MeFy Care Private Ltd.

Code Of Conduct

FOREWORD

Employees of MeFy Care, or any of its affiliates or subsidiaries (“MeFy”), and others performing work for MeFy or on its behalf, collectively referred to in this code as “Mefyineers”, are expected to act lawfully, honestly, ethically, and in the best interests of the company while performing duties on behalf of MeFy.

VOICE A CONCERN

In the event of any queries or concerns, you may contact HR manager, or, your HR business partner.

If you want to voice a concern or you believe that any MeFy policy, or Code of Conduct, or law, you may do so anonymously through the MeFy Grievance. MeFy aims to handle all such reports in a delicate manner and with circumspection.

NO RETRIBUTION

MeFy strongly condemns retribution against Mefyineers, who report or take part in an investigation of the probability of violation of MeFy policies, Code of Conduct or Law. In case of retribution, contact CEO or report maintaining anonymity through the MeFy Grievance.

CHAPTER 1

MAKE THE WORLDBETTER PLACE

“MeFy serves patients and the medical community not only by developing and deploying biomedical devices that put health data into action but also we strive to achieve a higher standard in dealing with its users and their information.”

1.1: Improve result-driven care toupgrade affordability and access

We believe that the fastest way to create more easily accessible care is to make useful, high quality, safe products. All products and services delivered and created by MeFy serve a specific purpose. We guarantee that our products and services deliver the desirable outcomes without sacrificing the safety, privacy, or quality. For this, MeFy strictly follows CDSCO, MoHFW laws, regulations and other relevant and applicable global laws and regulations for the development, manufacture, and promotion of products.

1.2: Gain and preserve the trust of thehealthcare community
1.2.1: Communicate and preciousinformation

Communication is the key to build a relationship with trust. MeFy expects its Mefyineers to be candid in delivering the information about the products to its users.

If you're unsure whether what you're saying is incomplete, incorrect, or biased, we advise you to enquire about it from someone with proper information and expertise within MeFy Care Private Limited.

1.2.2: Protect personal information

We urge our users to trust us with their personal details, which include their every personal health information. MeFy respects and protects the privacy of the information and realizes that it is the key factor in earning and preserving their trust. Hence, the protection of that data from any unauthorized access is the responsibility of each Mefyineer.

To control the access and use of the personal information, MeFy follows strict rules and policies that comply with the DISHA(sOll a drad), Health Insurance Portability and Accountability Act (HIPAA). We expect you to take in consideration all of these and comply with the following: -

  • MeFy Privacy Policies.

  • Applicable data protection laws.

  • Report pf any data incidence you witness, including incidents related to health information, immediately.

1.2.3: Report complaints related to the products and unfavorable events

We realize the fact that no product is perfect for all its users, and some may have issues or might experience adverse events (unexpected medical reactions to the products). You are under obligation to report any such feedback to the MeFy user success team, who will initiate the prioritization and screening of the incident. Follow the polices on reporting product related complaints and adverse events.

1.2.4: Valuable User Feedback

The users are the actual holders of our reputation and praise. The feedback of our users, positive or negative, are to be given importance and deliberated over, to increase our quality of service. They must result in an improvement of performance.

1.2.5: Maintenance and Management of records

MeFy Is required to hold on to certain records and follow specific guidelines in managing them, as per local, state, nation and other applicable laws, rules and regulations.


CHAPTER 2

YOU’RE PART OF ATEAM

"Talent wins games, but teamwork and intelligence win championships." – Michael Jordan

MeFy is commihed to an empatheOc and encouraging work environment, where each Mefyineer has the opportunity to reach and work to their fullest potential.

The Mefyineer Handbook provides more information on the conduct of Mefyineers at work.

2.1: Equal opportunities for employment

In MeFy, the sole criteria for employment is individual merit and qualifications directly where to the professional competence.

MeFy strictly forbids unlawful discrimination or harassment on any basis on characteristics that are protected by law.

2.2: Diversity and Incorporation

Diseases or any health issue does not discriminate on racial, religious, political basis or gender identity. In order to help people, live beher and healthier lives, we aim to build a diverse team with diverse backgrounds or perspectives, so as to tackle seriously. MeFy has a resolute commitment to seek, ahract and hold onto a diverse and inclusive workforce that has the culture to be open to respeciul decision on any topic.

“Follow The Golden Rule Of TreaPng Others As You
Would Like Being Treated”

2.3: Harassment, Bigotry and Bullying

MeFy prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. MeFy promotes the creation of a workplace culture, free of harassment, intimidation, bigotry and unlawful discrimination and takes it seriously. To learn more about what harassment, bigotry, and bullying each imply, do read the Mefyineer Handbook.

If you feel you have been bullied or harassed by anyone at MeFy, or by anyone associated, we encourage you to report such incident to your Head, HR, or both. Simultaneously. Leads and Head are to report such incidents immediately and MeFy will thoroughly investigate it and take appropriate action. Even at non-MeFy events, we expect everyone to respect their co-workers.

2.4: Consumption of Drugs, Smoking and Alcohol

MeFy is a healthcare company and the health and wellbeing of its Mefyineers is a priority, which is endangered by substance abuse. This implies:

2.4.1: No illegal drugs

Consumption or possession of illegal controlled substances (as defined under the juridical law) at MeFy’s offices or work events is strictly prohibited.

2.4.2: No smoking

Smoking cigarehes or use of devices resembling and operating like a cigarehe, including cigars, e-cigarehes, or other vapor smoke devices is not allowed in any part of the office at any moment inside MeFy premises.

2.4.3: No alcohol

Consumption of alcohol leading to impaired performances or inappropriate behavior, endangering the safety of others, or violating the law, is banned at our offices.

2.5: A Healthy and safe work environment

MeFy has Mefyineer health and safety (MHS) practices and policies aimed at protecting Mefyineers and contractors from any injury or harm. Mefyineers are expected to provide accurate and complete information about MHS – related incidents so that MeFy meets its legal obligation to make reports.

2.5.1: Handling hazardous materials with care

Follow regulations while handling, storing and disposing hazardous materials and hazardous wastes. Do it carefully.

2.5.2: Abstain from bringing weapons to the workplace

MeFy does not and will not tolerate threats and violence of any degree in the workplace. Carrying weapons to work is strictly prohibited and is frowned upon. If any incident occurs threatening the health, safety, security, or the environmental surroundings of people in or around the facility, inform security, the MHS team, and/or appropriate authorities.

2.6: Highly Aligned, Loosely Coupled

We expect each Mefyineer to spend a lot of time debating ‘inventions’ and trust others on the tactics without prior approvals. The success of ‘Highly Aligned, Loosely Coupled’ work environment relies on the collaborative efforts and ahempts of highly performing individuals and effective context.


CHAPTER 3

STEER CLEAR OF CONFLICTS OF INTEREST

"Talent wins games, but teamwork and intelligence win championships." – Michael Jordan

Conflicts of Interest arise when your pursuing maher provides you and your acquaintances with a personal benefit, at the expense of MeFy, or it’s users.

Abstain from puong yourself in such a situation. In all such cases, contact your Manager and Trust and Compliance for guidance.

Eight areas where such conflicts of interest usually arise:

3.1: Alternative employment, advisory roles and starting your own business

Do not accept or start employment, advisory positions, services, under any other company or your own business. In call these cases, contact HR manager.

3.2: Business opportunities you come across through work

MeFy has the sole right over any and all business opportunities discovered through your works.

3.3: Creation or Inventions

Developing or helping to develop to a third part any inventions may create a conflict of interest, when the invention:

  • Relates to MeFy’s existing or anticipated products or services

  • Relates to the position served by you at MeFy

  • Is developed using the corporate resources provided by MeFy

These inventions could concern the permissions of MeFy’s Confidential Information and Invention Assignment Agreement and other employment agreement.

Consult HR if any such questions arise about such potential conflicts or intellectual property ownership involving an outside invention or other intellectual property.

3.4: Close Acquaintances and relationships between Co-Workers

Abstain from taking any decision or being a part of it regarding potential or existing MeFy business relationships if such decisions involve close acquaintances or if they are being considered for a job.

Also ask HR manager to re-assign relationship management responsibilities if your partner is associated with a company for which you’ve been assigned as the relationship manager. Not all personal relationships create a conflict of interest.

If any such queries exist, you can discuss the issue with HR manager.

Romantic relationships at work may create actual or perceived conflicts of interest. This depends on factors such as work roles, projects etc. If there’s an actual or perceived conflict of interest, you and the concerned Mefyineer may be subjected to changes in work arrangements or even the termination of employment. Consult the Mefyineer Handbook for any additional guidance on such an issue.

3.5: Exchange of gids, entertainment or any other business courtesies

Before accepting gids, entertainment and other business courtesies, from any MeFy competitor or business partner, consult the HR manager and seek their approval, as such mahers can easily create the appearance of a conflict of interest, especially if the value of the item is significant.

In general, inexpensive non-cash gids, moderate business meals and entertainment with clients may be appropriate.

3.6: Collaborative Research with Healthcare Organizations, Providers and Research Institutions

MeFy may choose to collaborate for research work, that may include clinical

research, reviews or product and services development.

3.7: Outside Work Activities

All Mefyineers need to maintain the responsibility for good public relations, especially at community level, which includes MeFy member communities and the ones in which everyone lives.

However, these activities should not demand or take up excessive time and ahention from the Mefyineers, presenting them from fulfilling their work-related responsibilities. Additionally, Mefyineers are not to take part in activities, competing directly or indirectly, with MeFy’s business.


CHAPTER 4

USE OF CORPORATE EQUIPMENT AND FACILITIES

"Ethics is the new competitive environment." – Peter Robinson

Any action using MeFy's corporate electronic facilities might be monitored, accessed, or disclosed to people inside and outside the company. For example, MeFy may monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises when required by law (e.g., in response to a subpoena or warrant) or when there is a business need. These include protecting Mefyineers and users, maintaining the security of resources and property, or investigating suspected Mefyineer misconduct.

Connect to HR manager if you unsure about the use of equipment or facilities. Examples of these include:

  • Computers (and the information on them)

  • Mobile devices (and the information on them)

  • The network

  • Letters and documents on the company premises

  • Machines on the company premises


CHAPTER 5

UPHOLD FINANCIAL INTEGRITY AND RESPONSIBILITY

“Real integrity is doing the right thing, knowing that nobody’s going to know whether you did it or not.”- Oprah Winfrey

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This not only includes accurate reporting of our financials. The money spent on behalf of MeFy is of the company and, ultimately, our shareholders' money.

Each person at MeFy has a role in making sure:

  • Money is appropriately spent

  • Our financial records are complete and accurate

  • Internal controls are honored.

To make sure that we get this right, MeFy Admin maintains a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate and we expect each Mefyineer to stay in full compliance with them. In case of queries, be unhesitant in contacting HR manager, or Finance.

5.1: Spending MeFy's money wisely

It is important that we be cognizant of waste and regard MeFy's money as our own because we all benefit when MeFy becomes more efficient. In short, please spend wisely and allocate resources frugally.

Always ensure that the cost is reasonable and directly related to MeFy's business. Record the business purpose with appropriate documentation like receipts and other submission requirements for expense reports. You can always check with HR manager if any doubt regarding reimbursement prevails.

Please remember that travel can be a significant cost, hence do so with care and check-in with your manager to confirm that each international trip is important and appropriate.

HR Managers are responsible for all money spent and expenses incurred by their direct reports, and should carefully review such spend and expenses before approving.

5.2: Signing a contract

Each time you enter into a business transaction on MeFy's behalf, there should be documentation recording that agreement, approved by Legal. All of the following requirements must be met:

  • You are authorized to sign the contract under MeFy's Commitment and Signature Authority Policy. If you are not sure whether you are authorized, ask HR manager.

  • The contract is approved by Legal.

  • You have read and understand the terms of the contract and decided that entering into the contract is in MeFy's best interest.

All contracts at MeFy need to be comprehensive. This means all relevant terms to which the parties are agreeing to should be in writing.


CHAPTER 6

MAINTAIN ETHICAL AND PROFESSIONAL RELATIONSHIPS WITH OTHER COMPANIES

"The greatest homage we can pay to truth is to use it.” – Ralph Waldo Emerson

We expect the same ethical and professional conduct when our Mefyineers interact with our partners, as we expect within MeFy.

6.1: Hiring suppliers

Our aim is to work with the best and deliver the best. Hence, we evaluate suppliers for quality, service, reliability, cost, ethical business practices, and past compliance with the law.

6.2: Partnerships, including joint venture relationships

We partner closely with certain companies, in collaborations and by forming joint ventures, to deliver on our goal of helping people live healthier lives. Remember that when engaging with our partners, these companies are separate legal entities, and you should operate ensuring them as a completely different company. If you're a board member of the joint venture, you may provide input to the joint venture and, in that capacity, you have fiduciary duties to that entity.

Refrain from allowing a partner's Employees to use MeFy property (equipment, technology, and facilities) as its own without a contract, statement of work, or other formal exchange of services approved by Legal. Be careful not to share unrelated business or confidential information with joint venture or collaboration partners.


CHAPTER 7

PRESERVE CONFIDENTIALITY

“Confidentiality is a delicate bargain of trust.” ― Martin Uzochukwu Ugwu

Certain kinds of company information, if leaked prematurely into the press or to compeOtors, can hurt our product launches, eliminate our competitive advantage, and prove costly in other ways.

The guidelines mentioned below do not limit your right to communicate about pay, work hours, or other terms and conditions of working at MeFy with fellow Mefyineers or non-Mefyineers (including government agencies or officials) or your ability to communicate with a government agency or official regarding any violation of law.

7.1: External communications

Make sure to keep confidential material confidential.

  • Properly secure, label, and—when appropriate—dispose of MeFy confidential information

  • Keep information we get from others under nondisclosure agreements (NDAs) confidential

  • Take steps to keep our trade secrets and other confidential intellectual property secret

  • Refrain from sharing confidential information with members of the press or publicly on forums like blogs or social media without adequate permissions.

7.2: Get approval before speaking publicly on behalf of MeFy.

It's great to have our Mefyineers representing our company on important subjects and before partners, but we need to make sure that:

  • Events are appropriate for MeFy representation

  • Prospective speakers who will be speaking on the company's behalf are prepared to represent its positions and handle questions.

After familiarizing yourself with the Speaking Guidelines,

you must have approval from HR manager and MeFy CEO before you commit to speak on behalf of MeFy at an event which includes financial/investor conferences.

7.3: Decline all monetary honoraria for speaking engagements.

If you do speak at an event, you can accept reasonable travel and incidental costs coverage from the engagement host. It is preferred that the event organizer pays for travel and expenses directly to the supplier of travel. Obtain HR manager's approval and MeFy CEO if you plan on expensing travel and incidental costs to MeFy.

7.4: If you plan to speak at an external event but not on behalf of the company, be very clear in your acceptance of the invitation and in your remarks that you are speaking on your own behalf and not on behalf of MeFy.
7.5: Other companies

As a member of the MeFy & Seldec team, you must protect confidential information of any company to which you are given access. These circumstances, including through collaborations, rotations, systems, or 20% projects with another company. You may not access or use the confidential information of other company except as permihed and reasonably necessary for valid business purposes within the scope of your employment. All reasonable steps to maintain the confidential status of any such information must be taken. Do not disclose any confidential information about MeFy or Seldec company, without appropriate sign off from Legal, which may include Legal obtaining consent from other sister companies before any disclosures can be made.

7.6: MeFy partners and joint ventures

It's equally important not to disclose any confidential information from our partners or joint ventures. The reverse applies: don't accept confidential information from other companies without first having all parties sign an appropriate NDA approved by Legal. Even ader the agreement is signed, try only to accept as much information as you need to accomplish your business objectives. In case of any queries, contact Legal immediately.

7.7: Competitors and former employers

Do not use a competitor's or former employer's confidential information to the benefit of MeFy. We believe in healthy competition. Remember that you are bound by Confidential Information and Invention Assignment Agreement and MeFy's Trade Secrets Policy at all times. If you happen to come in possession of a competitor's confidential information, contact Legal immediately.


CHAPTER 8

OBEY THE LAW

“The only safe ruler is he who has learned to obey willingly.”- Thomas a Kempis

MeFy takes its responsibilities to comply with laws and regulations very seriously and compliance with applicable legal requirements and prohibitions is expected from all. Unlike other industries, healthcare is a heavily regulated industry and the laws provide a framework for your work. Get familiar with the major laws and regulations that apply to your work, and ask Legal if you're unsure.

8.1: Interactions with healthcare professionals

With the goal to make people healthier, your job may require you to work with healthcare professionals ("HCPs"). They include any individual or entity that provides healthcare services, treatment, or research. Your interactions with HCPs must:

  • Be professional and ethical at all times

  • Follow applicable law, regulations, and MeFy policies.

As a guiding principle, HCPs have an obligation to make independent decisions regarding MeFy products and services, so do not improperly influence HCPs in this regard. This independence is critical to ensuring the best possible clinical outcomes for our users. Go through MeFy's policy on Interacting with Healthcare Professionals

8.2: Interactions with government officials

We work within a regulated industry and therefore, your role may involve interacting with government officials. "Government officials" include:

  • Government employee

  • Candidates for public office

  • Employees of government-owned or controlled companies

  • Public university employee

  • Public international organizations

  • PoliOcal parties

Offering gids, entertainment, or other business courtesies that could be perceived as bribes becomes especially problemaOc if you're dealing with a government official. Infrequent and moderate expenditures for business entertainment for officials who are not healthcare professionals can be acceptable if:

  • Permitted under local law

  • Receive pre-approval from MeFy Legal

8.3: Fair competition

Most countries have laws – known as "antitrust," "competition," or "unfair competition" laws – designed to promote free and fair competition. Generally speaking, these laws prohibit:

  • Arrangements with competitors that restrain trade in some way

  • Abuse of intellectual property rights

  • Use of market power to unfairly disadvantage competitors

8.4: Trade controls

Various complex trade laws control where we can send or receive our products and services, as well as travel or conduct business. This applies to -

  • Importing and exporting goods to or from the India and other countries

  • Exporting services or providing services to Foreign persons

  • Exporting technical data, especially data originating in the India

8.5: Travel restrictions to certain countries and regions.

If you are involved in sending or making available products, services, sodware, equipment, or technical data from one country to another, work with HR manager and Legal to ensure that the transaction stays within the bounds of applicable laws. You should familiarize yourself with MeFy's trade compliance policies.

8.6: Anti-bribery laws

Unnecessary courtesies or dubious “profit opportunities” not only create potential conflicts of interest but could also be perceived as bribes in certain situations. Don't bribe anybody, anytime, for any reason. MeFy is subject to lots of laws that prohibit bribery in virtually every kind of commercial seong. We want to live our values and do more good.

8.7: Insider trading laws

Using material nonpublic information to buy or sell stock, or to pass it along to others so that they may do so not only violates this Code, it violates the laws.