CODE OF CONDUCT AND BUSINESS ETHICS POLICY

Document Information:

Document Name Code of Conduct and Business Ethics Policy

This policy sets forth core values, shared responsibilities, commitments,

and promises and ensures that every employee of the MuSo is aware
Description
of acceptable conduct and ethical behaviour, in consonance with the
Principles of Conduct and Action.

Original Author(s)

Document Owner Human Resources

Approved By CEO and Founder

Current Revision Author(s)

Last Printed

Revision History:

Version Revision Date Author(s) Revision Notes

1.0 First Draft

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 OBJECTIVE:
The objective of this policy is to help ensure that the conduct of an employee, specifically
at the workplace or while on duty, always enhances the company’s image, irrespective of
the level, function, or location.

While the Museum of Solutions (MuSo, “the Company”) has attempted to indicate the
expectations in this document, the list of norms described below is not an exhaustive one.
In every situation, employees are expected to use their discretion and judgment to decide
on a course of action that would maintain MuSo’s image as a respected and responsible
organization.

MuSo also expects its managers to lead by example and perform their duties in
accordance with this Code of Conduct and Business Ethics policy and ensure that this
Policy is communicated to, and understood by, all persons reporting to them.

SCOPE:
This Policy applies to all MuSo Employees. Employee shall mean all individuals on full-
time or part-time employment with the Company, probationary, trainee or retainer, interns,
consultants and volunteers. This policy also applies to third-party/contractual workforce.

In the following Code of Conduct and Business Ethics the word “Company” means and
includes Museum of Solutions (MuSo).

If a business location or region has policies, practices, laws, or regulations that require
more than what is stated in this Policy, then the Employees must follow this policy as a
minimum and comply with all such policies, practices, laws, or regulations in that
region/country.

ELEMENTS:

A. ORGANIZATION COMMITMENTS

1. National Interest
The Company shall be committed, in all its actions, to benefit the economic development
of the country. It shall not undertake any project or activity that will have an adverse impact
on the nation’s interest. It shall conform to trade procedures, including licensing,
documentation, and other necessary formalities, as applicable. The Company shall

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 conduct its business affairs in accordance with the law of the land and conform to the
Government's economic and foreign policies.

2. Corporate Citizenship
The Company shall be committed to good corporate citizenship, not only in the compliance
of all relevant laws and regulations but also by actively assisting in the improvement of the
quality of life of people in the communities in which it operates.

3. Ethical Conduct
a) Every employee is expected to be professional, honest, integral, and have high moral
and ethical standards. Additionally, every employee is expected to be fair and
transparent in his/ her conduct.
b) Employees and representatives are expected to observe high standards of business
and personal ethics in the conduct of their duties and responsibilities for the company.
They must practice honesty and integrity in fulfilling their responsibilities and comply
with all applicable laws and regulations.
c) When in doubt about the best course of action in a particular situation, employees are
encouraged to discuss any questions they have with their managers or other
appropriate personnel, such as members of senior management. MuSo’s CEO and
Chief Museum Officer have an “open door policy” for all staff.
d) If any employee feels that another’s conduct is inconsistent with this Code of Conduct
and Business Ethics or any other policy, they should immediately report their concern
to their reporting manager, head of department (HOD), or HR representative.
Furthermore, employees are encouraged to utilize the JSW Group’s Ombudsman,
Whistle-blower committee, and independent ethics hotline. Up-to-the-minute contact
information for these resources can be found online. The independent ethics hotline,
serviced by Integrity Matters, can be found at ethicsjsw@integritymatters.in,
https://ethicsjsw.integritymatters.in, 1-800-102-6969.
e) Employees must uphold the company's image through their conduct. Every employee
shall be responsible for the implementation of and compliance with the code.

4. SAFE, HEALTHY AND SECURE WORKPLACE

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 The company will strive to provide a safe, healthy, clean, and ergonomic working
environment for its people and prevent the wasteful use of natural resources.

5. EQUAL EMPLOYMENT OPPORTUNITY

a) The company will provide Equal Employment to all its employees and all qualified
applicants for employment without regard to their race, caste, religion, colour, ancestry,
marital status, gender, sexual orientation, age, nationality, ethnic origin, and disability.
b) Recruitment & Career Advancement will be on the basis of merit alone and will not be
influenced by factors like religion, caste, or gender. The company is an equal-
opportunity employer.
c) Employees at MuSo will be treated with dignity and in accordance with the policy of
maintaining a work environment free of all forms of harassment whether physical,
verbal, or psychological. Employee policies and practices shall be administered in a
manner consistent with applicable laws and other provisions of this code.

6. WORK ENVIRONMENT
a) The company is committed to fostering a work environment that is free from
harassment or disruptive activity. No form of harassment will be tolerated, including
harassment based on race, caste, religion, spiritual beliefs, disability, age, or gender.
No verbal or physical conduct by any employee, that harasses, disrupts, or interferes
with another’s work performance or that creates an intimidating, offensive, or hostile
environment, will be tolerated.
b) Protection Against Sexual Harassment deserves special mention and such incidents
will be dealt as per the Protection Against Sexual Harassment policy.

7. HARASSMENT AND DISCRIMINATION

a) The company respects the dignity of all employees working for the Company
irrespective of their gender and expects responsible and dignified conduct and
behaviour on the part of all employees at all levels. The company also expects mutual
respect among employees free of any gender bias.
b) Providing for a Safe and congenial work environment to all employees is an integral
part of the Company’s policy.
c) Employees’ behaviour at the workplace must uphold the dignity of all genders.

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8. MAINTAINING ACCURATE RECORDS
a) The integrity of the financial transactions and records is critical to the operation of the
company’s business.
b) The company is bound by certain standards for accurate financial group reporting and
is required to have appropriate internal controls and procedures, as per statutory and
legal requirements.
c) If any employee has responsibility for or any involvement in financial reporting or
accounting, one should have an appropriate understanding of, and one should seek in
good faith to adhere to, relevant accounting and financial reporting principles,
standards, laws, rules and regulations and the company’s financial and accounting
policies, controls, and procedures.
d) The Company’s external auditors have a duty to review the maintenance of financial
records in a fair and accurate manner. Employees must cooperate with them in good
faith and in accordance with law. Employees must never mislead them in any manner
regarding financial records, processes, controls or procedures or other matters which
they may enquire about.
e) Employees must fully and truthfully cooperate with any examination, audit, inspection,
or request for information from a regulator or law enforcement agency. Any contact with
law enforcement agencies or regulators must be coordinated through the Legal
Department.
f) All Company records shall be preserved and retained as required by the regulatory
agencies and as per companies QMS IT policy and Procedures.

9. CONFIDENTIALITY AND NON-DISCLOSURE

a) Every employee shall be required to maintain the highest level of confidentiality with
respect to the affairs of the Company.
b) No employee shall, either directly or indirectly, except in accordance with the general
and/or specific permission of the CEO and/or in bona fide performance of the duties
assigned to them, communicate and/or disclose any official information and/or contents
of documents to any person within the Company (colleagues, Internal customer,
superior, subordinate) or outside of the Company (customer, vendors, suppliers, third
party agency) whatsoever unless the employee is authorized to communicate and/or
disclose such information.

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B. INDIVIDUAL COMMITMENTS
1. Alcohol and Substance Use
To protect employees of MuSo from the abuses of illegal or controlled substances or
alcohol, MuSo calls for disciplinary action up to and including termination for anyone who
uses, sells, possesses, or is under the influence of illegal drugs or alcohol while conducting
business for MuSo, whether or not consumed during working hours or whether or not
consumed on MuSo premises. MuSo reserves the right, in certain circumstances, to test
for the presence of illegal or controlled substances.

2. Protecting Company Assets

a) The assets of the Company should be employed only for the purpose of conducting the
business for which they are duly authorized.
b) These include tangible assets such as equipment and machinery, systems, facilities,
materials, and resources as well as intangible assets such as proprietary information,
relationships with customers and suppliers, etc.
c) All intellectual property rights, including but not limited to patents, copyrights,
trademarks, trade secrets, and any other proprietary rights, arising out of or developed
under the scope of project/initiative/work shall be the sole and exclusive property of
MuSo.

3. Concurrent Employment
An employee of the Company will not accept part-time employment or a position of
responsibility (such as a consultant or a director) with any other organization, for
remuneration or otherwise, nor provide ‘freelance’ services to anyone. The CEO or Chief
Museum Officer may, on rare occasions, consider, and at their sole discretion approve,
exceptions to this policy.

4. Conflict of Interest
a) An employee of the Company shall not engage in any business, relationship, or activity,
which might conflict with the interest of the Company.
b) A conflict of interest, actual or potential, may arise where, directly, or indirectly, if an
employee engages in a business, relationship, or activity with anyone who is party to a
transaction with the company; an employee is in a position to derive personal benefit

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 or benefit to any of their relatives or friends by making or influencing decisions relating
to any transaction in the company.

5. Assignments Outside the Company

a) The employee may take the position of office bearer of a professional body, give talks
at programmes/seminars, be a part-time faculty at recognized degree or diploma
programmes, and/or publish books or papers. The employee must conduct these at
their own time and with their own resources.
b) Prior approval of the CEO is required if there is a conflict of interest or risk towards
company privacy or reputation or any other risk or if any outside activity interfere or
detract one from their work responsibility.
c) Furthermore, such an association should not result in the employee divulging
Company’s proprietary information, or the employee is neglecting their professional
duties of the Company.
d) The employee may retain any honorarium received in such activities, but the employee
shall inform their supervisor and the Head of HR.

6. Social Media Usage

a) Only designated employees are allowed to represent MuSo on social media.
Employees using social media for work purposes need to be aware that, while
contributing to the company’s social media activities, they are representing the
company. Employees need to ensure that their use of social media is compliant with
the law and the code of conduct policy.
b) Employees who manage company’s social media accounts are responsible for
ensuring that passwords and other access controls are of adequate strength and kept
secure.
c) Hiring Managers may use social media to promote advertised posts to potential
applicants and to identify potential candidates. However, in doing so, particular care
must be taken to avoid unconscious bias. The company will also use other channels to
publicise vacancies to avoid excluding potential applicants who do not use social
media.
d) Where employees use a private account that identifies their relationship with MuSo,
they need to make clear that they are not communicating on behalf of MuSo. It is best

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 practice to include an appropriate disclaimer, such as: “The views expressed here are
my own and in no way, reflect the views of MuSo”.
e) Employees should be aware that MuSo may observe content and information made
available by employees through social media. Employees should use their best
judgment in posting material that is neither inappropriate nor harmful to MuSo, its
employees, or network companies or customers or vendors.
f) Although not an exclusive list, some specific examples of prohibited social media
conduct
g) include posting commentary, content, or images that are defamatory, pornographic,
proprietary, confidential, harassing, or content that can create a hostile work
environment.
h) Employees are not to publish, post or release any information that is considered
confidential or not public. If there are questions about what is considered confidential,
employees should check with the Human Resources Department and/or their
supervisor.
i) Social media networks, blogs and other types of online content sometimes generate
press and media attention or legal questions. Employees should refer these inquiries
to authorized MuSo spokespersons and/or designated Marketing Head or
Communication Head.
j) Employees should get appropriate permission before they refer to or post images of
current or former employees, members, vendors, or suppliers. Additionally, employees
should get appropriate permission to use a third party's copyrights, copyrighted
material, trademarks, service marks or other intellectual property.
k) Examples of potential breaches of this policy include but are not limited to:
● Posting information to an online discussion forum about strategic initiatives, tie-ups,
plans, or budgets.
● Posting a comment on the Company’s website or social media pages in response
to a customer comment or complaint about your business.
● Uploading video footage to YouTube or any other platform showing anything that
could damage MuSo reputation.
● Making comments about or on behalf of MuSo on colleagues, customers, or
suppliers.

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 ● Posting obscene images or offensive comments about a work colleague where this
could constitute bullying, discrimination, or harassment.

C. STAKEHOLDERS COMMITMENTS:

a) Every employee in the organization, no matter in what function or level they are in, has
a responsibility towards the customer. Employees are expected to provide the best
possible service to museum colleagues so that the ultimate service, which we give to
the customer, is the best.
b) In all situations, employees are expected to be courteous and responsive to external
as well as internal customers.
c) Every employee should ensure that commitments given to the customer are honoured.
d) The company aims for the highest quality, and continuous improvement at all times.

1. Professionalism
a) All employees must show integrity and professionalism in the workplace.
b) All employees must follow the museum’s dress code and personal appearance
guidelines.
c) Employees should follow their standard working schedules. The Company can make
exceptions for occasions that prevent employees from following standard working
hours or days. But generally, the Company expects employees to be punctual when
coming to and leaving from work.

2. Public Representation
Only authorized employees are empowered to represent the organization. Employees
representing the organization at multiple forums (e.g.: Campus Presentations,
Conferences, Trade Fairs etc) are expected to engage in responsible communication
about the Company, its business, people, and associates.

3. Gifts and Donations / Use of Entitlements

a) MuSo and its employees shall neither receive nor offer or make, directly or indirectly
any illegal payments, remuneration, gifts, donations, or comparable benefits that are
intended or perceived to obtain uncompetitive favours which are intended or might be
seen to influence business decisions or create an obligation to do something in return.

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 The Company shall cooperate with governmental authorities in efforts to eliminate all
forms of bribery, fraud, and corruption.
b) In principle, employees should not accept any gift, in whatever form, and all attempts
must be made to return the gift to the donor.
c) In practice, it may be discourteous or impractical to return certain gifts. Under such
circumstances, the recipient must declare the gift to their heads of department and
deposit the gift with the HR department. Violations of these provisions will be treated
as misconduct, and the concerned employee will be liable for disciplinary action.
d) All entitlements permitted under the Company policy are expected to be used with a
sense of responsibility. The higher the entitlements, the higher are the responsibilities.
Any misuse of entitlement will be considered a violation of integrity of purpose.

4. Dealing with Business Associates, Customers, and Personal Relationships

a) MuSo and its employees shall not, unless mandated under applicable laws, offer, or
give any company funds or property as a donation to any government agency or its
representative, directly or through intermediaries in order to obtain any favourable
performance of official duties.
b) MuSo shall comply with Government procurement regulations and shall be transparent
in all its dealings with government agencies.
c) Employees will ensure that their dealings and relationships with business
associates/customers are maintained in the best interest of the company.
d) The work of Employees must be professional and commercially appropriate.
Employees must not seek or accept any favour from customers/business associates
that might put them under obligation.
e) Employees will ensure that their personal affairs do not in any way involve the name or
reputation of the Company.

5. Competition and Restrictive Trade practices

a) Neither MuSo nor its employees shall engage in restrictive trade practices, abuse of
market dominance or similar unfair trade activities.
b) MuSo and its employees shall market the Company’s products and services on their
own merits and shall not make unfair and misleading statements about competitors’
products and services. Any collection of competitive information shall be made only in

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 the normal course of business and shall be obtained only through legally permitted
sources and means.

6. Procurement Activity
a) MuSo shall purchase all equipment, supplies and services on the basis of merit, treating
suppliers, vendors, and sub-contractors fairly and without discrimination, except in
cases where the procurement process requires that we give preference to certain
groups for socioeconomic purposes.
b) Company employees are expected to employ the highest ethical standards in choosing
sources, in negotiations, in determining awards and in administering all purchase
activities. Employees should be especially careful to avoid conflicts of interest between
the company and the person or firm to be employed.
c) All records shall be accurately created and maintained to document the process and
substantiate procurement decisions.
d) All the steps in the bid request, evaluation and award/order process are to be executed
on a confidential basis. Do not divulge procurement information to anyone outside the
company or to persons inside the company who do not have a ‘need to know’.
e) It is essential that each employee involved in the procurement process avoid any
appearance of favouritism in the award of contract for goods and services. Any
relationship between an employee and a supplier or contractor must in no way
compromise the employee’s ability to transact business on a professional, impartial and
competitive basis or influence business decisions made by the company.

7. Careful Communication
a) MuSo employees are responsible for clear, correct, and appropriate communication.
Responsible and appropriate communications are essential not only to conducting our
business, but also to the Company’s reputation.
b) No employee shall, in any radio/TV/online broadcast or in any document published in
their own name or anonymously, pseudonymously or in the name of any other person
or in any communication to the press or in any public utterance, make any statement
of fact or opinion that will:
● Inflict an adverse criticism of any current or recent policy or action of the
Management.
● Embarrass the relationship between the Management and employees.

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c) Copies of communications may be used as evidence in a courtroom, in submissions to
government agencies that regulate our business, in the development of articles by the
media, and in determining corrective actions or discipline by Company representatives.
Communications include written memoranda, handwritten notes, drawings, e-mail,
computer files, voice mail, and photographs.

ADMINISTERING CODE OF CONDUCT AND BUSINESS ETHICS:

The Company’s HR and legal representatives are responsible for administering this Code.

INCIDENT HANDLING AND INVESTIGATIONS:

As mentioned in sections above, employees shall report any practices or actions believed
to be illegal, or inappropriate under this Code to their reporting supervisor or to the
appropriate members of the HR department, CEO, or Office of the Director. If it is appropriate,
in view of the nature of the reported matter, reports of violations may be made directly to
the JSW Group’s Ombudsman, Whistle-blower committee, or independent ethics hotline
as specified elsewhere in this document.

The Company has put in place processes to review and investigate all potential legal or
Code violations with HR and legal representatives, whether within the museum’s internal
organization or by utilizing resources within the larger JSW Group. Investigations will be
conducted with confidentiality and will be respectful and fair.

Employees who report potential violations of this Code in good faith will receive the full
support of the Company. This support is also extended to any person who is assisting in
any investigation or process with respect to such a violation as well. Retaliation against
those who report potential violations is strictly forbidden, and should be immediately
reported.

SUBJECTS OF EXTERNAL INVESTIGATIONS

Employees who become the subject of external investigations should immediately inform
their reporting supervisor and HR, unless prohibited by law.

REPORTING VIOLATIONS OF THE CODE OF CONDUCT AND BUSINESS ETHICS

a) As a general matter, if an employee has any questions or concerns about compliance

with this Code, they are encouraged to speak with reporting supervisor, HR or any
member of the Company’s leadership team.

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b) HR will keep records of all complaints and their resolution.
c) The Company may directly, or through partners such as the JSW ethics hotline,
involve appropriate authorities to gather, verify and validate facts related to reports of
violations
d) Following the conclusion of an investigation, outcomes and final determinations will be
reported to all relevant parties

AMENDMENTS / MODIFICATIONS TO THE CODE:

The Code of Conduct and Business Ethics will be reviewed annually to determine whether
revisions may be required due to changes in the law or regulations, or changes in the
Company’s business environment. Changes to this Code of Ethics and Business Conduct
must be approved by the CEO and Chief Museum Officer.

DISCIPLINARY ACTIONS:

Violations of this Code of Conduct and Business Ethics will result in appropriate disciplinary
action.

The matters covered in this Code of Conduct and Business Ethics are of the utmost
importance to the Company and its business partners and are essential to the Company’s
ability to conduct its business in accordance with its stated values. The company expects
all directors, officers, employees, and third-party agents to adhere to these rules in carrying
out their duties for the Company.

The Company strives for consistency and fairness in discipline for Code violations.
Discipline may include a verbal or written warning; suspension with or without pay; loss or
reduction of bonus or for the most serious offenses or repeated misconduct, termination of
employment.

Determining appropriate disciplinary actions will take into account the nature, severity, and
frequency of the violation and may vary depending upon local law. Employees must be
aware that those who violate the laws or regulations mentioned in the Code of Conduct
and Business Ethics could expose themselves and the Company to substantial civil
damages and criminal penalties.

Corrective action may be taken if the employee:

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• Violates the Code of Conduct and Business Ethics, Company policies and
procedures, or applicable laws.
• Directs others to violate the Code of Conduct and Business Ethics, Company
policies and procedures, or applicable laws.
• Is aware of a violation or potential violation and fails to report it.
• Fails to effectively monitor the actions of associates and colleagues..
• Does not cooperate in a Company audit or investigation.
• Fails to participate in required training.
• Retaliates against someone for reporting a concern in good faith or for participating
in an investigation of such a report.
• Discloses information learned during an internal investigation.

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