The Kytes
Code of Conduct

This document serves as the ethical framework for Kytes and outlines the principles and standards that guide how we conduct our business.

Purpose

To guide employee behavior and decision-making: By establishing clear ethical standards, the business ethics and code of conduct provide a structured framework for employees, consultants, contractors, vendors/suppliers, customers, and stakeholders to navigate complex situations and make choices that align with the company’s values.

To promote a positive and respectful work environment: By fostering integrity, transparency, and respect, these documents contribute to a culture where e employees, consultants, contractors, vendors/suppliers, customers, and stakeholders feel valued, safe, and empowered to contribute their best work.

Policy Statement – Business Ethics

Anti-Bribery:

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  • We will not engage in any form of bribery, extortion, or other corrupt
    activities.
  • Bribery can take many forms, including:
    • Cash payments.
    • Gifts (including lavish entertainment or travel).
    • Donations to political parties.
    • Job offers or promotions.
    • Discounts or other favors
  • We will comply with all applicable anti-bribery laws and regulations.
  • We will not offer, promise, or give anything of value to government officials
    or other third parties to obtain or retain business or any other improper
    advantage.
  • We will not accept any bribes or other forms of improper payments.
  • We may offer or accept gifts and hospitality in the ordinary course of
    business, provided that:

    • The gifts and hospitality are of modest value and are not intended
      to influence any business decision.
    • The gifts and hospitality are given or received openly and
      transparently.
    • Gifts and hospitality are not prohibited by any applicable laws or
      regulations.

Anti-Money Laundering:

  • We will commit to preventing money laundering in all our business
    activities.
  • We will implement measures to ensure that our financial transactions are
    legitimate and comply with all applicable laws and regulations.

    • Customer KYC
    • Vendor KYC/Vendor Registration Details
    • All transactions above nominal value (petty cash expenses) are
      paid/received through Banking channels only
  • We will do record keeping of all financial transactions.

Fair Competition and Anti-Trust:

  • We will compete fairly and ethically in the marketplace.
  • We will comply with all applicable competition laws and regulations.
  • We will avoid any form of anti-competitive behavior, such as price fixing or
    market allocation.

Conflicts of Interest:

  • We will disclose any potential conflicts of interest to our supervisor or HR
    representative.
  • We will avoid any situations where our personal interests could conflict with
    our professional responsibilities.
  • We will not use our position for personal gain or to benefit friends or family
    members.

Intellectual Property Rights:

  • We will respect the intellectual property rights of others.
  • We will protect our own intellectual property rights.
  • We will not use or copy the intellectual property of others without
    permission.

Export Controls:

  • We will comply with all applicable export control laws and regulations.
  • We will not export any goods, technology, or services that are subject to
    export controls without the required licenses and permits.

Data Protection and Security:

  • We will protect the privacy and security of all personal data we
    collect, use, or store.
  • We will comply with all applicable data protection laws and regulations.
  • We will take appropriate measures to protect personal data from
    unauthorized access, use, disclosure, loss, alteration, or destruction.
  • We will be transparent about our data collection and usage practices.

Financial Responsibility:

  • We will maintain accurate and complete financial records.
  • We will use our resources responsibly and efficiently.
  • We will avoid any form of financial fraud or misconduct.
  • We will comply with all applicable accounting and financial reporting
    standards.

Disclosure of Information:

  • We will disclose the required material information to our
    investors, shareholders, and the public in a timely and accurate manner.
  • We will comply with all applicable securities laws and regulations.

Wages and benefits, Working hours:

  • We will follow the Legal Framework, of India, The Indian Shops and
    Establishments Act, 1953 and other legal frameworks set by Indian Govt.
  • For offices of any other country (if it is located) local Legal frameworks and
    regulations shall be followed.
  • We adhere to
    • Minimum Age: 18 years
    • Minimum Wages: as per the Law, based on category of employment.
    • Benefits: EPF, Gratuity, Addl benefits/allowances/bonus based on the
      need, performance, and designation – are provided.
    • Working hours: Max 9 hours per day, 48 hours per week. Even in case of
      emergency work/additional hours, it shall not exceed 60 hours per week.
      All other working hours related rules as stipulated in the law.
    • Weekly off one day in seven days.
    • Any additional hours spent (beyond 48 hours), is voluntarily spent by the
      employee.
    • Leaves – Sick Leave, Casual Leave, Maternity Leave etc. as per the Law

Equality, Diversity, and Inclusion:

  • We embrace and celebrate the diverse backgrounds, experiences, and
    perspectives of our employees, customers, and stakeholders.
  • We promote equal opportunities and access to resources and advancement
    for all.

Harassment and non-discrimination:

  • We will not allow any unwelcome/unprofessional conduct based on any
    personal characteristic, such as race, color, religion, gender, national
    origin, ancestry, age, disability, sexual orientation, political affiliation,
    genetic information, or any other characteristic protected by law. This
    includes verbal, nonverbal, physical, and visual conduct.
  • We create a workplace free from discrimination, and bias based on any
    personal characteristic such as any personal characteristic, such as race,
    color, religion, gender, national origin, ancestry, age, disability, sexual
    orientation, political affiliation, genetic information, or any other
    characteristic protected by law.
  • We encourage all employees to report any incidents of harassment or
    discrimination to their manager, human resources, or any other reporting
    mechanism.
  • We will protect the confidentiality of all reports of harassment and
    discrimination.
  • We will not retaliate against an

Health and Safety:

  • We prioritize the health and safety of our employees, contractors, and
    visitors.
  • We provide a safe and healthy work environment by implementing and
    adhering to industry best practices and safety regulations.
  • We empower employees to report safety concerns and actively participate
    in safety initiatives.

Human Rights:

  • We respect and uphold the human rights of all individuals, including our
    employees, customers, suppliers, and the communities in which we
    operate.
  • We will not tolerate any form of discrimination, harassment, or unfair labor
    practices.
  • We will comply with all applicable laws and regulations regarding human
    rights.

Environmental:

  • We are committed to conducting our business in an environmentally
    responsible manner.
  • We will minimize our impact on the environment, including our use of
    resources and our generation of waste.
  • We will comply with all applicable environmental laws and regulations.
  • We will strive to continuously improve our environmental performance.

Whistleblower Policy:

  • We encourage employees to report any suspected violations of this
    Business Ethics Policy or any other illegal or unethical behaviour.
  • We will provide a confidential and anonymous reporting mechanism for
    employees who wish to report violations.
  • We will not retaliate against any employee for reporting a violation in good
    faith.

Retaliation:

  • We will not tolerate any form of retaliation against employees who report
    violations of this Business Ethics Policy or any other illegal or unethical
    behaviour.
  • Employees who report violations in good faith will be protected from any
    form of adverse action, such as termination, demotion, or harassment.

Training and Communication:

  • We will provide employees with training on this Business Ethics Policy and
    other ethical conduct matters.
  • We will communicate our ethical expectations to employees on a regular
    basis.
  • We will create a culture of ethical behaviour where employees feel
    comfortable raising concerns and reporting violations.

Policy Statement – Code of Conduct

Anti-Bribery:

  • You must not offer, promise, or give anything of value to government
    officials or other third parties to obtain or retain business or any other
    improper advantage.
  • You must not accept any bribes or other forms of improper payments.
  • You must report any suspected bribery or corruption to your supervisor or
    HR representative immediately.
  • You may offer or accept gifts and hospitality in the ordinary course of
    business, provided that:

    • The gifts and hospitality are of modest value and are not intended
      to influence any business decision.
    • The gifts and hospitality are given or received openly and
      transparently.
    • The gifts and hospitality are not prohibited by any applicable laws or
      regulations.

Anti-Money Laundering:

  • You must not do any financial transactions (payment/receipt) of the
    company in cash above nominal value.
  • You must get the KYC details of the parties to ensure that financial
    transactions are legitimate and comply with all applicable laws and
    regulations.

    • Customer KYC
    • Vendor KYC/Vendor Registration Details
  • You must do record keeping of all financial transactions.

Fair Competition and Anti-Trust:

  • You should comply with all applicable competition and anti-trust laws and
    regulations.
  • You should avoid any anti-competitive behavior, such as price fixing,
    market allocation, or misleading advertising.
  • You should treat all competitors fairly and with respect.

Conflicts of Interest:

  • You should disclose any actual or potential conflicts of interest to your
    supervisor or HR representative immediately.
  • You should avoid any situations where your personal interests could conflict
    with your professional responsibilities.
  • You should not use your position for personal gain or to benefit friends or
    family members.

Intellectual Property Rights:

  • You must respect the intellectual property rights of others, including
    patents, trademarks, copyrights, and trade secrets.
  • You must protect our own intellectual property rights and report any
    suspected infringement to your supervisor or HR representative
    immediately.
  • You must not use or copy the intellectual property of others without
    permission.

Export Controls:

  • You must comply with all applicable export control laws and regulations.
  • You must obtain necessary licenses and permits before exporting controlled
    goods, technologies, or services.

Data Protection and Security:

  • You should protect the privacy and security of all personal data entrusted
    to you.
  • You must comply with all applicable data protection laws and regulations.
  • You should be aware of and follow our company’s data protection policies
    and procedures.

Financial Responsibility:

  • You should handle company funds and assets responsibly and with
    integrity.
  • You must avoid any form of financial fraud or misconduct.
  • You must report any suspected financial irregularities to your supervisor or
    HR representative immediately.

Disclosure of Information:

  • You should be honest and truthful in all communications and reports.
  • You should disclose all material information to your supervisor or HR
    representative in a timely manner.
  • You must comply with all applicable securities laws and regulations
    regarding the disclosure of information.

Equality, Diversity, and Inclusion:

  • You should treat all colleagues with respect and dignity, regardless of their
    race, color, religion, national origin, sex, age, disability, sexual orientation,
    gender identity, or any other protected characteristic.
  • You should not engage in any form of discrimination, harassment, or
    bullying.
  • You should promote a workplace that is inclusive and fosters diversity of
    thought and experience.

Health and Safety:

  • You should comply with all company safety rules and procedures.
  • You should report any unsafe conditions or work practices to your
    supervisor or HR representative immediately.
  • You should take all necessary precautions to protect your own safety and
    the safety of others.

Human Rights:

  • You should conduct yourself in a manner that respects the human rights of
    all individuals.
  • You must avoid any involvement in activities that violate human rights,
    such as forced labor, child labor, or discrimination.
  • You should report any suspected human rights violations to your supervisor
    or HR representative immediately.

Environmental:

  • You should be mindful of your environmental impact and strive to minimize
    it.
  • You must comply with all applicable environmental laws and regulations.
  • You should conserve resources and use them efficiently.

Whistleblower Policy:

  • You are encouraged to report any suspected violations of this Code of
    Conduct or any other illegal or unethical behavior.
  • You can report concerns confidentially and anonymously to your supervisor
    or HR representative.
  • We will not retaliate against any employee for reporting concerns in good
    faith.

Retaliation:

  • You must not retaliate against any employee who reports concerns in good
    faith or cooperates with investigations.
  • Any employee who experiences retaliation should report it immediately to
    their supervisor, HR representative.

Training and Communication:

  • All employees will receive training on this Code of Conduct and other
    ethical conduct matters.
  • Employees will have access to the Code of Conduct electronically.
Download Tata Code of Conduct [PDF]