🔷 1. Purpose and Commitment

PUMEC Consultants Private Limited (“PUMEC”, “we”, “our”) is committed to conducting its business with the highest standards of integrity, professionalism, and ethical responsibility.

This Code of Ethics establishes the principles and expectations that guide the conduct of:

• Directors and Partners
• Employees and consultants
• Vendors and service providers
• Associated professionals and representatives

All stakeholders associated with PUMEC are expected to adhere to this Code in both letter and spirit.

🔷 2. Compliance with Laws and Regulations

PUMEC operates in full compliance with:

• Applicable laws and regulations in India, including corporate, tax, and foreign exchange laws
• Relevant international regulatory frameworks applicable to cross-border engagements
• Contractual obligations with clients, employees, and vendors

We ensure that all professional services are delivered in accordance with:

• Statutory requirements
• Regulatory guidelines
• Professional standards

🔷 3. Integrity and Ethical Conduct

We conduct our business with honesty, fairness, and transparency.

PUMEC does not engage in:

• Misrepresentation of facts or advisory positions
• Any form of unethical or unlawful conduct
• Practices that may compromise professional judgment

All decisions are expected to reflect sound ethical judgment and professional responsibility.

🔷 4. Professional Competence and Due Care

PUMEC is committed to maintaining a high level of technical competence and diligence.

We ensure that:

• Services are performed by qualified professionals
• Advice is based on appropriate analysis and applicable laws
• Deliverables meet quality and professional standards

Continuous learning and professional development are encouraged to maintain expertise.

🔷 5. Confidentiality and Data Protection

We maintain strict confidentiality of all client, employee, and business information.

Personal and professional information:

• Is used only for legitimate purposes
• Is not disclosed without authorization, unless required by law
• Is protected through appropriate safeguards

This obligation continues even after the end of professional or contractual relationships.

🔷 6. Independence and Objectivity

PUMEC maintains independence and objectivity in all professional engagements.

We:

• Avoid conflicts of interest
• Disclose any potential conflicts transparently
• Ensure that professional judgment is not influenced by external pressures

Where independence may be impaired, appropriate safeguards or disengagement may be considered.

🔷 7. Client Relationships and Professional Conduct

We are committed to building long-term client relationships based on:

• Trust and transparency
• Clear communication
• Ethical advisory practices

We:

• Provide objective and well-reasoned advice
• Clearly communicate assumptions, risks, and limitations
• Avoid aggressive or non-defensible positions

🔷 8. Fair Dealing with Employees and Vendors

PUMEC promotes a professional and respectful working environment.

🔷 9. Anti-Bribery and Anti-Corruption

PUMEC follows a zero-tolerance approach toward bribery and corruption.

We prohibit:

• Offering or accepting improper payments, gifts, or advantages
• Any activity that may influence business decisions unethically

All stakeholders must comply with applicable anti-corruption laws and standards.

🔷 10. Use of Technology and Information Systems

All systems and digital resources must be used responsibly and securely.

Users must:

• Protect confidential and sensitive data
• Avoid unauthorized access or misuse
• Comply with internal IT and data security policies

🔷 11. Reporting Concerns and Ethical Violations

PUMEC encourages the reporting of any suspected:

• Ethical violations
• Non-compliance with laws or policies
• Misconduct or inappropriate behavior

Reports will be handled:

• Confidentially
• Without retaliation
• In accordance with internal review procedures

🔷 12. Enforcement and Accountability

Failure to comply with this Code may result in:

• Disciplinary action
• Termination of employment or engagement
• Legal action, where applicable

PUMEC maintains appropriate mechanisms to monitor and enforce compliance.

🔷 13. Continuous Improvement

PUMEC periodically reviews and updates this Code to ensure alignment with:

• Evolving legal and regulatory requirements
• Industry best practices
• Organizational growth and global standards

🔷 14. Our Ethical Commitment

At PUMEC, we are committed to conducting our business in a manner that is:

• Ethical and transparent
• Compliant with laws and regulations
• Aligned with professional standards
• Respectful of all stakeholders

🔷 15. Effective Date

April 2026