New Concept Information Systems (P) Ltd.

ETHICS OR CODE OF CONDUCT POLICY

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1 - Scope

This policy – called the Ethics or Code of Conduct Policy is a broad definition of what types of behaviour and decorum are acceptable and encouraged in our Company. This is included in the HR induction protocol and specifically communicated to every inductee to our organisation.

2 - Features

2.1 Inclusiveness

We welcome and support people of all backgrounds and identities. This includes, but is not limited to, members of any social and economic class, educational level, gender identity, sexual orientation, race, culture, national origin, colour, immigration status, sex, age, size, family status, political belief, religion, and mental and physical ability.

2.2 Consideration

We all depend on each other to produce the best work we can as a company. Our behaviour will affect clients and colleagues, and we should take those considerations into account when making decisions.

2.3 Respect for colleagues/co-workers, clients, service providers

We respect all our colleagues, including those who work in non-professional capacities such as those who carry out the cleaning of the building, those who serve us refreshments, messengers and drivers. We do not differentiate in our behaviour on the basis of the kind of work a resource is mandated to do. We must show the greatest respect for colleagues, clients and all service providers.

We may have disagreements in the course of work, but disagreement is no excuse for disrespectful behaviour. We will all experience frustration from time to time, but we cannot allow that frustration become personal attacks. An environment where people feel uncomfortable or threatened is not a productive or creative one.

Issued and Approved by the Board

1^st December 2012

Adoption of the Policy on Prevention of Sexual Harassment at the Workplace 3rd March 2015

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New Concept has constituted a Complaints' Committee* with the following members: Uma Seth – Director HR & Admin, Surkhraj Vimal Kaur – Director NCCDC, Ramesh Dogra – Manager CDP, Lalit Thakur – Video Editor, and Bobby Nayak – Programme Manager, JMC (a not-for-profit). This Committee will examineand recommend action to Management on all cases of sexual harassment brought before it, till further notice of anychanges in the constitution of the Committee.

The New Concept Management acknowledges its responsibility to prevent or deter the commission of acts of sexual harassment on its office premises and elsewhere in the context of performance of office work.

Sexual harassment means any one or more of the following:

1. 1.Unwelcome physical contact and advances
2. 2.A demand or request for sexual favours
3. 2.Sexually coloured remarks
4. 4.Showing pornography
5. 5.Any other unwelcome physical or verbal or non-verbal conduct

Any employee who has been subject to any of the above listed acts, is encouraged and requested to come forward with a complaint to any member of the said Sexual Harassment Committee (SHC) set up for the purpose.The complaint may, at first be made verbally, and subsequently in writing. The Management is obliged to render any assistance sought by the complainant in this matter.

The following actions shall be taken in case of any complaint registered with the Committee set up for the purpose:

1. 1.Investigation based on the complaint will be initiated within eight working days of receipt of complaint, and a report based on the same will be tabled with the Management within t working days of completion of the investigation.
2. 2.If the report concurs with the complainant's report of events, then a charge of sexual harassment will be registered against the person(s) named, and a strict warning in writing will be issued to the same.
3. 3.The Management will ensure that there is no scope for such an event to occur again, taking careto eliminate similar circumstances or situation.

^*This Policy was adopted in 2015, but some members of the Committee constituted at that time are not with the company. The Committee is reconstituted on separation of any member. The present Committee was constituted by the company on 1st August 2021.

Issued and Approved by the Board

Safeguarding policy

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New Concept was founded in 1988 by a group of socially concerned professionals belonging to diverse disciplines. A good proportion of its efforts and revenues are directed towards social development initiatives led by its employees.

The directors and personnel across New Concept have for many years been committed to a wide range of concerns and incidents – including bullying and physical violence – that may cause emotional, physical, or sexual harm and taking all reasonable steps to prevent them and respond appropriately when these occur.

We believe that everyone we come into contact with, notwithstanding age, gender, ability or ethnic origin, has the right to be protected from all forms of harm, abuse, neglect and exploitation.

We are committed to address safeguarding through prevention, reporting and response.

Prevention

We are committed to ensure that

• all staff are familiar with, have access to, and know their responsibilities about this policy andunderstand it
• all staff receive training on safeguarding at a level commensurate with their role in the organisation
• all reports of safeguarding concerns are addressed promptly and according to due process
• all our programmes and activities protect people from any risk of harm that may arise from their coming into contact with New Concept.

Reporting

We are committed to

• making available safe, appropriate, accessible means of reporting safeguarding concerns to all staff
• accepting complaints from external sources such as our clients, digital users, partners and official bodies.

Staff members who have a safeguarding complaint or concern should report the same within the stipulated time frame to their line manager. If the staff member does not feel comfortable reporting to their line manager and they feel that the report will not be taken seriously, or if that person is implicated in the complaint/concern they may report to any other appropriate staff member.

Response

We are committed to follow up safeguarding reports and concerns according to policy and procedure and apply appropriate disciplinary measures to staff found in breach of policy.

We are committed to offer support to survivors of harm caused by staff regardless of whether a formal internal investigation is carried out.

We are committed to maintaining confidentiality at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management will be kept classified at all times.

Timeframes for action

• Receipt of report – within a fortnight of the incident
• Documentation and plan of action - within a fortnight of the receipt of report
• Enquiry, hearing, and disciplinary action (if required) - within one month of the receiptof report
• Feedback to the complainant and the wrongdoer within one week of the enquiry.

Issued and Approved by the Board

3^rd March 2015

On behalf of the Board of Directors – New Concept

Whistle-blower policy

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New Concept was founded in 1988 by a group of socially concerned professionals belonging to diverse disciplines. A good proportion of its efforts and revenues are directed towards social development. The purpose of the Whistle-blower Policy is to articulate the Company’s point of view on whistle-blowing, the process, and the procedure to strengthen whistle-blowing mechanism atthe Company.

This policy provides a system and forum for all employees to voice genuine concerns or grievances about unprofessional conduct without fear of reprisal.

• It provides an environment that promotes responsible and protected whistle-blowing
• It enables employees and directors to report any suspected violation of any law that applies to the Company and any suspected violation of the Company’s Code of Conduct
• It is a dynamic source of information about what may be going wrong at various levels within the Company
• It helps the Company in realigning the processes and take corrective actions as part of good governance practice.

Who is a whistle-blower?

A whistle-blower is any employee or director who discloses or demonstrates evidence of an unethical activity or any conduct that may constitute breach of the Company’s Code of Conduct. He/she reports an activity that he/she considers a concern of illegal or dishonest fraudulent activity.

The whistle-blower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Protection

Protection will be given to whistle-blowers against any unfair practices like retaliation, threat or intimidation or termination/suspension of service, compensation decreases, or poor work assignments, threats of physical harm, disciplinary action, transfer, demotion, refusal of promotion.

Protection is provided in two important areas - confidentiality and against retaliation. The confidentiality of the whistle-blower will be maintained as far as possible. However, it may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defence.

The Company affirms that it will not allow any whistle-blower to be victimised for making a complaint. Any kind of discrimination, harassment, victimisation or any other unfair employment practice adopted against the whistle-blowers is condemned.

Reporting in good faith

Every whistle-blower should report only after gathering adequate facts/data to substantiate the complaint and not complain merely on hearsay or rumour. However, if a complaint, after investigation proves to be frivolous, malicious or made with ulterior intent/motive, the Company will take appropriate steps to discourage such action in the future by demanding a public apology from the whistle-blower and reasonable monetary compensation to be paid to his/her grieved colleague.

Issued and Approved by the Board

3^rd March 2015

On behalf of the Board of Directors – New Concept