EPPL's Code of Conduct

INTRODUCTION TO THE CODE OF CONDUCT

We, Eagle Press Private Limited operating in a complex and highly regulated business environment. This Code of Conduct (this “Code”), which has been approved by the Eagle Press Private Limited Board of Directors, provides information about the standards of behavior and the level of integrity expected of all employees, directors, officers, and consultants, as well as any third parties, agents or representatives who deal with or act on behalf of Eagle Press Private Limited and its subsidiaries and controlled affiliates (the “Company” or “EPPL”).

This Code is not a contract of employment and does not create any contractual rights of any kind between the Company and its employees. However, complying with this Code is an obligation of every employee. Employees who do not comply with this Code or other Company policies may be subject to disciplinary measures to the extent permitted by applicable law and labor contracts, which could result in their dismissal. Third parties, agents and representatives that, as required, do not comply with this Code or other Company policies may be subject to appropriate sanctions in accordance with applicable laws or contractual provisions.

This Code is intended to be applied globally to all of our business activities and corporate operations in accordance with the cultural, social and economic differences in the various countries where the Company operates. Where local laws and regulations contain mandatory requirements that differ from the provisions of this Code, such requirements will prevail.

CORE PRINCIPLES

Eagle Press Private Limited is committed to the principles of Integrity, Trust, Respect and Excellence in all relationships in which it does business.

• We comply with all applicable laws and regulations governing the business worldwide and expect all of our employees, directors and officers to do the same. Equally, we expect our contractors, consultants and other third parties with whom we do business to comply with all applicable laws and regulations.
• We manage our activities in compliance with our core principles in all business operations and transactions.
• We act with integrity in all relationships and in all workplaces, avoiding all conflicts of interest between work and personal activities of our employees
• We are committed to the protection of our Company’s total assets, including our financial, physical and intellectual property assets, and guarantee the accuracy and transparency of all given information.
• We maintain a culture that fosters a safe workplace, equal opportunity, diversity, communication and innovation where everyone is treated with respect, fairness and dignity.
• We are committed to corporate social responsibility and, in particular, enabling our customers to provide educational, cultural, charitable and philanthropic opportunities to their citizens.

INTEGRITY

Standard of Conduct

EPPL conducts all its activities in an ethical manner, with integrity, trust, respect, and fair dealing. These values should govern our conduct in every decision we make which affects the Company. Regardless of the pressures involved in conducting business, it is our duty to act responsibly and with integrity. This means that we must avoid even the appearance of impropriety in carrying out Company business.

Commitment to Integrity

• Compliance is everyone’s responsibility. We must comply with all applicable laws and regulations. Unless otherwise prohibited by local law, as a condition of employment, we require all employees to acknowledge their commitment to comply with this Code and all Company policies.
• A violation of the applicable laws and regulations can cause harm to the Company in terms of its business reputation and the potential loss of confidence by our customers, shareholders and employees. Therefore, if at any time you have a question about proper business conduct or you are uncertain about a specific situation or circumstance or need interpretation of any provisions of this Code, you should ask for assistance from your supervisor or a representative of the Compliance, Legal or Human Resources Departments.
• In light of the above, we must take the time to learn and understand this Code, the Company’s policies and the laws and regulations applicable to our job responsibilities. We may also be required to attend training sessions to ensure we understand such policies, laws and regulations.

Fair Employment, Diversity and Harassment

• EPPL is committed to providing a work environment where everyone is treated with fairness, dignity and respect.
• The Company will not discriminate against anyone on the basis of race, color, creed, religion or belief, national origin, age, disability, sex, sexual preference, sexual identity, marital or civil partner status, pregnancy and maternity, military status, veteran status, or any other legally protected status in accordance with applicable law and regulations.
• Any employee found to have discriminated against a Company employee will be subject to disciplinary action which could result in their dismissal.
• Any kind of harassment or bullying by or against Company employees is prohibited. Prohibited conduct includes (but is not limited to) the making of degrading or humiliating jokes, slurs, intimidation, with employment decisions.
• Any employee found to have harassed or bullied a Company employee will be subject to disciplinary action which could result in their dismissal.
• The Company is also committed to providing a safe and healthy work environment and requires that each person report to work free from the influence of any substance that could prevent him/her from conducting his/her work activities safely and effectively.

Conflict of Interest

• We must avoid behaviors, relationships and situations that conflict or appear to conflict with our job responsibilities or the interests of the Company.
• A conflict of interest is considered to be any situation or arrangement where your personal activities or interests conflict with your responsibilities to the Company.
• Any outside activities or relationships that may involve a conflict of interest or even the appearance of a conflict of interest must first be approved by your manager and then disclosed to the HR Manager or his designee.

The following are examples of conflicts of interest:

• Engaging in any employment, business, professional or other activity outside of the Company.
• Holding a substantial direct or indirect financial interest in a current or prospective customer, supplier or competitor of the Company, or serving as an employee, consultant, officer, or director of that business.
• Directing Company business to a supplier owned or managed by you, a relative or close associate
• Using confidential Company information, taking advantage of Company business opportunities or improperly using Company assets for the benefit of yourself, a relative or close associate.
• Participation in non-business activities such as charity work or the carrying out of political roles can create a conflict of interest if your personal involvement creates obligations for the Company without Company approval or if your activity makes it appear that the Company has undue influence on decisions.

This is not a complete list of possible conflicts of interest but a sample of the kinds of relationships and activities that can create a conflict of interest. If you have questions whether any activity creates a conflict of interest, you should contact the HR Manager or his designee for approval prior to commencing such activity

Raising Concerns and Prohibition Against Retaliation

Each of us has a responsibility and an obligation to promptly report suspected or known violations of the Code, violations of law or regulations or dangers at work.( For example, this may include criminal activity, bribery, financial fraud, negligence or danger to health and safety. )

Ethical and compliance concerns should be communicated through regular reporting channels; if employees have any queries they should contact the HR department immediately.

Raising concerns or reporting misconduct, especially if it involves a friend or supervisor, may feel like a breach of personal ethical standards. However, being silent and not reporting the concern could bring serious harm to the Company, loss of confidence by customers, fines or other kinds of penalties.

The Company hopes that employees feel able to voice concerns openly under the Code. However, if employees want to raise concerns confidentially, the Company will (subject to local laws or regulations) make every effort to maintain confidentiality.

For a complete listing of ways to report suspected or known violations of the Code, law or regulations, please refer to the Avenues of Communication section at the end of this Code.

The Company will not retaliate or discriminate against anyone for reporting in good faith a suspected or known violation.

BUSINESS PRACTICES

Participation in Lotteries

• All employees, representatives and consultants shall not participate in or claim or receive any benefit, directly or indirectly, from any lottery game in any jurisdiction where the Company provides lottery services or products.
• Employees, representatives and consultants should advise immediate family members (parents, spouse, siblings, and children) and members of their household that they may be similarly restricted by state or local laws, regulations or the Company’s contracts in various jurisdictions
• In limited instances, employees, representatives and consultants may play customer lottery games provided that such play is related to their job, is permitted under applicable laws and contracts and the person obtains prior approval from their manager. Any winnings resulting from such play must be returned to the customer.

Participation in Gaming

No employee shall make any wager or otherwise participate in gambling activities in any gaming facilities which are prohibited by applicable contracts, regulations or licenses.

Intellectual Property

• The Company’s intellectual property, including (but not limited to) its copyrights, patents, trademarks and trade secrets are extremely valuable to the Company and its continued success.
• Intellectual property is one of the most important assets generated by the Company. These assets include extremely valuable proprietary information, such as computer software and source code, engineering designs and drawings, research and development, confidential processes and knowhow, marketing plans, etc.
• The loss, theft, unauthorized disclosure or misuse of the Company’s intellectual property jeopardizes its business and causes it harm.
• Each of us is responsible for preserving the Company’s intellectual property by complying with policies and procedures for its protection. This obligation continues even after a person leaves the employ of the Company.
• The Company also respects the intellectual property of others. It is against the Company’s policy to reproduce copyrighted software, documentation, or other materials without the owner’s permission.
• The Company respects the limitations specified in the licensing agreements of its software suppliers and does not use or copy software or documentation except to the extent that the applicable license agreement allows for such use or copying.
• All employees agree to assign to the Company all rights he/she may have or may acquire in any intellectual property including (without limitation) in any idea, invention information, concept or thing which is both (i) based upon or related to any Company confidential information, service(s) or product(s) and (ii) is generated during the term of their employment or within one year after termination, except in those instances where local laws and regulations contain mandatory requirements that differ from the provisions of this section.

Confidential Information

• Confidential Information (as defined below) is very important to the Company and the loss, theft, unauthorized disclosure or misuse of the Company’s Confidential Information jeopardizes its business and causes harm.
• Employees possessing Confidential Information shall not at any time either during or after the termination of their employment disclose to any person or use for their own purposes any Confidential Information concerning the organisation, business, finances, transactions or affairs of the Company other than as required by local laws or regulations.
• “Confidential Information” means information (whether or not recorded in documentary form, or stored on any magnetic or optical disk or memory) relating to the business, products, affairs and finances of the Company for the time being confidential to the Company and trade secrets including, without limitation, technical data and knowhow relating to the business of the Company or any of its business contacts.

Electronic Media and Communications Systems

• All electronic media and communication systems, including email, intranet, and Internet access and voice mail are Company assets and are to be used for appropriate business purposes.
• The Company has policies regarding the use of electronic media and communication systems, which show the importance of the correct use of such tools in order to prevent harm to the Company, in terms of loss of reputation, reduction of productivity and imposition of money penalties.
• The ability of the Company to access and control any personal communication or data created or stored on electronic media and communication systems provided by the Company is allowed for legitimate business purposes, unless otherwise prohibited by applicable law and, in any case, in accordance with a reasonable protection of confidentiality of the relationship between the Company and its employees.

Accuracy, Retention and Disposal of Documents and Records

• The Company’s books and records shall be complete, fair and accurate and shall comply with all legal reporting requirements.
• No entries will be made that intentionally conceal or disguise the true nature of any transaction.
• The Company will not create or permit the creation of false or misleading statements in financial reports or other documents submitted to or maintained for government agencies, customers or shareholders.
• The Company maintains rigorous business processes and a system of internal controls to protect its physical, financial and intellectual property assets and to ensure that management decisions are based on sound financial and economic analysis, including consideration of the risks.
• All records will be retained and destroyed strictly in accordance with the Company’s policies and applicable statutory and legal requirements.
• We are not allowed to remove or destroy records or documents prior to the specified date in the policy or remove or destroy them at all if the destruction policy is suspended due to threatened or pending litigation or investigation.

Accuracy, Retention and Disposal of Documents and Records

• The Company’s books and records shall be complete, fair and accurate and shall comply with all legal reporting requirements.
• No entries will be made that intentionally conceal or disguise the true nature of any transaction.
• The Company will not create or permit the creation of false or misleading statements in financial reports or other documents submitted to or maintained for government agencies, customers or shareholders.
• The Company maintains rigorous business processes and a system of internal controls to protect its physical, financial and intellectual property assets and to ensure that management decisions are based on sound financial and economic analysis, including consideration of the risks.
• All records will be retained and destroyed strictly in accordance with the Company’s policies and applicable statutory and legal requirements.
• We are not allowed to remove or destroy records or documents prior to the specified date in the policy or remove or destroy them at all if the destruction policy is suspended due to threatened or pending litigation or investigation.

Social Media

• Employees should not make statements in the social media about the Company’s business, its prospects or results.
• Employees should not make statements in the social media about the Company’s business, its prospects or results.
• All External communications will take place as per external communication policy by the HR Department or assigned by the Management.

Privacy and Data Protection

• The Company will, during the course of its activities, collect, store and process personal data about its employees, customers, suppliers and other third parties. Some of this data will be “sensitive” personal data (for example, information about an employee’s health or ethnicity).
• The Company is committed to individual privacy and recognizes the responsibility it has to protect the privacy rights of all persons whose personal information is within the Company’s custody and management.
• The Company will not intentionally gather or maintain personal information that is not relevant to conducting its business
• Each of us must take care to protect individually identifiable and personal information from inappropriate or unauthorized use or disclosure.
• In addition, the Company will ensure that personal data held is accurate and kept up to date.
• All Company operations must implement fair and responsible privacy and information protection procedures and take responsible steps to ensure compliance with such procedures and applicable law.

BUSINESS RELATIONSHIPS

Cooperation with Regulators

• The Company is committed to cooperating with the various regulators that oversee its business activities.
• Each of us who act on behalf of the Company will assist the Company in meeting its business obligations to these regulators and will provide maximum availability and responsiveness.

Business Courtesies

• Gifts and entertainment are frequently used as business courtesies designed to strengthen and foster business relationships.
• In some circumstances, however, lavish or disproportionate gifts or entertainment may be used as a form of bribe.
• We must avoid even the appearance of impropriety when giving gifts to or entertaining individuals who do business or are seeking to do business with the Company.
• Requesting or soliciting personal gifts, favors, entertainment, or services is always unacceptable.
• Any expenditure on gifts, entertainment or anything of value must be reported promptly and recorded accurately in the Company’s books and records.

Gifts

It is the Company’s policy to discourage the receipt or giving of gifts, directly or indirectly, by Directors or employees to individuals who do business or are seeking to do business with the Company.

However, where not otherwise prohibited by law or Company policy, we may give or receive gifts of a promotional nature on condition that:

1. The gift is reasonably connected to a business purpose
2. The value of the gift will be defined by the Board of Directors on time to time
3. The gift is not intended, and is not likely to be perceived as intended, to influence
4. Business choice of the recipient of the gift,
5. The gift complies with local applicable law,
6. The gift does not comprise cash or a cash equivalent
7. The gift is given openly, and not secretly, and
8. As far as you know, the gift is not contrary to the policy or internal rules that apply to the recipient.
9. All Employees are generally restricted to receive any gifts from vendors, service providers, liaison personals and other people who are associated with EPPL. If a gift is send by post, courier etc.,. the same should be informed to HR and the HR will decide the course of action.

Gifts and Entertainment and Public Officials

• Many national and state governments, and other public bodies, have strict rules and laws regarding gifts and other business courtesies.
• Each of us must be familiar with such rules and laws when dealing with such governments and bodies, where possible.
• Many of us may interact with public officials, including employees of government and government agencies. We must comply with the laws and regulations that pertain to the acquisition of goods and services by our governmental customers.
• The laws, regulations and government ethics rules regarding the payment of honorarium fees and the offering of items of value, including, among other things, meals, gifts and entertainment to public officials are varied and complex.
• No gifts, payments of any kind or any item of any value can be made or offered to any public official without prior written approval of the Board of Directors.
• This prohibition does not apply to the provision of basic hospitality of nominal value only, such as tea and coffee provided to public officials at the Company’s premises during the course of a business meeting.

Who is a Public Official?

In this Code, the term “public official” should be interpreted widely, and should be taken to include any individual who performs a public function. It may include individuals you would not necessarily think of as public officials.

The following should be treated as public officials:

• Employees, officers or representatives of, or persons otherwise acting in an official capacity for or on behalf of a government, or a governmental body, whether at the national, local or regional level, and whether foreign or domestic
• Persons holding a legislative, administrative or judicial position of any kind, regardless of whether elected or appointed, including judges, members of parliament, tribunal officials, customs, excise and tax officials, regulators, civil servants, officials responsible for issuing permits or licenses, planning officials and immigration officials
• Individuals who hold any other official, ceremonial or other appointed or inherited position with a government or any of its agencies; individuals who exercise a public function for or on behalf of a country or territory or for any public agency or public enterprise of a country or territory and officials or agents of a public international organization.

BUSINESS ENVIRONMENT

Competition Laws and Gathering Competitive Information

• The purpose of competition laws, which may also be known as antitrust, monopoly, fair trade or cartel laws, are designed to create a level playing field in the marketplace and to promote fair competition.
• The Company will vigorously compete in the marketplace with integrity and will comply with competition and antitrust laws in all jurisdictions where it conducts business.
• Anyone who acts on behalf of the Company will not enter into any agreements, formal or informal, that seek to limit or restrict competition or exchange information regarding the marketing and sale of products and services.
• Unlawful agreements include those which seek to fix or control prices, allocate products, markets or territories, customers or suppliers, establish resale prices of a product, or condition the sale of products on an agreement to buy other Company products.
• The Company will use only proper and legal means of gathering marketing and business information concerning its competitors.
• The Company does not induce or solicit confidential information from a competitor’s past or present employees.
• Severe penalties may be assessed against companies and individuals who violate antitrust laws.
• Therefore, it is the responsibility of each of us who has a question about potential antitrust implications to contact a representative of the Legal Department before any such action has taken place.

Improper Payments

• We are not allowed to give, promise, offer, or authorize a third party to make any payment or transfer of anything of value (e.g., money, goods or services), directly or indirectly, to a current or potential customer, supplier or public official to obtain or retain business or to secure any improper advantage.
• Bribes, kickbacks or other unlawful or improper payments while conducting Company business are strictly prohibited.
• This prohibition is absolute and applies at all times and in all countries where the Company conducts business whether or not there are any applicable laws which prohibit such a payment, loan or other action;
• There can be no exceptions whatsoever regardless of the amount or form of payment involved or the ingenuity used in establishing a scheme or arrangement to conceal the true nature of the payment being made.
• For the avoidance of doubt, facilitation payments, by which we mean small unofficial payments made to a public official to expedite or facilitate a routine governmental action for the benefit of the Company (where the payment is not required or permitted by written applicable law), are prohibited under this Code.

Money Laundering Prevention

• The Company will conduct business only with reputable customers and suppliers who are involved in legitimate business activities and whose funds are derived from legitimate sources.
• Money laundering is the process by which money acquired through illegal means or intended for illegal purposes is converted so that the money appears to be legitimately acquired or becomes untraceable to those using it for illegal purposes.
• The Company’s integrity and reputation can be severely damaged by failing to detect financial transactions which are attempts to launder money.
• The Company is committed to complying fully with all applicable antimoney laundering laws.

CODE OF ETHICS INSIDE THE COMPANY

1. Employees have the obligation to perform themselves in an honest and ethical manner and act in the best interest of the Company at all times
2. Employees should follow the policies, procedures and guidelines prescribed by the Company that includes QMS, ISMS, Physical Security Policies, Etc
3. Employees should adopt best practices of environmental policies and procedures
4. Employees should comply with all applicable laws and regulations of the appropriate jurisdiction.
5. Employees should follow the principles of time management of the Company
6. Employees should act professionally in all their dealings and show their maximum proficiency in work.
7. Employees should learn safety awareness and adopt safe working methods to prevent serious or fatal accidents.
8. Employees should adopt high standards of hygiene and housekeeping
9. Employees should wear company provided uniform during working hours
10. Employees should wear ID Cards as provided by the Company during working hours
11. Employees should express their views politely without being aggressive or overbearing
12. Employees should respect and obey their Superiors
13. Employees should take efforts to learn, update and develop their skills
14. Employees should avoid situations in which their personal interest could conflict with the interest of the Company
15. Employees should not bring any personal belongings including stationery items inside the factory premises
16. Employees should not take away any company assets including stationery items out of the factory premises
17. Employees should not involve in unnecessary chatting inside the premises during working hours
18. Employees should avoid roaming or wandering inside the premises during working hours
19. Employees should not encourage or allow tail gating or eavesdropping
20. Employees should not discriminate unlawfully within the working place
21. Employees should not involve in any type of harassment within the working place
22. Employees should not take leave without prior permission from their Superior officer
23. Employees should not use alcohol, tobacco/tobacco products, pan leaves, etc, with in the company premises.
24. Employees should not misuse/destroy the Company’s facilities or properties
25. Employees should not accept any type of gifts from the outsiders; not to bribe or be bribed.
26. Employees should not disclose or use any confidential information gained in the course of employment for personal gain or for the advantage of any other person
27. Employees should not use Internet, Email, Telephone or Fax for their personal use or for the use of any third party except for the company’s purpose.
28. Employees should inform to the Management if they witness or are made aware of any improper conduct, including any act of harassment or discrimination.
29. Any waiver of any provision of this Code of Conduct for any employee must be placed for approval before the Company’s Board of Directors.
30. Any instance of non-adherence to the Code of Conduct will be dealt with disciplinary process of the Company

GLOBAL COMPLIANCE AND GOVERNANCE

Global Business Conduct

• The Company is committed to abiding by the laws and regulations that govern its business conduct worldwide. The laws of the countries in which the Company conducts business often extend to Company operations, business activities and Company employees throughout the world.

Global Compliance and Governance Plan

• As a company subject to extensive global gaming laws and regulations and substantial oversight worldwide by lottery authorities and related governmental agencies and bodies, the Company is committed to the highest standard of business ethics and integrity and compliance with the laws and regulations governing its global business operations.
• This commitment is demonstrated by the Company’s Global Compliance and Governance Plan.
• The purpose of the Plan is to prevent, detect and correct violations of law and Company policies and procedures.
• The elements of the Plan include assessing the bribery and ethical risks that face the Company in its global operations, setting ethical business standards that address those risks, communicating these standards, providing a mechanism for reporting potential exceptions and monitoring, auditing and maintaining an organizational structure that supports the furtherance of the Plan.

WAIVERS AND AMENDMENTS

• Any waiver of any provision of this Code of Conduct for any employee must be placed for approval before the Company’s Board of Directors.