“Supplier” in this Code of Conduct means any business, company, corporation, person or other entity that provides, sells, or seeks to sell, any kind of goods or services to ATG Business Accelerators Private Limited and its subsidiaries (the Aeries Group/Aeries), including the Supplier’s employees, agents and other representatives.

Products and Services

The Supplier shall be committed to supplying products and services of high quality that meet all applicable standards. The products and services offered shall comply with applicable laws, including product packaging, labelling and after-sales service obligations. The Supplier shall market its products and services on their own merits and not make unfair or misleading statements about the products and services of competitors.

Regulatory Compliance

The Supplier shall comply with all applicable laws and regulations, both in letter and in spirit, in all the territories in which it operates.

Bribery and Corruption

The Supplier shall not engage in any form of bribery or corruption.

Child Labour

The Supplier shall not employ children.

Forced Labour

The Supplier shall not use forced or slave labour of any type (e.g. bonded, indentured, prison, or involuntary labour).

Health and Safety

The Supplier shall strive to provide a safe, healthy, and clean working environment for its employees.

Environment

The Supplier shall strive for environmental sustainability, particularly regarding the emission of greenhouse gases, consumption of water and energy, and the management of waste and hazardous materials. The Supplier shall endeavor to offset the effect of climate change in its activities.

Gifts and Hospitality

Business gifts and hospitality are sometimes used in the normal course of business activity. However, if offers of gifts or hospitality (including entertainment or travel) are frequent or of substantial value, they may create the perception of, or an actual conflict of interest or an ‘illicit payment’. Therefore, gifts and hospitality given or received should be modest in value, appropriate, and compliant with the law and company policies. Aeries employees will decline any offer of gift or hospitality that does not comply with the Aeries gifts and hospitality policy.

Third Party Representation

The Supplier shall not be authorized to represent Aeries to use the Aeries brand without the written permission of Aeries. Authorized representatives of Aeries are expected to abide by the Company Code of Conduct in their interaction with, and on behalf of Aeries, including the confidentiality of information shared with them.

Conflict of Interest

The Supplier shall not enter into a financial or any other relationship with a Aeries employee that creates any actual or potential conflict of interest for Aeries. The Supplier understands that a conflict of interest arises when the material personal interests of the Aeries employee are inconsistent with the responsibilities of his/her position with the company. All such conflicts must be disclosed and corrected. Even the appearance of a conflict of interest can be damaging to Aeries and to the Supplier and are to be disclosed and approved in advance by Aeries management.

Protecting Company Assets

The assets of Aeries shall not be misused; they shall be employed primarily and judiciously for the purpose of conducting the business for which they are duly authorised. These include tangible assets such as equipment and machinery, systems, facilities, materials and resources, as well as intangible assets such as proprietary information, intellectual property, and relationships with value-chain partners of Aeries.

Securities Transaction and Confidential Information

If the Supplier becomes aware of material, non-public information relating to Aeries or its business, it may not buy or sell Aeries securities or engage in any other action to take advantage of that information, including passing that information on to others. In addition, if the Supplier becomes aware of material, non-public information about any other company, including Aeries customers, suppliers, vendors or other business partners, that is obtained by virtue of the Supplier’s interaction with Aeries, then the Supplier may not buy or sell that company’s securities or engage in any other action to take advantage of that information, including passing that information on to others.

Supply Chain

The Supplier is expected to implement its own binding code of conduct and is expected to make reasonable efforts to promote the principles of this code in its own supply chain.

Monitoring

The Supplier shall maintain adequate documentation to demonstrate compliance with the principles of this code and allow access to Aeries to check compliance upon request with reasonable notice.

Reporting Violations

The Supplier shall notify Aeries regarding any known or suspected improper behavior by the Supplier relating to its dealings with Aeries, or any known or suspected improper behavior by Aeries employees by email to: compliance@aeriestechnology.com

Reported violations will be treated confidentially without retaliation.