Code of Conduct Policy

1. Overview

This Code of Conduct policy ("Code") applies to all Aleph employees, business associates, partners, consultants, advisors, independent contractors, vendors and suppliers of materials, products or services, including their subcontractors, agents, representatives, suppliers, third party consultants, and employees, regardless of the materials, products or services they provide to Aleph, including without limitation suppliers or vendors of raw materials, component parts, or professional services whether in India or overseas ("Suppliers"). Aleph recognizes the need to establish this Code for its Suppliers in order to define the way business relationships, official dealings, social behavior and comradiere needs to be maintained within and outside of office premises.

The present Code enlists various rules, principles, values, behaviors and policies which every Supplier is expected to follow while working with the Aleph group. Suppliers must adhere to all applicable laws; legal regulations, directives, and guidelines; and all obligations in any contract a Supplier has with Aleph. Suppliers must follow established Aleph procurement rules and procedures. As a condition of doing business with Aleph and partnering in our mission, we expect our Suppliers to share in our commitment to conduct business in the most ethical and professional manner and to maintain a healthy, friendly, conducive and a positive work environment.

2. ETHICAL BUSINESS PRACTICES

Aleph works every day to operate its business in a fair and ethical manner, and to set a high standard of business integrity. We expect the same from our Suppliers. Aleph does not buy market access, business, or policy outcomes with money, gifts, or other perks.

A. Business Integrity

Aleph strictly prohibits the receipt, offer orpayment of bribes, kickbacks, facilitation payments or the exchange of anything of value (directly or indirectly) intended to advance Aleph's business interests or provide undue or improper advantages for Aleph or you. While it may sometimes be appropriate to exchange gifts or offer entertainment, Suppliers should not use these business courtesies to gain an improper advantage or preferential treatment. Suppliers should ensure that gifts or entertainment are modest in value, infrequently provided, and consistent with local law and the internal rules of the recipient’s employer. Gifts of cash or cash equivalents, such as gift cards, are not allowed.

B. Aleph Framework includes Instructions of GOI / Guidelines of CVC

Aleph substructure strictly complies with all current and pertinent directives from the Government of India (GOI), including the CVC guidelines, the GFR issued by the Ministry of Finance, and other directives that are pertinent.

C. Political Lobbying

Suppliers are responsible for understanding when their activities for Aleph may beconsidered lobbying in a particular jurisdiction and for complying with all applicable laws. "Lobbying" generally means any activity thatattempts to influence laws, regulations, policies, and rules, and in some countries, can also mean business development and / or procurement activities.

D. Accountability/Professional Liability

As Aleph, we adhere to ethical business conduct standards and hold ourselves accountable to a particular level of priority. Since we are providing the information or service and payment is being made in accordance with the terms of the contract. In order to ensure adequate accountability, we stand up to maintain the professional standard with appropriate terms and conditions and curtain parameters. We complete our task with care and in accordance with industry standards that are currently in effect. The governed law is also reflected in Aleph's standard.

E. Unfair Competitive Advantage

We reject any policy promoting unfair competitive advantage and don't consider ourselves to be a part of it. Unfair competition occurs when another company uses wrong or deceptive business practices to gain a competitive advantage.

F. Financial Integrity, Records and Accounting

Aleph relies on our books and records to report our financial results, make required legal filings, and make business decisions. As our Supplier, we count on you to keep and maintain accurate books and records of all your business dealings with and for Aleph in accordance with applicable standard accounting practices.

G. Fraud

We expect our Suppliers to act honestly and with integrity. Seeking to gain an advantage of any kind by acting fraudulently, stealing, deceiving people or making false claims, or allowing anyone else to do so is prohibited.

H. Insider Trading

As an Aleph Supplier, more specifically employees, business associates, partners, independent contractors, you may have access to confidential information, documents, data and other material, non-public information about Aleph or other clients/companies. Such information and material shall be kept confidential at all times by the Suppliers and shall not be used in any manner to cause any harm to the Aleph group. Aleph has zero tolerance for misuse and unauthorized use of the information and assures that a strict action will be taken against any offending Supplier. Information is material if a reasonable investor would consider it important in deciding whether to buy, sell, or hold a company’s securities. Suppliers may not buy or sell Aleph securities while in possession of material, non-public information or provide that information to others who trade on it.

I. Donations to Political Parties and Government Agencies

Aleph, its Suppliers and employees shall not offer or give any company funds or property as donation to any government agencies or their representatives, directly or through intermediaries, in order to obtain any favourable performance of official duties.

J. Conflict of Interest

Suppliers must avoid all conflicts of interest or even the appearance of conflicts of interest. Suppliers are expected to promptly disclose to their Aleph business representative actual or potential conflicts of interest relating to their business activities as an Aleph Supplier.

Some examples of situations that could create conflicts of interest include:

• Hiring or making an offer of employment to an Aleph employee or their family member;
• Vendor or client or any third party, that are owned or controlled, directly or indirectly, by an Aleph employee or their family member;
• Providing any form of compensation, fees or commissions to Aleph employees;
• Pursuing or competing for business opportunities that belong to Aleph;
• Obtaining an unfair advantage by acting on information learned through the irrelationship with Aleph;
• Any other activity that might adverselyaffect Aleph, our business, or ourreputation.

K. Data Privacy and Information Security

Suppliers who collect, receive, store or otherwise process personal data in connection with the products or services they provide to Aleph must appropriately handle and protect such data (to Aleph's satisfaction at all times, before, during and after the relationship with Aleph), and comply with all native laws, rules, regulations and agreements with Aleph applicable to the processing of such data.

L. Confidential Information

Suppliers are expected to safeguard all Aleph confidential information, electronic data, intellectual property, know-how, and technologies. Suppliers must transfer any such confidential information, electronic data, intellectual property, know-how, or technologies in a way that secures and protects the intellectual property rights of Aleph and its business partners.

Suppliers may receive Aleph’s confidential information only as authorized by a confidentiality or non-disclosure agreement and must comply with their obligations therein to not disclose the confidential information. Also, Suppliers must never use any illegal or unethical means to get information about other companies in connection with their businesswith Aleph.

M. Anti Trustand Competition Laws

Aleph is committed to competing fairly for the benefit of consumers and following antitrust and competition laws in the India and internationally. We expect our Suppliers to comply with all applicable laws, regulations and standards of fair business, advertising and competition in India as well as in their domestic regions, as may be applicable.

N. Trade Compliance Laws and Regulations

Suppliers are responsible for: complying fully with all trade laws and regulations, including embargoes and sanctions; understanding how global trade laws and regulations apply to their business; and adopting appropriate policies, procedures and controls to comply with these laws, including import and export laws that apply to technology, software, intellectual property, and technical information as well as materials and goods.

O. Anti-Money Laundering Compliance and Reporting

Money laundering in any form is prohibited. Money laundering includes disguising or concealing the nature, location, source, ownership or control of unlawfully obtained money, or transforming such money into legitimate funds.

P. Conflict Minerals and Responsible Materials Sourcing

Aleph expects Suppliers to maintain sufficient knowledge of input materials and components to reasonably assure that they were obtained from permissible sources in compliance with all relevant laws and regulations. Suppliers are expected to cooperate with Aleph, in good faith, to perform the necessary due diligence to allow Aleph to report to regulatory agencies, as may be required from time to time. Suppliers are expected to use commercially reasonable efforts to supply commodity metals to Aleph that are “conflict-free”, and should be prepared to certify to such a designation upon request.

3. RESPECTFUL TREATMENT OF INDIVIDUALS

Aleph expects its Suppliers to embrace and support the following labor and human rights principles:

A. Anti-Harassment and Anti-Discrimination

Aleph is committed to the principles of equal employment opportunity, inclusion and respect. We do not tolerate discrimination on the basis of: race, color, religion, sex, pregnancy (including childbirth), lactation or related medical conditions, age (40 and over), national origin or ancestry, physical or mental disability, marital status, medical condition, sexual orientation, gender identity and gender expression, military service status, genetic information or any other status protected by law; nor do we tolerate harassment in any form against anyone.

Suppliers shall commit to a workplace that is free of harassment and abuse, including sexualharassment, corporal punishment, inhumanetreatment, or any harassing behavior (verbal, visual, or physical threats or demands) that creates an intimidating, offensive, abusive or hostile work environment.

Suppliers are expected to support diversity and equal opportunity in their workplaces, and prohibit unlawful discrimination of any kind.

B. Labour and Human Rights

Aleph is committed to compliance with human rights laws. We do not use or condone the use of child or involuntary labor or human trafficking, and we denounce any degrading treatment of individuals or unsafe working conditions.

Suppliers will not: participate in human trafficking or exploitation, or procure or supply goods tainted by human trafficking; use any form of involuntary, slave, forced, bonded or indentured labor, regardless of local business customs, or purchase products or services from companies using involuntary, slave, forced, bonded or indentured labor.

Suppliers must ensure that their workers have access to their passports and personal documentation at all times.

The use of child labor is prohibited. "Child" means any person under the age of 15, or under the legal minimum age for employment in the country, whichever is greatest. Suppliers must verify all workers’ dates of birth.

Suppliers shall operate in a way that ensures working hours, including overtime, are humane and productive and do not exceed applicable legal limits.

Aleph expects its Suppliers to embrace and support the following labor and human rights principles:

C. Working Hours and Compensation

Suppliers shall operate in a way that ensures working hours, including overtime, are humane and productive and do not exceed applicable legal limits.

Suppliers shall provide wages at least equal to the applicable legal minimum wage and any associated statutory benefits.

Where there is no legal minimum wage, Suppliers must compensate workers at a level that allows them to meet their basic needs.

D. Freedom of Association and Collective Bargaining

Suppliers are expected to permit their workers to associate freely, bargain collectively, and seek representation in accordance with local laws.

Workers should also be permitted to openly communicate and share grievances with management about working conditions without fear of reprisal or harassment.

4. HEALTH, SAFETY AND ENVIRONMENT

At Aleph, we are committed to safety and aspire to play a meaningful role in creating a sustainable future and addressing environmental challenges.

A. Safety, Reporting and Quality

Suppliers will provide their workers with a healthy and safe work environment, and take proactive measures that support accident prevention and minimize health risk exposure.

Suppliers must obtain and keep current all required environmental permits, approvals, and registrations, and follow their operational and reporting requirements.

Suppliers’ materials and products must meet regulatory quality and safety standards, in addition to our internal quality standards, policies, specifications, procedures, and contract requirements.

B. Protecting the Environment

Suppliers are expected to conduct their operations in a way that minimizes the impact on natural resources and protects the environment, customers and workers, and ensure their operations comply with all applicable laws related to air emissions, water discharges, toxic substances, and hazardous waste disposal.

Suppliers should look to international, federal, state and local environmental laws, rules and regulations to guide their efforts at minimizing the emission, generation, discharge and disposal of hazardous materials and other waste.

5. REPORTING CONCERNS

We expect our Suppliers to promptly report to us all violations or suspected violations of this Code. This includes reporting information about the potential misconduct of an Aleph employee. If allowable in the country where the report is lodged, the report can be made anonymously. Suppliers can contact their Aleph business representative or write an email on Aleph’s official email account to report known or suspected misconduct or raise an ethical concern.

Aleph takes compliance with this Code very seriously, and reserves the right to assess and monitor Suppliers’ compliance with this Code. Violations by Suppliers of this Code will result in a review of our business relationship, up to and including termination of the relationship according to our contractual rights and applicable law.

6. CODE OF CONDUCT FOR EMPLOYEES, PARTNERS, CONSULTANTS AND ADVISORS OF ALEPH WHO VISIT THE OFFICE OF THE COMPANY

The professional image of Aleph is directly linked to the way each employee presents themselves and behaves. Therefore, all employees are expected to maintain, conduct and behave professionally, both in the office and while on business in other locations. This includes maintaining a standard of good habits, quick and fair judgment, a courteous approach etc. to both clients and fellow employees. While Aleph will always support its employees in their growth, in the case of personnel who violate the policies contained in this Code or act in a manner that adversely affects the interests or reputation of Aleph, disciplinary measures shall be taken by Aleph.

A. Guiding Principles

Employees are expected to observe the following basic principles of service:

• Observe the office hours of their shift and work in a time bound manner (tardiness is not considerate of colleagues and is not acceptable).
• Be ready for work in appropriate attire as per the Dress Code Policy maintained by Aleph.
• Keep/place office equipment, documents, and the like to their respective places before leaving the office.
• Carefully use equipment, machines, instruments, and other supplies in the office, save expendable supplies, and carefully handle documents and keep them in strict confidence.
• Do not communicate/transfer any business information of the company to any other person without prior approval of the authorized person.
• Do not enter the office or use equipment, machines, instruments and other supplies in the office for any purpose other than business without prior approval.
• Keep things in order in the workplace and keep the workplace clean at all times.
• Do not interfere with any operation or disturb the discipline and order of the workplace.
• Do not illegally borrow money or receive a gift from an Aleph client or any third party in connection with services provided.
• Do not smoke anywhere other than designated places or use fire, including open-air fire and electric heaters. Building bye-laws must also be adhered to at all times.
• Do not leave the workplace during the working hours without permission.
• Do not receive visitors for personal reasons during working hours without prior approval from their supervisor.
• If offered corporate hospitality, entertainment, or personal services either free or at less than market price (unless at approved rates or discounts available to all employees), by a supplier as an enticement to conduct business, the employee should ensure that this doesn’t compromise their professional integrity and judgment.

B. Simple Misconduct

The following acts of omission and commission shall be treated as simple misconduct:

• Late or irregular attendance
• Negligence or neglect of work including slowing down of work.
• Furnishing false information regarding name, age, father's name, qualifications, previous service or any other matter germane to the employment, at the time of employment or during the course of employment.
• Sleeping while on duty.
• Personal use of a company computer and/or ancillary electronic equipment or other resources during working hours.
• Repeated or serious failure to follow instructions.
• Unreasonable behavior to work colleagues.

C. Gross Misconduct

The following acts of omission and commission shall be treated as gross misconduct:

• Theft, fraud, or dishonesty in connection with the business or property of the Company or of property of another person within the premises of the Company.
• Taking or giving bribes or any illegal gratification.
• Engaging directly or indirectly in any business, trade or profession or canvassing for any profession, business or trade owned or managed by a member of his family without written permission of the company.
• Transactions, by way of borrowing or lending money with fellow-employees habitually, or, with any other person/firm/private limited company/agent with whom the employee has or is likely to have any official dealings, including insolvency and habitual indebtedness.
• Abuse of official position or exerting pressure, directly or indirectly, to secure employment or any other pecuniary benefit for any member of employee's family in any undertaking having direct dealing with the company.
• Acceptance of gifts by the employee or any member of his family or any person acting on his behalf, in contravention of the rules and policies of the company.
• Willful insubordination or disobedience, whether or not in combination with others, of any lawful and reasonable order of the employee's superior in connection with the Company's work.
• Use of a company computer to view obscene, pornographic, racist, destructive and/or illegal material.
• Deliberate falsification of records or deliberate failure to maintain records.
• Any act of discrimination towards race, gender, colour, creed, age or disability.
• Habitual late or irregular attendance.
• Habitual negligence or neglect of work including slowing down of work.
• Interference or tampering with any safety devices installed in or about the premises of the Company or willful damage to any property of the Company.
• Gambling within the premises of the Company.
• Collection without the permission of the competent authority of any money within the premises of the Company except as sanctioned by any law of the land for the time being in force or rules of the Company.
• Commission of any act which amount to a criminal offence involving moral turpitude, including cyber offences such as cyber bullying.
• Habitual or prolonged absence from the employee’s appointed place of work without permission or sufficient cause.
• Commission of any act subversive of discipline or good behavior.
• Striking work or inciting others to strike work in contravention of the provisions of any law, or rule having the force of law.
• Breach or violation of the rules, regulations or orders applicable to the employees.
• Assaulting, threatening or abusing or insulting or intimidating or surrounding and forcibly detaining any employees or officer of the Company within or outside the premises of the Company.
• Abetment, or attempt at abetment, of any act which amounts to misconduct.
• Commission of any act of sexual harassment such as physical contact and advances, sexually coloured remarks, showing pornography, sexual demand and any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

NOTE: The above instances of both simple and gross misconduct are illustrative in nature and not exhaustive.

7. DISCIPLINARY PROCEDURE

A. Informal action

• Informal action will be taken in cases of simple misconduct. A one-to-one confidential discussion between the superior and the delinquent employee will be held with the intention of gaining sustained improvement in the employee's conduct.
• This discussion should enable the superior to provide constructive feedback and the employee to express his views on the issue. It is important for both parties to understand that informal action is not formal disciplinary action and employees are not entitled to representation at this stage.

B. Formal action

A formal action is usually taken when an allegation is made against the employee alleging that such employee has demonstrated unacceptable behavior/conduct, including gross misconduct. The following procedure shall be followed in situations where a formal action is required to be taken against such employees:

• Any employee/HR/manager who alleges gross misconduct on part of the other employee of Aleph shall present a written complaint to the immediate superior authority of such delinquent employee detailing the date and place of occurrence of the incident; details of the employee; witnesses, if any, and their statements.
• Once a written complaint is received by any superior, they shall conduct a preliminary enquiry and gather evidence against the delinquent employee. All the evidence has to be reduced to writing.
• The inquiry proceeding shall be headed by such adjudicating officer as authorized by Aleph from time to time.
• The employee must be given advance notice of at least 05 days before the first meeting so as to give the employee reasonable time for preparing his defense.
• The superior shall observe the principles of natural justice and procedural fairness at all times. The delinquent employee who is the subject of concern shall be informed of all the allegations in relation to his/her behavior and such employee shall be provided with the opportunity of being heard besides appointing a representative of his own choice. Such representative may be an employee of Aleph.
• The investigation will include the collation of evidence, taking statements from all relevant parties including witness(es), if any, to the alleged incident(s) of misconduct. Any witness to the alleged misconduct shall sign their written statement for accuracy as soon as possible after the investigation meeting.
• Once the investigation is complete, the adjudicating officer shall record his observations in writing considering the evidence placed before them. If the employee is found guilty, the adjudicating officer shall impose penalty as detailed in the foregoing provisions. The penalty imposed should normally be commensurate with the gravity of the misconduct.
• An employee on whom any of the penalty is imposed shall have the right of appeal to the senior authority notified in this behalf. An appeal shall be filed by the aggrieved employee within a period of 30 days from the date of imposing punishment.

C. Penalties

The following penalties may be imposed on an employee for gross misconduct committed by them in the present, previous or earlier appointment or for any other good and sufficient reasons:

• censure;
• withholding of increments of pay with or without cumulative effect;
• recovery from pay or such other amount as may be due to him of the whole or part of any pecuniary loss caused to the Company;
• reduction to a lower grade or post or to any lower stage(s) in their pay scale;
• suspension from service; and
• termination from service.

D. Suspension

In addition, in the below circumstances, Aleph India may suspend the person from work with immediate effect or require the person to vacate the office:

• When an employee is in possession of a weapon or other dangerous articles which are not necessary to perform their duties.
• When an employee is under the influence of drugs, alcohol or any kind of intoxication.
• When an employee has been arraigned before a court for any offence involving moral turpitude.

If an employee commits serious acts of misconduct such as assault or harassment or any grave offence against human body or property as contained in the penal laws of Indiaand their presence inside the work premises poses a threat to the safety of the personnel and material, they may be kept under suspension immediately, pending investigations. However, such suspension shall not be deemed as punishment for the alleged misconduct.

Compliance with this policy of business ethics and conduct is the responsibility of every Aleph India employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including termination.