BUSINESS PARTNER CODE OF CONDUCT POLICY

Objective

Sage conducts its business based on key principle of integrity. We expect our business partners to do the same. This Code acts as a reference for our business partners on what to do, how to do and, importantly, what not to do. The Code acts as a guiding principle but cannot envisage every situation or action; neither can it cover every regulation and law that is applicable to individuals and/or organizations at a given time. Moreover, in the modern connected and digital world, new issues emerge, and it is up to every individual and/or organization to exercise their judgment before taking action on a matter. When in doubt, please seek necessary advice to protect your reputation and integrity and that of Sage.

Principles

• Compliance with laws and regulations
• Ethical conduct of business
• Avoiding conflict of interest
• Treating others with respect and dignity
• Employment relationships
• Sub-contractor compliance with the Code
• Protecting personal data
• Intellectual property and confidential information
• Preventing fraud and money laundering
• Maintaining record

Understanding of Principles

Compliance with laws and regulations: Our business partners are expected to comply with all laws and regulations applicable to the business they conduct for Sage. They are expected to apply the principles laid down in this Code or apply equivalent principles. By signing a contract with Sage, business partners are deemed to have agreed to this Code.

Ethical business conduct: We expect our partners to conduct business fairly and with integrity. They will not make, offer, or authorize bribes, ethical sourcing of raw material or conduct any form of unethical business practice. Our partners do not offer Sage employees gifts or entertainment, cash, or cash equivalents.

Avoid conflict of interest: Decisions our partners’ employees take in regard to Sage business transactions may not be influenced by personal or private interests. If a business partner is related to or has an intimate relationship with a Sage employee, our partners must disclose this fact to Sage or encourage the concerned Sage employee to make the disclosure.

Respect and dignity: The people our partners deal with must be treated with dignity and respect. Our business partners do not discriminate on any ground whatsoever including religion, caste, color, or gender nor do they harass any person, whether sexually or otherwise. They adhere to laws against harassment and discrimination, including the POSH Act.

Employment relationships: The business partner’s employees hired and retained should be suitable for the job and have the requisite expertise. People shall not be employed against their will, transported for exploitation, engaged in slavery or servitude, nor deprived of their rights. Legal minimum age requirements as outlined in the law are adhered to and children under the age of 16 are not employed. Employees should be paid fairly.

Subcontractor compliance: Any party our partners engage on behalf of Sage or to perform work for the benefit of Sage will be made aware of the principles in this Code and will be held to act in accordance with them.

Personal data: Our partners take appropriate security measures to protect the personal data of Sage employees wherever located and use this data for legitimate and authorized business purposes only. They must be clear on when and how they collect, use, or share personal data.

IP, confidential information and Sage property: We expect our partners to respect intellectual property rights, including those of Sage. There must be appropriate measures to prevent disclosure or unauthorized use of Sage confidential information made available to them. This includes non-solicitation of Sage clients or business without permission. Our partners must use Sage assets for defined purposes only and report any/all security breaches.

Preventing money laundering and fraud: Our partners must have internal controls designed to detect, prevent, and respond to money laundering and fraud. Transactions must be properly recorded and subject to review. Any potential fraud that may have an impact on Sage must be reported to us immediately.

Maintain records: We expect our partners to keep accurate, complete, and up-to-date records on their transactions with Sage. These records must be shared with Sage whenever requested and retained in accordance with applicable laws.

Implementation

Business partner will have to give Sage a signed undertaking for exercising the afore-mentioned principles.

(Business Partner Code of conduct Policy | Policy Owner: Finance Department | Next Review: May 2024)