Personal Conduct

Section III. 1 Confidentiality Policy During the course of employment at “X”, employees come across information related to the trade in methods, processes or strategy which is key to the business. Our clients also entrust us with a lot of important and confidential information. It is an integral part of our role as brand custodians to respect the confidentiality of this information and ensure that we safeguard it against all possible leaks.

Therefore employees are required to sign a Confidentiality Code of Conduct, where they commit to not disclose, divulge or communicate to any person any confidential information pertaining to the organization, subsidiary, or client of the Company. “X” reserves its right to initiate appropriate civil and legal proceedings against any employees for a breach of these terms and conditions. Section III. 2 Professional Standards and Business Conduct “X” assumes that those associated with the organization will conduct themselves ethically and in accordance with standard business practices.

Each employee should be familiar with the policies and procedural guidelines that cover the business activities that are his/her responsibility. Legal and Ethical Conduct Under no circumstances will any payment, or promise to pay, gift or anything else of value be accepted from or given to customers, vendors, consultants, etc. if it is perceived as directly or indirectly influencing any business decision, or commitment of fraud. Gifts Gifts given by the Company to, or received from suppliers or customers should always be appropriate to the circumstances and should never be of a kind that amounts to impropriety.

Conflicts of Interest All employees have an obligation to act in the best interest of the Company. Conflicts of interest may arise when an individual’s personal or family interests conflict with those of the Company hence conflicts of interests are prohibited. The purpose of this policy is to ensure & protect both the Company and its employees from any actual or perceived impropriety. Dress Code Since employees are representing the company, they must report to work properly groomed and wearing appropriate clothing.

* Section III. 3 Corporate Communication & Commitments With the exception of the Management Committee, no employee is permitted to share any information or speak to the media on official matters concerning the agency, its clients and its business. Any formal or informal attempts by the media to seek information about the company, its business, its clients, its plans or any other operational matters, must be referred to the Director concerned without making any statements whatsoever. * Section III.

4 Prohibition of smoking and Substance Abuse “X” seeks to maintain a work environment that is safe and healthy for all employees and conducive to high work standards. In accordance with this, the Company complies with all pertinent regulations regarding smoking, drug and alcohol abuse in the workplace. All employees have the right to work in a smoke-free atmosphere. Consequently, smoking / consumption of any tobacco products is not permitted in open areas of the office – including the washrooms, office passages and open spaces.

Smoking may be permitted if you have a closed office or during any business meetings, if fellow colleagues are not discomfited. This applies to all guests and business associates visiting our offices. Any employee involved in the unlawful use, sale, manufacturing, dispensing or possession of controlled substances, illicit drugs and alcohol on Company premises or work sites, or working under the influence of such substances, will be subject to disciplinary action up to and including dismissal and referral for prosecution.