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B2. Code Of Conduct & Ethics, Whistleblower, POSH

Effective Date: October 1, 2025  |  Last Updated: October 1, 2025

A. Why We Have a Code

‘Etthnovistta’ is a retail and e-commerce brand—aided by SCM and technology. We are constantly changing. We make many decisions every day, and the right thing to do isn’t always clear. Our Code can help us make decisions that earn and build trust. It tells us about the behaviors we expect of each other and where to get more information or support. Our Code focuses on behaviors that:

• Build trust with our staff
• Build trust with our partners, sellers and suppliers
• Build trust with our customers
• Build trust in our business

Our Code reinforces that we are committed to complying with the laws and regulations in all locations where we operate. If you believe our Code conflicts with local law, contact our Legal department for guidance on what to do. Hereinafter ‘Etthnovistta’ and ‘Earthifactz Artizanz Pvt, Ltd.’ shall be referred to as ‘the company / brand’

When in doubt—reach out.

If you have questions or concerns, let your Manager, HR, or Ethics & Compliance know.

 

B. Who is Covered by Our Code

Our Code applies to all Members (employees , associates,  trainees, retainers, advisors, mentors and contractors). It also applies to board members when they are acting in their capacity as our directors.

The content of our Code of Conduct may be modified as we change and face new issues.

We expect our Partners (sellers, suppliers, vendors, service providers, and other business partners) to act with integrity and honor our values. Specific requirements for these third parties are included in the Standards for Suppliers and/or in our contracts with them.

Members and Partners who violate our Code may be subject to discipline, up to and including termination / exclusion. In rare cases, it might be appropriate to waive a part of our Code. When a waiver is sought, only the Board of Directors of ‘Earthifactz Artizanz Pvt, Ltd.’ (or a committee of the Board) may grant them, and they will be publicly disclosed when required by law.

C. Recognize and Avoid Conflicts of Interest

Fair and objective decisions build trust with our employees, customers, and third parties. When making business decisions, we put Etthnovistta’s interests before personal interests.

A conflict of interest occurs when personal interests interfere with, or may appear to interfere with, our work at ‘Etthnovistta’. While we can’t list every circumstance, it’s important to know and avoid the common situations that could create a conflict or the perception of a conflict.

Outside employment, financial investments, gifts and entertainment, and personal relationships are areas where conflicts can arise. If you realize an activity or situation could influence or appear to influence your ability to make objective business decisions, let your manager, HR, or Ethics & Compliance know. They can help you take steps to avoid or resolve a conflict.

• Outside Employment and Business Interests
  • Do not work for a competitor while you are associated with the company / brand. Discuss with your managers to determine if a conflict exists before accepting employment with a competitor or other employer, even if it is pro-bono.
  • Do not use your role in the company to promote your side business. Your side business cannot interfere with your work at the company, use our resources, supply products or service to/on ‘Etthnovistta’, supply products to any current or potential Supplier with whom you have a business relationship or influence, compete with the company / brand, or reflect negatively on the company / brand.
  • Your agreement of association with the company / brand may have additional restrictions or policies prohibiting you from working for another employer or operating a side business. Consult Ethics & Compliance if you have any questions regarding how this may apply to you.
  • While working for the company / brand , you may identify a business or investment opportunity that the company / brand may have an interest in pursuing. Do not take opportunities for yourself that you discover through your position or the use of the company / brand’s property or information. These are considered confidential corporate opportunities and they belong to the company / brand unless the company / brand determines not to pursue them.

• Financial Investments
  • Do not invest in a supplier of the company / brand if you can influence the company / brand’s relationship with that supplier.
  • Do not have a substantial interest (for example, stock ownership) in a competitor. Consult the Global Conflicts of Interest Policy for specific restrictions.

• Gifts and Entertainment
  • Decline gifts and entertainment from a supplier if you work with or could work with that supplier in your role. Asking / Demanding / Accepting any benefit from suppliers that we work with can cause a conflict. Persons demanding / accepting gifts will be terminated without pay.
  • Explain our policy on gifts and entertainment to new suppliers. Customs may differ in the countries where we work, but our policy on gifts and entertainment applies everywhere we do business.
  • Decline gifts and entertainment from any government official.
  • We often sample or test merchandise to help us better understand a product or business we may want to purchase. This is not a conflict so long as we reasonably limit sampling. Follow your local policy regarding sampling and testing products.

• Supplier Relationships
  • If a close personal friend, family member, or romantic partner works for a supplier over which you have influence, disclose it to your Manager, HR, or Ethics & Compliance to get advice on managing the potential conflict.
  • Before participating in the selection of a supplier which employs your family member, close personal friend, or romantic partner, disclose the relationship to your Manager, HR, or Ethics & Compliance to get advice on how to manage the potential conflict.
• Employee Relationships
• Family
  • Do not supervise or be directly involved in the hiring of a family member. Do not influence the conditions of employment (for example, pay, work hours, or job responsibilities) or performance rating of any family member. While it is generally avoided, in certain rare circumstances, the company allows family members to work in the same reporting chain if there is enough separation. If you learn that a family member is being considered for employment or is hired into your reporting chain, you should disclose this to your Manager, HR, or Ethics & Compliance.
    • A family member is any relative (spouse, child, parent, sibling, grandparent, or grandchild) by birth, adoption, marriage, domestic partnership, or civil union as well as any member of your immediate household, regardless of whether you are related.
  • Romantic
    • Do not have a romantic relationship with another Member (employee, associate, intern/trainee, retainer, contractor) or Partner (vendor, supplier, seller) especially if the Member or Partner is in your chain of command or you have influence over the conditions of association ,or performance , or financial outcome. If someone with whom you already have a romantic relationship comes under your supervision due to a change in organizational structure, you should immediately disclose the relationship to your Manager, HR, or Ethics & Compliance.
      • A romantic partner is someone you are dating or with whom you have a sexual relationship.

• Can Friendships cause a conflict in interest ?
  • Yes, if the depth of your close personal friendship impacts your ability to make objective decisions. A close personal friendship is not simply participating in some of the same community activities. Attending the same house of worship, having children on the same sports team, or being in the same neighborhood association would not by itself make you close personal friends. It can be difficult to determine on your own whether a close personal friendship could impact your objectivity.
  • Talk with your Manager, HR, or Ethics & Compliance about how to best manage the business situation if a close personal friend is involved.

D. Respect Each Other

‘Etthnovistta’ does not tolerate discrimination or harassment based on an individual’s :

• Race • Color • Ancestry • Ethnicity • Religion • Sex • Pregnancy • National Origin • Age • Disability • Marital Status • Veteran Status • Military Status • Genetic Information • Sexual Orientation • Gender Identity or Expression • Any Other Legally Protected Status

We comply with all laws in the countries in which we operate.

Respecting individuals starts with valuing diversity and inclusion. We believe having employees with different backgrounds, styles, experiences, identities, and opinions makes us a better company. Inclusion is an intentional act—it is investing time and energy to understand, support, and champion the uniqueness of individuals. Diversity and inclusion promote individual expression, creativity, innovation, and achievement—and help us better understand and serve our customers. We are committed to a workplace that is free of harassment and discrimination. We do not tolerate any behavior that diminishes the dignity of a person, inappropriately or unreasonably interferes with work performance, or creates an intimidating, hostile, or otherwise offensive work environment based on an individual’s protected status. We also do not tolerate retaliation against anyone who raises a concern about harassment or discrimination.

E. Speak Without Fear of Retaliation | Whistleblower

‘Etthnovistta’ does not tolerate retaliation for reporting a concern or participating in an investigation. Any Member or Partner who engages in retaliation will be subject to disciplinary action. If you feel that you have been retaliated against for reporting a concern contact HR or Ethics & Compliance. We know it takes courage to come forward and share your concerns. Discouraging employees from reporting an ethics concern is prohibited and could result in disciplinary action. When we speak out against things that are wrong, we uphold our values and Code. Reporting an issue in good faith will not get you in trouble, even if you make an honest mistake. Knowingly reporting false information is contrary to our values and will be subject to disciplinary action. We appropriately investigate reports of misconduct. We share information only on a need-to-know basis. If you are asked to participate in an investigation, give honest and complete answers

E.1. When to Speak Up

Building trust requires we do the right thing and speak up if we have questions or concerns. If you don’t know the right thing to do, ask for advice from your Manager, HR, or Ethics & Compliance. Ethics & Compliance can provide you with an opinion on the right action to take. Make your voice heard and get the answers you need. If you see, suspect, or are told about activity that violates our Code, compliance policies, the Standards for Suppliers, or the law, you must report it. Looking the other way or letting someone else take the lead may seem easier, but unethical or unlawful behavior hurts us all. It erodes trust. Report your concerns and cooperate fully and honestly in all internal investigations.

E.2. How to Speak Up

Most concerns can be reported to your Manager, HR, Ethics & Compliance, or Legal. However, if your concern is about one of the following, it must be immediately reported directly to Ethics & Compliance via the Ethics Helpline at 9810278284, contact@earthifactz.com :

• Bribery (including any suspected violation of our Anti-Corruption Compliance Policy)
• A company officer or direct report to any company CEO potentially violating our Code
• Falsifying financial records or interfering with our internal controls on accurate financial reporting

F. Do what is Right

Our Members and Partners are the key to our success and we will take good care of our customers and communities.

• Make Ethical Decisions : We build trust when we make decisions consistent with our values and take responsibility for our actions. Being ethical means doing the right thing even when no one’s watching.
• Create a Safe Place to Work and Shop : Making the company / brand a safe place to work and shop builds trust with our members, partners and customers—and it’s the right thing to do. If you see something that could put someone’s health or safety at risk, report it immediately and take action to keep yourself and others safe.
• Protect Our Property : Taking care of the company / brand’s property helps us achieve our business objectives. Our property— including hardware, software, merchandise, tools, furniture, vehicles, and office supplies—is provided so you can do your job so that we can succeed as a business. We are trusted to use company/brand property properly and protect it against loss, theft, misuse, damage, or waste. The company can recover from Members or Partners the appropriate value of property lost due to gross negligence.
• Use Data and Technology Respectfully and Ethically : When our customers, members, and business partners share data and information with us, we understand the importance of keeping it safe and using it—and technology—ethically in ways they expect. We will maintain and grow the trust people have in us by respectfully using technology, respecting individuals’ privacy, and protecting their data.
• Prevent Money Laundering and Consumer Fraud : We offer products and services, including bill pay and the use of gift cards, credit cards etc. Most customers perform transactions with good intent, but some criminals attempt to use our services for money laundering or to victimize customers. Preventing money laundering and consumer fraud protects our customers and company, and may stop serious crimes.
• Keep Accurate Records: Keeping honest and accurate financial records builds trust in our brand, informs our strategy, and helps operations run efficiently. We all share this responsibility.
• Never Engage in Bribery : We compete fairly and honestly everywhere we do business around the world. We never attempt to gain a business advantage through bribery, and we do not tolerate bribery or corruption in any form.
• Protect the Environment : We care about our communities, and we all have a role to play in protecting the environment. Designing our facilities and operating our business responsibly and consistent with environmental obligations helps us sustain our resources and care for our planet. It’s not only what we do, but how we do it that makes the difference.

G. Prevention of Sexual Harassment | POSH

The Prevention of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 was enacted to provide a safe, secure, and harassment-free workplace for women. It legally defines sexual harassment, mandates preventive measures, and prescribes a redressal mechanism.

Zero Tolerance Policy on Sexual Harassment

• At ‘Earthifactz Artizanz Pvt, Ltd.’ / ‘Etthnovistta’, we are fully committed to providing a safe, respectful, and inclusive workplace and business environment for everyone we engage with — including employees, contractors, vendors, suppliers, sellers, partners, and visitors.
• We maintain a zero-tolerance stance against any form of sexual harassment. This applies inside the workplace and across all business interactions conducted through our offices, digital platforms, or partner networks.
• What This Means
  • No form of sexual harassment will be tolerated — whether verbal, physical, visual, or digital.
  • The prohibition covers:
  • Employees at all levels (management, staff, contract, interns).
  • Third parties (vendors, suppliers, sellers, delivery partners, consultants, and customers).
  • Workplace-linked events, travel, or communication channels.
• Reporting & Action
  • Any incident of harassment can be reported confidentially to the Internal Committee (IC) or designated Grievance Officer.
  • Complaints will be handled promptly, fairly, and in line with the POSH Act, 2013.
  • Proven cases will result in strict disciplinary action, which may include:
  • Termination of employment.
  • Suspension or blacklisting of vendors/suppliers/sellers.
  • Reporting to law enforcement where necessary.
• Non-Retaliation
  • We strictly prohibit victimisation or retaliation against anyone who raises a complaint or supports an inquiry.

A brief overview of the POSH Policy is as indicated below :

G.1. Scope & Applicability

Applies to all workplaces in India (corporates, startups, government, NGOs, hospitals, schools, etc.).

Covers all women employees: permanent, temporary, interns, contract workers, visitors.

Covers harassment by anyone at the workplace (colleagues, managers, vendors, clients).

G.2. Definition of Sexual Harassment

Sexual Harassment includes:

• Unwelcome physical contact or advances.
• Demand/ request for sexual favours.
• Sexually coloured remarks.
• Showing pornography.
• Any other unwelcome physical, verbal, or non-verbal conduct of sexual nature.
• It also covers hostile work environment, quid pro quo, and intimidation.

G.3. Internal Committee (IC)

• Formed in every organization with 10+ employees.
• Headed by a senior woman employee.
• Includes 2 employees + 1 external member (expert).
• As of now , you may reach out to contact@earthifactz.com , 9810278284

G.4. Complaint & Redressal Process

• Step 1: Filing a Complaint
  • Complaint must be filed within 3 months of the incident (extendable to 6 months if justified).
  • Must be in writing to the Internal Committee.
• Step 2: Conciliation (Optional)
  • The complainant may request conciliation (no monetary settlement allowed).
• Step 3: Inquiry by Internal Committee
  • Notice issued to the respondent.
  • Both parties heard; witnesses and evidence examined.
  • Proceedings to be completed within 90 days.
• Step 4: Report & Recommendations
  • IC submits findings to the employer within 10 days.
  • Recommendations may include:
  • Warning or written apology.
  • Transfer or suspension of the respondent.
  • Deduction from salary for compensation.
  • Termination in severe cases.
• Step 5: Implementation
  • Employer must act within 60 days of receiving the IC’s report.
• Step 6: Appeal
  • Either party may appeal within 90 days to the appropriate authority/court.