Workplace harassment is a prohibited form of discrimination under this policy and can include harassment based on an individual’s sex, race, religion, national origin, sexual orientation, disability, age, etc. Such harassment can take many forms and includes unwelcome verbal or physical conduct directed against a fellow employee or third party (e.g., customer or supplier) such as distributing or posting (electronically or otherwise) hate literature, making fun of or defaming a member of a particular religion, race, sex, etc., through use of inappropriate stereo types, telling offensive jokes, use of ethnic slurs or taking other actions which have the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment.

Sexual Harassment is a specific form of workplace harassment which includes unwelcome sexual advances or requests for sexual favors where submission or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual. Sexual harassment also includes unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature or based on a person’s sex where such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.
All personnel who are responsible for hiring and promoting employees are strongly asked to support this effort and to respond promptly and appropriately to any concerns that are brought to their attention.
All managers and senior employees are strongly asked to support and educate their teams for maintaining the sanctity of this policy. It is the responsibility of each employee to strictly follow this policy without any deviations.

OUR STRONG CODE OF ETHICS
KOSO is serious about working ethically at all times. Our ethics policy sets out standards for our code of ethics. It’s essential that all employees, advisers and agents meet the highest ethical standards whenever they do business anywhere in the world. We believe that sound ethical conduct deepens trust and aids collaboration and teamwork, both within our business and in our dealings with customers.

BUSINESS INTEGRITY
KOSO insists on integrity, honesty and fairness in all aspects of business and we seek the same from those with whom we do business, directly and indirectly. No employee may directly or indirectly offer, pay, solicit or accept a bribe, or any other such payment which may be construed as such, in any form. Political donations by or on behalf of KOSO are also prohibited.

Gifts and entertainment may only be offered to any third party if they are consistent with customary business practices, modest in value and not in contravention of any applicable law. No employee should seek or accept a personal gift or entertainment that might reasonably be believed to influence commercial activity or the decision-making process. No employee should act in a manner that may bring KOSO into disrepute.

Employees must avoid private, financial or business activities (including those of immediate members of their families) that conflict with their responsibilities to KOSO.

All business transactions must be lawful, reflected accurately and fairly in KOSO’s accounts in accordance with established procedures and be subject to audit. KOSO’s accounting records will accurately reflect and describe the nature of the underlying transactions. Illegal, unfair or unethical practices are not acceptable.

OUR COMMITMENT TO STAKEHOLDERS
At KOSO, we recognize our corporate responsibility to six main groups of stakeholders. Below are our pledges to each group.

TO CUSTOMERS
To win and retain customers by developing and providing products and services that helps them to run successful businesses. To promote customer satisfaction, to be responsive to customer comments and complaints.

TO EMPLOYEES
To respect the human rights of all employees, whether directly employed or sub-contracted, consistent with the UN Universal Declaration of Human Rights. To provide and maintain safe conditions of work, with competitive terms and conditions of employment. Not to use any form of under-age or forced labour, and to act consistently with the International Labour Organization Declaration on Fundamental Principles and Rights at Work.
To promote diversity by selecting, developing and retaining employees on the basis of ability and qualifications for the work performed, without any form of discrimination or prejudice under any circumstances. To insist that harassment does not take place under any circumstances.
To encourage the involvement of employees in the planning and direction of their work.

TO SUPPLIERS AND BUSINESS PARTNERS
To seek mutually beneficial relationships with contractors, suppliers and joint-venture partners. To require that, so far as practicable, all of these adhere to business principles consistent with our own.

TO THE COMMUNITY
To conduct business as responsible corporate citizens, to observe the laws of land, to give proper regard to the health, safety and the environment of local communities, and to be sensitive to and supportive of local cultural, social, educational and economic needs.

TO SHAREHOLDERS
To build shareholder value through growth and total shareholder return. To conduct our operations in accordance with accepted principles of good corporate governance. To provide timely and accurate information on our activities and performance. To build and protect our reputation and our brand.

TO COMPETITORS
To respect the confidentiality of any competitor data that may be offered. KOSO employees should not solicit or accept any confidential competitor data. Any data received unsolicited should be destroyed. KOSO employees should never ‘bad mouth’ any competitors.

HEALTH, SAFETY AND THE ENVIRONMENT
It is KOSO’s policy to establish and manage safe and healthy working conditions for all employees. We seek effective and efficient ways to protect and enhance the environment in which we live and operate.

COMPLIANCE, MONITORING AND REPORTING
The KOSO senior management team is responsible for communicating this Ethics Code to all employees and for ensuring its contents are understood and adhered to. Day-to-day responsibility in this regard is delegated to the senior team at KOSO. Each employee is expected to make himself or herself aware of, and deal appropriately with, all significant legal, ethical and accounting considerations relevant to their work for the company.

Compliance with this Code is monitored and reviewed by the senior management team of KOSO as part of its risk management process, supported by relevant committees.

Breaches of the Code must be reported to relevant senior managers of KOSO. Breaches by an employee may be a disciplinary offence. KOSO has a ‘whistle blowing’ policy that encourages employees to report breaches of this Code and other concerns in confidence. Under this policy, KOSO will take all reasonable steps to ensure that no party suffers unjustified detriment and, equally, that no KOSO employee engages in victimization in any form.

The Code is intended to foster a search for continuous improvement in all aspects of our performance. It will therefore be reviewed annually and will be referred to in KOSO’s Annual Report as part of an ongoing improvement program.

The Purpose of this Policy

Koso India is committed to complying with the foreign and domestic laws applicable, satisfying the Company’s Code of Conduct and Ethics, and particularly to assuring that business is conducted with integrity and that the Company’s financial information is accurate. If potential violations of Company policies or applicable laws are not recognized and addressed promptly, both the Company and those working for or with the Company could face governmental investigation, prosecution, fines, and other penalties.

Consequentially, and to promote the highest ethical standards, the Company will maintain a workplace that facilitates the reporting of potential violations of Company policies and applicable laws. Employees must be able to raise concerns regarding such potential violations easily and free of any fear of retaliation. That is the purpose of this policy.
 

Your Duty to Report

Everyone is required to report to the Company any suspected violation of any law that applies to the Company and any suspected violation of the Company’s Code of Conduct and Ethics. It is important that you report all suspected violations. This includes possible accounting or financial reporting violations, bribery or violations of the anti-retaliation aspects of this Policy. Retaliation includes adverse actions, harassment or discrimination in your employment relating to your reporting of a suspected violation.

It is the policy of the Company that you must, when you reasonably suspect that a violation of an applicable law or the Company's Code of Conduct and Ethics has occurred or is occurring, report that potential violation. Reporting is crucial for early detection, proper investigation and remediation, and deterrence of violations of Company policies or applicable laws. You should not fear any negative consequences for reporting reasonably suspected violations because retaliation for reporting suspected violations is strictly prohibited by Company policy. Failure to report any reasonable belief that a violation has occurred or is occurring is itself a violation of this Policy and such failure will be addressed with appropriate disciplinary action, including possible termination of employment.
 

How to Report

You must report all suspected violations to
(i) your immediate supervisor;
(ii) the Managing Directors;

If you have reason to believe that your immediate supervisor or the Managing Director is involved in the suspected violation, your report may be made to the other official Board of Directors of the company.

Because you have several means of reporting, you need never report to someone you believe may be involved in the suspected violation or from whom you would fear retaliation. Your report should include as much information about the suspected violation as you can provide. Where possible, it should describe the nature of the suspected violation; the identities of persons involved in the suspected violation; a description of documents that relate to the suspected violation; and the time frame during which the suspected violation occurred. Where you have not reported anonymously, you may be contacted for further information.
 

Investigations after You Report

All reports under this Policy will be promptly and appropriately investigated, and all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action, in accordance with applicable law. Everyone working for or with the Company has a duty to cooperate in the investigation of reports of violations. Failure to cooperate in an investigation, or deliberately providing false information during an investigation, can be the basis for disciplinary action, including termination of employment. If, at the conclusion of its investigation, the Company determines that a violation has occurred, the Company will take effective remedial action commensurate with the nature of the offense. This action may include disciplinary action against the accused party, up to and including termination. Reasonable and necessary steps will also be taken to prevent any further violations of Company policy.
 

Retaliation is not Tolerated

No one may take any adverse action against any employee for complaining about, reporting, or participating or assisting in the investigation of, a reasonably suspected violation of any law, this Policy or the Company’s Code of Conduct and Ethics. The Company takes reports of such retaliation seriously.

Incidents of retaliation against any employee reporting a violation or participating in the investigation of a reasonably suspected violation will result in appropriate disciplinary action against anyone responsible, including possible termination of employment. Those working for or with the Company who engage in retaliation against reporting employees may also be subject to civil, criminal and administrative penalties.

Document Retention

All documents related to reporting, investigation and enforcement pursuant to this Policy shall be kept in accordance with the Company’s record retention policy.

Purpose
This policy describes KOSO’s guiding principles with respect to combating trafficking in persons.
KOSO is opposed to all forms of trafficking in persons and is committed to mitigating the risk of trafficking in persons in connection with its operations and programs. KOSO is committed to full compliance with the Government’s laws, regulations, and policies that prohibit trafficking in persons, any other regulations from other agencies and governments, as applicable. KOSO leadership understands the importance of anti-trafficking and has devoted resources to promote compliance.

Applicability
This policy applies to:
• KOSO staff and Executives, including the Board of Directors
• KOSO suppliers, sub-contractors, contractors, vendors and their employees

General Guideline
KOSO prohibits:
• Engaging in any form of human trafficking
• Engaging in commercial sex acts that may be directly associated with KOSO, which includes during work hours, while attending off-site functions, and any time in work travel status
• Using forced labor of any kind for any reason
• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity documents.
• Using misleading or fraudulent recruiting practices
• Charging employee candidates recruitment fees for employment
• Failing to pay contractually agreed return transportation costs for certain employees who have finished employment outside that employee’s nation of residence.
• Failing to provide proof of employment or similar work document in writing prior to the employee departing from his or her country of origin.

Policy Implementation
KOSO will implement this policy through:
1. Awareness of Policy and awareness training
2. Incident reporting.

Receipt of the Policy and Training
All KOSO staff will acknowledge & understanding overall Combating Trafficking in Persons Policy and accompanying resources upon hire. KOSO employees are responsible for complying with this policy as well as completing any associated training mandated as a condition of continued employment. When engaging outside parties, KOSO staff will ensure that the requirements of this policy are communicated to KOSO Vendors, independent contractors.

Incident Reporting
All KOSO staff are required to use their best judgments to report any suspected trafficking activity to HR Manager.

Enforcement
Any violations of this policy will result in disciplinary action that may include but is not limited to termination of employment for KOSO employees and termination of the relationship with KOSO for non-employees.
KOSO prohibits retaliation against any employee who reports any violation of this policy or who cooperates with any investigation of such reports. Employees who engage in any retaliation or other violation will be subject to corrective action up to and including termination of employment and reporting to local authorities as appropriate. Any supplier or supplier personnel engages in any prohibited activities, fails to report suspicious activities, or engages in retaliatory actions will be subject to action including termination of the business relationship and reporting as appropriate.