It is a duty of all Employees to report any known or suspected violation of this CoC, including any violation of the laws, rules, regulations or policies and procedures that apply to the Company. The Company’s policies and procedures apply to and are available to all employees of the Company.
The Company will use reasonable efforts to conduct the investigation in a manner that protects the confidential and anonymous reporting of your concerns pursuant to this CoC, consistent with law and the Company’s need to investigate your concern. It is Company policy that any employee who violates this CoC or any policy or procedure made pursuant to this CoC will be subject to appropriate disciplinary action, which may include termination of employment. An employee accused of violating this CoC will be given an opportunity to present his or her version of the events at issue prior to any determination of appropriate discipline Employees who violate the law or this CoC may expose themselves to substantial civil damages, criminal fines and prison terms in accordance with applicable laws, as well as face disciplinary action by the Company, including termination of their employment. The Company may also face substantial fines and penalties and many incur damage to its reputation and standing in the community. Your conduct as a representative of the Company, if it does not comply with the law or with this CoC, can result in serious consequences for both you and the Company.

The Company is committed to the standards set out in Code of Conduct and Business Ethics. Where a breach of the CoC has been identified by the Company, a response to the breach may result in Counselling, Disciplinary action, Termination of employment, Suspension and Laying of criminal charges or civil action.

Every employee has an obligation to comply with this Code of Ethics. In special cases, as and when required, few employees may be waived of this Code of Conduct but this decision will be made only by our Board of Directors and will be reported to our Audit Committee at its quarterly meetings. In addition, any such waiver will be disclosed to the public as required by law.

The Company values the help of employees who identify potential problems that the Company needs to address. Any retaliation against an employee who raises an issue honestly is a violation of the CoC. That an employee has raised a concern honestly, or participated in an investigation, cannot be the basis for any adverse employment action, including suspension, separation, demotion, loss of benefits, threats, discrimination or harassment. If you work with someone who has raised a concern or provided information in an investigation, you should continue to treat the person with courtesy and respect. If you believe someone has retaliated against you, report the matter to your supervisor or management.

Company employees are prohibited from trading in the shares or other securities of Company while in possession of material, nonpublic information about Company. Company employees who obtain material nonpublic information about another company in the course of their employment are prohibited from trading in the shares or securities of the other company while in possession of such information or helping others to trade on the basis of such information. Violation of insider trading laws can result in severe fines and criminal penalties, as well as disciplinary action by the Company, up to and including termination of employment.

Information is considered as non-public if it has not been made generally available to the public by means of a press release or other means of widespread distribution.

Application Nexus Webservices Pvt. Ltd. primarily works with United States, United Kingdom, Australia, New Zealand, India and other European countries. While working with global demographics, in none of the case Application Nexus will work with the clients from the countries those are prohibited for trade by laws of United States and India. The Company abides to follow all Indian and Australian civil laws, trade laws, import export guide lines, American federal laws, American civil laws; and environmental laws of all possible countries. It is expected for all employees to understand these laws while working with company. In any case the Company’s standards will be always higher than any permitted laws and it is expected from all its employees to work within the strict guidelines set by the Company and avoids activities those are considered legal by the law but not allowed by the Company’s own principles and ethics. On the other hand if the situation arises where certain activities can be allotted by company but not the law of the country where business is executed then it is advised to put the law on priority before the company interest.

Company operations and Company employees are subject to the laws of many countries and other jurisdictions around the world. Employees are expected to comply with the CoC and all applicable government laws, rules and regulations. If a provision of the CoC conflicts with applicable law, the law controls. Since Application Nexus Webservices Pvt. Ltd. is incorporated in India, our employees around the world often are subject to Indian Laws. Other countries also may apply their laws outside their borders to Company operations and personnel. If an employee is uncertain what laws apply to him, or if he or she believes there may be a conflict between different applicable laws, consult Company legal counsel before proceeding.

In principle, Application Nexus is against the use of child labor and believes its long-term elimination is ultimately in the best interests of children. However, the elimination of child labor must always be undertaken in a manner consistent with the best interests of the children concerned.

The global nature of our business may require interaction with officials of various governments around the world. In general, do not offer anything to a government official directly or indirectly in return for favorable treatment. You must obtain prior approval from Company’s legal counsel before providing anything of value to a government official. Ensure that any such payments are properly recorded in the appropriate Company’s account.

Many countries have passed legislation criminalizing bribery of government officials. The sanctions for violating these laws can be severe, including significant individual and corporate fines, and even imprisonment. A bribe is giving or offering to give anything of value to a government official to influence a discretionary decision. Examples of bribes include payment to a government official to encourage a decision to award or continue business relations, to influence the outcome of a government audit or inspection, or to influence tax or other legislation. Other payments to government officials also may constitute bribes in some jurisdictions. Obtain approval from Company’s legal counsel before making any payment to government officials.

The Company must comply with all applicable trade restrictions and boycotts imposed by the US, Australia, New Zealand, UK, European countries and Indian government. Such restrictions prohibit the Company from engaging in certain business activities in specified countries, and with specified individuals and entities. These restrictions include, for example, prohibitions on interaction with identified terrorist organizations or narcotics traffickers. Sanctions for non-compliance can be severe, including fines and imprisonment for responsible individuals, and the Company may be prohibited from further participation in certain trade. The Company also must abide by U.S. anti-boycott laws that prohibit companies from participating in any international boycott not sanctioned by the U.S. government.

The Company understands that the journey so far was only possible because being with principles. We didn’t and will never compromise on our principle just to earn more profits.

During your tenure in the company, you have access to variety of confidential information. Confidential information includes all information that is internally generated by the Company concerning the business, which may also include information obtained from sources outside the Company, including information about other companies or their securities. Confidential information includes all non-public information that might be of use to competitors, or, if disclosed, harmful to the Company or its customers, including, but not limited to information, financial, technical or otherwise, ideas, concepts, know-how, data, reports, methodologies, procedures, intellectual property information, trade secrets, compilations, studies, projections, forecasts, records, information pertaining to employees, vendors and customers, and other materials, in whatever form maintained, whether documentary, computerized, electronic, oral or otherwise, that contain or otherwise reflect information concerning the Company. In order to protect and maintain the confidential nature of such information, the Company may ask you to sign the non disclosure agreement, whenever necessary.

Ensuring the accuracy of all Company’s business and financial records, which include not only financial accounts, but other records such as payroll, project data, reports, time sheet, expense reports, e-mails, accounting and financial data, performance measurement records, electronic data files and all other records maintained in the ordinary course of our business and submissions such as benefits claim forms and resumes. Company records include booking information, payroll, time cards, travel and expense reports, e-mails, accounting and financial data, measurement and performance records, electronic data files and all other records maintained in the ordinary course of our business.

Ensuring accurate and complete business and financial records is everyone’s responsibility, not just a role for Human Resource, accounting and finance personnel. You are responsible for understanding and complying with our record keeping policy. Please ask your supervisor if you have any questions. Accurate record keeping and reporting reflects on the Company’s reputation and credibility, and ensures that the Company meets its legal and regulatory obligations.

An employee should not engage in personal activities during work hours that interfere with or prevent him or her from fulfilling the job responsibilities. Company computers and equipment should not be used for outside businesses, or for illegal or unethical activities such as gambling, pornography or other offensive subject matter. Also refer Application Nexus Webservices Pvt. Ltd. Employee Handbook. Protect the Company’s equipments and assets, and use them in the manner intended.

Employees should be aware that Company property includes all data and communications transmitted or received to or by, or contained in, the Company’s electronic or telephonic systems. Company property also includes all written communications. To the extent permitted by law, the Company has the ability, and reserves the right, to monitor all electronic and telephonic communication. These communications may also be subject to disclosure to law enforcement or government officials.

Theft of Company assets whether physical theft such as unauthorized removal of Company product, equipment or information, or theft through embezzlement or intentional misreporting of time, work or expenses may result in termination and criminal prosecution. The Company treats workplace theft of assets belonging to other employees the same way it treats theft of Company assets. The use of Company assets outside of your Company responsibilities such as using your Company work product in an outside venture, or using Company materials or equipment to support personal interests requires prior written approval from your supervisor or management. You must have this approval renewed annually if you continue to use the asset outside of work.

The Company places a high value on its credibility and reputation in the community. What is written or said about the Company in the news media and investment community directly impacts our reputation, positively or negatively. Our policy is to provide timely, accurate and complete information in response to public requests (media, analysts, etc.), consistent with our obligations to maintain the confidentiality of competitive and proprietary information and to prevent selective disclosure of market-sensitive financial data. To ensure compliance with this policy, all news media or other public requests for information related to and meant for investors should be directed to the Company’s investor relations department and all other communication including its customers, vendors, general public should be directed to the Company’s marketing department. The investor relations or the marketing department will work with you and the appropriate personnel to evaluate and coordinate a response to the request.

Our business success depends upon our ability to foster lasting client and customer relationships. The Company is committed to dealing with clients and customers fairly, honestly and with integrity. Specifically, you should keep the following guidelines in mind when dealing with clients and customers –

1. Information we supply to customers should be accurate and complete to the best of our knowledge. Employees should not deliberately misrepresent information to customers
2. Employees should not refuse to sell, service, or maintain products the Company has produced simply because a customer is buying products from another supplier
3. Customer entertainment should not exceed reasonable and customary business practice. Employees should not provide entertainment or other benefits that could be viewed as an inducement to or a reward for, customer purchase decisions

The Company deals fairly and honestly with its suppliers. This means that our relationships with suppliers are based on price, quality, service and reputation, among other factors. Employees dealing with suppliers should carefully guard their objectivity. Specifically, no employee should accept or solicit any personal benefit from a supplier or potential supplier that might compromise, or appear to compromise, their objective assessment of the supplier’s products and prices. Employees can give or accept promotional items of nominal value or moderately scaled entertainment within the limits of responsible and customary business practice.

The Company is committed to free and open competition in the marketplace. Employees should avoid actions that would be contrary to laws governing competitive practices in the marketplace, including federal and state antitrust laws. Such actions include misappropriation and/or misuse of a competitor’s confidential information or making false statements about the competitor’s business and business practices. Any actions will amount to gross misconduct and subject to disciplinary action, including dismissal.

The Company is committed to providing equal opportunity and fair treatment to all individuals on the basis of merit, without discrimination because of race, color, religious belief, national origin, sex (including pregnancy), sexual orientation, age, disability, or other characteristic protected by law. Every employee has the right to be treated with respect and dignity and is entitled to work in an environment free from harassment, victimization and bullying. The Company prohibits harassment in any form, whether physical or verbal and whether committed by supervisors, non supervisory personnel or non-employees. Harassment can be any unwanted or offensive conduct which makes another person uncomfortable. This may include, but is not limited to –

1. Unwanted Physical Conduct such as unnecessary touching, patting, pinching, brushing against another person’s body, insulting or abusive behavior or gestures, physical threats, assault, coerced sexual intercourse or rape.
2. Unwanted Verbal Conduct such as unwelcome advances or propositions, sexual flirtations patronizing titles or nicknames, propositions or remarks, innuendo, lewd comments, jokes, banter or abusive language, which refer to a person or a group’s gender, color, race, religion, ethnic or national origins, disability or sexual preference, etc., or repeated suggestions for unwanted social activities inside or outside the workplace. This ‘verbal’ conduct includes conduct either in printed format or via email or other electronic means.
3. Unwanted Non-verbal Conduct such as racially or sexually based messages or graffiti, including where it refers to an individual’s characteristics or private life, abusive or offensive gestures, leering, whistling, creation or distribution of suggestive or offensive pictures or videos including distribution of such pictures on any media including via email or on display units or network systems.
4. Bullying including persistent criticism and personal abuse, either in public or private.

Employees should avoid actions that would amount to harassment or discriminatory practices, including –

1. employment decisions based on stereotypes or assumptions about the abilities, traits, or performance of individuals of a certain sex, race, orientation age, religious belief, or ethnic group, or individuals with disabilities
2. denying employment opportunities to a person because of marriage to, or association with, an individual of a particular race, religion, national origin, or an individual with a disability;
3. harassment on the basis of race, color, religious belief, sex, national origin, disability, or age
4. retaliation against an individual for filing a charge of discrimination, participating in an investigation, or opposing discriminatory practices.

The behavior referred to above may be directed toward an individual or group. It should be noted that it is the impact of the behavior which is relevant and not the nature or intent behind it. The Company has implemented policies and procedures in the Employee Handbook to prevent unlawful discrimination or harassment including sexual harassment. Harassment at work in any form is unacceptable behavior and will not be permitted or condoned. Everyone must comply with this policy and employees should ensure that their behavior to colleagues and customers does not cause offense or constitute harassment. Sexual and racial harassment as well as harassing a person on account of gender, sexual orientation, age religious beliefs or disability, constitute discrimination and are unlawful. Harassment may also be a civil offense and a criminal offense and it may contravene health and safety legislation. If you have any complaints about unlawful discrimination or harassment including sexual harassment, report such conduct to your supervisor or the Human Resource Executive. All complaints will be treated with sensitivity and discretion. The Company will protect your confidentiality to the extent possible, consistent with law and the Company’s need to investigate your concern. Where our investigation uncovers harassment or unlawful discrimination, we will take prompt corrective action, which may include disciplinary action by the Company, up to and including, termination of employment. The Company strictly prohibits retaliation against an employee who, in good faith, files a complaint. Single offenses that amount to a serious breach of this policy, or repeated offenses, may result in dismissal or summary dismissal.

Application Nexus adheres to all environmental legislation, regulations and all local laws to facilitate the protection of the environment. We have a process that ensures conformity to local regulations, including those relating to the handling, recycling, and the elimination and disposal of dangerous materials and to work actively to improve the environment and proactively to pursue any initiatives that bring about that improvement.