Introduction

PS Associates is committed to maintaining the highest standards of ethical conduct, integrity, transparency, and professionalism in all business dealings. This Code of Ethics and Business Conduct applies to all employees, contractors, consultants, and representatives of the organization.

Core Ethical Principles

• Integrity and Honesty: All employees must perform their duties truthfully, fairly, and transparently. Misrepresentation, fraud, or any form of unethical behaviour is strictly prohibited.
• Professional Conduct: Employees must behave responsibly and respectfully with clients, vendors, partners, and colleagues. Professionalism must be upheld at all times.
• Confidentiality: Sensitive company information, client data, and internal documents must be protected. Employees must not disclose confidential information to unauthorized persons.
• Conflict of Interest: Employees must avoid situations where personal interests conflict with company interests. Any potential conflict must be reported immediately to management.

Anti-Corruption and Anti-Bribery Policy

• Prohibition of Bribery: Employees must not offer, give, request, or accept bribes, kickbacks, gifts, or anything of value intended to improperly influence business decisions.
• Gifts & Hospitality: Only modest and reasonable gifts or hospitality that are lawful and transparent may be accepted. Anything excessive, suspicious, or intended to influence business outcomes is forbidden.
• Compliance With Laws: All employees must follow applicable anti-corruption laws, including:
  • Prevention of Corruption Act, 1988 (India)
  • Companies Act, 2013
  • Any other relevant local or international compliance guidelines
• Third-Party Conduct: Vendors, subcontractors, and partners representing PS Associates must adhere to the same ethical and anti-corruption standards. Due diligence is required before engaging any third party.

Reporting Violations

Employees are encouraged to report any unethical or suspicious conduct without fear of retaliation. Reports may be submitted to:

• Immediate supervisor
• Compliance officer / Management
• Anonymous reporting mechanism (if applicable)

Disciplinary Actions

• Warning or written reprimand
• Suspension or termination
• Legal action, where applicable

Acknowledgement

All employees and representatives of PS Associates must read, understand, and comply with this Code of Ethics and Business Conduct. Signing the acknowledgment is mandatory.

Company's Ethics and Compliance Training

Employees Covered Under Training

• All full-time and part-time employees
• Contract staff and field personnel
• Supervisors, team leaders, and department heads
• Any employee involved in client interaction, finance, procurement, or operations
• Newly joined employees as part of induction/orientation

Training Frequency

• Annual Mandatory Training for all employees
• Induction Training for new hires within their first 30 days
• Quarterly Refresher Sessions for high-risk functions
• Special Training Sessions for updates to laws, policies, or client requirements

Key Topics Covered

• Code of Ethics and Business Conduct
• Anti-Corruption & Anti-Bribery Compliance
• Legal & Regulatory Compliance
• Workplace Conduct & Respectful Behaviour
• Confidentiality & Data Protection
• Reporting & Whistleblower Mechanism

Training Methods

• Classroom sessions
• Digital/e-learning modules
• Case studies and scenario-based exercises
• Periodic assessments and certification tests

Record Keeping

• Attendance, completion certificates, and training materials are documented and maintained
• Employees who fail to complete mandatory training must undergo make-up sessions

Third-Party Onboarding Process

Initial Screening

• Collection of registration documents, PAN, GST, licenses, certifications
• Verification of experience, reputation, and capability
• Assessment of alignment with PS Associates' standards

Risk Assessment

Third parties are classified as low, medium, or high risk based on service nature, financial stability, operational dependency, and compliance history.

Due Diligence

• Legal validity
• Financial soundness
• Reference checks
• Litigation history
• Workforce compliance
• Anti-bribery red-flag assessment

Training Requirements

• Code of Ethics & Business Conduct
• Anti-Corruption & Anti-Bribery Compliance
• Operational & Safety Requirements
• Data Protection & Confidentiality

Contractual Requirements

• Scope of work and service-level expectations
• Confidentiality and data-protection clauses
• Anti-corruption and compliance commitments
• Statutory compliance requirements
• Penalty clauses for non-compliance

Ongoing Monitoring & Compliance Oversight

• Periodic compliance checks
• Performance monitoring
• Risk-based audits
• Reporting & issue resolution

Annual Review & Re-Evaluation

All third parties are re-evaluated annually to ensure continued compliance and satisfactory performance.

Company's Reporting (Whistleblowing) Channels

Toll-Free / Service Support Number: (0755) 4222624

Alternate Contact: 9713000743 / 9109144388

Email ID: support@psaitech.com

Website: www.psaitech.com

Support Hours: 24 hrs