ROZANA VENDOR CODE OF CONDUCT

Effective November, 2025

The Rozana Vendor Code of Conduct ("Code") defines the ethical, labour practices, human rights, environmental compliance, health & safety, legal, and operational expectations Rozana Rural Commerce Private Limited and its affiliates ("Rozana") have from their vendors, service providers, and third-party partners ("Vendors"). This Code applies to all individuals and entities supplying goods, equipment, services, or labour to Rozana, including their subcontractors, agents, and representatives.

Rozana Rural Commerce Pvt. Ltd. requires its Vendors to act with integrity and demonstrate a strong commitment to responsible business practices. This Code must be communicated within the Vendor's organization and to any third parties involved in the supply relationship with Rozana.

1. Compliance with Laws and Regulations

Vendors must comply with all applicable laws and regulations including, but not limited to:

Labour laws: Minimum wages, working hours, paid leave, non-discrimination, POSH compliance, prohibition of child/forced labour.
Environmental regulations: Waste management, emissions control, pollution prevention, and sustainability practices.
Health and Safety: Vendors must maintain a safe, hygienic workplace and follow best practices to prevent injury and illness.

2. Financial Integrity and Documentation

Vendors must maintain transparent and accurate records. Any submissions to Rozana (invoices, statements, reimbursements) must be timely, complete, and truthful. Invoices should match contractual terms, include PO references (if applicable), and be supported with appropriate documentation.

3. Anti-Bribery, Anti-Corruption, and Anti-Fraud

Rozana has zero tolerance for bribery, corruption, or fraud. Vendors must not:

Offer, accept, or solicit bribes, kickbacks, or any undue advantage.
Engage in fraudulent billing, misrepresentation, or collusion.
Violate any anti-corruption, anti-money laundering, or anti-tax evasion laws.

Rozana reserves the right to audit and investigate any suspected violations. Any breach will result in immediate closure of business relationships.

4. Confidentiality and Intellectual Property

All proprietary, confidential, or sensitive information shared with Vendors must be protected against unauthorized access, disclosure, or misuse. Vendors must:

Limit access to such data to only those within their teams who need it.
Not copy, share, or commercially exploit any Rozana materials without written approval.
Respect Rozana's intellectual property, including logos, systems, product data, and brand assets.

5. Data Privacy and Protection

Vendors must ensure the protection, confidentiality, and lawful processing of all personal and business data shared by Rozana or collected on its behalf. Vendors shall:
Comply with all applicable data protection laws, including the Digital Personal Data Protection Act, 2023, where applicable
Collect, process, store, and use data only for authorized business purposes related to Rozana
Implement reasonable security safeguards to prevent unauthorized access, data breaches, loss, or misuse
Ensure that access to personal or sensitive data is restricted to authorized personnel only
Not share, transfer, sell, or disclose Rozana data to any third party without prior written consent
Immediately notify Rozana in case of any actual or suspected data breach or unauthorized access
Ensure that any subcontractors or third parties handling Rozana data adhere to similar data protection standards

6. Conflict of Interest

Vendors must avoid any relationships or actions that create actual or potential conflicts of interest with Rozana. Any personal or financial relationships with Rozana employees that may influence business decisions must be disclosed at: legal.compliance@rozana.in.

7. Product & Service Quality

Vendors must maintain high standards of quality and consistency in line with the agreed specifications, terms, and service-level commitments. Rozana encourages implementation of quality management systems.

8. Fair Competition and Business Conduct

Vendors must compete fairly and in accordance with all applicable competition laws.
They must not engage in price-fixing, collusion, or exchange of sensitive commercial information with competitors.
Vendors must not make unauthorized commitments on behalf of Rozana.

9. Grievance Redressal & Whistleblower Protection

Vendors must:

Maintain an internal grievance redressal mechanism to ensure workers can raise workplace concerns confidentially and without fear of retaliation.
Communicate Rozana's whistleblower email: legal.compliance@rozana.in, to report any ethical violations, grievance, or illegal activity involving Rozana or its representatives. Whistleblowers will be protected.

10. Labour and Human Rights

Vendors must:

Prohibit child labour, forced labour, or bonded labour.
Ensure fair wages, benefits, working hours, & conditions in compliance with Indian labour laws.
Foster an inclusive and discrimination-free work environment.
Comply with the POSH Act and ensure safety and dignity of women in the workplace.

11. Health, Safety, and Environmental Practices

Vendors must:

Comply with all applicable environmental, health, and safety laws.
Provide a clean, safe working environment and mitigate workplace risks.
Encourage sustainable operations, including waste reduction and responsible sourcing.

12. Assessment, Audit & Cooperation

Rozana may, at its discretion, conduct audits or assessments to verify compliance with this Code. Vendors must:

Cooperate fully and transparently during assessments.
Share relevant documentation when requested.
Take timely corrective actions if any gaps are identified.

13. No Authority to Bind Rozana

Unless explicitly authorized in writing, Vendors must not represent or speak on behalf of Rozana or commit it to any obligation. Misuse of Rozana's name or brand will result in disciplinary action and legal consequences.

14. Termination of Contract

Rozana reserves the right to suspend or terminate any vendor agreement in the event of:

Breach of this Code
Legal or reputational risks
Non-compliance with Rozana's operational, safety, or ethical standards

Termination may occur without liability or prior notice, subject to the terms of the contract.

15. Reporting Violations

Vendors are required to promptly report any actual or suspected violations of this Code, applicable laws, or any incidents that may pose legal, operational, reputational, or safety risks to Rozana.

The following types of incidents must be reported immediately (illustrative and not exhaustive):

Labour law violations, including child labour, forced labour, non-payment of wages, or unsafe working conditions
Fraud, bribery, corruption, or financial misconduct, including falsification of records or invoices
Data breaches or unauthorized access to any Rozana, customer, or employee data
Health and safety incidents, including workplace accidents, injuries, or hazardous conditions
Environmental violations, including illegal disposal of waste or regulatory non-compliance
Conflicts of interest that may influence business decisions involving Rozana
Any misconduct by Rozana employees or representatives involving unethical or illegal behavior

All reports must be made in good faith and submitted to: legal.compliance@rozana.in

Vendors must cooperate fully in any investigation and take corrective actions as required. Rozana will ensure confidentiality and protection against retaliation for whistleblowers.

Acknowledgment

By continuing/initiating the association with Rozana, the Vendor acknowledges having read, understood, and agreed to comply with this Code of Conduct.

Rozana reserves the right to amend, supplement, or rescind any part of this document at its sole and absolute discretion. This document is
subject to change at any time, and any such changes will be communicated to the relevant parties as appropriate. This document remains
the exclusive property of Rozana. For any clarification regarding this policy, please email legal.compliance@rozana.in