Code of Business Conduct
and Ethics

Definition

“The Company” shall mean PM Relocations Pvt. Ltd.

“Board” shall mean the Board of Directors of the Company.

“Board Members” shall mean the Members on the Board of Directors of the Company.

“Executive Directors” shall mean the Board Members who are in whole-time employment of the Company.

A 'relative' refers to family members of an individual as defined under Sections 2(41) and 6 along with Schedule IA of the Companies Act, 1956.

“Senior Management” shall mean:

• Executives who are in the grade of Manager and above,
• All Executives directly reporting to the Managers and Chief Executive Officer, and
• Chief Financial Officer, and

Purpose
The main objective of this Code is to ensure Corporate Governance and accountability. The Code of Conduct as approved and adopted by the Board of Directors shall be posted on the Website of the Company.

Relevance
This Code of Conduct applies to all employees, directors, and business partners working with the company. 
Business Associates includes the following persons/entities as well as their employees:

• Suppliers and vendors of products and services
• All service providers
• Channel partners
• Consultants
• Agents
• Sales representatives
• Independent contractors

All employees who deal with Business Associates should ensure that compliance with the Code is included in the contracts or arrangements between the Company and Business Associates and that they are made aware of the importance of and need to comply with the Code. Breach of the Code by Business Associates and/ or their employees may lead to penal consequences including termination of the agreement with the Company.

The Company is committed to conduct its business in accordance with the applicable laws, rules and regulations, and with highest standards of business practices and ethics. The issues covered in this Code are of utmost importance to the Company, its shareholders, and customers. These are accordingly relevant and important for all employees of the Company.

Fair Dealing
The Board Members and Senior Management should deal fairly with customers, suppliers, competitors and employees. They should not take unfair advantage of anyone through manipulation, concealment, abuse of confidential, proprietary or trade secret information, misrepresentation of material facts, or any other unfair dealing-practices.

Honesty & Integrity
Every employee shall discharge his duties with utmost integrity, honesty, devotion and diligence and do nothing which is likely to tarnish the image of the Company. Cases of fraud, corruption activity and dishonesty will attract penalty of dismissal.

Human Rights
At the Company, upholding people's fundamental rights is central in our everyday business operations. At a minimum the Company will comply with all applicable local, state and national laws regarding human rights and workers’ rights where the Company does business. All our businesses are compliant with applicable regulations, strive to uphold all labour rights and are aligned with the applicable laws. All employee’s business associates are required to comply with our Human Rights Policy.

PMR's human rights policy follows the UN Guiding Principles on business and human rights. It bans child or forced labor, either directly or through contract work. PMR will not tolerate any human rights violations by employees, suppliers, contractors, or other entities.

Financial Controls and Records
PMR's accounting and financial records must accurately and completely reflect every business transaction in a timely manner and reasonable detail. They must comply with legal requirements and PMR's internal control system. All employees and directors responsible for PMR's assets and transactions must establish and maintain internal controls in their area. This is to (a) prevent unauthorized, unrecorded or inaccurately recorded transactions; and (b) allow preparation of financial statements per generally accepted accounting principles.

Confidential Information:
Employees and directors must maintain strict confidentiality of all private company information, unless PMR authorizes disclosure or is legally required. Employees shall not share any information detrimental to PMR interests with anyone, except as permitted within approved company policies. Confidential information includes any non-public details about PMR, such as business plans, trade secrets, finances, products, clients, and third party information shared in confidence. Employees have an ongoing obligation to protect PMR's confidential information even after their employment ends.
PMR respects employee privacy and does not disclose any information to any third party

Conflict of Interest
A “Conflict of Interest” exist when a person’s private interest interferes in any way with the interests of the company. PMR Employee’s primary obligation is to the company. Employee shall avoid entering into any situation in which their personal or financial interests conflict with their duties to PMR. There are potential conflicts of interest inherent in certain situations such as when:

• An employee or their family member having a financial interest or obligation to an actual or potential competitor, supplier, or customer of the Company constitutes a conflict of interest.
• It is also a conflict if an employee conducts business for the Company with a supplier or customer where their relative works as a representative, officer or director.
• All employees are encouraged to report conflicts of interest that do arise so that as a company we may deal with and resolve them.

Discrimination and Harassment
PMR is committed to providing a work environment free from discrimination and harassment. As an equal opportunity employer, PMR makes employment decisions based on merit and business needs, not on unlawful factors. PMR does not tolerate any discrimination and provides equal employment opportunities regardless of age, race, color, religion, nationality, gender, disability, marital status, or sexual orientation. All employees are entitled to fair and equal treatment.
PMR tolerates no form of Sexual Harassment which includes

• Unwanted physical contact
• Demanding or requesting sexual favors
• Sexual comments
• Showing pornographic material
• Any other unwanted verbal, physical or non-verbal behavior of a sexual nature

Health, Safety and Environment Practices
PMR believes that sound environmental and safety and health management practices are in the best interests of its business, its employees, its shareholders and the communities in which it operates. PMR is committed to conduct its business in accordance with recognized industry standards and to meeting or exceeding all applicable Health, Safety and Environmental laws and regulations that may impact our business.

“Each and every employee has the responsibility to maintain a safe and healthy workplace for all by following safety and health rules and practices and by reporting any accidents, injuries and unsafe equipment, practices or conditions. Violent and threatening behavior are never permitted.”

PMR encourage and prioritise re-use and re-cycling methods throughout all of our businesses. All employees are encouraged to take an active role in identifying and supporting environmental improvement programmes. Our safety and health vision is that every person will go home safe and healthy every day. Achieving this goal is the responsibility of all employees and directors.

PMR’s safety and health policy is set forth in the Safety and Health Policy, and our environmental policy is set forth in the Environmental Policy.

Work Place Standards

• Internet browsing and surfing is strictly prohibited.
• Discrimination, harassment including sexual harassment is strictly unacceptable at PMR
• Child Labour is not permissible; we do not employ people below the age of 18 years
• All employees will be given proper training relevant to the function they perform
• The necessary conditions for a safe and healthy work environment shall be provided for all PMR Employees.
• PMR offers adequate wages that as a minimum comply with government norms.
• Understand your responsibility towards environment. Keep Environment clean and green.
• PMR does not appreciate personal calls during office timings. If unavoidable, restrict personal calls to within 3 minutes.
• Smoking, Chewing Tobacco, Gukta, consuming Alcohol is strictly prohibited in office premises and on job sites. 

Personal Code of Employees

• Employees must comply with the policy. All employees must wear I. cards
• Every employee shall maintain good conduct, discipline, punctuality and show courtesy and attention to all persons in their dealings with the company.
• Work stations, drawers, cabinets must be kept clean. 
• Clear all papers before closing for the day
• Switch off of all the equipment’s (computers, accessories etc.) provided to you before leaving from office.
• Where no legislation or rules govern personal conduct, each employee must exercise sound judgement and due care.
• Whenever in doubt, employees should raise their questions with a superior or another responsible staff member.
• All employees must be dressed appropriately & smartly in business attire.

Conducting Our Business
No cash may be offered to or accepted from customers, suppliers, consultants, government representatives, private person or company to seek any favour in the business in any circumstances. Nominal gifts of commemorative nature, for special events may be accepted and reported. PMR competes for business on fair terms and solely on the merits of its services.
No employee shall engage in any trade or business or accept employment or fee for any work done by him outside the Company.
No employee shall take an active part in politics and stand for election anywhere outside the Company.

Insider Trading
All employees, officers and directors with access to non-public data about the Company or any entity, cannot use or share that data to trade securities of the Company or entity, or any other purpose, except to conduct our business. Using non-public material for personal finance benefit or tipping others who may invest on that basis is dishonest, illegal.

Corporate Opportunity
All employees, officers and directors cannot take for personal benefit any opportunities discovered via corporate data or role without Company consent. No employee, officer or director can use corporate property, information or position for improper personal profit, nor compete directly or indirectly with the Company. Employees, officers and directors have a duty to the Company to advance its legitimate interests when such chances arise.

Corporate Responsibility
PMR is committed to minimize the environmental impact of our existing process/activities. We subscribe to sustainable development practices that insure the safekeeping of our natural resources and expect our business partners to also adhere to these principles. We have adopted a four-step approach to waste management within our offices:

• Reduce
• Reuse
• Recycle
• As a last option, dispose of waste using safe and responsible means.

The social, environmental and ethical commitments of PMR must be reflected in all dealings with customers, employees, suppliers and other stakeholders.

Disciplinary Actions
The Company shall take appropriate action against any employee whose actions are found to violate this Code of Conduct. Disciplinary action may include immediate termination of employment or business relationship at the Company's sole discretion. Where the Company has suffered a loss, it may pursue remedies against the individuals or entities responsible for the same.

Waiver and amendment of this Code
Any amendment to this Code must be approved by the Board and publicly disclosed as required by any applicable law or regulation. Any deviation/waiver from this Code can be affected only on the sole and absolute discretionary authority of the Board or any person/committee designated by the Board for this purpose.

Disclaimer
This Code of Conduct is intended solely as a guide. The Company expressly retains the right to unilaterally modify or amend these rules at its sole discretion, with or without notice to the Company’s employees. Any delay in taking preventive action shall not be construed as a waiver of such right by the Company.