We at KG Electro-Power (P) Ltd/ KGEP Ventures (P) Ltd (KGEP) aspire to be role models. With this in mind, we must act accordingly at all times and always in the interest of the company. This encompasses customers, employees, shareholders, and social responsibility, essentially all stake-holders.

Because the way in which a company’s employees conduct themselves has a major influence on how the company is perceived and accepted, it is more important than ever before for us to stand by our social responsibility, assume it consciously, and act sustainably to bring about a benefit to society. It is not just economic strength that matters to us; the way in which we achieve it is equally important. We at KGEP adhere to the highest ethical and moral standards as we go about our business. This conduct has earned us great respect among all our stakeholders. They all rightly trust us to uphold these standards in everything we do. And this is a duty that falls to us all at KGEP – no matter what our job is. After all, we represent the company in all its manifestations, at all times, and wherever we happen to be.

KGEP stands for clean business – this is our uncompromising stance. We expect it of ourselves, our employees, our managers, and our Managing Board members; and from our customers, partners, and all other company stakeholders.

With our Business Conduct Guidelines, you hold the binding code of conduct in your hands. Its contents are built from our values and are mandatory for all of us at KGEP - employees, managers, and the Managing Board. The Business Conduct Guidelines set out the fundamental principles and rules governing how we act within our company and in relation to our customers, external partners and the general public. At the same time, they also offer valuable guidance and answers to important questions.

Please do not hesitate to turn to it for advice and support if you are ever in doubt about what to do. I ask you to read through the Business Conduct Guidelines carefully and to act at all times as if KGEP were your own company.

Director – KG Electro-Power (P) Ltd/ KGEP Ventures (P) Ltd

The company is committed to conducting its business with the highest standards of ethics, integrity, and responsibility. These Business Conduct Guidelines are designed to provide employees with a clear understanding of the company's expectations and to promote a culture of ethical behaviour. This code of conduct and ethics sets forth the standards of behaviour expected of all employees of KG Electro-Power (P) Ltd/ KGEP Ventures (P) Ltd, a leading distributor for LV & MV Electrical Products in India, partnered with the some of the most reputable, responsible & reliable brands. The purpose of this code is to promote a culture of integrity and professionalism, and to ensure that all employees act in the best interests of the company and its stakeholders.

• Ownership Culture: Employees are expected to always act as if they were the owner of the company and to make decisions that benefit the company in the long term.
• Values: The company is built on a foundation of core values, including honesty, integrity, fairness, and respect. These values should guide employees in their work and interactions with others.
• Behaviour: Employees are expected to act with professionalism, respect, and dignity in all their dealings, both within the company and with external stakeholders.
• Leadership: The company's leaders are expected to model the highest standards of ethical behaviour, and to provide guidance and support to their teams.
• People Orientation: The company is people-oriented, and employees are expected to be respectful, supportive, and inclusive in their interactions with others.
• Equity: The company is committed to promoting equality and equity, and to avoiding all forms of discrimination.

• We Behave Correctly: Employees are expected to act in accordance with the law, and to avoid any actions that could compromise the company's reputation. We must be aware of and comply with the laws and regulations that apply to our daily work. Violations of the law or failure to comply with the Business Conduct Guidelines can have serious consequences for our company and us, such as, disciplinary action, fines and damages or imprisonment.
• We Respect Each Other: Employees are expected to treat their colleagues and other employees with respect and professionalism, and to avoid any actions that could create a hostile or uncomfortable work environment. We respect the personal dignity, privacy, and rights of each individual. We work together without regard to ethnic origin, culture, religion, age, disability, skin colour, gender, sexual identity and orientation, or worldview. Employees must not engage in discriminatory or harassing behaviour, or create an intimidating, hostile, or offensive work environment. This includes avoiding any activities that might result in harm to others, or that might create a hostile or intimidating workplace.

We do not tolerate discrimination, sexual or any other form of harassment, or inappropriate behaviour toward individuals or groups.

• We Create Trust: Employees are expected to act with integrity and transparency in all business dealings, and to maintain the confidentiality of sensitive company information. We are open and honest. We take our responsibility seriously, we are reliable, and we only make promises we can keep.

We are sincere. We help clarify and eliminate potential deficiencies, problems, and misunderstandings. We do everything to fulfil the trust placed in us by our customers and the users of our products, services, and industry solutions.

• We Protect Our Company: Employees are expected to be vigilant in protecting the company's assets and reputation, and to report any suspected violations of this code of ethics.
• We protect our Integrity: Gifts and Gratuities, employees must not solicit or accept gifts, gratuities, or other favours that might influence their judgment or compromise their integrity. This includes avoiding any activities that might result in a personal financial benefit, or that might compromise their ability to perform their work impartially.
• As Managers, We Have a Special Responsibility: Managers are expected to be role models of ethical behaviour and to provide guidance and support to their teams. We create a trusting working environment and are always available to discuss with our employees uncertainties, compliance with legal requirements, questions, or professional and personal concerns with our employees. We set a good example and ensure our teams understand the importance of acting in accordance with the Business Conduct Guidelines. Managers’ special responsibilities and duties do not release them from their own responsibilities as employees. We must work together to comply with the law and KGEP’s guidelines.

The company is committed to providing employees with safe and healthy working conditions, and to protecting their health, occupational safety, and personal security. KGEP fosters fair cooperation among management, employees, and employee representatives, and protects the fundamental rights of its employees.

• No discrimination or intimidation: The principles of equal opportunity and equal treatment are guaranteed without regard to skin colour, ethnic or social origin, religion, age, disability, sexual identity, worldview, or gender. In accordance with the labour laws, discrimination based on these characteristics, sexual harassment, or other inappropriate behaviour toward individuals or groups will not be tolerated.
• Free choice of employment: No one should be employed or forced to work against their will. All forms of forced labour are prohibited.
• Prohibition of child labour: Child labour is strictly prohibited.
• Adequate compensation: KGEP pays fair wages for labour and adheres to all applicable wage and compensation laws globally. KGEP observes “equal pay” principles and does not discriminate on the basis of gender.

We place integrity at the heart of everything we do. Antitrust violations can have serious consequences for our company and the employees involved, such as high fines, exclusion from public tenders, claims for damages, damage to reputation, and imprisonment.

a. Fair Competition: The company is committed to fair competition, and to avoiding any actions that could violate antitrust law or compromise its reputation. The company also complies with trade and export control regulations. Fair competition is in line with our values, KGEP stands for fair competition in which only market economy criteria (quality, price, innovation, service, etc.) are the decisive factors for business decisions. Competition should not be distorted by unfair methods or means.

b. Protecting What Makes Our Company Valuable: We Create Trust and Protect What Makes Our Company Valuable: The company is committed to protecting its brand, avoiding conflicts of interest, and ensuring financial integrity. The company also has a responsibility to protect its corporate assets, to comply with data protection and privacy regulations, and to prevent money laundering and the funding of terrorism. We must only make business decisions in the interest of KGEP.

• The Brand: A Promise of Reliability and Quality: Employees are expected to work towards maintaining the reputation and image of the brand, and to act in a manner that aligns with the brand's values and promises. In addition to the KGEP brand, intellectual property rights, patents, copyrights, and confidential know-how, and their protection, are essential for our business success.
• Conflicts of Interest: Employees are expected to make business decisions in the best interest of the company and not in their personal interest. Conflicts of interest arise when an individual's personal interests interfere with the interests of the company. Employees are expected to avoid conflicts of interest and report any potential conflicts to the relevant authorities. These conflicts may be: Secondary employment, Competition directly or indirectly with KGEP, Investment in third-party companies etc.
• Money Laundering and the Funding of Terrorism: Our company does not engage in or support money laundering or the funding of terrorism in any way. Employees are expected to comply with anti-money laundering laws and regulations, and to report any suspicious activities to the relevant authorities.
• Financial Integrity: Our company strives to maintain financial integrity and transparency in all its business dealings. This includes accurate financial reporting, internal controls, and compliance with financial regulations. Employees are expected to act with honesty and integrity in their financial dealings and to report any suspected violations of financial regulations.
• Responsibly Protecting Corporate Assets: Our company's assets, including its property, information, and intellectual property, are valuable and must be protected. Employees are expected to be vigilant in protecting these assets and to report any suspected violations to the relevant authorities.
• Data Protection and Privacy: Our company is aware of its responsibilities with regards to data protection and privacy. Employees are expected to handle it carefully and responsibly and respect everyone’s privacy. Personal data is information about specific or identifiable natural persons, such as name and address, photos, personnel number, bank data, digital identifiers, or health data. The loss or improper use of personal data can have serious consequences for the individuals concerned. It is therefore very important for KGEP to ensure that this data is effectively protected and used only for legitimate purposes.

All of us who handle the personal data of employees, customers, or third-parties bear a high level of responsibility.

• Our Service/ Solutions: In our areas of responsibility, we ensure that our products, services, and industry solutions are safe and comply with applicable technical requirements of our customers for their safety, approval, marketing, and use. We keep our technical promises. If we become aware of any quality, safety, or other conformity defects in our area of responsibility, or if there are any indications of such defects, we will follow-up and report them. We must at all times be completely transparent with our stakeholders, any kind of deception, Active or by Omission is not tolerated.
• Our Partners: We work with responsible partners, we bring to our stakeholders, only the best and most reputed brands, known worldwide for their ingenuity, integrity, transparency, reliability & quality, while delivering the highest standards of innovation. We carefully select our suppliers and other business partners.

We only work with suppliers who are prepared to eliminate problems or implement risk reduction measures.

KGEP is committed to sustainable business practices that minimize environmental impact. All employees are encouraged to reduce waste, conserve resources, and comply with all applicable environmental laws and regulations. Employee must:

• Conserve energy and resources
• Comply with environmental regulations
• Support waste reduction and recycling

Employees must not post content that could harm the company’s reputation. Any public commentary related to KGEP must be appropriate, respectful, and aligned with company values. Confidential company information must never be disclosed on digital platforms.

• No unauthorized or harmful representation of the company online
• Do not disclose confidential information on social platforms
• Be respectful and responsible when using digital channels

By providing a safe and confidential means of reporting suspected violations, the company is committed to ensuring that all employees are able to report suspected violations without fear of retaliation. The company expects all employees to embrace and uphold these values and standards in their day-to-day work, and to act in the best interests of the company and its stakeholders.

• Encouragement of Reporting: The company encourages employees to report any suspected violations of this code of conduct and ethics, or any other unethical or illegal behaviour. Employees who report suspected violations in good faith are protected from retaliation, and will not be subject to any adverse employment action as a result of their reporting.
• Confidential Reporting: Employees may report suspected violations confidentially, either to their supervisor, or the company's management, or via email anonymously. The company will protect the confidentiality of employees who report suspected violations, and will not disclose their identity without their consent, except as required by law.
• Protection from Retaliation: Employees who report suspected violations in good faith are protected from retaliation, and will not be subject to any adverse employment action as a result of their reporting. The company will take all necessary steps to prevent retaliation against employees who report suspected violations, and will take appropriate action against any employee who engages in retaliation.

By adhering to this code of conduct and ethics, and by taking personal responsibility for their actions and decisions, employees of [Company Name] can help to minimize the risk of liability and ensure the success of the company. The company expects all employees to embrace and uphold these values and standards in their day-to-day work, and to act in the best interests of the company and its stakeholders.

• Employee Responsibility: Employees are solely responsible for their own actions and decisions, and the company cannot be held responsible for any problems that result from these actions. This includes any violations of laws, regulations, or company policies, or any damage or harm to the company or its stakeholders.
• Compliance with Laws and Regulations: Employees must comply with all applicable laws and regulations, and must act in accordance with the company's policies and procedures. This includes, but is not limited to, compliance with the Companies Act, 2013, the Income Tax Act, 1961, and the Prevention of Corruption Act, 1988. The company cannot be held responsible for any problems that result from the employee's failure to comply with these requirements.
• Responsibility for Consequences: Employees are responsible for the consequences of their actions, including any damages or losses incurred by the company or its stakeholders. The company cannot be held responsible for these consequences, and employees may be held personally liable for any damages or losses incurred.
• Due Diligence: Employees must exercise due diligence in their work and must act with care and attention to detail. The company cannot be held responsible for any problems that result from the employee's failure to exercise due diligence.

The company's commitment to promoting clean and transparent business practices, and its zero tolerance policy for non-compliance, serve as a foundation for its culture of integrity and compliance, and are intended to ensure that all employees and business partners act in accordance with the company's values and standards.

• Clean and Transparent Business: The company is committed to promoting clean and transparent business practices, and to avoiding any actions that could compromise its integrity or reputation.
• Zero Tolerance Policy: The company has a zero tolerance policy for any violations of this code of conduct and ethics, or any other unethical or illegal behaviour. Any employee who violates this code of conduct and ethics will be subject to disciplinary action, up to and including termination of employment.
• Reporting Obligations: Employees are required to report any suspected violations of this code of conduct and ethics, or any other unethical or illegal behaviour, to their supervisor, the company's compliance department, or to an anonymous hotline.
• Monitoring and Enforcement: The company will monitor compliance with this code of conduct and ethics, and will take appropriate action to enforce its provisions, including conducting investigations into suspected violations and taking disciplinary action against employees who violate this code of conduct and ethics.

KGEP expects us to report possible violations of the Business Conduct Guidelines. In so doing, we help to identify and eliminate misconduct and grievances and protect ourselves and the company against risks or damages that may result.

We may report circumstances that indicate a violation of the Business Conduct Guidelines to the following persons or entities:

1. Managers
2. Compliance Officer
3. Management Board
4. Email : compliance@kgep.in

Information on possible violations of the Business Conduct Guidelines can be provided confidentially and anonymously as needed. Siemens will examine all reports and take appropriate measures.

All allegations of possible violations of the Business Conduct Guidelines are responded to in accordance with formal company-wide processes. These processes take into account the presumption of innocence and the participation rights of employee representatives where required by local policy. KGEP will take appropriate disciplinary action in the event of demonstrable violations.

KGEP will apply the same principles to allegations of wrongdoing brought by third-parties.

All employees will receive training on these guidelines upon joining and through periodic refreshers to ensure understanding and implementation.

• Conflict of Interest: Personal interests interfere with company interests.
• Discrimination: Unfair treatment based on identity or beliefs.
• Whistleblower: An employee who reports misconduct.
• Integrity: Consistently ethical behaviour.
• Personal Data: Any identifiable personal information

These Business Conduct Guidelines are designed to promote a culture of ethical behaviour and to provide employees with a clear understanding of the company's expectations. Employees are expected to adhere to, uphold and embrace these guidelines, and to act in accordance with the highest standards of ethics and integrity. The liability for any unethical or illegal actions rests with the employee.

Chirag Ghosal, Chief Compliance Officer