Legal
Code of Conduct
Last updated: March 8, 2026
CIXIO TECHNOLOGIES PRIVATE LIMITED
1. Introduction and Scope
1.1 Our Commitment
Cixio Technologies Private Limited is committed to conducting its business with the highest standards of Integrity, Professionalism, and Transparency. This Code of Conduct reflects our core values and legal obligations.
1.2 Who Must Follow This Code?
This Code applies globally to all:
- Directors and Key Managerial Personnel (KMPs).
- Full-time, part-time, and temporary employees ("Personnel").
- Contractors, consultants, vendors, agents, and third parties acting on Cixio's behalf.
1.3 Key Guiding Principles
Personnel must always ask: "Is my action legal, ethical, honest, and in the best interest of Cixio?"
2. Workplace Culture and Professionalism
2.1 Diversity, Inclusion, and Equal Opportunity
Cixio values the diversity of its workforce and is committed to fostering an inclusive environment where all individuals are treated with dignity and respect.
- Equal Opportunity: Employment decisions (hiring, promotion, compensation, training) will be based solely on merit, qualifications, and business needs.
- Non-Discrimination: We prohibit discrimination or harassment based on race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, marital status, or any other characteristic protected by law.
2.2 Anti-Harassment and Anti-Bullying
We maintain a workplace free from all forms of harassment, intimidation, and abuse, including:
- Sexual Harassment: Unwelcome sexual advances, requests for sexual favours, and other verbal or physical conduct of a sexual nature. This is a serious offence under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act) in India.
- Bullying: Repeated unreasonable behaviour directed toward an employee or group of employees that creates a risk to health and safety.
2.3 Health, Safety, and Environment (HSE)
Personnel must comply with all relevant HSE laws, regulations, and company procedures to ensure a safe and healthy working environment.
3. Business Integrity and Ethical Dealings
3.1 Conflicts of Interest (COI)
A COI arises when a Personnel's personal interest actually or potentially interferes with the best interests of Cixio. Personnel have an affirmative obligation to disclose any potential COI.
| Category | Prohibited Actions (Require Disclosure) | Mitigation Requirement |
|---|---|---|
| Outside Employment | Working for, consulting for, or serving as a director of a competitor, supplier, or customer. | Must be disclosed to and pre-approved by the Compliance Officer. Approval is rare if the outside role is related to the IT sector. |
| Financial Interests | Having a significant financial stake (more than 1% of equity or being a KMP/Director) in a competitor, supplier, or customer. | Must be disclosed. Personnel may be required to divest the interest or be excluded from related decisions. |
| Relatives/Friends | Being in a position to supervise, hire, compensate, or audit a close family member or person with whom the Personnel has a close personal relationship. | Must be disclosed to HR and the Compliance Officer. An alternative reporting structure will be implemented. |
| Corporate Opportunity | Taking advantage of an opportunity discovered through the use of company property, information, or position for personal gain, unless Cixio formally declines the opportunity. | Must be formally offered to and declined by the Cixio Board/Senior Management in writing. |
3.2 Anti-Bribery and Anti-Corruption (ABC)
Cixio has a zero-tolerance policy against all forms of bribery and corruption, strictly adhering to the Indian Prevention of Corruption Act, 2018.
- Prohibition: Personnel must not offer, promise, give, or accept anything of value (directly or indirectly) to improperly influence a business outcome or gain an unfair advantage. This applies to both Government Officials and private sector individuals.
- Facilitation Payments: Strictly prohibited. These are small payments made to expedite a routine action, even if customary in some areas.
- Gifts and Hospitality: Gifts and entertainment should be infrequent, nominal in value (e.g., typically under ₹2,000), and permissible under local laws. Cash or cash equivalents are strictly prohibited. Anything exceeding the threshold must be reported and approved by the manager and Compliance Officer.
3.3 Fair Dealing and Competition
We compete vigorously but ethically and legally. Personnel must not engage in any anti-competitive behaviour, such as price-fixing, market allocation, or abuse of a dominant position.
4. Protection of Company Assets and Information
4.1 Confidentiality and Trade Secrets
Confidential Information (CI) is any non-public information that could be useful to competitors or harmful to Cixio or its customers if disclosed.
- CI includes, but is not limited to: source code, algorithms, business plans, financial data, unreleased product features, customer lists, and merger/acquisition data.
- The obligation to protect CI continues even after employment ends.
- CI must not be shared through social media, public forums, or unauthorized internal/external communications.
4.2 Data Protection and Privacy
Cixio is committed to protecting the Personal Data of its customers, employees, and third parties in compliance with all relevant privacy frameworks (e.g., IT Act, 2000, and global regulations like GDPR/CCPA where applicable).
- Access Control: Personnel must only access personal data strictly required for their job duties (Need-to-Know basis).
- Security: Personnel must utilize strong, unique passwords, employ multi-factor authentication, and comply with all IT security policies (e.g., endpoint protection, encryption).
- Data Breach: Any loss, misuse, or unauthorized access to personal data, whether accidental or intentional, must be immediately reported to the IT Security Team and the Compliance Officer.
4.3 Responsible Use of Assets
Company assets, including equipment, software licenses, network access, and time, must be used primarily for legitimate business purposes.
- Unauthorized downloading, copying, or distributing of copyrighted material is prohibited.
- Incidental and minimal personal use of IT systems is generally permitted but must not interfere with work, consume excessive resources, or violate any law or policy (e.g., pornography, illegal downloads).
5. Reporting and Accountability
5.1 Reporting Misconduct (Speak Up Policy)
Cixio encourages and expects Personnel to speak up if they know of or suspect any actual or potential violation of this Code, company policies, or the law.
- Reporting Channels: Concerns can be reported to your Manager, Human Resources (HR), the Legal Department, or the designated Compliance Officer.
- Whistleblower Hotline: Cixio maintains a secure, external Whistleblower Hotline or dedicated email channel for confidential and, where legally permitted, anonymous reporting.
5.2 Non-Retaliation Guarantee
Cixio strictly prohibits any form of retaliation, punishment, or negative employment action against any individual who, in good faith, raises a concern or participates in an investigation. Anyone engaging in retaliation will face severe disciplinary action.
Note: Reporting must be made in good faith. Making a report known to be false is a violation of this Code and may result in disciplinary action.
6. Consequences and Enforcement
6.1 Disciplinary Action
Violations of this Code of Conduct will result in disciplinary action, which may include, but is not limited to:
- Verbal or written warnings.
- Demotion, suspension, or loss of pay.
- Immediate termination of employment or contract.
- Referral to appropriate legal or regulatory authorities, potentially resulting in civil or criminal penalties.
6.2 Code Administration
This Code will be administered by the Compliance Officer (or designated Ethics Committee) and reviewed annually by the Board of Directors to ensure it remains current and effective.
Acknowledgment:
I have received, read, and understand the Cixio Technologies Private Limited Code of Conduct. I agree to comply with this Code and acknowledge that my failure to do so may result in disciplinary action, including termination of employment.
Name: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Signature: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
CIXIO TECHNOLOGIES PRIVATE LIMITED | | Corporate Office: support@cixio.com | Phone: