Code of Conduct

 

PURPOSE, SCOPE AND USERS 

The Amagi Code of Conduct outlines standards of personal and professional conduct that all Amagi employees must always strive to uphold and behave ethically and professionally.  The Code provides a basis for all employees to maintain a working environment that is productive, positive, enjoyable, safe and free from harassment and discrimination.  It will also assist managers in inducting employees into Amagi and address any circumstances that may conflict with the stated standards and Values.  

The Amagi Code of Conduct applies to all full-time employees and contractors, including permanent employees, direct contract employees, EOR contract employees, consultants and interns. In addition to this, third-party contractors continue to be governed by any applicable rules/code of conduct as per their parent organization(s). 

The Amagi Code of Conduct extends to all vendors/suppliers/clients who work with Amagi employees. Amagi employees are expected to abide by the Code of Conduct while interacting with vendors/suppliers/clients on-premises/outside of Amagi premises.

 

PROCESS

The Code of Conduct provides a framework for appropriate behaviour for all Amagi employees where they can address ethical issues: 

• conduct themselves towards other colleagues, employee representatives, government authorities and clients; 
• perform their duties and obligations 
• fulfil the mission, goals and objectives of Amagi and 
• practice fairness and equity. 

The Code of Conduct is established on the following principles - integrity, honesty, conscientiousness, compassion, courtesy, fairness, and respect. The Code of Conduct stands true to the 4 Amagi Values – Be vulnerable, be you, Have fun with challenges, Goodness Wins, and Think macro, do the micro. This relies on individuals being responsible for their own professional behaviour within the provisions of this code, Amagi policies, legislation and relevant industrial clauses that apply to individual contracts of employment. 

Where there is doubt as to the application of the Code, or the appropriate course of action to be adopted, employees affected should discuss the matter with their manager. 

 

RESPONSIBILITIES

Employees responsibilities

All employees have a responsibility to:

• be personally responsible and accountable for their own performance, behaviour and attendance in the workplace
• undertake their duties and behave in a manner that is consistent with the provisions of the Employee Code of Conduct.
• report any departure from the Employee Code of Conduct by themselves or others
• comply with Amagi policies and procedures
• promote a positive, safe and healthy environment in the conduct of their work

Managers responsibilities

Managers are responsible and accountable for:

• undertaking their duties and behaving in a manner that is consistent with the provisions of the Employee Code of Conduct
• informing employees in their teams about the Employee Code of Conduct, relevant policies, and procedures 
• providing appropriate training and/or performance counselling to ensure the required standard is met.  
• reporting any departure from the Employee Code of Conduct by themselves 
• acting consistently and fairly in dealing with behaviour that breaches this code.

ATTENDANCE & PUNCTUALITY

• Employees are expected to be punctual and regular in their attendance – according to the shift and hours of work. Amagi observes flexible hours of work for the General Shift – with core hours as 10 AM to 4 PM
• Employees should apply for leave(s) as per the procedure specified by the People team, using appropriate tools as required. Employees who have mandatory attendance, need to keep their Managers informed through the assigned procedure/tool by the People team.
• The employee should apply for leave according to the leave policy of the country in which the employee is located in (e.g. India, US, UK, etc.) or as specified in the contractual agreement of the employee
• When an employee is unavoidably absent from work due to sickness or any other reason, the employee should call their manager (via phone / mobile phone) (or appropriately delegate) promptly (before their normal starting time of planned absence) and indicate their date of likely return to work.  
• Managers may exercise their responsibility to contact employees who have not contacted them directly within a reasonable timeframe to ascertain the reasons for that individual’s absence.

 

NATURAL JUSTICE, FAIRNESS AND EQUITY 

All investigations must be made in a consistent, prompt, fair and timely manner. The principles of natural justice must be maintained in dealing with each investigation. Appropriate committees are assigned for any such arising investigations.

 

USE OF FACILITIES AND EQUIPMENT

Employees should take all possible care when using Amagi property, goods, intellectual property and services and ensure they are used efficiently, carefully and honestly. Unless permission has been granted by the employees’ manager & People team, Amagi resources are not to be used for private purposes.

 

INFORMATION TECHNOLOGY AND SECURITY

Information Technology: 

• Employees must ensure fair and ethical usage of all IT infrastructure owned by Amagi, that is allocated to them. 

• Adherence to the Amagi Acceptable Use Policy is mandatory and any exceptions shall be explicitly approved by the Management and notified to the Information Security team.

• Amagi reserves the right to monitor all activities carried out on IT equipment and infrastructure that contain /host Amagi Information and its information processing systems.

Information Security: 

• Security of Information owned, controlled or processed by Amagi is governed by Amagi’s Information Security policies that are hosted on the Intranet portal. 

• Employees shall ensure they are familiar with all relevant information security policies and processes, and periodically undertake associated trainings.

Confidentiality and Privacy: 

• Employees must not access information that they are not authorized to access or use; those who have privileged / restricted access must not allow any other person access to any such confidential information. This information is to be used for Amagi purposes only and should remain secure and confidential.  
• Employees must take all reasonable precautions, including password maintenance and file protection measures to prevent unauthorized access and have an obligation to maintain the privacy, security and confidentiality of the information systems over which they have responsibility or control and that are owned or used by agreement.
• Employees who have access to or are working with sensitive personnel information (owned by Amagi or the Customer) must ensure adherence to applicable legal and regulatory obligations during the storage, transmission and processing of such information.

 

REMOTE WORK CONDUCT

In today's flexible working environment, Amagi recognizes the importance of maintaining professional standards, whether working on-site or remotely. To ensure productivity and uphold company values during remote work, employees are expected to adhere to the following guidelines:

1. Professionalism in Virtual Spaces:

   Employees should maintain the same level of professionalism in virtual meetings as they would in physical office spaces. This includes being presentable, punctual and engaged during video conferences.

   Backgrounds should be appropriate, and distractions minimized to maintain focus and respect for the meeting's objectives.

    

2. Secure and Productive Environment:

   Employees must ensure that their remote workspace is secure, with proper tools for confidentiality and data protection in place, such as secure Wi-Fi connections and password protection for devices.

   It is recommended that employees create a dedicated workspace free from personal distractions to maintain productivity during work hours.

    

3. Communication and Availability:

   Employees working remotely are expected to remain accessible during working hours, adhering to agreed-upon communication norms and timelines. Response times for emails and messages should be timely, ensuring seamless collaboration with colleagues and teams.

   Remote employees should keep their managers informed of their availability, including any changes due to personal circumstances.

    

4. Adherence to Company Policies:

   All employees working remotely are still bound by the company’s core policies, including data protection, confidentiality, and the appropriate use of IT infrastructure. Remote employees must also comply with local labour laws concerning working hours and rest breaks.

 

ENVIRONMENTAL RESPONSIBILITY

“Goodness Wins” being one of its core values, Amagi is committed to sustainability and corporate responsibility with all employees encouraged to contribute to minimizing the company’s environmental footprint. The following guidelines are suggested for promoting environmentally responsible behaviour:

Resource Efficiency:

• Employees are encouraged to use resources—such as paper, electricity, and office supplies—judiciously to reduce waste. For example, using digital alternatives where possible and printing documents only when necessary
• Encourage energy conservation by turning off electronic devices, such as monitors, computers, and lights, when not in use, especially at the end of the workday.

Sustainable Work Practices:

• Employees should seek out environmentally friendly alternatives for work-related tasks where possible. Examples include opting for virtual meetings over travel and utilizing public transport or carpooling for business travel when feasible.
• Remote workers are encouraged to use energy-efficient home office setups, minimizing the environmental impact of working from home.

Recycling and Waste Management:

• Employees should make use of recycling facilities available at Amagi offices and adopt proper waste segregation practices. Ensuring responsible disposal of electronic waste is crucial to minimizing environmental harm.

• Remote workers should follow similar waste management principles at home, responsibly disposing of items like batteries, paper, and other office supplies.

Environmental Advocacy:

• Amagi employees are encouraged to participate in company-wide environmental initiatives and contribute ideas for improving sustainability in the workplace. This could include volunteering in Goodness Wins projects and initiatives focused on environmental conservation.

 

ANTI-BRIBERY

Amagi maintains a zero-tolerance approach to bribery and is committed to conducting business ethically, with integrity, and in compliance with all applicable laws. Bribery, in any form, is strictly prohibited, including the offering, giving, receiving, or soliciting of anything of value to influence a decision, gain improper advantage, or secure a benefit.

Scope and Definition:

Bribery: The act of offering, promising, giving, or receiving something of value (monetary or otherwise) to influence the actions of an individual in a position of power, usually to gain an improper business advantage.

Facilitation Payments: Small payments made to expedite routine government actions (e.g., processing paperwork) are also considered bribery and are prohibited.

Key Guidelines:

Prohibited conduct: 

• Employees, agents, or any person acting on behalf of Amagi must not engage in offering, promising, or giving bribes to any person, whether in the private sector or government, to secure or retain business, or to obtain any other advantage.

• Similarly, no employee should solicit or accept any form of bribe from any entity or individual with the intent of compromising Amagi's interests.

Gifts and entertainment: 

• Gifts, entertainment, or hospitality may be offered or received only when they are reasonable, customary, and meant to foster legitimate business relationships, without creating an obligation or perception of impropriety.
• Gifts or hospitality that could influence, or be perceived to influence, business decisions or the award of business contracts are prohibited.
• All gifts and entertainment must be declared to HR and recorded, especially if their value exceeds INR 1000 for India or USD 50 for overseas.

Third-party due diligence: 

• Employees must ensure that any third-party agents, contractors, consultants, or business partners acting on behalf of Amagi comply with anti-bribery laws.

• Amagi will conduct due diligence on third parties before entering any business relationship, particularly in jurisdictions where bribery is considered a high risk.

Employees must report any suspected or actual bribery incidents immediately to the Office of Equal Opportunity (OEO) or escalate them by the Whistleblower Policy. Failure to comply with this policy will result in disciplinary action.

 

ANTI-CORRUPTION

Amagi is committed to upholding the highest standards of ethical behaviour and ensuring that its operations are free from corruption. Corruption erodes trust, distorts markets, and undermines the integrity of the business.

Scope and Definition:

Corruption: The abuse of entrusted power for private gain. This can include acts such as bribery, nepotism, extortion, or using one’s position for personal benefit.

Kickbacks and Facilitation Payments: Any payment or favour given in return for favourable treatment or to expedite processes is strictly prohibited.

Key Guidelines:

Prohibited actions: 

• Employees must not engage in any corrupt practices, including the offering, giving, receiving, or soliciting of anything of value to improperly influence the actions of another party.

• Employees must not engage in any activities that could be construed as exerting undue influence on government authorities or industry regulators. Amagi prohibits facilitating payments and any attempts to unduly influence public officials.

• Special care must be taken when dealing with government entities. Amagi prohibits facilitating payments and any attempts to unduly influence public officials.

Accurate record-keeping: 

• All business transactions and financial records must be maintained in an accurate, complete, and transparent manner, by applicable laws and company policies.

• Amagi prohibits the falsification of records, including inflating expenses, misreporting financial performance, or concealing transactions.

• Audits will be conducted periodically to ensure compliance with these standards and to identify potential risks of corruption.

Third-party relationships:

• Amagi requires all suppliers, vendors, and partners to adhere to anti-corruption laws and expects full transparency in all dealings.

• Any suspicious behaviour or signs of corrupt practices by third parties should be reported immediately.

Employees must be vigilant and report any concerns about corrupt activities to the Office of Equal Opportunity (OEO). Violations of the Anti-Corruption Policy will lead to disciplinary action, up to and including termination and legal prosecution.

 

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Anti-Fraud

Amagi is dedicated to preventing, detecting, and addressing fraud in all forms. Fraud undermines business integrity and can severely impact the company’s reputation and financial stability. All employees have a role to play in safeguarding the company against fraudulent activity.

Scope and Definition:

Fraud: Any deliberate act intended to secure an unfair or unlawful gain, including but not limited to theft, misrepresentation of data, falsification of records, or embezzlement.

Examples of fraud:

• Falsifying company records, including financial statements.

• Submitting false expense claims or inflating supplier invoices.

• Misappropriation of company assets, intellectual property, or funds.

• Collusion with third parties to manipulate contracts or gain kickbacks.

Key Guidelines:

Internal controls: 

• Amagi will implement stringent internal controls to detect and prevent fraud. This includes separation of duties in financial transactions, regular audits, and comprehensive financial reporting processes.

• Any employee responsible for managing budgets, handling cash, or approving expenses must adhere to Amagi’s financial protocols.

Fraud prevention: 

• Employees are expected to maintain the highest levels of honesty and transparency in their work. All financial transactions must be accurate, verifiable, and comply with Amagi’s internal policies.

• Fraud prevention training will be mandatory for all employees involved in finance, procurement, and management to ensure awareness of fraud risks and prevention techniques.
• Third-party fraud risk: 
• Amagi requires all business partners, vendors, and contractors to maintain anti-fraud protocols in their dealings. Contracts must include clauses that allow Amagi to audit vendor transactions for transparency.
• Any signs of fraudulent activity by third parties must be reported immediately to the management or the Office of Equal Opportunity (OEO).
  
  

Reporting and investigations:

• Any suspected fraudulent activities, whether internal or external, must be reported to the Office of Equal Opportunity (OEO) or through the Whistleblower Policy.
• Investigations into fraudulent activities will be conducted promptly, with confidentiality maintained throughout the process.
• Employees who report fraud will be protected from any retaliation or adverse consequences.

Employees are required to report any suspicions or knowledge of fraudulent activities to their manager, the Office of Equal Opportunity (OEO). Engaging in or failing to report fraud may result in disciplinary action, termination, and legal proceedings.

PREVENTION OF CHILD LABOR

Amagi is committed to ensuring that child labour is strictly prohibited across its operations and supply chain. We adhere to international labour standards and applicable local laws to protect the rights and well-being of children.

1. Zero Tolerance for Child Labour

• Amagi prohibits the employment of individuals below the minimum legal working age as defined by applicable national and international laws (such as the International Labour Organization (ILO) conventions).
• No individual under the age of 18 shall be engaged in hazardous work that may jeopardize their health, safety, or moral development.

2. Supplier and Partner Compliance

• All suppliers, vendors, and business partners must comply with Amagi’s strict no-child-labour policy.
• Suppliers must maintain proper documentation to verify the age of their employees.
• Any violation of child labour laws must be immediately reported and corrective action must be taken.

3. Remediation and Responsibility

• If any case of child labour is identified within Amagi’s operations or supply chain, immediate measures will be taken to remove the child from work and provide appropriate remediation.
• Amagi reserves the right to terminate relationships with suppliers or partners found to be in violation of child labour policies.

Amagi upholds the principles of fairness, dignity, and ethical labour practices, ensuring that every child’s right to education and safe childhood is protected.

 

CONFLICT OF INTEREST

If an employee becomes aware of the potential for conflict of interest, then they must notify their manager of the potential or actual conflict of interest. Amagi expects employees to:

• declare any likely conflict of interest to supervisors 
• avoid any detrimental outcome as a result of a conflict of interest

If a conflict of interest arises where an employee: 

• engages or is likely to engage in activities or advances, or 
• is likely to advance personal or other interests at the expense of Amagi’s interests or the interests of other employees, Amagi may then intervene. 

Employees must ensure that there is no conflict or incompatibility between their personal interests, whether pecuniary (e.g. money) or non-pecuniary and the impartial fulfilment of their duties.  It is not possible to define all potential areas of conflict of interest, but a few situations are given below: 

• Money, gifts and hospitality offered where there is an expectation of a return favour (which may or may not be detrimental to Amagi)
• additional employment that prevents or hinders the performance of a person in their role
• decisions regarding the employment or promotion of relatives or friends
• promotion of or soliciting for clients for their own private business

If an employee is in doubt as to whether a conflict exists, he/she must contact their manager. Wherever possible employees should disqualify themselves from situations of conflict of interest.  

Where an employee has an impartiality, financial or proximity interest in any matter regarding provisions outlined within this Code, or which might be perceived as being in conflict with the interest of another person who may be affected, then the employee must immediately disclose this to the Chief Executive Officer or at the meeting if prior disclosure is not possible.

Employees may report any observed any incidents involving conflict of interest to oeo@amagi.com (Office of Equal Opportunity)

 

Financial interests

Employees should avoid any financial involvement or undertaking that could directly or indirectly compromise or undermine the performance of their duties or Amagi’s objectives or activities.  Financial conflict of interest may arise where an employee, who has a financial interest in a company or other business, is able to influence contracts or transactions between Amagi and that business.  

This conflict may extend to any business undertaking in which employees and their immediate family, or the employees are acting in direct competition with Amagi’s interests for personal gain.

Employees may report any observed incidents involving financial conflict of interest to oeo@amagi.com (Office of Equal Opportunity)

 

Use of official information

While employees can contribute to the public (by definition – to the ‘public external to Amagi’) debate on social issues, there are some circumstances in which public comment is inappropriate.  Public comment by employees should not imply that the comment, although made in a private capacity, is in some way an official comment by Amagi. The employee may only disclose official information, with due regard to confidentiality, in order that it is in their official capacity and duties. 

An employee can disclose confidential or restricted information or documents acquired in the course of their employment only when required to do so by law, in the course of their duty, when called to give evidence in court, or when proper authority has been given. Approval to release confidential information on employees should be sought from the Chief Executive Officer and communicated to the Information Security Team. 

In circumstances where employees are requested to provide information, they should provide it in a timely and accurate manner which complies with the principles of Freedom of Information, confidentiality, and the rights of the individual. Employees acting in honorary capacities may be asked by third parties to make comments on Amagi policy or procedure and in such cases, employees should confine comments to information.  Where employees are privy to information of a restricted nature, which may compromise the position of Amagi or infringe on the privacy of members of Amagi, the information should not be divulged.

 

Employee/client boundaries

The term ‘employee/client boundaries’ identifies the importance of the trust inherent in the relationship between employees and their clients; however, breaching of employee/client boundaries is going outside the limits of the employee/client relationship.  

Employees are expected to maintain proper boundaries with clients.  Employees are expected to make themselves aware of any workplace and/or program-specific policies/guidelines in this area.

 

Relatives and close friends

A conflict of interest may arise when an employee makes or participates in decisions affecting another person with whom they have a personal relationship (such as a relative, spouse, close friend or personal associate).  

In cases where a conflict may arise, employees must take advice from their manager.  Wherever possible employees should disqualify themselves from dealing with those persons in such situations.

Employees may report any observed incidents involving conflict of interest to oeo@amagi.com (Office of Equal Opportunity).

 

Personal and professional behaviour

Employees should perform the duties associated with their position to the best of their ability, diligently, impartially and conscientiously. In the performance of their duties, employees should: 

• comply with legislative and industrial obligations and administrative policies
• fulfil their Equal Employment Opportunity and Occupational Safety & Health Obligations
• strive to keep up to date with advances and changes in the knowledge and the professional and ethical standards relevant to their areas and expertise
• maintain adequate documents to support decisions made
• treat all persons with courtesy and sensitivity to their rights and provide all necessary and appropriate assistance
• not take or seek to take improper advantage of any official information gained in the employment with Amagi
• not harass or discriminate against employees or in work practices on the grounds of sex, pregnancy, race (including colour, ethnic background or national identity), marital status, disability, sexual preference, political or religious belief, or age
• act responsibly when becoming aware of any unethical behaviour or wrongdoing by any employee. Such information should be forwarded to the CEO
• continuously improve work performance. All employees should actively pursue quality improvements
• not make disparaging remarks about other employees

 

Alcohol and substance abuse or misuse

Employees must ensure that the safety and health of other employees, volunteers and clients are not endangered by any misuse. Amagi expects employees to perform their jobs with skill, care and diligence.  Employees should not perform any act or omission that is likely to have a detrimental effect on their work performance and that of other employees and clients.  Accordingly, employees should not be under the influence of alcohol or other substances while they are at work or at work functions.

Possession use or trafficking in illegal drugs on the premises is not permitted. Amagi premises include but are not limited to all buildings, vehicles, car parks, meeting rooms, and open spaces.  Any such activity will be immediately referred to the police and Amagi may take disciplinary action, which may include termination of employment.

 

SMOKING

Smoking is not permitted in Amagi-owned or leased vehicles or buildings. 

Employees may only smoke on their own time during authorized breaks as set out in the agreement or employment contract and/or as authorized individually by their manager.

 

Discrimination and Equal Employment Opportunity (EEO)  

Anti-discrimination laws provide guidelines on respecting personal differences. Treating people differently based on personal characteristics is unlawful.  

The following are examples of attributes: age, industrial activity, parental status, political belief, personal association, race, ethnic background, career status, marital status, pregnancy/potential, lawful sexual activity, unrelated criminal record, impairment, religious belief/activity, physical features, gender identity, disability and sex. Discrimination is unacceptable within Amagi and all reported incidents will be investigated.   

Employees can report incidents of discrimination to oeo@amagi.com (Office of Equal Opportunity).

 

Harassment 

Harassment is any type of behaviour that:

• the other person does not want and does not return
• offends, embarrasses, or scares them, and may be either sexual or non-sexual in nature
• targets them because of their race, sex, pregnancy, or other protected attribute under the law
• constitutes a form of bullying
• harassment does not have to be a series of incidents or an ongoing pattern of behaviour.  Neither does harassment need to be intentional to attract disciplinary action.  Harassment can occur in any work-related context including:

• Working at office premises / working from home - on call / on chat apps like Hangouts, Skype, etc.
• Social functions
• Conferences
• Office social gatherings
• Business trips

Harassment and discrimination form part of a continuum of unacceptable behaviour that can include sexual assault, stalking and harassing phone calls, some of which are also against criminal law, which means the police may prosecute anyone who commits such acts. Fair discipline, performance counselling or workplace control practices based only on performance issues do not, in themselves, constitute harassment.

Employees may refer to the Prevention of Sexual Harassment Policy for further details on Sexual Harassment of women employees and can write to the email ID internal.committee@amagi.com to report any incidents constituting Sexual Harassment. This email ID is addressed to all Internal Complaints Committee (ICC) members who are responsible for addressing all issues regarding Sexual Harassment.

Employees may also report incidents of any kind of harassment to oeo@amagi.com (Office of Equal Opportunity)

 

Occupational safety and health 

Amagi is committed to providing a safe and healthy workplace for all employees and visitors - however, employees have a responsibility to make the workplace a safe and healthy place for all concerned, as far is reasonably practical. It is therefore important that employees are familiar with the standards or procedures in their area of work.  If employees have not been advised of these standards or procedures during the induction process, they must as a matter of urgency ask their immediate manager to obtain the necessary information.

 

All employees are responsible for:

• knowing and complying with the Occupational Safety & Health (OSH) rules and guidelines
• working so as not to endanger themselves or any other person by any act or omission
• use and follow OSH instructions, training or other information
• report all incidents, accidents, injuries and hazards to management for action

 

Ownership of products/patents and copyright

All products, literary, dramatic, musical, cinematographic and artistic works, computer programs, material in written or other format, discoveries, inventions and improvements in relation to such matters, together with all copyright and intellectual property created, authored, discovered, developed or produced by the employee for the purpose of, or in the course of, the employee’s employment will remain the property of Amagi and will not be used by the employee other than for the purpose of Amagi business.

Unless otherwise agreed, Amagi retains the copyright of work produced by you during your employment with Amagi

Upon termination of employment, the employee will return all correspondence, documents, data, information, equipment and things, including copies thereof, belonging to the employer that may be in the employee’s possession, custody or control.  

 

STANDARDS FOR SUPPLIERS AND BUSINESS PARTNERS

Amagi expects its suppliers to uphold high ethical standards, operate responsibly, and comply with all applicable laws. This Supplier Code of Conduct outlines the fundamental principles that suppliers must adhere to while conducting business with Amagi.

Legal and Ethical Compliances

• Suppliers must comply with all local, national, and international laws.
• Business dealings must be ethical, transparent, and free from corruption or bribery.
• Suppliers must avoid conflicts of interest and disclose any potential risks to Amagi.

Business Integrity and Ant-Corruption

• No supplier shall engage in bribery, money laundering, or unethical business practices.
• Transactions must be accurately recorded and comply with financial regulations.
• Suppliers may only use Amagi’s trademarks, brand names, and logos with explicit consent.
• Direct solicitation of Amagi employees, contractors, or consultants is prohibited.

Labour and Human Rights

• No forced or child labour shall be employed.
• A safe and healthy workplace must be provided, adhering to all occupational safety regulations.
• Employees must be fairly compensated as per applicable wage laws and industry standards.

Data Privacy and Information Security

• Suppliers must protect sensitive information, including personally identifiable information (PII).
• Strict data security measures must be in place, including access controls and incident response plans.
• Compliance with Amagi’s privacy and security policies, as well as global security standards (e.g., ISO 27001), is expected.

Confidentiality and Security

• All business-related information shared by Amagi must be treated as confidential.
• Access to Amagi’s data should be limited to authorized personnel only.
• Suppliers must maintain robust cybersecurity practices and conduct regular security audits.

By complying with this Supplier Code of Conduct, suppliers contribute to a responsible and sustainable business ecosystem. Amagi values ethical partnerships and expects its suppliers to align with these principles.

 

BREACHES OF THE CODE

Amagi is committed to the standards set out in the Employee Code of Conduct.  Where a breach of the Code has been identified, an employee can reach out to the Office of Equal Opportunity (OEO) at oeo@amagi.com. After reviewing the concern, the OEO may either try to resolve the matter by itself or forward the concern to one of the following:

• Whistle Blower Committee
• Internal Complaints Committee
• Grievance Redressal Committee

A response to the breach may result in:

• counselling
• disciplinary action
• termination of employment  
• suspension
• laying of criminal charges or civil action.

The Code of Conduct is implemented and reviewed by the Head of People Function. The company reserves the right to amend, abrogate, modify, rescind/reinstate the Code of Conduct or any part of it at any time.

 

RELATED POLICIES

• Prevention of Sexual Harassment Policy
• Whistle Blower Policy
• Amagi Information Security Policies
• Grievance Redressal Policy

 

POLICY CIRCULATION AND ACCESSIBILITY

Amagi is committed to ensuring that the Anti-Bribery, Anti-Corruption, and Anti-Fraud policies are readily available and accessible to all relevant stakeholders, both internal and external.

Internal Access:

These policies will be made available to all employees via the employee portal, ensuring that everyone is fully informed of the company’s standards and expectations regarding ethical business conduct.

Regular communications and training sessions will be conducted to reinforce awareness and compliance with these policies.

External Access:

The policies will also be published on the company’s website, ensuring transparency and accessibility for external stakeholders, including clients, vendors, suppliers, investors, and regulatory bodies.

External stakeholders will be notified of their obligation to comply with these policies when engaging in business dealings with Amagi.