CODE OF CONDUCT FOR THE EMPLOYEES OF FOCUS COMPUTERS

1-Preamble

It has been said that the essence of a successful and visionary company is the ability to preserve its core values and to stimulate progress. Since inception, FOCUS has been trying to do both. Organizational excellence, cutting edge technology, and nation wide customer relationships have driven our remarkable success. As a measure to strengthen our organization, we have decided to introduce code of conduct to the employees of us.

2. Introduction

The Code of Conduct is a statement reinforcing the principles of good conduct and the
Standards of behaviour, which the employees of Focus Computers Private Limited demonstrate in the performance of their duties and functions.

The customers expect, and has a right to demand, that employees maintain a high standard of
ethical conduct. Maintaining the trust of the customer means properly using Company’s resources, information and powers.

Although the code is not required by Law, the Company strongly believes in the need for a code of conduct for the employees. As it is a prerequisite for the successful organization and management of the Company, the code of conduct has been formed in consultation with concerned and appropriate organizations and individuals including the employees of Focus Computers.

Employees are required to comply with the provisions of the code.

3. Purpose

The purpose of this Code of Conduct is to outline the minimum standard of conduct expected of all employees (staff) of Focus Computers Pvt. Ltd. It is recognized that it is not always clear what might be the right thing or wrong thing to do in a given situation. An action that may offend one's personal ethics may be quite legal while another action that seems quite innocent may, in fact, violate another.

The Code of Conduct is only a guide and should be viewed as the minimum standard to be followed by all employees (staff) of Focus Computers Pvt. Ltd. All Personnel are responsible for reading, understanding and acting in compliance with this Code of Conduct.

4. Scope

This code of conduct applies to all staff (employees) of Focus Computers Private Limited and its subsidiaries and undertakings.

5. Statement of principles

. Always act with honesty, good faith, reasonable care and diligence while performing duties.

. Perform duties with professionalism, integrity and efficiency.

. Protect company's confidential information, trade secrets, and other important data.

. Take responsibility for the words and action or conduct.

. Show compassion in relationships with fellow employees, customers, and the public.

. Be conscientious and responsible in the performance of duties and functions and in the use of company information, equipment and facilities.

. Treat fairly and demonstrate impartiality to fellow employees, customers, suppliers, and shareholders, through adherence to all applicable laws, regulations and a high standard of behavior.

. Respect fellow employees, customers, suppliers, and shareholders, while showing willingness to solicit their opinions and value their feedback

. Exercise courtesy, and consideration in dealings with fellow employees, suppliers, customers, contractors, and the public.

. Conduct in a manner that generates customer trust and confidence in professional capacity, and enhances the role and image of the company

. Manage and conduct the day-to-day operations with a focus on service to the customers

. Work cooperatively with team spirit as a member of a team to achieve company's goals.

. Act within the employee's level of authority and delegation and comply with lawful and reasonable direction from a more senior employee in work matters.

. Take reasonable care to protect own health and safety and that of others.

. Dress appropriately for the work being done. Where it is provided, the corporate uniform is to be worn in the manner prescribed.

. Avoid real or perceived conflicts of interest.

. Avoid acts and conduct that slow down efficiency and productivity of the company at large.

. Refrain from acts, conduct, or behaviour that may bring disrepute to the company or an employee.

. Maintain a safe and healthy environment, free from harassment, intimidation, bullying, substance abuse, and/or violence, and free from bias and discrimination.

. Abstain from making sexual remarks, sexual advances, requests for sexual favors, and sexual jokes to fellow employees.

. Help to create a culture of caring through understanding and support.

. Refrain from making misleading, deceptive, or untrue statements in relation to the Company or employees.

. Refrain from any act, conduct, or attitude that may hinder smooth and successful operations of the company.

. Immediately intervene in any code of conduct violation, that has a negative impact on employees or the customers, in a manner that preserves confidentiality and the dignity of the concerned person.

. Demonstrate responsible citizenship by maintaining a high standard of conduct, self-control, and ethical behavior.

6. Abide by the Code of conduct

An employee has an obligation, at all times, to comply with the spirit, as well as the letter, of the law and with the principles of this Code.

7. Violation of Code of Conduct

Appropriate disciplinary measures will be taken against those employee who violate code of conduct. The disciplinary measures may include counseling, advice, warning, fine, suspension, or even termination of service at Focus Computers.