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BUSINESS ETHICS POLICY Issue No./Dt. 01 / 01.01.2013

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1.0 PURPOSE:
To document the policy, procedure, standard or guidance in respect of SIS Group business ethics.

2.0 SCOPE:
This policy documents applicable to all Companies and Groups of SIS Group Enterprises.

3.0 RESPONSIBILITY:
™For Issue, review & amendment - Group CEO
™Approval – Group CMD
™All employees are required to ensure this ethics policy is cascaded throughout their business and
display personal commitment by regularly endorsing this policy & confirming compliance within
their own area of responsibility.

4.0 MESSAGE FROM GROUP CHAIRMAN & MANAGING DIRECTOR

Dear Colleagues,
Within the SIS Group, we share following long-term objectives:
) To become one of the global leaders in our chosen
markets - enhancing businesses.
) To be the preferred partner for our Customers for providing
“Business Support Solutions” through Service
specialization, Quality and Compliance assurance
) To deliver superior value over the long term for our
customers and shareholders.
) To create a performance-driven culture across all of our
divisions and most preferred place to work in the industry
through fair employment practices
We have well-defined strategies in order to achieve these goals and be successful. However,
success cannot be sustained unless we commit ourselves to the values, which we cherish.
First amongst these is Honesty in all aspects of our conduct. This includes acting with integrity
in how we run our businesses, both with respect to our external dealings with customers,
suppliers, representatives and competitors, and in our internal dealings with colleagues.
The Code of Business Ethics, as set out herein, is to assist all of us at SIS Group Enterprises
while conducting business. It starts by reinforcing the group’s values and seeks to clarify what
constitutes good ethical behaviour.
I ask you to participate wholeheartedly in this effort and extend your full support. Success only
comes when the words are translated into action.

R.K.Sinha
Group Chairman & Managing Director

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5.0 CODE OF SIS BUSINESS ETHICS

This Code of Business Ethics is rooted in the core SIS values. It takes our value of Honesty and Integrity and
seeks to expand into a fuller set of guiding principles grouped into four subject headings given below.
Prescriptive rules cannot be formulated for every business circumstance, but our values and the spirit of the
Code should guide you toward the appropriate and ethical course of action.

Working with Collaborating with Collaborating with Compliance

Business Partners Colleagues Shareholders Assurance

Preferred partners for

Preferred place to Superior Investment Benefits to everyone
Business support
work in the industry Opportunity involved
solutions

Honesty

Speed Empowerment

SIS
VALUES

Delivery Ownership

Definitions
“Honesty” - Scrupulous with regard to telling the truth and acting without fear, fraud or breach of laws.
“Integrity” - Steadfast principled adherence to the Code of Business Ethics.
“Empowerment”-Creating an environment of autonomy for employees to take initiative & succeed.
“Ownership” - Taking personal ownership of the responsibility of our roles.
“Delivery” - Performing to the highest standards against the commitments we make both internally as
well as externally to our customers.
“Speed” - Ensuring that our business decisions are made and actions executed with a sense of urgency.

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6.0 INTRODUCTION: DOING BUSINESS WITH HONESTY & INTEGRITY

Our values of honesty and integrity are the foundation of our reputation and of the way we do business. So,
in addition to the personal integrity that each of us brings to our work at the company, we need to
demonstrate organizational integrity – ensuring that all of our combined efforts align with our values and
commitments.

Our company values underlie the important commitments that we make to our customers, the marketplace,
our communities and other stakeholders. Our group philosophy of operating with autonomy and
accountability provides our companies with the most effective way to achieve our high standards. Our
values, and in particular the requirement for honesty and integrity, are the foundation of this operating model.

This Code of Business Ethics sets the standard for how we conduct business. It is designed to ensure that all
employees make decisions that are consistent with our values and that help us meet our many
commitments. It applies to members of the Board of Directors and all employees of all divisions within the
SIS group. Furthermore, the group should seek only to do business with partners whose business practices
are consistent with the spirit of this Code.

Any employee, who breaches the policies included in this Code of Business Ethics either in
letter or spirit, will be subject to disciplinary action, up to and including termination of
employment.

Alternate Reporting, or Whistle blowing

If an employee has a concern that he / she is not comfortable raising matter related to business ethics with a
senior, or if it has been raised but not been properly addressed, he/ she can report this concern using the
SIS toll free number 18001801303 or reporting directly to Group CEO. This resource is intended as an
alternative measure if other channels do not help to resolve the concern. Such concerns are treated in
absolute confidence. Such concerns can also be reported anonymously, but such reporting may limit the
company’s ability to investigate and resolve the matter.

Addressing concerns
The company is committed to responsively address all concerns made in good faith. It will investigate any
reported concern and, where a violation has occurred, take immediate corrective action to resolve the matter.
At times, employees may feel pressure to meet operational results, “make the numbers” or go along with
others’ decisions. While motivation to achieve high expectations is appropriate and necessary for a
successful business, no employee should ever feel that he or she must resort to conduct that is unethical or
illegal. The company stands behind its commitment to operate with honesty and integrity – this means for all
operations and activities at all times.

If you feel that you are being asked to do something that is wrong, you always have someone to talk to –
your senior, a senior executive, or the SIS Toll free number. It is the company’s responsibility to provide you
with helpful resources that can assist you; it is your responsibility to use them.

Non-retaliation
The company will not tolerate retaliation against any individual who makes a report of suspected misconduct
in good faith or provides assistance to an investigation. It will take corrective action against any employee
found to have retaliated against someone for these actions, regardless of his / her position.

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Using the Code

This Code of Business Ethics is not intended to address each and every situation that you may encounter.
What it does is to provide overall standards and framework for many common issues for you to resolve other
ethics and compliance issues. If in doubt about what is the proper action, ask yourself the following questions
about the issue:
• To which stakeholders does the company have responsibilities or commitments?
• What are my specific responsibilities in my job?
• What laws, regulations, industry standards or company policies address the issue?
• What person can help me to effectively resolve the issue?
• What options should I consider to determine the best response?

Do not ever hesitate to seek additional guidance from your controlling office, a senior or Head of HRD.

Political Contribution
SIS does not make contributions to political parties, political candidates or organizations,
which are politically active, without accounting for it in its book of accounts.

No direct or indirect pressure in any form is ever to be directed toward employees to make any political
contribution or participate in the support of a political party or the political candidacy of any individual.

This policy shall not affect the right of directors, officers, employees, and agents of the Company to make
personal political contributions to the party, committee, or candidate of their choice as long as the donation is
derived exclusively from that individual's personal funds or time and in no way was compensated directly or
indirectly by the Company.

7.0 WORKING WITH BUSINESS PARTNERS

Our company’s reputation, in ultimate analysis, boils down to how we work with others – the trust we develop
with them and the commitments that we keep to them. Each employee’s daily interactions and discussions
with our customers, suppliers and other business partners make the difference in our success. Conduct
these interactions with the utmost honesty and integrity. Avoid dealings with partners whose business
practices do not conform to the spirit of this Code.

7.1 Fair Dealing

Always deal fairly with company business partners, including current and prospective
customers, suppliers, and other representatives. Never manipulate, conceal or abuse
privileged information, misrepresent material facts or engage in any other unfair-dealing
practice.

Answer all customer and supplier questions truthfully. Never mislead customers about any of our services.
Our customers and business partners count on us to act with honesty and integrity and to demonstrate
commitment to our values in all of our actions. Actions that put our commitment to fair dealing into question
are never appropriate.

7.2 Gifts and Hospitalities

Only such gifts, entertainment and other hospitalities are permitted to be extended to customers and
associates, which are appropriate to business relationship but do not strictly constitute as an incentive for
business interests or improper conduct or lack of compliance.
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On appropriate occasions, exchanging modest gifts, entertainment or extending hospitalities can help us to
form or strengthen relationships with our business partners. While a small gift can be a gesture of goodwill &
a business dinner may provide an opportunity to know a customer better; Inappropriate gifts or other
hospitalities suggest improper influence in business transactions and indicate attempts to conduct business
using illegitimate tactics.
On all occasions such as major festivals, new year’s day etc., appropriate gifts are decided by Corporate PR
and distributed to employees for extending the same to customers/ business associates.
7.3 Bribery and Corruption
SIS is resolutely opposed to bribery and corruption in whatever forms it may take.

Demonstrate integrity in your actions and never exchange anything of value that could be
considered as an improper incentive for a business action. Before taking an action that may be
questionable, ask yourself whether the appearance of it may compromise the company’s or your
personal integrity or reputation.

We do business on the basis of our service excellence, never because of exchanges of improper
payments or other things of value. We remain mindful that sometimes the appearance of what we
exchange also can be wrong for the company. Improper payments are always wrong; the company
would rather lose business if the only other option is to make an improper payment.

Do not:
• Offer, provide or accept anything of value that is intended – or may be perceived as an
effort – to influence a business decision. These may not always be a payment or gift but
may be in form of entertainment, other hospitality, a favor, a job offer or other benefit.
• Following a business transaction, offer, give or accept any form of a “kickback” tied to
helping to facilitate the business transaction. A kickback can be a bonus, incentive or
anything of value, potentially from a customer or other party. It also can come disguised as
a gift or form of entertainment.
• Use an agent, contractor or other company representative to make any payment or provide
anything else of value that you are not permitted to provide.
• Do business with partners who are known to have been involved in bribery or other corrupt
practices.

Consider the following questions to avoid corruptive practices:

) Do I feel a need to provide something of value to secure a business contract?
) Is the gift/ hospitality, which I offer is usual in the local culture or business context?
) Would I find it embarrassing if I disclosed the acceptance of something from a business
partner to a colleague, my senior or a family member?
) Do I know what is legal and illegal to offer, provide or accept in the location where I am
doing business?
) Do I know what my business partners are able to accept from me?

If you or are in doubt, talk it out!

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7.4 Fair Competition

Help ensure that the company competes fairly in all of its markets while competing vigorously to
serve our customers. Follow all competition laws and know and adhere to company standards
regarding fair competition.

The company is committed to vigorous and fair competition, and we believe we can accomplish
both of these objectives at the same time. If your work involves marketing, sales, or contracts, you
especially must understand the competition rules related to your work. Laws

The specific facts of each competition situation are very pertinent to determining whether it is
appropriate. Discuss these facts with your controlling officer, a senior executive or Head-HRD to
identify the correct resolution.

Dealing with Competitors

• Do not enter the company into any agreement or understanding with a prospective or current
competitor that is intended or likely to suggest unfair competition. Do not even discuss these
agreements or understandings or exchange related information with a competitor. If any of the
improper topics listed below arise in a meeting involving competitor, state that you believe the
discussion is improper, immediately excuse yourself and report the matter to Group CEO/COO.
Such situations can risk the company’s reputation and continuing ability to market its products
and services.
Improper topics include:
– “Price fixing,” or setting prices with competitors, or even exchanging pricing information
with competitors.
– Allocation of markets, customers or territories among competitors.
– “Bid rigging”, or arranging bids with competitors (for example, an arrangement to ensure that
a competitor wins one bid while another will win another bid).
– Boycotts with competitors of an individual or group of customers or suppliers or refusals
with competitors to deal with a certain customer or supplier.
– Restrictions with competitors on production levels or distribution channels.

• Before beginning any discussions or other communications with a competitor about a partnering
arrangement, such as a joint venture or teaming, first seek advice from the Group CEO/COO or
Head HRD.

Dealing with Customers and Suppliers

Do not enter the company into any understanding or agreement with a current customer, supplier
that is intended or is likely to suggest unfair competition.

Independent Actions
• Do not allow or help the company to engage in any action with the specific intent to drive out
competitors or otherwise unfairly compete. Improper topics include:
– Predatory pricing, such as setting prices below cost to drive out a competitor from the market.
– Price discrimination, for example, unfairly setting prices for certain customers based on
characteristics that are improper to consider, such as the management’s race or gender.
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Gathering Competitive Information

• Only gather information on the competitive market place from proper sources, such as
newspapers, a competitor’s publicly available marketing material, discussions with customers,
and observations of competitors’ services available to the market.
• Never accept confidential information directly from a competitor.
• Check with legal counsel before using any competitor information that is marked as confidential,
such as “Internal Use Only” or “Company Confidential.”
Competitor Representations
• Help the company to compete principally based on the strength of its services, not on the
weaknesses of competitors’ services. Do not disparage competitors or their services, particularly
with comments that cannot be substantiated. Ensure that any service comparisons are based on
factual data or competitors’ marketing or communications.
7.5 Trade Control
Support the company’s responsibilities for cross-border trade and follow the embargo requirements
set by the countries in which we do business.
7.6 Contacts with Outside Parties
Show care for the company’s assets and reputation. Only speak with or provide information about
company operations to outside parties if you are authorized to do so.
Many parties have an interest in the company’s activities: investors, regulators, local communities,
the press, potential suppliers, and others. We need to communicate in a clear, unified and accurate
voice to outside parties. Our commitment to honesty and integrity demands it.
Communicate with these parties when you are authorized. Forward any requests for information
you are not, to your controlling officer or Group CEO/COO for their action.

7.7 Working with Third Parties

Protect the company’s reputation: ensure that third parties’ work for the company holds to our
values and standards. It is imperative that they understand our approach for conducting business
and our standards of conduct.
Specifically:
• Properly review potential third parties before engaging them to ensure that they have a record of
responsible business practices and that their business approach is aligned with that of the
company.
• Clarify for third parties the company’s expectations regarding how they conduct business for the
company, as identified in any agreement or contract; provide them with the company’s Code of
Business Ethics with the expectation that they follow all applicable topics (certain conflicts of
interest will not apply to third parties, though we expect them to inform the company of any
potential situations that could conflict with their identified duty to the company).
• Do not use third parties to conduct improper business activities.

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8.0 COLLABORATING WITH COLLEAGUES

Our people are our greatest asset. They provide the innovations, drive and spirit that turn good
ideas and intentions into practical success. So, it is vital that we create a working environment in
which team spirit and commitment to the goals and values of SIS are maintained. The Company
will ensure that each employee is treated fairly and with dignity & respect, providing equal
opportunity to each one without bias of cast, creed or gender.

8.1 Fair Employment

SIS is committed to provide fairness in employment opportunities and has zero tolerance towards
discrimination of any kind. We make employment decisions on the basis of an individual’s merits
and company needs. No decisions shall ever be made based on gender, race, ethnicity, religion,
age or other improper characteristics. Equal opportunity shall be provided for career advancement
and no decisions will be ever influenced by considerations other than employee’s performance,
ability and aptitude. Employees will also be provided with the opportunity to develop their potential
and to develop their careers further with the company through a transparent & scientific
Performance Management process.

8.2 Respectful Treatment

Show respect for your colleagues and business partners; never act improperly toward them. Do not
engage in any conduct that could be considered as disrespectful, intimidating, aggressive, violent
or harassing, including any form of sexual harassment.

8.3 Human Rights

SIS supports the human rights standards (ILO Declaration) and ensures that company operations
adhere to these important standards. Thus, in accordance with local legislation and practice we will
respect freedom of expression. SIS adheres to employment as Employee’s free choice with no use
of forced or child labour and we will not discriminate on the basis of gender, colour, ethnicity,
culture, religion, sexual orientation or disability.

8.4 Health and Safety

SIS places the highest priority on promoting the health and safety of employees whilst at work. We
promote a positive workplace where all employees feel safe and protected from harm. We
sincerely believe that only then can employees be at their best and effectively contribute to the
company’s success. To help the company meet this objective, all employee are expected to:

• Follow all laws, regulations and company policies regarding workplace health and safety.
• Attend any training sessions before using equipment that requires training.
• Use protective equipment, clothing and other safety devices for work as required.
• Report to Client representative or controlling authority any unhealthy or unsafe situations that you
encounter.
• Never use or remain under the influence of illegal drugs when on duty. Ensure any use of alcohol
is restrained and limited to company social functions, and approved by company management.
• Ensure that any medications you use will not interfere with your job duties and especially with
operating equipment or vehicles.

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8.5 Terms of employment

We at SIS will work towards creating permanent long-term relationships. Employees will be paid for
and work hours at least as favourable as the terms established by national legislation or as per
agreements with our customers who are the principal employer and on whose behalf we work as
security agency.
8.6 Harassment
Harassment can be defined as unwanted behaviour, which a person finds intimidating, upsetting,
embarrassing, humiliating or offensive. Conduct involving the harassment (racial, sexual or of any
other kind) of any employee is unacceptable. Should an employee believe that he or she has been
harassed the matter should be raised with the relevant Human Resources Manager who will
arrange for it to be investigated without delay, impartially and confidentially.

8.7 Conflicts of Interest

All SIS colleagues must avoid business, financial or other direct or indirect interests or relationships
which conflict with the interests of the Company, or which divides his or her loyalty to the
Company. Any activity which even appears to present such a conflict must be avoided or
terminated unless, after disclosure to the appropriate level of management, it is determined that
the activity is not unethical or improper, does not compromise integrity and is not detrimental to the
reputation and standing of the company.

All employees have a duty to review any potential conflicts of interest with their controlling authority
to ensure that any actual conflicts are addressed. Together, you will determine whether to consult
with other management or legal counsel.

8.8 Confidential information

Employees must not make use of confidential information obtained through their employment for
personal gain. The disclosure of confidential information to any third party during or after
employment is not permitted unless the disclosure has been appropriately authorised, is for a
legitimate business reason and the information is being securely communicated. ‘Confidential
information’ is either information that has been specifically described as being confidential or is
otherwise obviously confidential from the surrounding circumstances.

The term ‘confidential information’ does not include information in the public domain or information
which the individual concerned is required by law to disclose.

9.0 COLLABORATING WITH SHAREHOLDERS

We commit to creating sustainable, long term value for our shareholders. All shareholders are
communicated to openly and transparently within the bounds of commercial confidentiality and
regulatory limits.

9.1 Business Conduct

We recognise the growing interest in the way we conduct our business. Our shareholders and
other stakeholders are entitled to know our values and standards and can expect us to live up to
them.
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9.2 Engagement
We have an effective and transparent engagement approach with our shareholders, including
independently verified reporting arrangements.

9.3 Compliance
We comply with the laws and regulations of India, including the listing obligations and governance
codes of the Stock Exchange and are therefore required to comply with the rules and regulations of
India.

9.4 Communications
We ensure that all public announcements are accurate, complete, fair, timely, and understandable
and comply with all applicable laws and regulations.

9.5 Inside Information

Buying or selling shares (or encouraging others to do so) on the basis of information not publicly
disclosed is unethical and prohibited and may amount to the criminal offence of insider dealing.

9.6 Share Dealing

We maintain our Share Dealing Code and ensure that all relevant colleagues are made aware of
their obligations to uphold it. The code provides a mechanism which will help to prevent dealing in
listed securities by an individual which is prompted by knowledge of the affairs of a company which
is not public.

10.0 COMPLIANCE ASSURANCE

It is extremely important for us to maintain honest, transparent and ethical relationships with
governments, statutory & regulatory bodies and officials.
10.1 Accounting Control
Always comply with the company accounting procedure and controls, and all applicable laws.
Properly record all financial data and transactions. SIS does not permit the use of “slush funds” or
other unrecorded funds or assets. All disclosure contained in reports and documents filed with
securities regulators and other governmental authorities by or on behalf of SIS shall be full, fair,
accurate, timely and understandable.

10.2 Protection of our Interests

We promote and defend our business interests through co-operation with governments and other
organizations, both directly and through bodies such as trade associations, in the development of
proposed legislation and regulations that may affect our interests.

10.3 Competition
We are committed to competing strongly yet fairly and complying with appropriate competition
laws. We do not collude with our competitors to fix prices, rig bids or do other things which fall foul
of competition laws.

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10.4 Engagement with the Community

We work in partnership with several local, national and international charities to help address the
social and environmental needs of the communities in which we operate.

10.5 The Environment

As part of our goal to develop a sustainable business, we aspire to make continuous
improvements in the management of our environmental impact with emphasis on the need
to reduce energy consumption, and waste production.

10.6 Bribes and Facilitation payments

We will not give or receive, directly or indirectly for business or financial gain, any financial
inducement or improper advantage, or engage in any form of corruption. SIS does not enter into
facilitation payments – it is a bribe by any other name.

10.7 Compliance with the law

SIS will comply fully with all relevant national and international laws and will act in accordance with
local guidelines and regulations, including those which are industry specific, governing our
operations.

10.8 External reporting

SIS businesses may be required to make statements or provide reports to regulatory bodies,
government agencies or other government departments. Care should be taken to ensure that such
statements or reports are correct, timely and not misleading. Senior management must be made
aware of any sensitive disclosure before it is made.

Care must also be taken when making statements to the media that information given is correct
and not misleading.

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Code of Business Ethics Acknowledgment

I acknowledge that I have received the Code of Business Ethics (the “Code”) and
am responsible for familiarizing myself with the standards it establishes. I am aware
of my duty to seek guidance when unsure of the proper course of action.

I understand the company’s expectations that I

• act with honesty and integrity when conducting company business and
• follow fully and abide by the standards set out in the Code.

I understand that if I breach the standards in the Code, I can be subject to

disciplinary action, up to and including termination of employment. In addition, I
understand that certain breaches could result in civil or criminal prosecution.

I understand that I have an on-going obligation to notify the company if I become

aware of any breaches of this Code or personal conflicts of interest at any time in
the future.

Name of the Employee :- ( Signature )

Date :-

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