1. Introduction

This Professional Code of Ethics & Business Conduct (“Code”) sets out the ethical standards and expected behaviour for everyone who represents PROCEKA TechSol Private Limited (“PROCEKA”, “we”, “us”), including directors, employees, consultants, empanelled professionals, freelancers, contract staff, interns, and technology partners, where applicable to their role.

2. Purpose

This Code establishes a culture of integrity, promotes ethical business conduct, protects clients and personnel, protects PROCEKA’s reputation, and provides clear principles for responsible decision-making across our business.

3. Scope

This Code applies to all business conducted in PROCEKA’s name, including client engagements, internal operations, Website use, and use of technology and AI tools in the course of PROCEKA business.

4. Definitions

“Personnel” means directors, employees, consultants, empanelled professionals, freelancers, contract staff, and interns engaged by PROCEKA. “Conflict of Interest” means a situation where personal interest could improperly influence, or appear to influence, professional judgement exercised on PROCEKA’s or a client’s behalf.

5. Mission & Ethical Commitment

PROCEKA exists to provide integrated, trustworthy business advisory and technology services. We believe ethical conduct is not separate from good business — it is the foundation of the trust our clients place in us, and we expect everyone connected with PROCEKA to share this commitment.

6. Core Values

Our conduct is guided by Integrity, Honesty, Professional Competence, Due Care, Accountability, Transparency, Confidentiality, Respect, Fairness, Inclusiveness, Innovation, Continuous Learning, a Client-Centric Approach, Compliance with Law, Professional Independence, Responsible Technology Use, and Environmental & Social Responsibility, each reflected in the sections that follow.

7. Professional Integrity

Personnel are expected to act honestly and consistently, keep commitments made to clients and colleagues, and avoid conduct that would reasonably be seen as dishonest or misleading, even where not strictly prohibited by law.

8. Honest Communication

Communications with clients, colleagues, and the public must be accurate and not misleading. Personnel must not overstate PROCEKA’s capabilities, guarantee outcomes that cannot genuinely be guaranteed, or misrepresent the nature of our services.

9. Compliance with Laws

Personnel must comply with applicable laws and regulations relevant to their role, including the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and applicable professional, tax, and corporate law obligations. Compliance with this Code complements, and does not replace, compliance with the law.

10. Client Confidentiality

Personnel must protect client confidentiality at all times, using confidential information only for legitimate business purposes connected with the relevant engagement, consistent with Section 20 of our Service Engagement Terms & Conditions.

11. Data Protection

Personnel handling personal information must do so in accordance with our Privacy Policy and applicable data protection law, using personal information only for the purpose it was collected.

12. Information Security

Personnel must follow applicable information security practices described in our Information Security Policy, including protecting access credentials, exercising care with confidential information, and reporting suspected security incidents promptly.

13. Professional Competence

Personnel must provide services within their genuine competence, exercise independent professional judgement where required, seek appropriate support or escalation where a matter exceeds their expertise, and maintain their professional knowledge on an ongoing basis.

14. Conflict of Interest

Personnel must promptly disclose any actual or potential conflict of interest to appropriate management, and must not allow personal interest to improperly influence professional judgement exercised on PROCEKA’s or a client’s behalf, consistent with Section 35 of our Service Engagement Terms & Conditions.

15. Gifts & Hospitality

Personnel may accept modest, reasonable gifts or hospitality connected with normal business courtesy, but must never accept anything that could improperly influence, or appear to improperly influence, a business decision. Any gift or hospitality of significant value should be disclosed to management.

16. Anti-Bribery

Personnel must not offer, give, solicit, or accept a bribe or improper payment, in any form, to obtain or retain business or secure an improper advantage. This applies to dealings with clients, government officials, and any other third party.

17. Anti-Corruption

PROCEKA is committed to conducting business with integrity and does not tolerate corrupt practices, including facilitation payments made to expedite a routine government action. While no organisation can guarantee the complete prevention of misconduct by any individual, we maintain reporting channels described in Section 30 to identify and address concerns.

18. Fair Competition

Personnel must compete fairly and lawfully, and must not engage in misleading comparisons with competitors, misappropriate a competitor’s confidential information, or engage in unlawful anti-competitive conduct.

19. Responsible Financial Practices

Personnel involved in financial matters, whether PROCEKA’s own accounts or client engagements, must maintain accurate records and must not knowingly participate in fraudulent or misleading financial reporting.

20. Responsible AI & Technology Use

Where personnel use AI or other technology tools in the course of PROCEKA business, they must do so in accordance with our AI Usage & Responsible AI Policy and Acceptable Use Policy. AI should support, not replace, professional judgement, and personnel remain accountable for work product regardless of the tools used to help prepare it.

21. Respectful Workplace

PROCEKA is committed to a workplace and business environment where personnel treat each other, clients, and third parties with respect and professionalism.

22. Equal Opportunity

PROCEKA aims to provide equal opportunity in its business dealings and engagement of personnel, without unlawful discrimination on any protected basis.

23. Anti-Harassment

Harassment of any kind, whether directed at personnel, clients, or third parties, is not tolerated. Concerns about harassment should be raised through the reporting channels described in Section 30.

24. Diversity & Inclusion

PROCEKA values diverse perspectives and aims to foster an inclusive environment where personnel and clients from different backgrounds are treated fairly and with respect.

25. Social Media Conduct

Personnel representing PROCEKA on social media or in public online forums should do so professionally, avoid disclosing confidential client or business information, and avoid statements that could reasonably be seen as speaking for PROCEKA without appropriate authorisation.

26. Public Communications

Public statements made on PROCEKA’s behalf, including Website content and marketing communications, must be accurate and consistent with this Code and our Website Terms & Conditions, avoiding exaggerated or misleading claims about our services or capabilities.

27. Protection of Company Assets

Personnel must use PROCEKA’s systems, information, and other assets responsibly and for legitimate business purposes, consistent with our Acceptable Use Policy and Information Security Policy.

28. Intellectual Property

Personnel must respect PROCEKA’s intellectual property and that of clients and third parties, consistent with our Intellectual Property, Copyright & Trademark Policy, and must not misuse or misappropriate proprietary methodologies, client deliverables, or confidential business information.

29. Whistleblower Principles

Personnel who become aware of suspected unethical, unlawful, or improper conduct are encouraged to raise the matter in good faith through the channels described in Section 30, without fear of retaliation as described in Section 32.

30. Reporting Ethical Concerns

Concerns about conduct inconsistent with this Code may be raised with management or through the process described in our Grievance Redressal & Customer Complaint Resolution Policy, and should include reasonably sufficient detail to allow the matter to be investigated.

31. Investigation Process

Reported concerns are reviewed and, where appropriate, investigated by management, with reasonable confidentiality maintained and any conflict of interest in the investigation itself addressed by involving another appropriate person, consistent with Section 26 of our Grievance Redressal & Customer Complaint Resolution Policy.

32. Non-Retaliation

PROCEKA does not tolerate retaliation against anyone who raises a good-faith concern about conduct inconsistent with this Code, even where an investigation does not substantiate the concern.

33. Consequences of Misconduct

Conduct inconsistent with this Code is addressed through appropriate action proportionate to the nature and seriousness of the conduct, which may include corrective guidance, formal action, or, for engaged professionals, freelancers, or contractors, review of the engagement itself.

34. Continuous Improvement

We treat this Code as a living document, and expect our ethical standards and governance practices to evolve as our business, technology, and the regulatory environment develop, including as we introduce future AI-enabled services, a SaaS platform, or a marketplace.

35. Annual Review

This Code is intended to be reviewed at least annually, and updated as necessary to remain consistent with our values, applicable law, and the evolving nature of our business.

36. Contact Information

PROCEKA TechSol Private Limited
Rajabandha, Ghatgaon, Keonjhar, Odisha, India
Email: info@proceka.com
Phone: +91 91785 66135

37. Effective Date

This Professional Code of Ethics & Business Conduct is effective as of 24 July 2026.