Code of Business Conduct

This Code sets out the standards of behaviour expected at SISLCloudWorx Pvt. Ltd. and its subsidiaries, and of everyone who works with us — employees, contractors, business partners, agencies, suppliers, subcontractors, and their representatives.

It is not a substitute for the law or for your contract with us. Where this Code and local law differ, follow whichever sets the higher standard; where they genuinely conflict, tell us before you act.

If you work with us and cannot meet a requirement in this Code, say so. We would far rather have the conversation than discover the gap later.

We expect work to be done with integrity, competence, and candour:

– Keep commitments, and describe status honestly — including when it is bad.

– Raise problems early, when they are still cheap to fix.

– Never let a customer form a false impression through silence or selective disclosure.

Compete on the merits of our work.

– Do not agree with competitors to fix prices, rig bids, or allocate customers or territories.

– Do not obtain a competitor's confidential information improperly.

– Do not disparage competitors with claims you cannot substantiate. Any comparative claim we publish must be accurate, current, and defensible.

Protect information entrusted to us — our own, our customers', and our partners' — with safeguards appropriate to its sensitivity, and use it only for the purpose it was shared for.

– Never paste customer data, credentials, or confidential material into an external tool, including a third-party AI assistant, that has not been approved for it.

– Comply with applicable data protection law, including the Digital Personal Data Protection Act, 2023 and, where relevant, the GDPR and UK GDPR.

– Report any suspected data breach immediately (see Raising a Concern). Do not attempt to resolve it quietly first — we have regulatory notification deadlines measured in hours.

Comply with the laws that apply wherever we operate, including export controls and trade sanctions, anti-money-laundering rules, anti-bribery and anti-corruption law, tax law, and any sector regulation that flows down to us from our customers.

– Keep honest, complete, and timely records. Never falsify a record, backdate a document, or create one to mislead.

– Respect intellectual property. Use only properly licensed software, and do not incorporate third-party code, models, or datasets into our products without confirming the licence permits it.

– Use company assets, cloud accounts, and credentials responsibly and for legitimate business purposes.

We build and operate systems that process our customers' data and, increasingly, route their AI workloads. That carries obligations beyond ordinary software delivery:

– Describe capability, cost, and performance accurately. Do not publish a benchmark or a saving we cannot reproduce.

– Do not train models on customer content, and do not engage a provider that reserves the right to.

– Design defaults that protect the customer — the most restrictive data-retention posture for new accounts, spend controls that fail safe, and security controls that fail closed where failing open would expose data.

– Decline work intended to build unlawful surveillance, deceptive content at scale, or systems that make consequential decisions about people without human review.

We support internationally recognised human rights, and we hire and promote on merit.

Discrimination or harassment on the basis of race, colour, religion, caste, sex, gender identity, sexual orientation, national origin, age, disability, marital status, or any other protected characteristic is prohibited.

Sexual harassment is treated as a serious violation and is handled through our Internal Committee under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

We prohibit child labour, forced labour, bonded labour, and human trafficking in our operations, and we expect the same of our suppliers.

Suppliers must verify the age and right to work of their personnel and keep those records available to us on request. Working hours, wages, and benefits must meet applicable law.

Provide a safe place to work, report hazards and incidents promptly, and meet applicable environmental obligations.

– Never offer, promise, give, request, or accept anything of value to obtain an improper advantage. This includes facilitation payments.

– Particular care applies to government officials and to public-sector procurement.

– Modest, infrequent, transparent hospitality is acceptable. Anything that could reasonably create a sense of obligation is not — if you would be uncomfortable seeing it reported, decline it and tell your manager.

– Political and charitable contributions must never be used to obtain business advantage.

Disclose promptly any interest that could compromise, or appear to compromise, your judgement — an outside role, a financial interest in a customer, competitor, or supplier, or a personal relationship affecting a procurement or hiring decision.

Disclosure is usually enough. Concealment is the problem.

If you see something that appears to breach this Code, the law, or our security and privacy commitments, report it. You may report to your manager, or confidentially to conduct@sislcloudworx.com. Reports may be made anonymously.

– Security or personal data incidents: report immediately to privacy@sislcloudworx.com. Speed materially affects our regulatory obligations.

– We prohibit retaliation against anyone who raises a concern in good faith, or who assists an investigation. Retaliation is itself a breach of this Code.

– We investigate proportionately, and as confidentially as we can while still investigating properly.

Breach of this Code may lead to disciplinary action up to termination of employment, termination of a contract or supply relationship, and referral to the authorities where the law requires it.

SISLCloudWorx Pvt. Ltd.

A-10/11, Mohan Cooperative Industrial Estate, Mathura Road, New Delhi – 110 044, India

Code of Conduct and whistleblower reports: conduct@sislcloudworx.com

Privacy and security incidents: privacy@sislcloudworx.com

Phone: +91-11-26700800