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ETHICS and Code of Conduct Policy

ETHICS and Code of Conduct Policy

Descriptions Policy Owner Risk & Compliance Applies to Unnatim Group and Its Group of Companies Date of Commencement February 09, 2024 Version V.01.2024 Review Mode Annual Contents 1. About this Code 3 1.1. Overview 3 2. Conduct of business 3 2.1. Ethical business practices 3 2.2. Equal opportunity, non-discrimination, and diversity 3 2.3. Child labour 4 2.4. Workplace safety and conduct 4 2.5. Alcohol and drug-free workplace 4 2.6. Protecting the environment 4 3. Protecting information 5 3.1. Confidentiality 5 3.2. Information Security 5 3.3. Insider trading 5 4. Protecting Unnatim’s interest 6 4.1. Protecting Unnatim’s assets and using them appropriately 6 4.2. Communications 6 4.2.1. Social media and other types of communication 6 4.2.2. Acting and speaking on behalf of Unnatim 6 4.2.3. Circulation of unauthenticated market-related news 6 4.2.4. Responding to inquiries from regulators or other government agencies 6 5. Employee activities 7 5.1. Conflict of interest and personal relationships 7 5.1.1. Conflict of interest 7 5.1.2. Outside business activities 7 5.1.3. Personal relationships 8 5.1.4. Personal Finances 8 5.2. Gifts, favours, bribes, etc 9 5.2.1. Gifts and favours 9 5.2.2. Anti-bribery and corruption 9 5.3. Preventing fraud 10 5.4. Leaving UNNATIM 10 6. Record Retention 10 7. Reporting and disclosures 11 7.1. Raising concerns, seeking advice and reporting violations 11 7.2. Report criminal, legal or regulatory proceedings that involves employee personally 11 8. Approval process 11 9. General 11 10. Relationship to other policies 11 11. Other business specific obligations 11 12. Interpretation 12 1. About this Code 1.1. Overview UNNATIM’s1 Code of Ethics (‘Code’) embeds its core values of integrity, excellence, accountability and preserves its strong ethical culture. We must never underestimate the importance of our conduct. This Code is our commitment to operate with the highest level of integrity and ethical conduct. Compliance with this Code is a term and condition of employment with UNNATIM, and each employee has a responsibility to adhere to it. New hires are required to provide an affirmation that they have read and understand this Code, will comply with it and will report suspected violations as required by the Code. New hires must complete Code training within 30 days of joining. All employees are required to complete Code training and provide an affirmation on an annual basis. Employees must co-operate with any investigation, inquiry, examination or litigation relating to UNNATIM’s business as directed by UNNATIM. In addition to this Code, all employees are expected to comply with applicable laws in the jurisdictions in which UNNATIM does business and to maintain the highest standards of ethical and professional conduct. Employees should conduct their activities on behalf of UNNATIM consistent with fairness, integrity and transparency. If faced with a potential violation of law, or a conflict of laws, or a conflict with this Code, they should seek immediate guidance from the Legal or Compliance departments. This Code applies to all employees of UNNATIM. 2. Conduct of business 2.1. Ethical business practices In addition to compliance with applicable laws and regulations, all employees must hold themselves to the highest standards of ethical conduct and treat all customers in a fair, ethical and non-discriminatory manner and work to achieve a competitive advantage through superior products and services. Employees shall always deal fairly and in good faith with UNNATIM’s customers, suppliers, competitors, business partners, regulators and other employees and never take unfair advantage of anyone through manipulation, concealment and abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice. 2.2. Equal opportunity, non-discrimination, and diversity UNNATIM is committed to equal employment opportunity without regard to race, colour, religion, sex, sexual orientation, age, disability, pregnancy, citizenship status, or any other basis prohibited by applicable law, at all levels of employment, compensation, benefits, demotion or transfer, promotions, disciplinary action and terminations. UNNATIM prohibits discrimination or harassment or exploitation of any kind. 1 UNNATIM includes UNNATIM India Limited and its group of companies (‘UNNATIM’ and “UnPay”) 2.3. Child labour UNNATIM will not engage in nor support employment or use of child labour and will only employ workers who meet the applicable minimum legal age requirement for their location. Forced, bonded or indentured labour or involuntary prison labour will not be utilised. 2.4. Workplace safety and conduct UNNATIM strives to create an environment where employees can work in safety and comfort. UNNATIM relies on its employees to comply with applicable laws and UNNATIM’s policies as they relate to ensuring the health, safety and security of UNNATIM’s workforce, premises, physical assets, intellectual property, other confidential, sensitive and proprietary information, customers and others who may be present on UNNATIM premises. UNNATIM maintains a workplace safe and free from violence by prohibiting the possession or use of dangerous weapons on company property. UNNATIM is committed to a non-violent working environment, free of threats, intimidation and physical harm. Any acts or threats of violence towards another person or UNNATIM’s property should be reported immediately. The unauthorized possession or use of weapons, or menacing references to weapons, while at work, on UNNATIM property or while on UNNATIM’s business or during UNNATIM’s sponsored events, is also prohibited. Photography and audio or video recording in the workplace using personal devices, as well as the posting of such photographs or recordings on social media is strictly prohibited. Do not allow unauthorized individuals into secure areas. Employees should promptly report any criminal activity, health or safety concerns. 2.5. Alcohol and drug-free workplace Employees are not permitted to manufacture, distribute, possess, sell or attempt to sell, receive, consume or use illegal drugs or be under the influence of illegal drugs (or abuse controlled substances) on UNNATIM property, off-sites or when conducting UNNATIM’s business. Prohibited drugs include controlled substances that are prohibited by law. Bringing alcohol for consumption in the workplace, drinking or being under the influence of alcoholic beverages in the workplace or while conducting business is also prohibited, except for moderate and responsible consumption of alcoholic beverages in appropriate social situations where alcohol is served during a company-sanctioned event. 2.6. Protecting the environment UNNATIM is committed to being environmentally responsible in its operations. UNNATIM recognizes the potential of its operations and large employee footprint, to create an impact on natural ecosystems through usage of resources such as energy and water as well as through emissions and other outputs. UNNATIM therefore believes that environment considerations should form an important element of its business activities and strives to minimize this impact. UNNATIM will endeavor to use climate-friendly products and processes to reduce power consumption and greenhouse gas emissions. As a business, UNNATIM is fully committed to improving environmental performance across all of its business activities, and encourages employees and members of the wider community to join us in this effort. 3. Protecting information 3.1. Confidentiality Confidential Information includes personal information about employees, customers, and non-public information about clients, partners and their business. Any information that is not readily available from a public source and is obtained by the employees in the performance of their duties related to UNNATIM’s employees, customers, clients or applicable third parties will be treated as confidential. It is essential that we protect our company resources and our intellectual property. All intellectual property including copyrights, trademarks, trade secrets, designs etc. created by the employees of UNNATIM within the scope of their employment shall be confidential and intellectual property of UNNATIM. Such confidential information shall not be disclosed orally or in writing or electronically, directly or indirectly to anyone other than as required by the regulator/government/court or with consent where applicable. 3.2. Information Security UNNATIM employees have a responsibility to protect the information assets of UNNATIM including proprietary and confidential information about products, services, clients, and employees by ensuring that the confidentiality, integrity, and availability of Information are appropriately secured. Employees are required to comply with UNNATIM Information Security Policy. Given below is an indicative list of manner of usage of information by employees • UNNATIM Information Assets and Infrastructure must be used only for business purposes. • Transmission of Confidential Information outside UNNATIM or inside UNNATIM to unauthorized persons is prohibited. • Storing of UNNATIM information on external media or non-approved cloud is prohibited. • Passwords must be available only with the password owner and must not be shared with anyone else except while sharing password-protected documents on a need-to-know basis. • Information shall not be used for any personal gain or in any manner that would be contrary to the law or detrimental to the legitimate and ethical objectives of the organization • No information should be shared/ illustrated in a collaborative platform to any unauthorized persons. Clicking pictures of display screen is strictly prohibited. All breaches of information security, actual or suspected, shall be reported to Infosec Incident (risk@unpay.in). 3.3. Insider trading The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, prohibit trading in securities that are either listed or proposed to be listed on a stock exchange when in possession of unpublished price- sensitive information (UPSI). The regulations also provide that UPSI shall not be disclosed or communicated to others, except where such communication is in furtherance of legitimate purposes, performance of duties or discharge of legal obligations. 4. Protecting UNNATIM’s interest 4.1. Protecting UNNATIM’s assets and using them appropriately UNNATIM’s assets (including assets entrusted to UNNATIM by others) should be used only for legitimate business purposes and should be properly safeguarded against risks such as cyber-related attack, theft, loss, waste or abuse. UNNATIM assets include physical assets, such as equipment, supplies, technology assets, such as computer hardware, software and information systems, financial assets, and UNNATIM’s name, its brand and clients. In general, employees should not use UNNATIM’s assets (including technology or information resources) for their personal activities. Reasonable personal use of electronic communications devices (email, telephone, etc.) is permitted. All messages and transmissions composed, sent, stored or received on the UNNATIM’s electronic communications systems are, and remain, the exclusive property of UNNATIM and are not to be considered private property of any employee. UNNATIM reserves the right to monitor and review all such data and communications through such processes as it deems appropriate, to the maximum extent allowed by law and this Code. Employees should not have any expectation of privacy or confidentiality in any electronic communications. Electronic communications systems include employee-owned devices approved by UNNATIM under the ‘Bring your own device’ (BYOD) program for connection, and access to, UNNATIM’s network allowing for separation of personal and corporate data. 4.2. Communications 4.2.1. Social media and other types of communication Employees shall follow the applicable guidelines/policies of UNNATIM with respect to the use of social media as may be communicated on the intranet. Employees need to take care in the way they communicate, both internally and externally, whether on a formal or informal basis. Employees have a duty to be honest, professional, and respectful with both the public and UNNATIM colleagues. Electronic communications such as email, instant messaging or social media tools (such as blogs or social networking sites) can be used in valuable and creative ways to extend UNNATIM’s brand, communicate with the market, and address the needs of clients, customers and other stakeholders, subject to compliance with the brand policy of Unnatim Group. 4.2.2. Acting and speaking on behalf of UNNATIM Employees should never sign any documents or otherwise represent UNNATIM, or authorize any action on UNNATIM’s behalf, unless specifically authorized to do so. Employees should know the limits on their authority and not take action that exceeds those limits. Any delegation of authority, where permitted, should be limited in scope and closely managed to prevent abuse. Whether online or in public speaking engagements in personal capacity, employee should not be perceived as someone who is representing or speaking for UNNATIM. Don’t make any statements on behalf of UNNATIM unless authorized to do so. Refer all media inquiries to the marketing and communications team. 4.2.3. Circulation of unauthenticated market-related news Employees of UNNATIM Ratings and Research (regulated products) shall, in addition, comply with the activity to prevent on circulation of unauthenticated market-related news. 4.2.4. Responding to inquiries from regulators or other government agencies Any inquiries, queries/requests (other than routine) from regulators or other government agencies should be directed to the Legal and Compliance departments, and respective Business head only. 5. Employee activities 5.1. Conflict of interest and personal relationships 5.1.1. Conflict of interest A conflict of interest exists when an employee or relative is involved in an activity that affects or could potentially appear to affect his/her objectivity as an employee of UNNATIM. Conflict of interest could potentially arise out of an employee’s personal relationship, outside activity or personal trading activity. A conflict of interest can also arise whenever an activity is opposed to the best interests of UNNATIM, its clients or customers, creates the appearance of impropriety or misconduct or creates divided loyalty between employees and UNNATIM. Each employee should be free from any interest or influence that would make it difficult to give UNNATIM the employee’s best efforts and undivided attention. Employees may not take for themselves or divert to others any business opportunity in which the company has, or can reasonably be expected to have, an interest. Also, a conflict of interest is presumed if work is done for a firm that has business dealings with, or competes with UNNATIM or is otherwise detrimental to the interests of UNNATIM. Employees are responsible for avoiding activities or relationships that might affect their objectivity in making decisions as a UNNATIM employee. Employees should never permit their personal interests to conflict or appear to conflict with the interest of UNNATIM. It is not possible to list every situation that could present a potential conflict, but there are certain areas where conflicts typically arise, such as • An employee’s spouse working in a senior management position with a client company • An employee or his / her immediate relative [as defined under SEBI (Prohibition of Insider Trading Regulations, 2015)] owning securities in a company in whose assignment he / she is involved in • An employee who has been employed in the recent past with a company in whose assignment he / she is involved in • An employee’s relative (as defined under the Companies Act, 2013) working for an entity which is competing with UNNATIM • An employee’s relative is working in the same organization/business. All employees shall provide a conflict of interest declaration in the applicable format as per Annexure I. This declaration is to be provided at the time of joining the organization and thereafter on an annual/semi-annual/quarterly basis as applicable for securities holding statement submissions. In addition, employees shall also provide this declaration immediately when such conflicts arise. 5.1.2. Outside business activities Employees may not generally do any work for other employers or other businesses for honorarium or otherwise as this would conflict with the employee’s obligations to UNNATIM. A conflict arises if outside work consumes an employee's time and energy as to impair the ability to perform their UNNATIM job effectively. Also, a conflict of interest is presumed if an employee does outside work, for a firm that has business dealings with, or that conflicts with his/her scope of work or competes with, UNNATIM. Employees should also avoid any association with third parties that is otherwise detrimental to the interests of UNNATIM. With regard to outside activities, in general employees may not: • Take or divert to others any business opportunity in which UNNATIM has, or can reasonably be expected to have, an interest • Accept a business opportunity from someone who does or seeks to do business with UNNATIM if the offer is made because of your position in UNNATIM • Allow the activities, or the time spend on them, to interfere with the job performance • Take a business opportunity that represents an opportunity for UNNATIM • Engage in a business that competes with business of UNNATIM • Work for, or serve as, a director, officer of, or advisor to, a competitor • Directly or indirectly own any interest (more than 1%) in another entity without approval. Service on the boards of companies as a Director /officer is generally discouraged and is subject to enhanced review. Employees shall not accept position of a Director on any company where there is a conflict of interest with UNNATIM. Before taking up appointment as a Director on the Board of a company, the employee should take the approval of the Managing Director & CEO. The Managing Director & CEO will take approval of the Board of Directors of UNNATIM before taking up appointment as a Director on the Board of a company. All requests for approval should be made in writing/email. The approval/disapproval shall be granted in writing / email. All the records shall be kept for a minimum period of five years. In addition to the conflict of interest declaration, the outside business activity shall be subject to review and prior approval from the Compliance department, Human Resources and Senior Director/President in the supervisory chain. Charitable contributions UNNATIM encourages its employees to become involved with charitable activities or organizations provided it does not interfere with their job at UNNATIM. However, soliciting clients, vendors or other employees for contributions or other participation is generally prohibited or restricted and may depend on any applicable laws governing these activities. In some cases, clients or vendors may request we make a contribution to a charity or non-profit organization. Charitable contributions may not be given as a condition of or in order to influence a business decision. Any contribution requested by or that would benefit a government official requires pre-clearance from the Risk & Compliance department. Political activities UNNATIM respects the employee’s right to engage in personal political activity, but employees have to make sure that the activities are lawful and appropriate and do not involve the use of UNNATIM’s time or resources. Soliciting clients, vendors and other employees for political contributions is generally prohibited or restricted. Employees shall not use UNNATIM’s name to solicit political contributions or engage in other political activities on behalf of UNNATIM. Employees may volunteer for a political campaign on their own time in their individual capacity and not as a representative of UNNATIM. Employees have the right to make personal contributions from your own funds, subject to applicable legal limits and regulatory requirements, but employees cannot be reimbursed or compensated by UNNATIM for any contribution they make. Because UNNATIM has government entities as customers, certain employees may be subject to additional limitations on their personal political contributions. These activities/contributions including any lobbying on behalf of UNNATIM shall be subject to review and prior approval from the Compliance department and Senior Director/President in the supervisory chain. 5.1.3. Personal relationships Personal relationships shall cover relatives as defined under Companies Act, 2013, and also include any romantic, sexual or fiduciary/agent relationship. This applies to employees who are related to, or in personal relationships with, another employee, and also where employees are related to, or in a personal relationship with, UNNATIM consultants/contractors. Employees are required to disclose any conflict arising out of personal relationships immediately to the Human Resources and Compliance departments, and the Business head in the supervisory chain, for review. Such employees may not report to each other or work in the same supervisory chain/business that might compromise, or appear to compromise, their independence or evaluations. 5.1.4. Personal Finances In view of the nature of UNNATIM’s business, any improper handling of employee’s personal finances could undermine the employee’s credibility and that of UNNATIM. It could also cause others to question the employee’s decision-making on the job. Employees have to handle their personal finances responsibly, with integrity, and in compliance with the law. In general, employees may not participate in any personal financial transaction with fellow employees, customers or suppliers or their representatives including shared investments (unless widely held or as part of a UNNATIM-sponsored, co-investment plan). Employees may not borrow money from or lend money to or act as guarantor, co-signer or surety for customers, suppliers or other employees. Employees may however borrow, only in emergency situations or involving a family member, from other Employees with intimation to Human Resources. It is permissible to borrow from or conduct financial dealings2 (such as investing in mutual funds, bonds etc.) with customers in their normal course of business as long as employees are not granted preferential treatment. Consumer credit purchases from a customer or supplier in the normal course of business — again may be made, as long as the customer or supplier is not granting the employees any preferential treatment. In every case, employees have to use good judgment, look at each situation objectively, ensure there is no misuse of their official position and before moving forward, employees should ask themselves how their actions would look to someone outside of UNNATIM. Note also that you may not participate in gambling or betting of any kind, including office pools, at any UNNATIM location, or use UNNATIM’s resources (such as email, phone and copy machines) in connection with any gambling or betting activity, even if it is legal in the employee’s location. 5.2. Gifts, favors, bribes, etc. 5.2.1. Gifts and favors No gift or entertainment having more than nominal value extended as a customary courtesy of business life and no loan (other than products offered in the regular course of business) shall be given or accepted from/ by the employee from any person or firm having current or prospective dealings with UNNATIM. Gifts and entertainment must never be extravagant and must always be reasonable in terms of value and frequency and appropriate to the occasion and circumstance and also to the customs of the marketplace and business situation. In the event of any such gifts being offered or accepted, the same should be notified to Compliance. Specific prohibitions under this Code include • No cash or cash-equivalent may be given or received – this can include cheques, travelers cheques, money orders – unless given or received under a UNNATIM-sanctioned sponsored program • Any gift or entertainment, irrespective of amount, which is, or appears to be, linked to a competitive procurement or bidding process • Soliciting or encouraging gifts to be given by business contacts • Providing a service or subscription for free in lieu of payment, for which UNNATIM would otherwise charge, excluding any UNNATIM sanctioned program in connection with regulators or regulatory agencies; • Charitable giving used as a mechanism to conceal payments made to improperly Influence anyone with decision making authority. Link to Gift policy 5.2.2. Anti-bribery and corruption Bribery is the act of giving, offering, promising to give, or receiving anything of value – directly or indirectly – with the intent of securing improper help to obtain or retain business, gain a business advantage, or influence a business decision. Corruption is the abuse of a position of trust to gain an undue advantage. Bribery often involves the transfer of funds, usually disguised as a fee or commission paid through an intermediary and either misidentified on company books or left off altogether, to a person able to affect the outcome of decisions that impact business. Public officials, because of the nature of their position and responsibilities, pose a higher bribery and corruption risk than persons in the private sector. Facilitation payments are typically small payments to public officials in order to secure or expedite routine nondiscretionary government functions. Employees may be solicited for bribes or compete against businesses that use bribery to secure an advantage – thereby creating the perception that bribery is necessary to achieve a business objective. Furthermore, UNNATIM operates in countries with varying degrees of anti-bribery legislation and enforcement, exposing it and its employees 2 Subject to applicable requirements of Personal Trading Policy to environments with higher tolerance for bribery and corruption. In those jurisdictions, it is important to be aware of these risks, specifically with regard to state-owned enterprises. UNNATIM employees may not give or receive anything of value – directly or indirectly – to or from any person, including but not limited to private entities, public officials, government bodies, customers (existing or potential), or third parties, in India or abroad, if it is intended or could reasonably appear as intended for the sake of improperly influencing any business decision or in connection with any activity of UNNATIM. This includes vendors/suppliers. Facilitation payments are also not permitted. This prohibition applies regardless of whether the recipient works in the private or public sectors. Employees are expected to comply with all applicable laws of anti-bribery and anti-corruption to maintain highest standards of ethical and professional conduct. 5.3. Preventing fraud Generally speaking, fraud is an act of deception intended to result in a financial or personal gain. Fraud sometimes occurs when employees are facing pressures like deadlines or revenue targets. Examples of fraud include but are not limited to • Submitting false or misleading expense reports • Reporting revenue that has not been earned or does not exist • Submitting false or misleading financial statements • Misappropriation of physical assets such as a company issued laptop or intellectual property. Employees shall not carry out any fraudulent activity with respect to any services provided to or by UNNATIM 5.4. Leaving UNNATIM There are certain responsibilities employees will have to adhere to after leaving UNNATIM including, but not limited to, • Returning all UNNATIM assets in their possession. • Maintaining the confidentiality of information covered in clause 3, of UNNATIM, its clients and employees. • Refraining from buying or selling securities when in possession of unpublished price sensitive information relating to those securities (insider trading) • Assisting with any investigations, litigation related to their job. 6. Record Retention Maintain accurate and complete information and records Records provide valuable information for the business and evidence of our actions, decisions and obligations. Employees shall: • ensure all transactions are properly authorized, recorded and reported, as required. • follow applicable rules, regulations of UNNATIM and as applicable to the function or business when creating, maintaining, retaining or destroying documents. • retain personal data only for as long as it is required for the purpose for which it was collected unless it is to be retained for a longer period under any applicable regulation. Each employee of business unit and corporate function shall assure that records maintained in offices, or stored outside the office environment are appropriately identified and maintained to assure accurate and prompt retrieval. They should also ensure that such storage is at a location with the required level of security. 7. Reporting and disclosures 7.1. Raising concerns, seeking advice and reporting violations Employees may raise concerns, seek advice and report violations, if any, with either their manager, the Human Resources department representative, or the Legal or Compliance departments. Employees may also raise concerns at risk@unpay.in UNNATIM will promptly investigate the concern, or violation reported in good faith. The escalation will be treated confidentially to the extent permissible by law. Employees are expected to cooperate in any investigation conducted by UNNATIM. At the conclusion of the investigation, appropriate actions will be taken to resolve the issue. UNNATIM strictly prohibits any intimidation or retaliation against anyone who makes a good faith report about a known or suspected violation of the Code or any policy or procedure, or any law or regulation or who assists with any inquiry or investigation of any such violation. The information, especially the name of complainant, provided will be handled confidentially and shared only on a need to know basis. Link to Whistleblower policy 7.2. Report criminal, legal or regulatory proceedings that involves employee personally Employee must at the time of joining and on an on-going basis, immediately report to the Human Resources department the following incidents whether they relate to the business of UNNATIM or not: • Any arrest, charge, conviction or legal proceeding relating to a criminal charge, a police caution, including unresolved criminal charges, however minor and out-of-judicial / law process settlements. • Disclose any prior civil/criminal cases and/or settlements. • Any inquiry or action by a financial services regulator, law enforcement agency or similar authority, including any denial or suspension of a license or request seeking to take testimony or interview an employee regarding conduct at UNNATIM or any other financial services institution • Any legal claims against an employee asserting fraud, dishonesty, or unfair or unethical conduct related to financial services • Generally, employees do not need to report minor traffic offenses. If employees have questions on whether to report a criminal, legal or regulatory proceeding, contact the Human Resources department. 8. Approval process All requests for approvals including exceptions, if any, under the Code should be directed to the Business head and the Risk & Compliance department. 9. General UNNATIM takes violations of this Code seriously. Failure to comply with this Code, company policies, or the law or applicable regulations could result in disciplinary action up to, and including, termination of employment. In addition, violations of the law could result in civil or criminal penalties imposed by a governmental agency or a court of law. 10. Relationship to other policies This Code should be read in conjunction with applicable policies and procedures of UNNATIM. If there is a conflict between UNNATIM’s policies and other applicable policies, the more restrictive or specific policy applies. 11. Other business specific obligations Employees agree to comply with any other applicable business policies/regulations/obligations that may apply from time to time. 12. Interpretation Employees should seek clarification from the Risk & Compliance department concerning any interpretation of the provisions of the Code of ethics. Annexure I: Disclosures of conflict of interest by all employees (Please tick appropriate options and elaborate as required) 1(a) I know of no potential conflict of interest or any conflict that might arise from family connections or employment. or 1(b) The following are the potential conflicts and/or conflicts that arise from my family connections or employment. 2(a) I/My Relative do not hold an elected office in any local, state or national governmental or political entity, nor do I hold an office in any political party. or 2(b) I/My Relative do hold an elected office in a local, state or national governmental or political entity, or hold an office in a political party. Signature Name of the employee Date Note: 1. The term ‘family connections’ includes Relatives. Relative as defined in the Companies Act, 2013 means anyone who is related to another, if (i) they are members of a Hindu Undivided Family; (ii) they are husband and wife; or (iii) one person is related to the other in the following manner; • Father (includes step-father) • Mother (includes the step-mother) • Son (includes the step-son) • Son’s wife. • Daughter. • Daughter’s husband. • Brother (includes the step-brother) • Sister (includes the step-sister) Immediate relative: As defined in the Personal Trading Policy 2. Some examples of potential sources of conflict of interests can be: • An employee’s spouse working in a senior management position with a rated company • An employee or his / her immediate relative owning securities in a company in whose rating process he / she is involved in • An employee who has been employed in the recent past with a company in whose rating process he / she is involved in • An employee in an analytical role being involved in interactions of a commercial nature with a rated company • An employee’s relative working for a competing rating agency. UNNATIM Privacy Notice UNNATIM respects your privacy. We use your contact information, such as your name, address, and email id, to fulfil your request and service your account and to provide you with additional information from UNNATIM and its subsidiaries (collectively, the “Company) you may find of interest. For further information, please visit unpay.in

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