Code of Conduct & Ethics

1. Purpose & Scope

This Code of Conduct & Ethics ("Code") establishes the fundamental standards of behavior expected of all Zentish Exim Pvt Ltd employees, officers, directors, contractors, agents, and representatives ("Personnel") in conducting business on behalf of the Company. It applies globally across all Zentish Exim entities, subsidiaries, and joint ventures.

Compliance with this Code is a condition of employment and engagement. Violations may result in disciplinary action up to and including termination, and where applicable, legal action.

2. Core Principles

3. Key Compliance Areas

3.1 Anti-Corruption & Anti-Bribery

• Zero tolerance for bribery, kickbacks, facilitation payments, or corrupt practices in any form.
• No offering, promising, giving, or accepting anything of value to improperly influence business decisions.
• Gifts and hospitality must be modest, customary, and transparent; never cash or cash equivalents.
• Compliance with the Indian Prevention of Corruption Act, UK Bribery Act, US FCPA, and all applicable anti-corruption laws globally.

3.2 Conflicts of Interest

• Personnel must avoid situations where personal interests conflict with Company interests.
• Disclose any actual, potential, or perceived conflicts to the Compliance Officer promptly.
• No self-dealing, competing with the Company, or using Company assets for personal gain.

3.3 Confidentiality & Information Security

• Protect proprietary information, trade secrets, customer data, and non-public financial information.
• No unauthorized disclosure, use, or removal of confidential information during or after employment.
• Comply with all data protection laws (GDPR, India DPDP Act) and Company information security policies.

3.4 Fair Competition & Antitrust

• Comply with all applicable competition and antitrust laws globally.
• No price-fixing, bid-rigging, market allocation, or collusion with competitors.
• No sharing of competitively sensitive information (pricing, costs, customers, strategies).

3.5 Foreign Trade Compliance

• Comply with all export controls, sanctions, embargoes, and customs regulations.
• Screen all counterparties against sanctions lists (UN, EU, US, India, etc.) before transactions.
• Obtain required export licenses for controlled chemicals, dual-use goods, and restricted technologies.

3.6 Health, Safety & Environment

• Comply with all applicable HSE laws, regulations, and Company standards.
• Report all incidents, near-misses, and hazards immediately.
• Minimize environmental impact through responsible chemical handling, waste management, and emissions control.

3.7 Human Rights & Labor Practices

• Zero tolerance for forced labor, child labor, human trafficking, and modern slavery.
• Respect freedom of association, collective bargaining, and non-discrimination.
• Provide fair wages, safe working conditions, and reasonable working hours.

3.8 Data Protection & Privacy

• Comply with GDPR, India DPDP Act, and all applicable data protection laws.
• Process personal data lawfully, transparently, and for specified purposes only.
• Respect data subject rights (access, rectification, erasure, portability, objection).

4. Reporting & Whistleblower Protection

Zentish Exim maintains a confidential whistleblower channel for reporting actual or suspected violations of this Code, laws, or Company policies:

• Email:compliances@zentish.com
• Web Form:Anonymous Web Form

Protections:Zero retaliation policy. Confidentiality maintained. Presumption of innocence. Good-faith reporters protected from retaliation, discrimination, or adverse employment action.

5. Enforcement & Disciplinary Action

Violations of this Code may result in disciplinary action including:

• Verbal or written warning
• Suspension or demotion
• Termination of employment or contract
• Referral to law enforcement where criminal conduct is suspected
• Recovery of damages and legal costs

6. Training & Acknowledgment

• All Personnel must complete Code of Conduct training upon onboarding and annually thereafter.
• Annual written acknowledgment of understanding and compliance required.
• Specialized training for high-risk roles (sales, procurement, finance, logistics).

7. Monitoring & Audit

• Regular compliance risk assessments and internal audits.
• Periodic testing of controls for anti-corruption, trade compliance, and data protection.
• Third-party due diligence for agents, distributors, and joint venture partners.

8. Document Control & Revision

This Code is reviewed annually by the Compliance Officer and approved by the Board of Management. Updates are communicated to all Personnel with mandatory re-acknowledgment.