Business Code Of Conduct

Scope and Purpose

Eterno Infotech Private Limited (“Eterno” or “We” or “our”) Code of Business Conduct (“Code”) describes the philosophy and cultural expectations on working together with our customers and partners (hereinafter referred as “Business Partners”). We are committed to act ethically and responsibly in business engagements.

The Code sets out the standards by which we operate and guides our behaviours and the standards which we expect from our Business Partners. The Code emphasizes a culture of trust, integrity, reporting and conducting business in an ethical way. 

We expect that our Business Partner(s) including their subcontractors and associated staff share and embrace these values as well as our commitment to compliance.

This Code applies to Eterno and the company’s wholly owned or controlled by Eterno (“Eterno Group”). 

Eterno takes violations of the Code extremely seriously. We will not hesitate to take appropriate disciplinary actions (including dismissal, if required) against anyone who does not live up to the highest ethical business standards.

Business Conduct

• Eterno shares and pursues values of People, Innovation, Excellence, and Integrity. We at Eterno cultivate creativity & challenge, acknowledging that future competitiveness depends on innovation and development.
• While Business Partners are independent entities from Eterno Group, the business practices and actions of a Business Partner may significantly impact our reputation. Because of this, we expect all Business Partners, including Agencies and their employees, agents, and subcontractors ("Representatives") to certify their willingness to comply with the Code.
• It is the responsibility of our Business Partner and their representatives to understand and adhere to this Code. Business Partner should notify Eterno if and when any situation develops that causes the Business Partner Vendor or its representative to operate in a way that may be in conflict with Code. Eterno may request the removal of any Business 

Partner or its representative who behaves in a manner that we consider to be acting inconsistent with these Code. 

• As a responsible industry leader, we take our responsibilities very seriously. We are transparent and responsible and comply with all applicable laws and ensure that employees are aware of those laws relevant to their roles.

Compete

Eterno is committed to conducting business in a legal, ethical, and responsible manner and requires that our approved Business Partner work at the same high level of standards. Eterno Code sets out the principles, guidelines, and expectations we have of our Business Partners in conducting business responsibly and with integrity. In addition, Business Partners are expected to fully comply with the laws and regulations of the countries in which they operate. Eterno will compete fairly at all its operations around the world, abiding by national laws and regulations and relevant international standards governing the conduct of business.

Confidentiality

Business Partners are expected to protect confidential information. Business Partners must adopt and maintain processes to provide reasonable protections for personal, proprietary, and confidential information, including information that they access, receive or process on behalf of Eterno. Business Partner should recognize that unauthorized use or disclosure of such information may have personal, legal, reputational and financial consequences for the Business Partner, the individuals whose personal information may be implicated, and for Eterno. In addition, Business Partner must comply with all applicable privacy / data protection and information security laws and regulations. 

Expected Regulatory Compliance Practices

Business Partners and their Representatives shall conduct their business activities in compliance with the applicable laws and regulations. While conducting business with and/or on behalf of Eterno in addition to any specific obligations under the relevant arrangement/ agreement with Eterno, all Business Partner shall, without limitation:

• Comply with all applicable laws including but not limited to Trade compliance, anti-bribery and anti-corruption, competition laws etc. 

• Be honest, direct, and truthful in discussions with regulatory agency representatives and government officials. 

Expected Business Practices

Business Partners and their Representatives shall conduct their business interactions and activities with integrity and in accordance with their obligations under their relevant arrangement/agreements with Eterno. In addition to any specific obligations under the relevant arrangement/ agreement with Eterno all Business Partner and its Representative shall, without limitation:

• Honest and precisely record (including contracts) and report all business information and comply with all applicable laws that deal with their completion and accuracy.
• Comply with the intellectual property ownership rights of the Company not limited to trademarks, patents and trade secrets and use software, hardware, and content only in accordance with their associated license or terms of use.
• Protect and use the physical and intellectual property of the Company responsibly.
• Not exploit any business opportunity, outside employment, or investment which would interfere with the ability to perform their responsibility or make an improper personal benefit.
• Create, retain and dispose of business records in full compliance with all applicable legal and regulatory requirements.
• Not engage in dialogue with investors or media without the prior consent of appropriate internal functions. 
• All employees who were previously employed with the Government of India or any of its departments (including but not limited to the defence services, police services, city corporations) or previously engaged in political activities will mandatorily need to adhere to this Policy. Additionally, employees for whom this clause is applicable will need to fill up a questionnaire on the same and provide an undertaking that this employment will not constitute a conflict of interest for the Company.

Diversity & Equal opportunity

• Eterno expects its Business Partner and representatives to share its commitment to human rights and equal opportunity in the workplace.
• Eterno respects individual freedom, human rights, dignity and is committed to treating all Business Partners and employees with trust and respect and provides equal opportunities to each person. We do not support any form of discrimination or harassment in the workplace and do not tolerate any behaviour that would commonly be considered offensive or unacceptable.
• Any act such as “physical contact and advances”, a demand or request for sexual favours, sexually coloured remarks, showing pornography and any other unwelcomed physical, verbal or non-verbal conduct of a sexual nature will be treated as a severe offence. 

Child Labour

Business Partners must not employ child labour and should take the necessary preventive measures to ensure that it does not employ anyone under the applicable legal minimum age of employment. Such measures include age verification systems, training for managers, and communicating with subcontractors and suppliers on child labour issues. The Business Partner must ensure that such employment is in accordance with the relevant law and must provide adequate protection against any conditions that may be hazardous to the health and safety of young workers.

Compliance with Local Law

Business partners shall comply with all local and national laws and regulations of the jurisdictions in which we do business. Business partners and clients associated with us shall further deploy consultants who are committed to meeting required standards as per local & national laws.

Corruption and Bribery 

We prohibit the offering or receipt any illegal payments or offer something of value to another person or someone who is an employee of the government or a public agency with the purpose to influence which includes comparable benefits that are intended to obtain undue favors for  the conduct of business.  You will comply with all applicable anti- money laundering, anti- fraud and anti-corruption laws.

Gifts, Favours, and Benefits

Gift giving is a widely accepted way of showing appreciation to the individuals with whom we form working relationships. However, because giving or accepting a gift may create the expectation of a favour in return, business partners must as a general rule avoid giving or accepting any gifts, favours, benefits, sponsorships to an event or gratuities in connection with their official duties. Business must be carried out with a high degree of ethics, honesty and fair dealings ensuring we are committed to a high performing professional relationship.

Conflict of Interest 

All Business Partners (including employees) shall act in the interest of the company and in case of any potential or actual conflict of interest, the concerned must immediately report such conflicts to below mentioned e-mail id, thereafter We will within a reasonable time take necessary steps to address or resolve the conflict amicably. If there is a failure to make the required disclosure and We become aware of a conflict of interest that should have been disclosed, the management shall consider appropriate disciplinary actions.

Misconduct & Reporting

Misconduct would include mishandling of office assets/finances, violation of Intellectual Property Rights, violation of confidentiality, theft or pilferage, use of inappropriate language. These are only indicative. Any action that is detrimental to discipline would be dealt with strictly are unacceptable.

In case any of the business partners associated with Eterno fail to meet the Code or are found to violate the standards set at any given time, the Company may proceed with strict measures as deemed appropriate including discontinuation of this association.

REPORTING OF QUESTIONABLE BEHAVIOR AND/OR POSSIBLE VIOLATIONS 

If you wish to report a concern, you may write to hr@eternoinfotech.com