Code of Ethical Business Conduct

Code of Ethical Business Conduct
Tech Mahindra
-Anusha T and Abu Talha
Tech Mahindra represents the connected world, offering innovative and customer-centric
information technology experiences, enabling Enterprises, Associates and the Society to Rise™.
We are a USD 4.9 billion company with 131,500+ professionals across 90 countries, helping
946 global customers including Fortune 500 companies. Our convergent, digital, design
experiences, innovation platforms and reusable assets connect across a number of technologies to
deliver tangible business value and experiences to our stakeholders. Tech Mahindra is the highest
ranked Non-U.S. company in the Forbes Global Digital 100 list (2018) and in the Forbes Fab 50
companies in Asia (2018).
This specifies the code of ethical business conduct of Tech Mahindra and its subsidiaries
TRAINING AND CERTIFICATION
Tech Mahindra‘s training Program for Code of Ethical Business and Conduct (CEBC) and Policy
on Prevention of Sexual Harassment is intended to give associates the understanding and
awareness required to carry out their responsibilities in compliance with legislation and
regulations.
All associates are required to complete training and mandates as assigned acknowledging that they
have read, understood and comply with CEBC Policy. Reporting Managers are responsible for
ensuring that associates who report to them, directly or indirectly, comply with this policy and
complete certification and training required of them.
All associates are required to clear an assessment test within 30 days of commencement of their
employment and whenever considered necessary (for example after significant changes to
content). Associate will receive communication about the mandate along with instructions and
deadlines
Action in the event of non-completion of mandatory certification:-
Timelines Action
1. Beyond 30 days E-mail warning
2. Beyond 60 days Warning letter + InCit record in Ide@s
3. Beyond 90 days De-allocation from project / assignment
(POSH) Disciplinary action including - Suspension / Termination (CEBC)
ACTING WITH INTEGRITY
It is the company policy to conduct all of their business in an honest and ethical manner. We take
a zero-tolerance approach to bribery and corruption and are committed to acting professionally,
fairly and with integrity in all our business dealings and relationships, wherever we operate, and
to implementing and enforcing effective systems to counter bribery
LEGAL, HONEST AND ETHICAL CONDUCT
The Directors and Associates are required to conduct their duties legally, honestly and ethically
while acting for and on behalf of Tech Mahindra or in connection with its business or operations.
They shall:
 Act in the best interests of, and fulfil their fiduciary duties to the stakeholders of the
company;
 Act honestly, fairly, ethically, with integrity and loyalty;
 Conduct themselves in a professional, courteous and respectful manner;
 Act in good faith, with responsibility, due care, competence, diligence and independence;
 Act in a manner to enhance and maintain the reputation of the company;
 Treat their colleagues with dignity and shall not harass any of them in any manner.
NON ALLIANCE WITH POLITICAL PARTIES

 Tech Mahindra as a company complies with the applicable laws and the governance
systems of the country in which it operates.
 The company is committed, not to campaign for, support and offer any funds or property
as a donation or otherwise to any political party or to any independent candidate for the
political office. The company strives to preclude any activity or conduct which could be
interpreted as a favor to and from any political party or person.
 The Company does not make contributions to political parties which are so made to
influence any decision or gain a business advantage. The Company only makes donations
that are legal and ethical under local laws and practices.
SUSPECTED FRAUDULENT BEHAVIOR
Any acts of commission or omission which are detrimental to the business of the company i.e.,
bribery, corruption, fraud, pilferage, theft etc., will be termed as misconduct. Any such suspected
fraudulent behavior is liable to be investigated as per process laid down and defined by the
CORPORATE OMBUDSMAN and the Associate/s concerned is / are liable to face appropriate
disciplinary action including termination from the services of the company which may extend to
legal action.

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Code of Ethical Business Conduct

TRAINING AND CERTIFICATION

(POSH) Disciplinary action including - Suspension / Termination (CEBC)

ACTING WITH INTEGRITY

LEGAL, HONEST AND ETHICAL CONDUCT

 Act honestly, fairly, ethically, with integrity and loyalty;

 Conduct themselves in a professional, courteous and respectful manner;

 Act in a manner to enhance and maintain the reputation of the company;

NON ALLIANCE WITH POLITICAL PARTIES

SUSPECTED FRAUDULENT BEHAVIOR

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