Last updated: May 27, 2025

(Adapted for Internal Use)

Applies to: All employees, officers, directors, agents, contractors, consultants, and business partners globally.

1. Values & Purpose

Founded on Srinsoft Inc.’s five core values: Integrity, Excellence, Customer Delight, Adaptability, and Responsibility. This Code applies to all employees, officers, directors, suppliers, and business partners globally.

2. Scope & Applicability

Mandatory for all Srinsoft Inc. and its subsidiaries and associates, employees, directors, officers, suppliers, and third parties globally. Sets minimum ethical standard; strict local laws take precedence.

3. Core Principles

Act with the highest moral and ethical standards with no tolerance for bribery or corruption. Uphold corporate citizenship, respect communities and the environment, and behave honestly and transparently.

4. Employee Commitment

Employees must conduct business with professionalism, honesty, integrity, and transparency, and are personally responsible for compliance. Promote equal opportunities and a harassment-free workplace.

5. Bribery, Gifts & Political Neutrality

Strictly prohibits illegal payments, gifts, donations that seek to influence decisions or obtain unfair advantage. Only nominal, commemorative gifts are permitted. No donations to political parties or candidates.

6. Financial Integrity & Reporting

Requires accurate, fair accounting and audits, with no hidden funds or misrepresentation. Employees must comply with all applicable laws; if weaker than the Code, the Code prevails.

7. Conflicts of Interest

Employees must avoid personal or familial interests that conflict with company interests. Such conflicts must be disclosed in writing and managed by internal procedures.

8. Use of Assets & Confidentiality

Company assets must be used only for legitimate business purposes. Insider information must be handled carefully—no trading on confidential knowledge.

9. Stakeholder & Environmental Responsibility

Commitment to community development, environmental stewardship, and volunteering. Maintain fair competition, customer satisfaction, and shareholder value.

10. Training & Communication

Annual training on code of conduct, anti-corruption laws, corporate policies, and red-flag detection. Communicated with employees and third parties.

11. Risk Monitoring & Review

Periodic risk assessments, audits, and compliance reviews by ethics team or Internal Audit. Annual compliance reports submitted to Board/Directors.

12. Enforcement & Discipline

Violations lead to disciplinary actions up to termination and possible criminal penalties. Facilitators, intermediaries, and companies may be held strictly liable.

13. Reporting & Whistleblowing

Encourages employees to report concerns in good faith. Ensures confidentiality and prohibits retaliation for whistleblowers.