Global Business Conduct

1. CAGlobal Global Business Conduct Policy

1.1 Purpose and Scope

This Business Conduct Policy sets out how CAGlobal and all associated firms, partners, employees, contractors, interns and advisors (“CAGlobal People”) are expected to behave in all professional activities. It applies to:

All CAGlobal entities and network firms in India and overseas.
All services (audit‑adjacent, risk, advisory, tax, technology, ESG and related services).
All interactions with clients, regulators, vendors, alliance partners and the public.

Local addenda may refine requirements to reflect jurisdiction‑specific laws (e.g., Indian law, GDPR, other data/privacy laws) but must meet or exceed this global baseline.

1.2 Our Values and Expected Behaviours

CAGlobal is built on Indian ethics and global standards. Our core values are:

Integrity first: We are honest, transparent and reliable; we do what we say.
Outstanding value to clients and markets: We aim for quality work that stands scrutiny by regulators, investors and the public.
Respect and inclusion: We treat everyone with dignity, free from harassment, discrimination or retaliation.
Accountability and stewardship: We take responsibility for our actions and for safeguarding client and firm assets.

All CAGlobal People are expected to:

Comply with applicable laws, professional standards and this Policy at all times.
Exercise professional scepticism and good judgment.
Speak up and report concerns about misconduct in good faith.

1.3 Compliance with Laws and Professional Standards

CAGlobal will comply with:

Applicable national and local laws (e.g., Indian Companies Act, SEBI regulations, RERA, tax laws, data‑protection laws).
Professional standards issued by ICAI, ICSI, ICoAI and other regulators, and relevant international standards (e.g., IFAC Code of Ethics) where applicable.
Client‑specific regulatory regimes (e.g., LODR, listing rules, sector‑specific regulations) when providing services.

Where there is a conflict between this Policy and local law, local law prevails; however, CAGlobal People must seek to uphold the highest ethical standard permissible.

1.4 Integrity, Honesty and Transparency

CAGlobal People must:

Never knowingly misrepresent facts, conceal information, or mislead clients, regulators or colleagues.
Ensure that reports, deliverables and statements are accurate, complete, and supported by appropriate evidence.
Disclose relevant limitations, assumptions and uncertainties in our work.

Fabrication or manipulation of data, time records, expenses, or deliverables is strictly prohibited.

1.5 Independence, Conflicts of Interest and Objectivity

We maintain objectivity and avoid conflicts of interest, both real and perceived:

CAGlobal People must promptly disclose personal, financial or other interests that could influence—or appear to influence—their professional judgment.
We do not allow personal relationships, investments or outside activities to compromise independence with respect to clients or assignments.
Where conflicts cannot be effectively managed (e.g., independence requirements), we will decline or withdraw from the engagement.

CAGlobal will maintain conflict‑checking processes before accepting new clients or engagements and will perform independence assessments for relevant services.

1.6 Anti‑Bribery, Anti‑Corruption and Gifts

CAGlobal has zero tolerance for bribery and corruption. CAGlobal People must not, directly or indirectly:

Offer, give, solicit or accept any bribe, improper payment, facilitation payment or other undue advantage to obtain or retain business or influence decisions.
Circumvent anti‑bribery laws via third parties, intermediaries, agents or partners.

Gifts, hospitality and entertainment must be:

Reasonable, proportionate and infrequent.
Not intended or perceived to improperly influence a decision or obtain an unfair advantage.
Compliant with applicable client policies and local law.

All high‑value or unusual gifts/hospitality must be pre‑approved and recorded under internal procedures.

1.7 Fair Treatment, Anti‑Discrimination and Anti‑Harassment

CAGlobal is committed to a workplace free from unlawful discrimination, bullying and harassment.
CAGlobal People must not:

Discriminate on grounds such as gender, caste, religion, race, ethnicity, disability, age, sexual orientation, marital status or any category protected by law.
Engage in verbal, physical, visual or online harassment, sexual harassment, or any behaviour that creates a hostile work environment.

CAGlobal will:

Provide reporting channels for harassment concerns, including anonymous options where permitted.
Investigate allegations promptly, fairly and confidentially, and take appropriate action.
Prohibit retaliation against anyone who raises concerns in good faith.

1.8 Confidentiality and Information Security

CAGlobal People must protect confidential information belonging to clients, CAGlobal or third parties:

Use confidential information only for authorised business purposes and only on a need‑to‑know basis.
Not disclose confidential information to unauthorised persons during or after employment/association.
Comply with CAGlobal’s information security, data classification, and secure‑handling standards (including use of approved tools, encryption, and secure transfer mechanisms).

Any suspected data breach, loss or unauthorised access must be reported immediately following incident‑response procedures.

1.9 Use of Firm Assets and Resources

CAGlobal assets—physical, financial, technological, intellectual property and reputation—must be used responsibly:

Use firm equipment, systems and time primarily for business purposes.
Protect assets from theft, damage, misuse, unauthorised access or disclosure.
Respect software licences and intellectual‑property rights of the firm and third parties.

1.10 Professional Quality and Documentation

We commit to high‑quality, risk‑aware service delivery:

Perform engagements in line with internal methodologies, quality standards and applicable professional guidance.
Maintain adequate documentation to support conclusions, advice and reports.
Participate in training and quality reviews; remediate findings promptly.

1.11 External Communications and Social Media

Only designated spokespersons may speak on behalf of CAGlobal to the media, investors or regulators.
CAGlobal People using social media must:

Clarify that personal views are their own, not CAGlobal’s, unless authorised.
Not disclose confidential or proprietary information.
Avoid posts that are discriminatory, defamatory or harmful to CAGlobal or its clients.

1.12 Reporting Concerns (“Speak Up”)

CAGlobal encourages open dialogue and reporting of unethical behaviour, violations of this Policy, or suspected illegal acts.
Channels may include:

Reporting to a line manager or engagement leader.
Contacting the Ethics/Compliance Officer or HR.
Using an independent ethics/whistleblower hotline or email where available.