Code OF Conduct

This Mentor Code of Conduct (“Code”) is effective from September 1, 2022 (“Effective Date”) and applies to ReachOne, its subsidiaries and joint ventures over which the ReachOne exercises management control (“We”, “Us”, “Our”, “Company”). The Code applies to all Mentors engaged to provide services to the Company.

Our Code has been created to help to support the Mentors of the Company, with high standards of ethical behaviour and compliance with local laws and regulations being essential to protecting and long term success of the business.

Our Company run with the motto of serving the customer and earn their trust. All of our communications and other interactions with our customers should increase their trust in Us. 

1. COMPLIANCE WITH LAWS

(a). All the Mentors are expected to comply with all Company’s policies, procedures, and regulations.

(b). The Mentor is expected to know and understand the legal obligations and act within the bounds of applicable laws, rules, and regulations of the localities where Company do business.

(c). The Mentor shall comply with all applicable privacy laws including IT Act, 2000 and the rules thereunder, Consumer Protection Act 2019, General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and so on.

(d). The Mentor must comply with all localities’ anti-corruption laws where the Company does business, including The Prevention of Corruption Act, 1988 in India.

(e). Where any provision of the Code conflicts or is inconsistent with applicable laws, the provisions of that law must be complied with and override this Code.

(f). Violation of applicable government laws, rules, and regulations may subject us to individual criminal or civil liability. Such individual violations may also subject the Company to civil or criminal liability, to the loss of reputation or business, and both these events may attract disciplinary action by the Company.

2. 
   CONFLICTS OF INTEREST

(a). The Mentors are expected to use their best judgment and work for the best interest of the Company while on duty and should attempt to avoid actual or apparent conflict of interest with their personal matters with that of Company’s matter.

The following are some examples of conflict-of-interest situations:

(1). influencing an approval process resulting in the hiring of a relative or entering into a business relationship. For the purpose of this clause, relative means a close relative, spouse, grandparent, grandchild, uncle, aunt, nephew, or niece.

(2). an Mentor engaging in private employment or rendering services for any person or organization that has or may have business dealings with the Company.

(b). On apprehension of such conflict, the Mentor shall disclose such information to their supervisor/manager and try and avoid entering into such a transaction without the guidance of the supervisor/manager. The appropriate parties will decide to determine if the conflict is substantial enough to exclude the Mentor from any further involvement in such activity or decision process.

3. 
   EQUAL OPPORTUNITY APPOINTMENT OF MENTORS

(a). Our Project Appointment Policy is based upon individual merit and qualifications related to professional competence. We also make all reasonable accommodations to meet our obligations under the laws protecting the rights of the disabled.

(b). We promote a diverse, inclusive, and equal workplace. Every Mentor of the Company is expected to treat everyone with whom We have contact with dignity, courtesy, and respect.

(c). We do not discriminate against any person because of their gender, caste, religion, age, nationality, sexual orientation, disability, or any other trait protected by law, concerning any terms of appointment such as hiring, promotion, transfer, compensation, and benefits, etc. It is expected that the managers/supervisors shall take appointment-related decisions based only on the merit of the person and not discriminate against any person because of their personal characteristics/traits.

(d). In accordance with the provisions of the Rights of Persons with Disabilities Act, 2016 and rules thereunder, Company thrives to ensure that the work environment is free from any discrimination against any persons with disabilities and expect the same from all Mentors working for the Company.

4. 
   HARASSMENT AND DISCRIMINATION

(a). The Company prohibits discrimination or harassment in any form including verbal, physical, and visual form and has a zero-tolerance policy against any kind of harassment in a work-related situation based on sex, race, colour, caste, religion, ethnicity, nationality, age, physical or mental disability, or any other category protected under applicable state and central laws. If any Mentor believes that he/she has been bullied, harassed, or discriminated against, such Mentor shall immediately report the incident to their supervisor, HR team of the company. Similarly, the supervisors and managers shall on knowing such incident report it to the HR team. HR team shall take prompt action on such complaints and take appropriate action. The Mentor can report any harassment or discrimination in the following method with full confidentiality and protection:

The Mentor can report any harassment or a case of misuse of data to Geetika Kapoor.

5. 
   USE OF COMPANY PROPERTY

(a). The Company may entrust the Mentor with a wide range of valuable assets to help work on the Company’s behalf.

(b). Each Mentor is responsible for the property acquisition, use, maintenance, and disposal of Company assets, including materials, equipment, tools, tangible properties, information, data, intellectual property, etc.

(c). The The Mentors are expected to treat these assets with care and use them with the business’s interests in mind and according to the Company’s latest security policies. In case if the property is damaged or lost due to a fault on the part of the Mentor, Mentor shall be liable to replace or refund the amount as suggested by Company.

(d). The Mentor shall never use the Company’s property for personal gain or other purposes other than as envisaged under the company policy.

6. 
   CONFIDENTIAL INFORMATION AND PRIVACY

(a). During the course of appointment as a Consultant of the Company, the Mentor will have access to information (whether or not recorded in writing or on computer disk or tape) which the Company treats as confidential or which has the necessary quality of confidentiality.

(b). Further, the Mentor understands that the Company from time to time has in its possession information that is claimed by others to be proprietary and which the Company has agreed to keep confidential.

(c). Access to proprietary information will be limited to those needing to know. The Mentor is required to maintain the confidentiality of Company information even if they leave the Company’s services.

(d). Our clients and other stakeholders rely on us to maintain accurate and complete records and accounts. Mentor shall throughout their tenure as a Consultant, handle the information with integrity and responsibility. All Mentors have an obligation to know and comply with all currently applicable record retention policies and procedures. This includes how data is shared, stored, and retrieved, and the circumstances under which it may be disposed of.

7. 
   INSIDER INFORMATION

(a). The Mentor understand and agree that because of the position at the Company and relationships of the Company, owners, executives, and clients that the Mentor may learn certain information that constitutes “insider information” for the Securities and Exchange Board of India (“SEBI”) and securities laws and regulatory purpose.

(b). The Mentors shall never disclose any such insider information to anyone, and not use such insider information to trade in securities, or to attempt in any way to profit from any such insider information.

(c). If required, the Mentors shall execute specific agreements or other documents as requested by the Company in connection with this. Mentors of Company may be subject to criminal and civil liability for engaging in transactions involving insider information. Further, such activity may subject the Company to substantial penalties. The Company considers violations of its insider information policy to be grounds for immediate termination of employment.

8. 
   INTERNET USAGE AND CYBERSECURITY

(a). The electronic communication system must be utilized exclusively to facilitate the business of the Company. Mentors are cautioned against using the internet for matters of personal gain and entertainment.

(b). Logging into any of the Company’s accounts from personal devices such as mobile phones, tablets, or laptops, can put our Company’s data at risk. We do not recommend accessing any Company’s data from personal devices. If so, is inevitable, Mentors are obligated to keep their devices safe, with proper security protection.

(c). We recommend all Mentors follow the following practices:

(1). Keep all electronic devices password secured and protected with the latest security features.

(2). Only log in to the Company’s account using safe and secure networks.

(3). Upgrade antivirus software regularly on the devices.

(4). Don’t leave any devices unprotected or exposed.

(d). Emails can carry scams and malware. If the Mentor is not sure if the email received or any data is safe, they can always contact Our IT specialist for advice.

(e). To protect the data of the company, all Mentor shall:

(1). Abstain from opening or clicking any links or attachments when it is not from within the company or a reliable source.

(2). Always make sure the emails are from valid email ids within the organization or from a reliable source.

(3). Be careful about inconsistencies and clickbait titles like offering prices, advice, surprise, etc.

(f). Use passwords with upper case, lower case, numbers, and symbols. Do not exchange credentials when not requested or approved by the supervisor.

(g). The Mentor shall avoid transferring any personal data including customer and Mentor confidential data and shall adhere to all applicable personal data protection laws while dealing with it.

(h). These cybersecurity guidelines and procedures have to be strictly followed even when working remotely. In case of intentional or repeated breaches, or are harmful to Company, the Companywill take serious action including termination of the Employment.

9. SOCIAL MEDIA POLICY

(a). We respect your right to participate in social media and understand that your time outside of your work is your own. But it is also important to protect the goodwill of the Company while using social media. if the person engages in social media activity that identifies you as Our Mentor or your work at Our Company, even if done off-premises and while off-duty, it could affect the reputation of the Company.

(b). Always ensure that your social media activity is subject to relevant policies of the Company. This includes this Code as well as requirements for protecting confidential information.

(c). When you are using external social media channels, make sure you are not using your official email for the same and shall not represent in any social media content that you are not authorized to speak on behalf of the Company, or that the Company has approved your content, without the prior written approval from your supervisor/manager.

10. 
    PERSONAL APPEARANCE

(a). Every Mentor must maintain an appropriate standard of dress and personal appearance at work and professionally conduct themselves at all times both within the workplace and when representing the Company.

(b). The appearance of Mentor while working for the Company contributes to Our reputation and the development of Our business. All Mentors are required to be neat, clean and tidy and of smart appearance in a way to present themselves at all times in accordance with their professional status and dress in a manner appropriate to their role, whether working on Company’s premises or elsewhere.

(c). The Mentor who occupies roles that require protective/safety clothing or footwear is obliged to wear this clothing while carrying out their duties as required by law or by the Company’s rules.

(d). Any Mentor who disregards these rules will be subject to disciplinary action. However, it is anticipated that minor breaches of the policy will be dealt with as informally as possible. In serious cases, where an Mentor’s appearance in the Company’s view transgress the limits, the Mentor will be asked to change the dress and, in these circumstances, the Mentor will not be paid for the duration of such absence from the work.

11. 
    ATTENDANCE AND PUNCTUALITY

(a). To ensure adequate staffing, positive Mentor morale, and meet expected productivity standards throughout the organization, Mentor will be held accountable for adhering to their workplace schedule. In case the Mentor is unable to meet the schedules, he/she must get prior written consent from their supervisor/manager for schedule changes.

(b). An Mentor is deemed absent when he/she is unavailable for work as assigned/scheduled and such time off was not scheduled/approved in advance by the concerned supervisor/manager.

12. 
    COMMUNICATION AND COLLABORATION

(a). Each Mentor in this Company must show maximum respect to every other person within the organization and outside contacts in a business context. Mentors should strive to maintain a civil work atmosphere at all times and refrain from shouting, yelling, using vulgarities, or swearing at co-workers or customers.

(b). If the Mentor is contacted and requested to discuss Company business with any member of the press, investor, market analysts, or any other outside parties, such Mentor should refrain from doing so and instead, refer the request to the designated spokesperson in the Company. For any further clarification on this, the Mentor can contact the HR department.

(c). Meetings are a formal means of communication that happens constantly through all the departments. People handling functions that occur at multiple destinations and those who work independently are required to meet regularly. In addition, there would be regular meetings of the supervisors/managers with the Company management.

13. 
    RECEIVING THE GIFT

(a). The Mentors are prohibited from accepting gifts of any kind, that are offered by vendors, suppliers, customers, potential Mentors, potential vendors, and suppliers or any other individual or organization at any time, on or off the work premises except as specifically allowed under this policy.

(b). “Gift” under this clause would include any gratuitous non-monetary benefits that the Mentors can use or consume.

(c). If an Mentor receives a gift in violation of this Policy, such Mentor shall report such an incident to Supervisor and shall follow the following procedure:

The Mentor shall immediately report the Gift to his/her immediate Supervisor.

14. ANTI-BRIBERY

(a). The Mentor shall not take any action, directly or indirectly, that would result in violation of or has violated the Prevention of Corruption Act, 1988, as amended, and any other applicable anti-bribery or anti-corruption laws. This includes without limitation, using any funds for any unlawful contribution gift, entertainment, or other unlawful payments to any foreign or domestic government official or Mentor. The Mentor shall not permit or authorize anyone in the Company to offer, pay, promise to pay, or authorize the payment of any money, or offer, give, promise to give, or authorize the giving of anything of value, to any officer, Mentor or any other person for any governmental authority or any enterprise owned or controlled by a government authority, any political party or official thereof, or any candidate for political office, or any officer or Mentor of a public international organization or to any person under circumstances where such Mentor has reason to believe or is aware of a high probability that all or a portion of such money or thing of value would be offered, given or promised, directly or indirectly, to any government official for the purpose of bribing.

15. 
    DRUGS AND ALCOHOL

(a). We thrive to protect the health and safety of every person of the Company. Drug and alcohol use can affect a person’s ability to work safely. It creates a risk to workers and hampers the work atmosphere.

(b). Whenever the Mentors are working, are operating any Company assets, are present on the Company premises, or conducting Company related worked offsite, they are prohibited from:

(1). Using, possessing, buying, selling, manufacturing, or dispensing, an illegal drug.

(2). Being under the influence of alcohol, or an illegal drug.

(3). possessing or consuming alcohol.

(c). An Mentor who is taking a prescription drug is required to present a statement from the prescribing physician that the drug will not impair the Mentor’s work performance or safety.

(d). The Mentor who tests positive, or otherwise violates this policy, will be subject to disciplinary action including immediate termination from the employment.

16. 
    DISCIPLINARY ACTION

(a). If the disciplinary actions for violation of this code are not mentioned under the respective preceding clauses, the Company may follow the following Progressive Disciplinary Action:

(1). Verbal warning:

• • The manager/supervisor reprimands the Mentor that his/her performance is unacceptable and gives the warning to refrain from any such activities.

(2). Written warning:

• • A written warning letter be given to the Mentor concerned. A warning letter describes the performance problems or work violations of the Mentor in specific detail and explains the consequence of failure to rectify the same within the specified time and any repetition of the same violation.

(3). Suspension:

• • A period of time during which the Mentor is not allowed to work and for which the Mentor will receive no compensation when it has been determined that the Mentor’s performance of duty or personal conduct is unsatisfactory.

(4). Termination:

• • If the Mentor is found to be in gross violation of this Code, he/she will be dismissed from the consultancy services with immediate effect.