ETHICS & COMPLIANCE POLICY

Purpose

UClik Technologies Pvt. Ltd. is committed to conducting business with integrity, transparency, and accountability. This policy establishes a comprehensive framework to guide ethical decision-making and ensure compliance with applicable laws and regulations. It promotes a culture where ethical behavior is embedded into everyday operations and organizational values.

Ethics & Compliance Framework

The Company maintains a structured Ethics & Compliance Framework designed to prevent, detect, and address misconduct. It includes clearly defined policies, internal controls, risk assessments, and governance processes. Regular monitoring and continuous improvement ensure that compliance measures remain effective, relevant, and aligned with evolving regulatory and business requirements.

Code of Ethics and Conduct

The Code of Ethics and Conduct defines the standards of behavior expected from employees and stakeholders. It emphasizes honesty, fairness, and professionalism. It covers compliance with laws, anti-corruption practices, conflict of interest management, confidentiality obligations, and respectful workplace behavior, ensuring that all actions align with the Company’s ethical values.

Whistleblowing Mechanism

The Company provides a secure and confidential whistleblowing mechanism that enables employees and stakeholders to report unethical conduct, fraud, or policy violations. Reports can be made anonymously and are handled with sensitivity. The Company ensures prompt investigation of concerns and strictly prohibits retaliation against individuals reporting in good faith.

Monitoring and Effectiveness

The Company regularly evaluates the effectiveness of its Ethics & Compliance Program through internal audits, compliance reviews, and performance metrics. Incident tracking, employee feedback, and periodic risk assessments help identify gaps and improvement areas. Senior management actively reviews findings to ensure accountability and continuous strengthening of the compliance framework.

Training and Awareness

UClik Technologies conducts regular training programs to ensure employees understand ethical standards and compliance requirements. This includes onboarding sessions, refresher courses, and awareness campaigns. Training materials are updated periodically to reflect regulatory changes, ensuring employees are equipped to identify risks and act in accordance with company policies.

Third-Party Engagement

The Company engages with vendors, subcontractors, and partners responsibly and is working towards strengthening its third-party compliance due diligence processes. Efforts are focused on ensuring that all external parties align with the Company’s ethical standards, minimizing risks associated with third-party relationships and promoting responsible business practices across the supply chain.

Contractual Compliance

All Company contracts include compliance-related provisions to ensure adherence to legal and ethical standards. These clauses cover anti-bribery obligations, confidentiality, regulatory compliance, and rights to take corrective actions. This ensures that all contractual relationships uphold integrity and provide mechanisms to address non-compliance effectively.

Business Partner Expectations

The Company expects its business partners, including suppliers and subcontractors, to maintain high ethical standards. Partners are required to comply with applicable laws and include compliance clauses in their agreements. This ensures consistent ethical practices throughout the value chain and reinforces the Company’s commitment to responsible business conduct.

Core Principles

UClik Technologies operates on core principles of integrity, accountability, transparency, respect, and compliance. These principles guide decision-making at all levels of the organization. By embedding these values into daily operations, the Company fosters trust with stakeholders and ensures sustainable and ethical business growth.

Anti-Bribery

The Company follows a zero-tolerance approach toward bribery and corruption. Employees and representatives must not offer, accept, or solicit any improper advantage. All business dealings must be conducted transparently and ethically, ensuring compliance with anti-corruption laws and maintaining the Company’s reputation for integrity.

Conflict of Interest

Employees must avoid situations where personal interests conflict with the Company’s interests. Any potential or actual conflicts must be disclosed promptly. Transparent handling of such situations ensures unbiased decision-making and protects the integrity of business operations and stakeholder trust.

Confidentiality

The Company is committed to protecting confidential and sensitive information, including client data and intellectual property. Employees must ensure that such information is not disclosed without proper authorization. Adherence to data protection practices safeguards business interests and maintains trust with clients and partners.

Workplace Conduct

UClik Technologies promotes a respectful, inclusive, and safe workplace environment. The Company enforces zero tolerance for harassment, discrimination, or bullying. Employees are expected to communicate professionally and treat others with dignity, fostering a culture of collaboration, equality, and mutual respect.

Reporting & Non-Retaliation

Employees are encouraged to report concerns related to unethical or non-compliant behavior. The Company ensures that all reports are handled confidentially and fairly. A strict non-retaliation policy protects individuals who report in good faith, reinforcing trust in the reporting system.

Disciplinary Action

Violations of this policy are taken seriously and may result in disciplinary actions, including warnings, suspension, or termination. In severe cases, legal action may be pursued. These measures ensure accountability and reinforce the importance of adhering to ethical and compliance standards.

Policy Review

The Company periodically reviews and updates this policy to ensure alignment with changing legal, regulatory, and business environments. Continuous evaluation helps maintain the relevance and effectiveness of the Ethics & Compliance Program and supports ongoing improvement.

Acknowledgment

All employees and stakeholders are required to read, understand, and comply with this policy. Formal acknowledgment ensures awareness and commitment to ethical standards. Adherence to this policy is essential for maintaining the Company’s integrity and reputation.