The document outlines the code of business conduct and ethics for Smartlet, a digital wallet service company. It begins with an overview of compliance with laws and defines key terms. It then states Smartlet's vision of making cashless transactions easy, safe and secure while protecting customer data. The code establishes standards for avoiding conflicts of interest, misusing information/equipment, accepting gifts, and accurately reporting finances. It prohibits harassment, discrimination, and retaliation while encouraging public discourse through approved channels. Violations will face disciplinary action according to company by-laws. The code provides mechanisms to report issues anonymously and protects whistleblowers.

1. Code of Business Conduct and Ethics 1
Code of Business Conduct and Ethics

2. Code of Business Conduct and Ethics 2
Table of Contents
1. Statement of compliance with the law 3
2. Definition of terms. 3
3. Vision statement. 3
4. Standards and compliance expectations for handling: 4
a. Professional conflicts of interest 4
b. Misuse of information 4
c. Misuse of equipment and supplies 4
d. Acceptance of gifts and entertainment 5
e. Internal and external factors attempting to influence business activities 5
f. Ownership of information or project development 6
g. Accurate accounting – financial transactions, attendance/time reports in company
books and records 6
h. Workplace Harassment, Discrimination or Retaliation 6
i. Public Discourse 7
j. Political Involvement and Lobbying 7
5. Consequences for a violation of the Code of Ethics 7
6. Reporting mechanisms 8

3. Code of Business Conduct and Ethics 3
1. Statement of compliance with the law
All Smartlet employees, executives and directors are obligated to comply with the
code of business conduct and ethics and the laws of the State. It is the responsibility
of all associated with Smartlet to learn and understand the laws and ethics code to be
able to act responsibly and uphold the values of the company. Any violation or
aberration should be promptly reported and acted upon by the designated authority.
2. Definition of terms.
Code of Business Conduct and Ethics applies to individuals who serve Smartlet as
full-time employees, employees or consultants on contract, suppliers, service
providers, agents and channel partners.
In the due course of this code of conduct, few familiar terms will be used.
 Company refers to our organization ‘Smartlet’.
 Board of Directors are the selected representatives of the shareholders of the
company
 Manager may refer to supervisor, lead or project head
 Employee refers to individuals who work full time, part-time, as freelancer or
as volunteers
 Shareholders refers to investors who have ownership interest in Smartlet
 External Stakeholders like suppliers, service providers, agents and channel
partners are the businesses that help Smartlet run its business from outside.
They are not employed by Smartlet.
3. Vision statement.
As a digital wallet service, Smartlet aims to make cashless transactions easy, safe and
secure. It certainly aims to be the best in the business and provide the best-in-class
service to its customers. Our datacenters house huge amounts of highly confidential
customer information whose safety and security are our primary concern. Any
proliferation or data misuse will be strongly acted against. Also, Smartlet, being a
strong advocate of green technology, endeavors to leverage sustainable energy
resources to run its datacenters and service bases around the globe.

4. Code of Business Conduct and Ethics 4
4. Standards and compliance expectations for handling:
a. Professional conflicts of interest
Smartlet employees at all levels are expected not to involve in or work with its
competitors at any business level during their tenure in Smartlet. They are
expected to return every Smartlet document or data in their possession if they
happen to leave the company. Also, employees should not be doing any
profitable business activity that is in conflict of interest with Smartlet.
To site an example, Smartlet employee should not do any business or open any
profitable venture in the fields of digital wallet, ecommerce, business analytics
and likes. Employees are advised to contact the Human Resource department
if they happen to start their own side venture or any profitable enterprise.
b. Misuse of information
Smartlet has a very strict intolerance towards misuse of data or information by
its associates inside and outside the company. As a holder of huge amount of
customer data, it is our responsibility to keep the privacy of the data intact and
secure. No customer data or information should be used for personal interests
or for nefarious purposes. Every piece of data and information related to
Smartlet’s business is strictly to be used for Smartlet’s business interests and
not to be mishandled by anybody in the hierarchy. Employees should also
strictly refrain themselves from sharing any insider information to anybody
outside the company. Anybody found guilty of insider trading will be show
caused and handed over to the law enforcement.
c. Misuse of equipment and supplies
No Smartlet equipment or supplies should be used for personal purposes.
Employees are expected to utilize the supplies in their day to day business
activities pertinent to Smartlet. Digital devices loaned out-of-office to the
employees should only be used for the specific purposes they have been issued
for. No equipment is to be used cause harm to anybody or engage in any
unlawful activities. Strong disciplinary action will be taken against those
found guilty. The guilty may also be handed over to the law enforcement.

5. Code of Business Conduct and Ethics 5
d. Acceptance of gifts and entertainment
Gifts have increasingly become ways to embolden business relationships.
Smartlet employees can go on accepting gifts if the following conditions are
met:
 It should not influence the business decisions
 It is within the acceptable limits of $100 or equivalent amount
in other currencies
 It is thoroughly justifiable
 It’s disclosure will in no way embarrass Smartlet in the public
However, Smartlet employees or agents acting on Smartlet’s behalf should not
give gifts to influence any decision making of their business counterpart.
e. Internal and external factors attempting to influence business
activities
Smartlet believes in fair trade and business with right morals. Being a flag
bearer of equal opportunity player, Smartlet strives to do good business with
its business partners and external stakeholders. The external stakeholders like
vendor, suppliers, marketers and likes are expected to participate in fair
bidding process facilitated by Smartlet as and when an opportunity of doing
business with Smartlet comes along. No employee or executives of Smartlet
should involve in any kind of horse trading that might influence the bidding
process. Any case of such infraction should be reported without undue haste to
the ethics office of HR department.
Smartlet is highly competitive and strives to be ahead of the curve through
customer centric innovation, hard work and best-in-class customer service.
But the company has a zero tolerance towards engaging in unscrupulous
means to remain competitive. Under no circumstances, acts of espionage or
sponsoring of insider trade in competitor businesses will be tolerated within
the organization of Smartlet. Anybody guilt of the same will be immediately
terminated.

6. Code of Business Conduct and Ethics 6
f. Ownership of information or project development
Any data or information pertinent to Smartlet is considered as the assets of
Smartlet with sole and unquestionable ownership. Any employee working or
handling the data and the information should understand that sharing of
Smartlet’s information outside the company is strictly illegal and a potential
felony.
Also, employees, having a past association with other businesses, are strongly
discouraged to not share any inside information from his/her past employment
with anybody in Smartlet. Any such activity will be considered a serious
misdemeanor.
g. Accurate accounting – financial transactions, attendance/time reports
in company books and records
Smartlet employees are expected to spend money efficiently and report the
same accurately in compliance with the company’s policies on spending. They
should never interfere or influence in the auditing of financial records.
Smartlet believes and implements in flexible working hours based on the
needs of the project. However, the employees should always record correct
working hours to enable better HR policy making.
Any event of an attempt to falsify financial or timesheet records will be sternly
dealt with, even leading to termination. The onus is on all to report any
discrepancy in financial records without any delay.
h. Workplace Harassment, Discrimination or Retaliation
Smartlet is an equal opportunity employer and is strictly intolerant towards
any sort of bias based gender, race, sex, color, nationality, ethnicity, religion,
age, physical or mental disability, sexual orientation, marital status or genetics
or any other category protected under the law of the land. Any suspicion of
harassment, discrimination or retaliation should be promptly reported to the
ethics office of the Human Resource department.

7. Code of Business Conduct and Ethics 7
i. Public Discourse
In today’s day and age, public communication in social media is an intrinsic
part of doing business. Smartlet employees should be very careful of the
image of the company before resorting to make any social media post. They
should not many public statement that might embarrass or mar the image of
Smartlet. Employees are requested to seek help of or discuss with the PR
department of the company before issuing any public statement.
j. Political Involvement and Lobbying
Smartlet encourages its employees to participate in political process but it
should not become an impediment to the company’s business process as a
result. Smartlet will not bear any cost for political campaigning and its name
should not be used in any way to influence outcome. Anybody inside the
company should inform the HR department well before contesting for a public
office. Political contributions, if made, should be deemed strictly personal and
will not be reimbursed by Smartlet.
Employees, contractors or agents who are required to participate in lobbying
communications with members of the legislative body should obtain written
permissions from the office of CEO or CFO.
5. Consequences for a violation of the Code of Ethics
Smartlet follows a zero tolerance towards disobedience of its business code of
conduct and professional ethics. Anybody found guilty of the mischief will face
disciplinary action deemed appropriate by the ethics officer of the Human Resource
department as per the by-laws of the company or handed over to the Law
Enforcement. No person associated with Smartlet is above the code of ethics. Any
mercy plea will be considered and adjudged by the board of directors and the same
will be shared with the investors and shareholders.

8. Code of Business Conduct and Ethics 8
6. Reporting mechanisms
If anybody in Smartlet gets to learn about or faces a violation in code of ethics should
report the same to the managers, supervisors, HR department or the executive body
via email, phone call, in person or any way feasible. Smartlet strongly values the
protection of the whistleblowers and under no circumstances the identity of the
reporter will be revealed or compromised. Anybody caught in the due course of
investigation, keeping mum even after having the full knowledge of the violations
will be taken to task. Smartlet also strongly discourages false reporting against
anybody out of grudge, retaliation or personal animus. Strong disciplinary action will
be taken against those indulging in such acts of cowardice.

9. Code of Business Conduct and Ethics 9