All associates of PmSeva are expected to uphold the highest standards of ethical conduct in the course of their duties. The objective of this policy is to ensure that all business activities are carried out with integrity, transparency, and in full compliance with applicable laws and regulations. Personal gain or advantage must never influence professional judgment or company decisions.

This document outlines PmSeva’s policies regarding:

1. Gifts, favors, entertainment, and payments
2. Conflicts of interest
3. Confidentiality and professional conduct
4. Social media usage
5. Plagiarism and journalistic fairness

General Policy Application

Gifts, Favors, and Payments Given by PmSeva

Gifts, favors, or payments may be made at company expense only when all of the following conditions are met:

1. They align with accepted and ethical business practices
2. Their value is modest and cannot be interpreted as a bribe or inducement
3. They comply with all applicable laws and ethical standards
4. Public disclosure would not cause embarrassment or reputational harm to PmSeva

Any payments, commissions, or benefits provided to employees, family members, or associates of customers—unless explicitly required under a written contract—are strictly prohibited.

Gifts, Favors, Entertainment, and Payments Received by Associates

1. Associates must not solicit or accept gifts, favors, entertainment, payments, or personal benefits without a legitimate business purpose from any individual or organization that does business with, seeks to do business with, or competes with PmSeva. Personal loans are prohibited except for standard loans at market rates from recognized financial institutions.

Acceptable Courtesies

Associates may accept customary business courtesies of nominal value, including:

• Meals hosted by vendors, including occasional invitations extended to spouses
• Low-value promotional items such as pens, calendars, notebooks, or similar items
• Event tickets (sports, arts, etc.) only if the vendor accompanies the associate and prior approval is obtained from the appropriate company authority
• Overnight outings only when representatives from other organizations are present, limited in duration, and approved in advance
• Perishable seasonal gifts such as sweets, fruits, or holiday food items

The acceptance of alcoholic beverages is discouraged.

Strict Prohibitions

• Cash or cash-equivalent gifts (including stocks, securities, or digital assets) are never permissible
• Use of vendor-owned facilities for personal or family use is prohibited unless the vendor is present, the visit is infrequent, limited in duration, and pre-approved
• Day outings such as golf, fishing, or hunting require prior approval; vendors must be present, and family participation is not allowed

2. Managers and supervisors must not accept gifts of more than nominal value from employees under their direct or indirect supervision.

Conflicts of Interest

Associates must avoid any situation where personal interests conflict, or appear to conflict, with the interests of PmSeva. All associates are required to act in the best interests of the organization and promptly disclose any potential conflict in writing to their reporting manager.

Conflicts of interest may include, but are not limited to:

1. Ownership by an associate or immediate family member of a significant interest in any organization that does business with or competes with PmSeva
2. Serving as a director, officer, consultant, partner, or employee of an external organization that has or seeks a business relationship with PmSeva, unless explicitly approved by the Chief Executive Officer
3. Acting as an intermediary, broker, or representative for a third party in transactions involving PmSeva
4. Personal or family relationships that could impair objective decision-making

Confidential Information

Unauthorized disclosure, misuse, or mishandling of confidential information—including business plans, editorial decisions, personnel data, or proprietary content—is strictly prohibited. Any violation may result in disciplinary action, up to and including immediate termination.

Compliance and Reporting

Violations of this Code may lead to administrative action or termination of association with PmSeva. Any associate aware of a potential violation must report it promptly to the appropriate management level or Human Resources. Senior leadership is responsible for ensuring compliance within their respective areas. Questions regarding this policy should be directed to Human Resources.

Social Media Guidelines

Introduction

All associates are expected to exercise sound judgment and professionalism when using social media. Content shared online is public, permanent, and widely accessible.

Remember:
When you post online, you are making a public statement that may be viewed, recorded, and shared indefinitely. Intent is irrelevant—public perception determines impact.

Understanding Social Media

Social media includes all forms of online communication such as blogs, personal websites, social networking platforms (including Twitter/X, Facebook, Instagram, LinkedIn, YouTube), forums, chat rooms, and similar digital platforms, whether or not affiliated with PmSeva.

Respect Company Policies

Online conduct must comply with this Code and all company policies. Content involving discrimination, harassment, threats, or unlawful behavior is strictly prohibited and may result in disciplinary action.

Speak for Yourself

Associates must clearly state that opinions expressed online are personal and do not represent PmSeva. When discussing company-related matters, associates must disclose their affiliation and include a clear disclaimer.

Be Respectful and Professional

Posts must not be offensive, defamatory, misleading, threatening, or harassing. Respect privacy, avoid false statements, and do not contribute to a hostile environment. This policy does not restrict legally protected activities such as discussions related to wages, working conditions, or labor rights.

Honesty and Accuracy

Ensure all information shared is truthful and accurate. Errors must be corrected promptly and transparently.

Legal and Confidentiality Obligations

Associates must respect intellectual property rights, privacy laws, and regulatory requirements. Confidential or sensitive information must never be disclosed without authorization.

Reporting Concerns

Any suspected violation of this policy should be reported to Human Resources. Retaliation against individuals reporting concerns in good faith is strictly prohibited.

Plagiarism

PmSeva maintains a zero-tolerance policy toward plagiarism. All content must be original or properly attributed, in accordance with accepted journalistic and ethical standards.

Fairness and Editorial Integrity

Journalists and contributors must ensure fairness by presenting all relevant perspectives. Individuals or organizations subject to criticism or allegations must be given a reasonable opportunity to respond, and such responses should be presented accurately and in full context.