Code of Conduct Policy:

Pinnacle’s Code of Conduct sets forth the core values, shared responsibilities, collective and individual commitment to integrity and provides practical guidance to each of our stakeholders in how we expect business to be conducted worldwide. It provides general guidance about the Company’s expectations, highlights situations that may require particular attention, and references additional resources. To continue to be the global leader in BIM, Pinnacle drives the highest standards of integrity, accountability, sustainability and transparency.

PURPOSE & SCOPE OF THIS CODE:

The Code sets out the principle ethical framework and the professional standards of conduct that define the values, behaviors and duties that employees must consider and adhere to while working in PIS whether inside or outside of place of work to establish

• a strong cultural foundation for the business and maintain discipline and minimize disruption on the work floor and inside the premises of PIS.

• an atmosphere of commitment within the organization.

• the values of the organization that drive its actions and theprinciples that underline decision-making.

Employees should comply with the Code of Conduct and any breach will be investigated under the disciplinary procedure and may result in disciplinary action. Serious or repeated breaches of the code of conduct will be considered gross misconduct and may lead to further HR actions.

All Reporting Managers will be responsible for maintaining the overall discipline of their respective teams. They are supposed to report to local HR on the disciplinary instances of their respective team members.

APPLICABILITY:

The Code of Conduct applies to all employees including trainees, consultants, contractors, volunteers and any other stakeholders associated with Pinnacle Infotech Solutions, India.

The policy outlines and covers the following:

A. PROFESSIONAL ETHICS

B. RESPECTING EACH OTHER

C. HEALTH, SAFETY AND ENVIRONMENT

D. PROTECTING COMPANY ASSETS

E. COMPLIANCE AND ENFORCEMENT

A. PROFESSIONAL ETHICS

A.1. Punctuality & Attendance

A.1.1. Office Timing: (Standard Timing – General Shift) :

Monday to Thursday 9:00 AM - 6:45 PM Friday 9:00 AM – 6:00 Lunch Break 45 mins included

a) Employees shall mark their attendance by punch-in with their access card / biometric during Entry to the Office.

b) If an employee is not able to punch in due to system failure / biometric dysfunction, the admin–front office should be informed and should apply for attendance regularization in the HROne portal.

c) In case of attending official events, he/she should for OD in the HROne portal.

d) Total time between first Punch-in and last Punch-out will be considered as total working hours.

e) Leaving Office before 6:45 P.M. (Monday to Thursday) and before 6:00 P.M. (Friday) needs approval from the respective PDH/HOD. All employees should get a gate pass permission signed by their reporting manager whenever they intend to go out of the office premises during working hours. The Gate Pass has to be submitted to the Security Personnel at Main Gate.

f) Failure to punch in and out of the access card/biometric shall be considered as absence from duty.

g) Unapproved absences may result in disciplinary action, up to and including termination of employment.

h) A pattern of frequent absenteeism may result in corrective action, including counseling and formal disciplinary measures

A.1.2. Flexible Time Office:

a) A flexible entry time of 15/30/60 minutes later than the scheduled time in the morning from 09:00 hrs or separately notified as per the defined shift, is permitted with corresponding flexibility on the time of exit.

b) Grace time allowance:

->15 mins: allowed 4 times in a month

->30 mins: allowed 3 times in a month

->60 mins: allowed 1 time in a month.

c) HROne will show ‘NO Late” upto 9:15 am / 9:30 am / 10 am. Out-Punch will stretch to the equivalent time of the grace time to meet complete 9 hrs for the day. Same-day late entry and early leaving are not permissible.

d) The flexible timing schedule will not be applicable for employees on OSD / business travels.A.2. Dress Code

A.2. Dress Code:

Employees are brand ambassadors of the Organization and their attire reflects the culture of the Organization. Workplace dress code will serve as a guideline for standards of dress and appearance that are compatible with our business environment. Employees are expected to be formally dressed during office hours.

A.2.1. Monday to Thursday: Dress code is formal:

a) Men should wear formal shirts and trousers with formal shoes, with the shirt tucked in.

b) Women should wear formal shirts with trousers/skirts with formal shoes or formal ethnic wear like salwar kameez / kurti / saree.

A.2.2. Friday: Dress code is Business casuals:

a) Men can wear jeans and solid colour cargos.

b) Women can wear casual including Decent Jeans, T-shirts and trainers only on Friday, when a less formal dress code is applied.

c) Employees should take care of personal grooming like clean & ironed clothes, polished shoes, neat haircuts and trimmed beards (for men if they keep beards).

A.2.3. Personal Grooming:

a) Certain clothing are to be avoided like jeans that have decoration/are torn/too low and shorts, printed cargos and kurtas for men. Sleeveless tops/ torn Jeans/short pants and shorts are to be avoided for Women.

b) Avoid footwear like sandals, slippers and floaters.

c) Good oral and body hygiene is to be maintained.

d) No Body piercing except nose and ears.

e) Tattoos are to be covered by clothing or concealer makeup.

A.2.4. Safety Gear:

Employees coming to the office by Motorcycle/ Scooter mandatorily need to wear helmets. Without helmet entry will be denied and necessary action will be taken.

A.3. Professional Etiquettes:

Etiquette refers to certain rules and regulations necessary for an individual to follow to find a respectable place in society. One must be courteous enough for others to draw inspiration and look up to him. An individual without good manners is often lost in the crowd and fails to make his mark. We should maintain professionalism, show maturity & behave sensibly at the workplace. A casual attitude at work will not be acceptable. One needs to be careful about what he wears, what he speaks, and how he interacts with his fellow workers. With an individual spending the maximum time at the workplace, it is essential to be comfortable at work and demonstrate utmost business conduct at the workplace.

A.3.1. Clean Desk

At Pinnacle, we support and drive the ‘Clean Desk’ initiative aimed at maintaining a tidy and clutter-free workspace. This is especially important in environments where sensitive information is handled, such as in offices dealing with confidential documents or data.

Key Components of a Clean Desk

a) Keep your workstation clean and organized.

b) Make sure you don’t throw paper and wrappings here and there. Throw them in dustbin.

c) Throw all unwanted pens, pencils, highlighters, erasers, markers and so on. Keep all your stationery items in their proper places. Throw away what all you don’t need.

d) Avoid keeping stacks of files at your desk. It gives a cluttered look to your workstation. Keep them in their respective drawers with a label on top of each file to avoid unnecessary searching. Never keep old files/documents in your drawers, if you are not specifically authorized to do so.

e) Develop the habit of using a table top calendar. Mark important tasks against the deadlines to avoid forgetting them.

f) Ask the attendant to clean your drawer once in week. Staple important documents together and keep them in their respective files. Avoid giving unnecessary printouts.

g) Personal Items:

Personal items should be kept to a minimum to avoid clutter.

Avoid bringing soft toys, photo frames, candle stands to work.

Keep your car keys, Bluetooth, earphones and other personal belongings at one place.

Do not leave phone chargers plugged in when you leave the desk. Phone Chargers, if left plugged in for long time can short circuit by overheating and cause fire.

Do not bring newspaper from home and pile on your desk

h) Secure Storage:

Secure storage solutions like locked drawers or filing cabinets should be provided.

Do not store eatables in your workstation drawers as these attract rats, rodents, cockroaches and insects Rats/rodents cut the network/communication lines and can render the workstation unusable permanently. Go to the Pantry /break out area for tea/coffee or eat anything you want to.

i) Confidential Information:

Confidential information should never be left out in the open.

Sensitive documents should be shredded if no longer needed.

j) Desktop Computers and Laptops:

Computers should be logged off or locked when not in use.

Turn off your printer, scanner, computer, light and AC when you leave for the day.

B. Respecting Each Other:

Respect for one another is a fundamental principle that fosters a positive, productive, and harmonious environment. This section of the Code of Conduct outlines the expectations and guidelines for treating each other with dignity and respect in all interactions within the organization. PIS strives to establish a respectful, inclusive and harmonious work environment where every employee feels valued and can contribute to their fullest potential.

B.1.Values and Expected Standards of Behavior:

B.1.1. Human values:

Do treat co-workers / fellow colleagues with empathy and understanding.

Do celebrate diversity and respect differences in culture, background, and belief systems.

Do seek feedback and suggestions for improvement from colleagues and supervisors.

Don't engage in or tolerate bullying, harassment, or discrimination of any kind.

Don't make assumptions about others based on stereotypes or prejudices.

B.1.2. Responsibility values:

Do communicate proactively with your supervisor and colleagues to ensure everyone is on the same page.

Do take ownership of your mistakes and work collaboratively to find solutions.

Do prioritize your tasks and responsibilities to ensure they are completed on time and to the best of your ability.

Don't avoid taking on new responsibilities or tasks outside your comfort zone.

Don't procrastinate or delay completing work significantly if it impacts others.

B.1.3. Trust values:

Do maintain confidentiality and be discreet with sensitive information.

Do act with honesty and transparency in all your dealings with others.

Do follow through on your commitments and promises.

Don't engage in any form of fraud or deceitful behavior.

Don't engage in conflicts of interest or activities that could be seen as unethical.

B.2. Discipline at the Workplace

Discipline in the workplace is how supervisory personnel correct behavioral deficiencies and ensure adherence to established company rules. The purpose of discipline is correct behavior. It is not designedto punish or embarrass an employee.

Employees should maintain and respect the following decorum at the premises including the Production Floor:

a) Leaving the work floor without intimating the manager will not be accepted and if any employee is found doing so action will be taken.

b) Absence from the desk or roaming on the work floorwithout any purpose, talking and chatting not related to work is strongly discouraged and work environment harmony should not be disturbed. The manager should take note of those Team members, who are violating the code of conduct on the Production Floor and report to HR on the same for further action.

c) Use of Mobile Phones inside the Production Building: Carrying and using mobile phones at the work floor and inside the production building is strictly prohibited, if not authorized explicitly in writing by the Departmental Head.

d) Conduct prejudicial to good order and discipline: Insubordination, Refusal to do allotted work, Negligence of duties / assigned tasks, Unprofessional conduct especially culpable neglect of duties, unacceptable or improper behavior; Misrepresentation of facts; Feigning sickness/diseases will not be acceptable.

e) The official phone should be used only for official purposes. Avoid long calls as your Boss might need you urgently.

f) If you need to talk to any of your colleagues, use the extension phone. Never shout from your desk. It is bad manners and disturbs others. If you do not have access to the extension phone, get up and walk to the other person’s desk.

g) Take care of your tone and pitch while speaking. Remember other employees are sitting around you as well.

Pinnacle Infotech Solutions office campus fosters productivity, collaboration, and employee well-being

a) One should maintain decent conduct inside the Pinnacle campus with colleagues. Indulging in obscene/ indecent acts objectionable to fellow residents is strictly forbidden

b) Disturbing peace and tranquility, disrupting good order and discipline, making noise, using foul, profane and abusive language and indulging in quarrel and affray is strictly forbidden.

B.3. Discipline at Dormitory (refers to Durgapur Location only)

a) Dormitory dwellers should be at their respective buildings by 11:00 P.M. Roaming around the PIS premises beyond 11:00 PM for Dormitory dwellers is strictly prohibited.

b) Carrying or cooking Food and consuming it inside the Dormitory is strictly prohibited.

B.4. Misconduct:

Non-Cooperation or Misbehavior with Security Personals:

For security reasons, anyone can be searched before entry or any time when in the premises. Anyone who declines to be searched or has prohibited items may be denied entry or ejected or necessary action may be taken.

Obstructing any security personnel from performing their duty or misbehaving with him will be treated as misconduct.

C. HEALTH SAFETY & ENVIRONMENT

The organization is committed to providing a safe, healthy, and environmentally sustainable workplace. This section of the Code of Conduct establishes standards and guidelines that promote health, safety, and environmental sustainability within the organization.

C.1. Health and Safety Practices

C.1.1. Drug-Free Workplace:

Employees must comply with this drug-free workplace policy at all times.

a) The use, possession, solicitation for or sale of narcotics drugs or psychotropic Substances on the Company's or client's premises or while performing an assignment will adversely affect the employee's work performance, the safety of the employee or others or put at risk the Company's reputation.

b) The presence of any detectable amount of such prohibited substances in the employee's system while at work, while on the premises of the company or its customers or while on company business is strictly prohibited. "Prohibited substances" include illegal drugs and Psychotropic Substances.

c) Use Consumption & Possession of Alcohol: The use, consumption, possession, entering/ carrying and solicitation for or sale/purchase of alcohol and alcoholic drinks in workplaces, dormitories, gardens, grounds, offices, cafeterias and premises is strictly prohibited except when specifically permitted in corporate organized events and parties.

C.1.2. Smoke-Free Workplace:

Smoking within the bounds of the PIS campus is prohibited except in three designated smoking zones in the Dormitory. Smoking inside the dormitory room is prohibited. Abuse of Tobacco/Gutka/pan and Chewing gum is strictly prohibited within the Premises including the Production Floor.

C.1.3. Anti-Harassment and Non-Discrimination:

The organization is committed to providing a work environment that is free from harassment and discrimination and promotes respect, equality, and dignity for all employees and other stakeholders. Harassment is any unwelcome behavior that creates an intimidating, hostile, or offensive work environment. This includes, but is not limited to:

a) Verbal Harassment: Offensive or unwelcome comments, jokes, or slurs based on race, gender, sexual orientation, religion, disability, or any other protected characteristic.

b) Physical Harassment: Unwanted physical contact, threats, or physical intimidation.

c) Visual Harassment: Displaying offensive images, cartoons, or objects that demean or insult individuals based on protected characteristics.

Discrimination is treating someone unfavorably because of their race, gender, age, religion, disability, sexual orientation, national origin, or any other protected characteristic.

C.1.4. Social Media and Digital Conduct:

The organization recognizes the importance of social media and digital platforms in personal and professional communication. Employees should responsibly and appropriately use social media and digital noting the following guidelines:

a) One should clearly state that opinions expressed are personal and not reflective of the organization's views.

b) Limit personal social media use during work hours to avoid interference with job responsibilities.

c) Avoid sharing content that could harm the organization's reputation or violate its policies.

d) Ensure that all professional social media activity aligns with the organization's values, policies, and branding guidelines.

e) Maintain professional boundaries when interacting with colleagues and clients on social media.

f) Do not engage in or tolerate any form of harassment, bullying, or discrimination online.

D.PROTECTING COMPANY ASSETS:

D.1. Confidentiality and Non-disclosure:

a) Do use discretion when discussing PIS information in public areas or with individuals not authorized to access the information.

b) Do report any suspected security breaches or data leaks to the appropriate individuals or departments.

c) Do maintain the confidentiality and privacy of PIS data during and after employment with the company.

d) Don't use PIS information for personal gain, benefit, or any third party’s benefit.

e) Don't leave confidential PIS data exposed or unattended in public areas or on unsecured devices.

f) Don't take or make copies of confidential PIS data without authorization. g) Don't disclose or use any confidential information or data after leaving employment with the company.

D.2. Use of Company Assets:

a) The use of Company assets for individual profit or any unlawful, unauthorized personal or unethical purpose is prohibited.

b) The information technology, intellectual property, facilities - equipment, machines, software, and cash may be used for business purposes only, including responsible and accurate expense reimbursement, and by applicable policies.

c) Other assets (e.g., computers, printers, and copiers) may be used for minor and incidental personal purposes provided such use is kept to a minimum and does not create any significant incremental costs, interfere with work duties, or violate any laws or Pinnacle policies.

d) It is your responsibility to prevent unauthorized access through the use of ID badges, passwords, or other security codes, and physical security measures (such as using computer cable locks, not leaving computers unattended in cars, and other normal precautions).

e) Software used in connection with the business of Pinnacle should be properly licensed and used only in accordance with that license.

f) Proper Use of company assets only for the intended business purposes and by company policies.

g) Take reasonable care to maintain and protect company assets from damage, misuse, and theft.

E. COMPLIANCES & ENFORCEMENT:

Our organization values integrity, transparency, and ethical conduct in all aspects of our operations. The code outlines guidelines for identifying, disclosing, and managing conflicts of interest to ensure fair and unbiased decision-making.

E.1. Conflict of Interest:

a) There should be no personal interests or relationships that could improperly influence the employees’ judgment or actions in performing the duties for the organization.

b) No spouses or any other close relative should be posted in the same department. The term “relative” is used to refer to any person who has a relation by blood or marriage with our active employee.

c) All employees need to abide by the employment agreement terms and conditions. Any violation to the duly signed agreements and covenants specific to NDA (non-disclosure agreements) will depend on the severity of the violation and accordingly will act to:

The Code of Conduct serves as a cornerstone for building a respectful, ethical, and legally compliant organizational culture. By outlining clear expectations and providing mechanisms for addressing issues, it helps maintain a positive and productive environment for all stakeholders.