidiaries and affiliates.
• The Supplier shall provide the declaration (Format B) and the disclosures (Format A) in the prescribed format on a periodicity as determined by the Company.
• Supplier can register a complaint on the violation of the Code of Conduct by Syndrome Employee by sending an email from their registered EMAIL ID on compliance@syndrometech.net. Supplier registering a complaint should provide as much specific information as possible including names, dates, places and events that took place.