To be adhered by RoboRAM employees, subcontractors and anyone acting on behalf of, or representing RoboRAM Education (herewith as associates of RoboRAM Education).

Introduction

• RoboRAMs’ belief the trust from its clients and stakeholders is the key to its success as an organisation and as an individual; and to sustain RoboRAM brand and reputation, RoboRAM recognizes the need to conduct its business honestly, transparently and in fairly

• RoboRAM is committed to uphold the principles of integrity and maintain the highest standard of professional behaviour in the challenging environment in which its business operates

• As part of this commitment, RoboRAM encourages an open culture where associates of RoboRAM can exchange ideas and information, seek advice and raise concerns, without fear of retaliation. This will allow RoboRAM to continuously strive to improve and preserve the confidence entrusted by its clients and stakeholders

Philosophies of integrity

• We want to be truthful in everything we do. No circumstances justify lies, deceit or a lack of truthfulness. We mandate the highest ethical standard of ourselves and others. Impartiality in fairness: we seek to deal fairly and respect others. We avoid taking one-sided advantage through manipulation, theft, concealment, abuse of confidential information, misrepresentation or other unfair practices. Our conclusions will be guided by respect for principles and standards of good behaviour, not by random choices or personal preferences

• Faithfulness in accountability: we take responsible of our actions and accept the consequences of our choice and do not blame others for our actions

Integrity of services

Our services shall be delivered professionally and honestly in accordance with agreed criteria, requirements and procedures. RoboRAM maintains its independence of judgment and does not surrender to pressure and encouragement to misrepresent activities performed. All reports shall be adequately and accurately documented and shall not be changed improperly. No untruthful or misleading reports and activities will be done.

Conflicts of interest

In general conflicts of interest, or the possible appearance of a conflict of interest, shall be avoided. Associates of RoboRAM are expected to declare to RoboRAM as soon as they become aware that their personal interests may potentially conflict with the interests of RoboRAM. A conflict of interest arises when the person’s opportunity for personal gain could interfere with his/her judgment, objectivity, independence or loyalty to RoboRAM. Conflicts of interest can arise in many ways, if in doubt, guidance should be sought with RoboRAM. The person shall declare immediately in writing all such potential conflicts of interest to RoboRAM and refrain from the decision-making process as long they are affected by a potential conflict of interest. Some circumstances of conflicts of interest are forbidden to associates of RoboRAM which include:

• personally, offering or participating in any form of professional or consultancy services to a customer or prospective customer of RoboRAM

• competing with RoboRAM or working for a competitor of RoboRAM

• obtaining a personal gain, by abusing a position within RoboRAM or accessing RoboRAM information

• Personal investments in suppliers, competitors and customers

• knowingly engaging the services of a supplier or sub-contractor of RoboRAM in which an employee directly or indirectly has a significant shareholding or other financial interests is not permitted unless:

• The potential conflict has been transparently declared to RoboRAM

• The employee affected by the conflict does not take part in the procurement process

Making a personal investment in a supplier, sub-contractor, competitor or customer of RoboRAM is not permitted, unless by way of acquiring shares on a publicly traded stock exchange.

Integrity of financial information

• RoboRAM’s all transactions must be properly, accurately and timely reported and recorded. All financial related records shall be supported by proper documentation according to contract/ agreement/ policies/ issued by bona fide parties and shall be maintained in accordance with applicable indian laws

• RoboRAM does not pay or offer any form of improper incentive to securing business for RoboRAM

Bribery and corruption

RoboRAM does not engage in bribery or corruption of any form, in any of the countries where it operates. Associates of RoboRAM, shall not offer or make payments to government officials, whether directly or indirectly, or offer them any gift or entertainment with the aim of influencing their decision, or encourage them to secure an improper advantage for RoboRAM. This applies equally to officers and employees of private entities. Any associates of RoboRAM who receives a demand for a bribe must report the matter immediately to RoboRAM management

Gifts and entertainment

• No gift, hospitality or entertainment should be offered or accepted if they influence improperly or create the appearance of an improper influence on business decisions. Gifts, hospitality and entertainment shall not exceed what is usual in normal business relations. Any form of entertainment that could be damaging to the reputation of RoboRAM must be avoided. The following rules clarify the expected standard of behaviour of associates of RoboRAM

• Gifts offered to associates of RoboRAM the following shall not be accepted:

• Payment of cash, tips, loans or cash equivalent gifts from suppliers or customers

• Any personal gifts, favours, entertainment or hospitality when those are given in connection with services performed by RoboRAM

• Employees involved in decisions on procurement or selection of suppliers must not accept personal gifts offered by suppliers or prospective suppliers. Usual hospitality and entertainment, including participation in trade fairs and similar professional events which are sponsored by suppliers, is acceptable, subject to reporting and clearance obligations

Reporting and clearance obligations

Associates of RoboRAM are required to report and seek the prior approval of RoboRAM before accepting any gift. If gifts received cannot be refused or returned without causing offence, the person receiving the gift should report to RoboRAM management for choosing a suitable method of disposal

Use of company assets and funds

Associates of RoboRAM have a duty to safeguard and to use company assets and funds under their control appropriately. It is not permitted to use RoboRAM assets or resources for any form of personal benefit or to perform work for an external party. For company computers, network systems and electronic communication tools shall be used for professional purposes, in accordance with RoboRAM policies. Use of e-mail, internet and other modes of electronic communication may be monitored and audited by RoboRAM when suspicion of abuse arises

Procurement

Associates of RoboRAM in charge of purchasing goods and services from suppliers or selecting sub-contractors must do so with the sole aim of securing the best overall value for such services, with due regard to supplier quality and reputation. When appropriate, competitive offers must be sought prior to selecting a supplier or sub-contractor. RoboRAM does not award contracts to suppliers on the basis of personal preferences. Soliciting any form of personal advantages from a supplier or from a person seeking to offer services to RoboRAM is strictly prohibited.

Truthful and respectful

• Associates of RoboRAM are expected to treat their fellow associates with respect

• Associates of RoboRAM must be truthful and respectful at all times in dealing with their colleagues and management. This extends to RoboRAM clients, suppliers, their employees and management

• Associates of RoboRAM are expected to obtain approval from the superior for any absenteeism, leaving early or leaving half way from works

No tolerance for violations

Any breach of the integrity policy, however small, that can harm RoboRAM’s reputation and brand will not be tolerated. Violations of the policy will result in disciplinary action, including termination of employment / relationship and criminal prosecution for serious violations