Code of Conduct

Indi Trade expects all employees to act in accordance with the highest standards of personal and
professional integrity in all aspects of their employment. This is required to outline the
obligations of every individual that governs the organization’s decisions and actions. Any act
which is dishonest or deceitful and against the following rules of code of conduct will be
considered as fraud and unethical activity. All employees are required to sign a copy of the
“Code of conduct” at the time joining the organization.

1. Compliance Policies

1.1 Know Your Customer:

This policy requires employees to collect necessary information on all prospective customers so
that employees have a clear understanding of the customer’s genuineness and source of funds.

1.2 Anti money Laundering:

Money laundering is the process of converting illegal proceeds so that funds are made to appear
legitimate. Any information or suspicion of AML activity should be reported to Compliance
Officer and CEO of the organization.

2. Confidentiality Policy

One of our most important assets is keeping our customers’ trust. All information related to the
customer which is shared with us should be used only for the reason it has been given to us or if
the law requires us to do so. While employed and after employment terminates, no employee
may disclose confidential information about a customer, supplier or distributor to anyone
including other employees who are not authorized to receive or know about the information.

3. Receiving/Giving gift Policy

No gifts may be accepted by the employees from the customer, supplier or others. Exception is
for non-cash gifts whose value should not exceed Rs.1000. All gifts irrespective of the amount
have to be informed in writing to the supervisor. Company policy does not permit gifts.

Indi Trade Microfinance Page 1

However, if circumstance warrants, the organization policy provides giving a customary gifts for
special occasions. The person receiving this gift should not interpret this as in lieu of a
consideration or business favor.

4. Customer Selection

Employee should not be biased in the selection of customers due to personal interest and refrain
from providing incorrect and untrue information about the customer.

5. Whistle Blower Policy

If an employee suspects a possible violation of a law, regulation or ethical standards of the

company, or if the employee is being asked to do something which is improper or illegal, the
employee has to report his/her concern to the supervisor/ HR department. All reported case will
be handled confidentially and thoroughly investigated. The organization assumes that the whistle
blower has acted in good faith and that the complaint has been used on a genuine concern. If the
finding by the investigating team indicates that the complaint has been done with malice or is
discriminatory, frivolous, baseless, and other than in good faith, action will be initiated against
the complainant.

6. Accuracy of Organization Records and reporting

The records, data and information sourced, owned, used and managed by the employees must be
accurate and complete.

7. Sharing of Personal Computer Software

Employees are prohibited from copying, selling or distributing software and software manuals in
violation of license agreements and copyright laws. This policy specifically covers use of
personal computer software distributed to employees at the time of hiring.

8. Information Security

Employees are prohibited from sharing passwords, access rights and login rights with team
members or supervisors. Employees should ensure that unauthorized software is not loaded to

Indi Trade Microfinance Page 2

computers. No employee is allowed to access another employee’s system to send mails, make
system updates or access any files in the presence or absence of other employee.

9. Harassment and intimidation

Indi Trade prohibits sexual or any other kind of harassment or intimidation whether committed
by or against a co-worker, supervisor, customer or visitor. Employees will not use any abusive
language either among colleagues, clients, subordinates or supervisors. Employees will not
discriminate on any issue based upon caste, creed, religion or gender. Any offensive behavior
should be reported to supervisor or HR.

10.Drug Free Workplace

Using, selling, manufacturing, distributing, processing or being under the influence of drugs or
alcohol on the job is prohibited. Smoking and chewing tobacco is prohibited within the office
premise.

Indi Trade Microfinance Page 3