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Shaping the future of software driven business

Business Responsibility Report •

169

Code of Conduct

Company’s Code of Conduct (also referred to as the ‘Code’) outlines its commitment to highest levels of ethical standards

and compliance. Company’s Code is based on its values and clarifies the ethics and compliance expectations for everyone

who works for the Company. The Code includes sections on operating safely, responsibly and reliably; its people; its business

partners; the Governments and communities the Company works with and its assets and financial integrity. The Code takes

into account key points from the Company’s internal standards related to anti-bribery and corruption, anti-money laundering,

competition and anti-trust law and trade sanctions. The Company conducts due diligence on all its vendors and customers in

accordance with these policies.

Whom the Code of Conduct applies to

The Code applies to every employee of the Company and its subsidiaries and a separate Vendors’ Code of Conduct is extended

to all its contractors and business partners. Where feasible, the Company seeks a contractual commitment from its contractors

and business partners to comply and work in line with the Code. Where the Company has the right to do so, it may consider

terminating contracts where a contractor has not complied with the obligations or not renewing a contract where a contractor

has acted in a manner that is not consistent with the Company’s values or the Code. The Company rigorously follows ethical

business decisions, ensuring the actions of all its employees, vendors, business partners and customers are consistent with

the law.

The Company gives attention on fostering of fair business practices while working with the internal and external stakeholders.

Further, the Company is committed for creating an ethical and sustainable business environment. This commitment is reflected

through various company policies and practices being observed towards the respective stakeholders of the Company.

Certifying the Code

All employees sign the Code of Conduct annually. It is embedded in the annual performance contract of all employees to

comply with the Code and to create an environment where people can confidently raise concerns without fear of reprisal. The

compliance with this Code by each employee is being monitored by the Company on a regular basis.

Fostering a ‘speak up’ culture

The Company is committed to providing an open environment where its employees, contractors and other stakeholders are

comfortable speaking up whenever they have a question about the code of conduct or are of the opinion that law, regulations or

the Code, may have been breached. All stakeholders are encouraged to raise concerns with the Company’s management team.

The Company has adopted Anti Harrasment Policy and its Internal Complaints Committee is duly constituted. during the year

under report, your Company has received one complaint of sexual harrasment which was disposed During the year.

The Policy is available at

https://www.persistent.com/ethical-practices-at-persistent-systems/anti-harassment-policy/

Also, the Company conducts internal survey for obtaining feedback from the employees about the work culture in the Company,

in the department and inter-se relationship between the superiors and subordinates.

Principle 2

Business should provide goods and services that are safe and contribute to sustainability throughout their life cycle.

1.

List up to 3 of your products or services whose design has incorporated social or environmental concerns, risks

and / or opportunities.

The Company is in the business of software development services and products. Hence, these products do not attract

social or environmental concerns, risks and/or opportunities.

2.

For each such product, provide the following details in respect of resource use (energy, water, raw material etc.) per unit

of product (optional):

a.

Reduction during sourcing / production / distribution achieved since the previous year throughout the value chain?

Not Applicable

b.

Reduction during usage by consumers (energy, water) has been achieved since the previous year?

Data centers are the highest consumers of power and energy. To achieve the minimum usage, the company has taken

following major:

1.

Monitoring of power consumption and ensure that the consumption is optimized.