Code of Conduct

INTRODUCTION

Officers of Trustlancers Solutions Pvt Ltd. and others performing work for Trustlancers or on its behalf, collectively referred to in this code as “Trustlancers Officer”, are expected to act lawfully, honestly, ethically, and in the best interests of the company while performing duties on behalf of Trustlancers.

This code provides some guidelines for business conduct required of Trustlancers Officer. Persons who are unsure whether their conduct or the conduct of other Trustlancers Officer complies with this code should contact their manager, another Trustlancers manager or Human Resources. This code applies to all Trustlancers Officer, including members of the Board of Directors (in connection with their work for Trustlancers ), officers, and Officers of Trustlancers Solutions Pvt Ltd. and its corporate affiliates, as well as contingent workers (e.g., agency workers, contractors and consultants) and others working on Trustlancers’ behalf. This code is subject to change and may be amended, supplemented, or superseded by one or more separate policies.

CONFLICTS OF INTEREST

Trustlancers Officer is expected to use their judgment to act, at all times and in all ways, in the best interests of Trustlancers while performing their job duties. As such, Trustlancers Officer should attempt to avoid actual or apparent conflicts of interest. A conflict of interest exists when your personal interests interfere with the best interests of Trustlancers . A conflict of interest may arise from your personal relationship with a customer, supplier, vendor, competitor, business partner, or other Trustlancers Officer if that relationship impairs or may be perceived to impair your objective business judgment.

Other specific areas of potential conflict of interest such as external business relationships, serving on boards, personal investments, gifts, entertainment, corporate opportunities, and certain personal relationships with other Trustlancers Officer are discussed in more detail below.

OUTSIDE BUSINESS AND CONSULTING ENGAGEMENT

Trustlancers Officer must obtain approval from the Human Resources via the online tool prior to (1) beginning any employment, business, or consulting relationship with another company that is a current or potential competitor of Trustlancers or that otherwise has a business relationship with Trustlancers , or

(2) accepting any teaching engagements with an educational institution, establishment, or other organization. In addition, you should avoid conducting Trustlancers business with members of your family or others with whom you have a significant personal or financial relationship without the prior approval of the Conflicts Committee.

CORPORATE OPPORTUNITIES

Trustlancers Officer may not exploit or take advantage of business opportunities that are discovered through the use of Trustlancers’ property, information, or position for personal gain unless the opportunity is disclosed fully in writing to the company and Trustlancers declines to pursue such opportunity.

HARASSMENT

Trustlancers does not tolerate unlawful harassment or any mistreatment by or of workers (including individual contributors, managers, and contingent workers), guests, clients, or agency partners in the workplace or in a work-related situation on the basis of sex, race, color, nationality, ethnic or national origin, ancestry, citizenship, religion (or belief, where applicable), age, physical or mental disability, medical condition, sexual orientation, veteran status, marital status, genetic information or characteristics (or those of a family member), or any other category protected under applicable federal, state, or local law. If you suspect harassment, discrimination, or retaliation (as described in our Harassment Policy) has occurred, you are encouraged, and managers are required, to promptly provide a written or oral complaint to an HR Business Partner (HRBP).

PROTECTION OF USER DATA & OFFICER DATA

Depending on your role at Trustlancers , you may have access to information systems or tools that enable you to view certain information relating to users and other individuals (including your coworkers, as well as registered and non-registered individuals), which would otherwise not be visible to you. These tools are important and necessary to enable you to perform your work effectively. However, it is of the utmost importance that all Trustlancers Officer treat this data access with extreme sensitivity and caution.

You are only authorized to access this data to the extent it is required for you to do your job. This data is confidential and subject to privacy protections in many jurisdictions. Trustlancers  's brand and the trust users put in us depend on your responsible use of tools that allow you to view user information that would otherwise not be visible to you. Please read the User Data Access Policy, available on the wiki, which governs your use of and access to user data. In your role at Trustlancers , you will have access to information systems or tools that enable you to view personal information relating to Trustlancers Officer. These tools are important and necessary to enable you to perform your work effectively.

However, this data is confidential and subject to privacy protections in many jurisdictions. To learn about the sensitivity of different types of Officer data, and how to appropriately protect it, please refer to the Data Classification Standard and Data Handling Guidelines on the wiki.

PROTECTION AND USE OF TRUSTLANCERS ASSET

Trustlancers provides Trustlancers Officer with a wide range of valuable assets to help you perform your work on behalf of Trustlancers at the highest level. These assets include computer equipment, mobile devices, communications platforms and equipment, software, office and electronic equipment, and facilities. Trustlancers Officer are expected to treat these assets with care and use them with the interests of the business in mind and in accordance with the Information Security Policy. This means that assets should be well maintained and not subject to unreasonable use. If something you are using is damaged, please see that it gets fixed. In addition, you should use your judgment in using the company assets for personal matters.

Trustlancers’ assets are property of the company and provided for business

use. While we recognize that personal use occurs, it should not be excessive and should not interfere with the performance of your business duties.

DATA PRIVACY

Trustlancers Officer must comply with all applicable data privacy laws and legal requirements. These include laws governing the collection, access, and use of data. Anti-Corruption Trustlancers Officer must comply with all anti-corruption laws of the countries in which we do business.