1. Message and Commitment

Alomind Labs is committed to conducting business with honesty, fairness, transparency and respect. Our reputation is built on the trust of our customers, employees, partners, suppliers, investors, regulators and communities. This Code of Conduct and Code of Ethics explains how we are expected to act and make decisions every day.

Every person covered by this Code is expected to read, understand and follow it. When the right course of action is unclear, individuals should seek guidance from their manager, Human Resources, Legal/Compliance or the designated Ethics Officer.

2. Scope and Applicability

This Code applies to:

• All directors, officers, employees, consultants, interns and trainees of Alomind Labs;
• Vendors, contractors, channel partners, consultants, distributors and business partners when acting on behalf of or in connection with Alomind Labs;
• All business activities, locations, events, digital platforms, customer interactions and third-party engagements of the Company.

Where local laws, customer requirements or contractual obligations set higher standards than this Code, those higher standards must be followed.

3. Our Values and Ethical Principles

4. Code of Conduct

4.1 Professional Behavior

• Act honestly, responsibly and professionally in all Company-related activities.
• Be punctual, prepared and respectful in meetings, customer engagements and workplace interactions.
• Avoid behavior that could damage the Company's reputation or stakeholder trust.
• Use respectful language in verbal, written and digital communication.

4.2 Compliance with Policies and Instructions

• Follow Company policies, procedures, standard operating processes and lawful instructions.
• Complete assigned training and certifications where applicable.
• Maintain accurate records, reports and documentation.
• Escalate issues that may cause legal, financial, safety, quality or reputational risk.

4.3 Fair Treatment and Non-Discrimination

• Provide equal opportunity and fair treatment regardless of gender, age, caste, religion, race, disability, marital status, nationality, sexual orientation, political opinion or any other protected characteristic.
• Do not engage in bullying, harassment, intimidation, retaliation or abusive behavior.
• Respect cultural, personal and professional differences.

4.4 Quality, Customer Service and Product Responsibility

• Represent Company products and services accurately and honestly.
• Do not make false, exaggerated or misleading claims.
• Respond to customer issues with professionalism and urgency.
• Report quality, safety, compliance or service concerns promptly.

5. Code of Ethics

Ethical conduct requires more than legal compliance. It requires good judgment, fairness, transparency and responsibility. All individuals covered by this Code must make decisions that can withstand scrutiny by customers, colleagues, regulators and the public.

5.1 Ethical Decision Test

Before acting, ask:

1. Is it legal and compliant with Company policy?
2. Is it fair, honest and transparent?
3. Would I be comfortable if this decision became public?
4. Could it harm customers, colleagues, partners or the Company?
5. Have I sought guidance if I am unsure?

6. Conflicts of Interest

A conflict of interest arises when personal interests, relationships, financial interests or outside activities could influence, or appear to influence, professional judgment.

• Disclose actual, potential or perceived conflicts to the Company.
• Do not use Company position, information or resources for personal gain.
• Avoid outside employment, investments or relationships that compete with or compromise the Company.
• Do not participate in decisions involving relatives, close personal contacts or entities in which you have a financial interest without disclosure and approval.

7. Anti-Bribery, Anti-Corruption and Gifts

Alomind Labs has zero tolerance for bribery and corruption. No person may offer, promise, give, request or accept any bribe, kickback, facilitation payment or improper advantage.

• Gifts, hospitality and entertainment must be modest, infrequent, lawful, transparent and for legitimate business purposes.
• Cash, cash equivalents, personal favors and improper commissions are prohibited.
• Interactions with government officials, public sector entities and regulated customers require special care and approvals where applicable.
• Donations, sponsorships and charitable contributions must not be used to obtain improper business advantage.

8. Confidentiality, Data Privacy and Information Security

• Protect confidential, proprietary, technical, commercial, financial, employee, customer and partner information.
• Access information only when required for legitimate work purposes.
• Do not share confidential information externally or internally without authorization.
• Use strong passwords, secure devices and approved systems.
• Report data breaches, cyber incidents, loss of devices or unauthorized access immediately.
• Comply with applicable data protection and privacy laws.

9. Workplace Conduct and Human Rights

• Maintain a workplace free from harassment, discrimination, intimidation and violence.
• Respect privacy, dignity, safety and lawful employment rights.
• Do not use forced labor, child labor or unethical labor practices.
• Encourage open communication and constructive feedback.
• Report workplace concerns without fear of retaliation.

10. Compliance with Laws and Fair Business Practices

• Comply with all applicable laws, regulations, industry standards, licenses and contractual obligations.
• Compete fairly and do not engage in price-fixing, bid-rigging, market allocation or unfair trade practices.
• Do not misuse confidential information of competitors, customers or partners.
• Maintain accurate books, records, invoices, expense claims and statutory filings.
• Cooperate honestly with audits, investigations and regulatory inquiries.

11. Use of Company Assets and Technology

• Use Company assets, funds, equipment, devices, software, intellectual property and facilities responsibly and only for authorized purposes.
• Do not misuse Company systems for illegal, offensive, fraudulent or unauthorized activities.
• Protect Company intellectual property, including designs, documents, code, trade secrets, data, brand assets and inventions.
• Return Company property and information when employment or engagement ends.

12. Environment, Health and Safety

• Follow safety procedures and report hazards, injuries, near misses and unsafe practices.
• Use resources responsibly and seek to reduce waste, emissions and environmental impact.
• Comply with applicable environmental, health and safety laws and customer requirements.
• Do not work under the influence of alcohol, illegal drugs or substances that impair safety or judgment.

13. Reporting Concerns and Whistleblower Protection

Concerns may be reported to a manager, Human Resources, Legal/Compliance, the Ethics Officer or through the designated reporting channel: support@mindlabs.cloud.

Reports may include suspected misconduct, fraud, bribery, harassment, discrimination, safety risks, data breaches, policy violations, conflicts of interest or any unethical behavior.

Non-Retaliation

Alomind Labs prohibits retaliation against anyone who raises a concern in good faith or participates in an investigation. Retaliation itself is a violation of this Code and may lead to disciplinary action.

14. Responsibilities, Breaches and Disciplinary Action

• All covered individuals are responsible for understanding and complying with this Code.
• Managers must lead by example, create an ethical work environment and respond promptly to concerns.
• Violations may result in corrective action, termination of employment or contract, recovery of losses, legal action or reporting to authorities, depending on severity and applicable law.
• False or malicious complaints may also lead to disciplinary action.

15. Review and Governance

This Code will be reviewed periodically and updated as required by changes in law, business operations, stakeholder expectations or Company policies. The latest approved version is published on the Company website and made available to employees and relevant stakeholders.

Quick Reference: Expected Behavior

16. Acknowledgement

Everyone covered by this Code is expected to read, understand and comply with this Code of Conduct and Code of Ethics of Alomind Labs, and to report concerns or potential violations in good faith. This Code was approved by the Board of Alomind Labs Private Limited on 02 July, 2026.