Vendor Code of Conduct

This Vendor Code of Conduct (the “Code”) sets out the standards of integrity, legal compliance, safety and responsible business conduct that Maestroedge Solutions Private Limited, operating under the brand name “Snabbit” (“Snabbit”), requires from every Vendor in all its dealings with Snabbit.

Snabbit provides on-demand home services through a hyperlocal network of trained and verified service professionals (“Experts”) to its customers (“Customers”). Many of the goods and services Snabbit buys are used by Experts inside Customers’ homes, or are supplied at Snabbit’s offices, hubs and training centres. The trust that Customers and Experts place in Snabbit depends on the conduct of its Vendors as much as on Snabbit’s own conduct. Snabbit therefore expects its Vendors to share its commitment to safety, honesty, fairness and respect.

This Code draws on the principles of the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the Ten Principles of the UN Global Compact.

In this Code:

• “Vendor” means every person or entity that supplies, or seeks to supply, goods, materials, equipment, software, manpower or services to Snabbit or any of its affiliates under a purchase order, contract or other arrangement, and includes its directors, partners, employees, workers, agents, representatives and Sub-Vendors.
• “Sub-Vendor” means any subcontractor, supplier, agent or other person engaged by a Vendor, at any tier, in connection with the goods or services supplied to Snabbit.
• “Terms” means Snabbit’s Terms and Conditions for Purchase of Goods and Services, as published on Snabbit’s website and incorporated into each purchase order.
• “Public Official” means any officer or employee of any government, ministry, department, agency, regulator, local body or court, any employee of a government-owned or government-controlled entity, any political party, party official or candidate, and any person acting in an official capacity for any of them, in each case in India or elsewhere.
• “Snabbit Personnel” means the directors, officers, employees, interns and consultants of Snabbit and its affiliates.

Capitalised terms used but not defined in this Code have the meanings given to them in the Terms. Words such as “including” are illustrative and do not limit the general words before them. The headings in this Code are for convenience only.

• This Code applies to all Vendors, irrespective of the value, nature or duration of their engagement with Snabbit, and to prospective Vendors during bidding, evaluation and onboarding. It applies to every category of Vendor, including:
  • Manpower Vendors: Vendors who deploy personnel to work at Snabbit premises or on Snabbit’s operations, such as staffing, contract labour, security, housekeeping, facility management and field support providers;
  • Service Vendors: Vendors who provide services, such as training and assessment, logistics and delivery, marketing and creative, technology, professional and maintenance services; and
  • Product Vendors: Vendors who supply goods, such as cleaning products and chemicals, tools, equipment, uniforms, kits, consumables, branded merchandise, hardware and software.
• This Code is incorporated by reference into the Terms and every purchase order issued under them, in accordance with Clause 8.10 of the Terms. A Vendor is bound by this Code upon accepting any purchase order, and no separate signature is required.
• This Code supplements, and does not replace, the Terms, any purchase order or any agreement executed between Snabbit and a Vendor. If there is any conflict between this Code and the Terms, a purchase order or such an agreement, the Terms, the purchase order or the agreement (as applicable) shall prevail. Where this Code imposes a stricter or additional obligation than any of them on the same subject, the Vendor shall comply with both.
• This Code sets minimum standards. Vendors must comply with all applicable laws, and where this Code and the law differ, Vendors must meet whichever standard is higher.

• Compliance: Vendors must comply with this Code and all applicable laws in every activity connected with Snabbit, and must hold all licences, registrations and permits that those laws require.
• Independent employer: Vendors are independent contractors and the sole and exclusive employers of their personnel, including personnel deployed at Snabbit premises. Vendors alone are responsible for the recruitment, supervision, discipline, wages, statutory dues, insurance and welfare of their personnel, and must not represent or treat any of them as employees of Snabbit.
• Management system: Vendors must adopt policies, procedures and controls appropriate to their size and business to monitor and ensure compliance with applicable law and this Code, identify and mitigate related risks, and maintain the documents needed to demonstrate compliance.
• Communication and training: Vendors must communicate this Code to their relevant personnel and Sub-Vendors in a language they understand, and train them on it.
• Flow-down: Vendors must ensure that their Sub-Vendors comply with standards no less stringent than this Code, and remain fully responsible to Snabbit for any non-compliance by their Sub-Vendors.
• Responsible persons: Vendors must designate a person responsible for compliance with this Code and share that person’s contact details with Snabbit on request.
• Self-monitoring and declarations: Vendors must monitor their own compliance with this Code, share the results with Snabbit on request and, at least once a year if Snabbit so asks, confirm their compliance in writing and disclose any exceptions.
• Changes in the Vendor: Vendors must notify Snabbit in writing, within the time required by the Terms, of any change in their ownership, control, management or constitution, and of any insolvency proceeding, investigation, blacklisting or loss of licence, and must re-submit the onboarding documents that Snabbit requires following such a change.
• ESG information: Vendors must, when requested, provide accurate environmental, social and governance information about their operations, such as energy and water use, waste, workforce, training, health and safety and welfare data, to enable Snabbit to meet its own reporting and disclosure requirements.

5.1 Anti-Bribery and Anti-Corruption

Snabbit has zero tolerance for bribery and corruption in any form, whether involving Public Officials or private persons, and whether committed directly or through any other person. Vendors must uphold the same standard in all their dealings connected with Snabbit.

(a) Applicable laws. Vendors must comply with all anti-bribery and anti-corruption laws that apply to them or to their dealings with Snabbit, including the Prevention of Corruption Act, 1988, the relevant provisions of the Bharatiya Nyaya Sanhita, 2023, the U.S. Foreign Corrupt Practices Act, 1977 and the U.K. Bribery Act 2010, and the anti-corruption laws of every jurisdiction in which the Vendor or Snabbit is incorporated or operates, or which otherwise apply to the transactions contemplated under any purchase order or agreement with Snabbit (together, “Anti-Corruption Laws”). Vendors must also comply with Snabbit’s Anti-Bribery and Anti-Corruption Policy, as published on its website or otherwise communicated to them.

(b) Anything of Value. In this Code, “Anything of Value” has the widest meaning and includes cash and cash equivalents (such as vouchers, gift cards and digital wallet credits), gifts, hospitality, meals, travel, accommodation and entertainment, loans, discounts, rebates, commissions and kickbacks, employment, internship or business opportunities (including for relatives), donations, sponsorships, services, favours and confidential information, whether tangible or intangible.

(c) Representation and undertaking. Each Vendor represents that neither it nor any person acting on its behalf has violated any Anti-Corruption Law in connection with Snabbit, and undertakes that it will not do so.

(d) Prohibited conduct. Vendors must not, directly or indirectly, and must not permit or authorise any other person to:

• offer, promise, give, transfer or authorise the giving of Anything of Value to any person, including any Snabbit Personnel, Expert, Customer, Public Official or any of their relatives or associates;
• request, agree to receive or accept Anything of Value from any person; or
• acquiesce in or facilitate any of the above,

where the purpose or effect is public or commercial bribery, extortion, the payment or receipt of a facilitation or “speed” payment, the improper performance of any function or activity, or any other unlawful or improper means of obtaining or retaining business or securing a commercial advantage.

(e) Public Officials. Vendors must not make any payment, including any facilitation payment, or give Anything of Value to any Public Official in connection with Snabbit’s business. Vendors must not engage, or employ, any Public Official or any relative of a Public Official on any matter relating to Snabbit without prior written disclosure to Snabbit. Vendors must not deal with any Public Official, regulator or authority on Snabbit’s behalf, including to obtain any licence, permit, approval, clearance or inspection outcome, unless Snabbit has specifically authorised them to do so in writing, and must then act lawfully and transparently.

(f) Third parties and intermediaries. Vendors must not do indirectly what they may not do directly. Vendors must carry out appropriate due diligence on any agent, consultant, Sub-Vendor or other intermediary they use in connection with Snabbit, ensure that every payment to such a person is for legitimate services actually rendered, is commensurate with those services and is accurately documented, and ensure that such persons comply with this Section 5.1.

(g) Political contributions, donations and sponsorships. Vendors must not make any political contribution, charitable donation or sponsorship on behalf of Snabbit, or in order to obtain, retain or influence Snabbit’s business.

(h) Books and records. Vendors must record every payment and transaction connected with Snabbit accurately, completely and in reasonable detail, and must not maintain any undisclosed or unrecorded fund or account, create any false or misleading entry or invoice, or disguise the nature or purpose of any payment.

(i) Compliance programme. Vendors must maintain a written anti-bribery and anti-corruption policy and controls appropriate to their size and risk, including training of relevant personnel, due diligence on intermediaries, approval of gifts and hospitality, and a mechanism for reporting concerns, and must certify their compliance with this Section 5.1 to Snabbit whenever Snabbit requests.

(j) Warning signs. Vendors must refuse to participate in, and must report under Section 13, any request or arrangement that shows signs of corruption, such as a request for a cash payment or for payment to a third party or an overseas account; an unusual commission, success fee or discount; a vague, inflated or unsupported invoice; a request to bypass Snabbit’s procurement process; or a suggestion that a payment will secure an approval or a purchase order.

(k) Threats to personal safety. Nothing in this Section requires any person to put their life, liberty or physical safety at risk. If a payment is extorted under an imminent threat to personal safety, the Vendor must report it to Snabbit immediately, and in any event within twenty-four (24) hours, and record it accurately. Such a payment must never be repeated or treated as a routine practice.

(l) Notification and cooperation. Vendors must notify Snabbit immediately of any actual or suspected violation of this Section 5.1 in connection with Snabbit, and of any allegation, investigation or proceeding against the Vendor or its owners, directors or key personnel concerning bribery or corruption, and must cooperate fully with any resulting inquiry.

(m) Consequences. A breach of this Section 5.1 is a material breach of the Terms. Snabbit may, in accordance with the Terms and without any liability to the Vendor, suspend payments, suspend or terminate any or all purchase orders and arrangements with the Vendor with immediate effect, recover all amounts paid under the affected purchase orders and its losses, blacklist the Vendor, and report the matter to the relevant authorities. These rights are in addition to any other right or remedy available to Snabbit under the Terms or applicable law.

5.2 Gifts, Hospitality and Entertainment

• Vendors must not offer or give any gift, cash or cash equivalent (such as vouchers or gift cards), loan, hospitality, travel, entertainment, discount, service or other personal benefit to any Snabbit Personnel, Expert or representative, or to their family members, including on festive or personal occasions such as Diwali, Eid, Christmas, New Year, birthdays or weddings.
• Snabbit Personnel are not permitted to accept such benefits. Any request for one must be declined and reported under Section 13.
• Ordinary business meals of modest value that are directly connected to a business meeting may be provided only with the prior approval of Snabbit’s Legal and Compliance team.

5.3 Conflicts of Interest

• Vendors must avoid any situation that creates, or appears to create, a conflict between their interests and those of Snabbit.
• Vendors must disclose in writing to legal@snabbit.com, before accepting any purchase order and promptly whenever it arises, any relationship (including employment, family, financial, shareholding or other business relationship) between the Vendor, its owners, directors, partners or key personnel and any Snabbit Personnel or Expert, as required by Clause 3.9 of the Terms.
• Vendors must not employ or engage any Snabbit Personnel, or any person who was Snabbit Personnel within the preceding twelve (12) months, to work on any matter relating to Snabbit without disclosing it to Snabbit in writing.
• Vendors must not enter into any personal business dealing with, or provide any loan, investment opportunity or financial assistance to, Snabbit Personnel who are involved in selecting, managing or paying the Vendor.
• Failure to disclose a conflict of interest is a violation of this Code, whether or not any harm results.

5.4 Fair Competition and Procurement Integrity

• Vendors must comply with the Competition Act, 2002 and must compete for Snabbit’s business fairly, on merit and on the basis of accurate information.
• Vendors must not engage in bid-rigging, cover bidding, price-fixing, market or customer allocation, or any other cartel conduct, and must not share competitively sensitive information (such as prices, costs, margins, capacity or bid terms) with competitors in relation to any Snabbit tender or purchase order.
• Vendors must not seek or use confidential information about Snabbit’s procurement, including competitors’ bids, budgets or evaluation criteria, that has not been officially shared with all bidders, and must report any attempt by any person to provide such information.
• Vendors must not engage in unfair trade practices or misrepresent the qualities, origin or price of their goods and services.

5.5 Accurate Records, Invoicing and Prevention of Fraud

• Vendors must keep complete and accurate books, records and accounts, and must never create false, misleading or incomplete records or convey any false information to Snabbit.
• Every bid, quotation, invoice, claim, timesheet, report, certificate and other submission to Snabbit must be accurate, complete, itemised and supported by documents, and must be submitted on time.
• Invoices must be valid tax invoices that quote the purchase order number and comply with the Terms. Vendors must not split an invoice, or ask Snabbit Personnel to split a purchase order, to avoid any of Snabbit’s approval requirements, and must not invoice for goods or services not supplied.
• Vendors must not misuse, misappropriate or damage Snabbit’s funds, property, Buyer Materials or systems, and must report any suspected fraud affecting Snabbit immediately.
• Vendors must retain records relating to their dealings with Snabbit for the periods required by law and the Terms, and must not destroy any record that is relevant to an audit, investigation or dispute.

5.6 Tax Compliance and Anti-Tax Evasion

Snabbit has zero tolerance for tax evasion or its facilitation. Vendors must comply with all tax laws, including GST registration, invoicing, return-filing and deposit obligations, so that Snabbit’s input tax credit is not put at risk. Vendors must have procedures in place to prevent their personnel and others acting for them from committing or facilitating tax evasion.

5.7 Anti-Money Laundering, Sanctions and Trade Controls

Snabbit is committed to preventing money laundering, terrorist financing and the evasion of sanctions, and will not knowingly deal with any person who facilitates them.

(a) Definitions. In this Section:

• “Sanctions Laws” means all economic, financial and trade sanctions, embargoes and restrictive measures administered or enforced by the United Nations Security Council, the Government of India (including designations under the Unlawful Activities (Prevention) Act, 1967), the United States (including the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury, the U.S. Department of State and the U.S. Department of Commerce), the United Kingdom (including HM Treasury’s Office of Financial Sanctions Implementation) and the European Union and its member states.
• “Sanctioned Person” means any person or entity that is (i) listed on, or the subject of, any sanctions list maintained under Sanctions Laws, including OFAC’s Specially Designated Nationals and Blocked Persons List, the U.S. Commerce Department’s Entity List, the UN Security Council Consolidated List, the UK Consolidated List and the EU Consolidated List; (ii) located, organised or ordinarily resident in a country or territory that is the subject of comprehensive sanctions; or (iii) owned fifty per cent (50%) or more, individually or in aggregate, or controlled, directly or indirectly, by one or more persons described in (i) or (ii).
• “AML Laws” means all applicable anti-money laundering and counter-terrorist financing laws, including the Prevention of Money-Laundering Act, 2002 and the rules made under it, the Unlawful Activities (Prevention) Act, 1967, the Foreign Exchange Management Act, 1999, and the corresponding laws of every other jurisdiction that applies to the Vendor or its dealings with Snabbit.

(b) Representations. Each Vendor represents, on accepting every purchase order, that neither it, nor any of its beneficial owners, directors, officers or, to its knowledge, employees, agents or Sub-Vendors acting in connection with Snabbit, is a Sanctioned Person, and that it is not engaged in any activity that would cause Snabbit to breach any Sanctions Laws or AML Laws.

(c) Undertakings on sanctions. Vendors must comply with all Sanctions Laws, and must not, directly or indirectly:

• engage with, contract with, or make or receive any payment to or from, any Sanctioned Person in connection with Snabbit;
• use any part of any payment received from Snabbit to fund or benefit any Sanctioned Person or any activity in a sanctioned country or territory;
• supply to Snabbit any goods, components, software or services that originate from, or are routed through, a sanctioned country or territory or a Sanctioned Person in breach of Sanctions Laws; or
• engage in any conduct designed to evade or avoid, or that has the effect of evading or avoiding, any Sanctions Laws.

(d) Undertakings on money laundering. Vendors must comply with all AML Laws, and must not engage in, or facilitate, any activity that may involve or be perceived as money laundering or terrorist financing, including accepting, concealing, converting, transferring or using any funds or property derived from criminal activity. Vendors must not structure or split transactions to avoid reporting or approval requirements, must not make or accept cash payments in connection with Snabbit, and must receive payments from Snabbit only into a bank account held in their own name in India (or as otherwise approved in writing by Snabbit), without routing them through any third party.

(e) High-risk jurisdictions. Vendors must apply enhanced due diligence before dealing, in connection with Snabbit, with any person located in a jurisdiction identified by the Financial Action Task Force (FATF) as a high-risk jurisdiction subject to a call for action or as a jurisdiction under increased monitoring, and must not deal with any such person where doing so would breach Sanctions Laws or AML Laws.

(f) Know your vendor. Vendors must disclose their ultimate beneficial owners to Snabbit during onboarding and whenever they change, and must provide promptly, on request, all information and documents that Snabbit reasonably requires to verify their identity, ownership, source of funds and compliance with this Section, including for Snabbit’s own screening and compliance procedures.

(g) Screening and vigilance. Vendors must maintain risk-based procedures to screen their own customers, suppliers, Sub-Vendors and other counterparties against applicable sanctions lists, remain vigilant for, recognise and monitor warning signs of money laundering, terrorist financing or sanctions evasion, such as reluctance to provide ownership information, unexplained third-party or offshore payments, unusually complex structures or transactions inconsistent with a counterparty’s business, and must never carry out any conduct that would expose Snabbit to a risk of penalties under Sanctions Laws or AML Laws.

(h) Trade controls. Vendors must comply with all applicable export, re-export, import and customs laws, including India’s Foreign Trade (Development and Regulation) Act, 1992 and its SCOMET controls where relevant, obtain all licences these laws require, and ensure that no goods, technology or services supplied to or by Snabbit are diverted to any Sanctioned Person or to any prohibited end-use or destination.

(i) Disclosure and notification. Vendors must disclose to Snabbit in writing, before accepting any purchase order, any past violation of Sanctions Laws, AML Laws or trade control laws and any ongoing inquiry or investigation into such matters that is publicly known or could affect their engagement with Snabbit. Vendors must notify Snabbit immediately if they, or any of their beneficial owners, directors or officers, become a Sanctioned Person, or if they become aware of any actual or suspected breach of this Section.

(j) Consequences. If a Vendor or any of its beneficial owners, directors or officers is or becomes a Sanctioned Person, or the Vendor breaches this Section 5.7, Snabbit may, in accordance with the Terms and to the extent permitted by applicable law, immediately suspend or withhold any payment (including where any payment would be blocked or prohibited under Sanctions Laws), suspend or terminate any or all purchase orders and arrangements without liability to the Vendor, recover its losses, blacklist the Vendor, and report the matter to the relevant authorities.

5.8 Honest Representations and No Authority to Bind

• All statements, representations and communications made to Snabbit must be true, complete and made by persons authorised by the Vendor.
• Vendors have no authority to make any representation, commitment or warranty on behalf of Snabbit, or to bind Snabbit in any way, unless Snabbit has specifically authorised them to do so in writing.
• Vendors must not involve Snabbit in any dispute between the Vendor and a third party, and must not defame or disparage Snabbit, its Experts, Customers or other Vendors.

5.9 Insider Information

Vendors may, in the course of their work, receive unpublished price-sensitive information about Snabbit, its affiliates, investors or any other company whose securities are listed or proposed to be listed. Vendors must not disclose such information to anyone except as required for their work, must not deal in the securities of any such company while in possession of it, and must not advise or induce anyone else to do so, in compliance with the SEBI (Prohibition of Insider Trading) Regulations, 2015 and other applicable law.

6.1 Safety of Customers, Experts and Snabbit Personnel

The safety of Customers, Experts and Snabbit Personnel is Snabbit’s highest priority. Vendors must not do anything, and must not supply anything, that puts their safety, health, privacy or dignity at risk, and must report any incident or concern affecting their safety to Snabbit within twenty-four (24) hours.

6.2 Conduct at Snabbit Premises and Customer Homes

Where Vendor personnel attend Snabbit premises or, only where expressly authorised by Snabbit in writing, any Customer’s home, the Vendor must ensure that they:

• have completed identity and police or other background verification satisfactory to Snabbit before being given access;
• carry valid photo identification at all times, and follow Snabbit’s access, security, safety and conduct rules;
• behave courteously and professionally, and never harass, threaten, intimidate, discriminate against or otherwise mistreat any person, with particular care for the safety and dignity of women, children, elderly persons and persons with disabilities;
• are not under the influence of alcohol or drugs, and do not carry weapons or prohibited items;
• do not photograph, record, copy or remove any document, data, property or information without Snabbit’s prior written permission, and respect the privacy of Customers’ homes and belongings;
• do not access any area, system or record that is not necessary for their work; and
• do not ask Customers or Experts for personal contact details, payments, tips or favours.

6.3 Fair Treatment and Non-Solicitation of Experts and Customers

• Vendors must treat Experts fairly and with respect, including in any training, assessment, uniform or kit supply, and must not charge Experts any fee or deposit unless Snabbit has approved it in writing.
• Vendors must not contact, solicit or market to any Expert or Customer using information obtained through their dealings with Snabbit, offer any Expert or Customer services outside the Snabbit platform, or encourage any Expert to leave or reduce their work on the Snabbit platform.

7.1 Quality

Vendors must deliver goods and services that meet the agreed specifications, applicable Bureau of Indian Standards requirements and quality control orders, and good industry practice. Vendors are encouraged to operate a quality management system aligned with recognised standards such as ISO 9001, and to keep batch and lot traceability for the goods they supply.

7.2 Product Safety and Genuine Goods

• Goods used by Experts in Customers’ homes, including cleaning products, chemicals, tools, equipment and uniforms, must be safe when used as directed, and must carry clear instructions, hazard warnings and safety data sheets where applicable.
• Vendors must comply with all laws that prohibit or restrict particular substances or materials in goods, and with all labelling, packaging and legal metrology requirements.
• Vendors must supply only genuine, new goods from legitimate sources, and must never supply counterfeit, grey-market, stolen, expired or tampered goods.
• Vendors must notify Snabbit promptly of any defect, contamination, safety concern, complaint, regulatory notice or recall affecting goods supplied to Snabbit, and must cooperate fully with any recall or corrective action.

7.3 Business Continuity

Vendors must maintain plans and procedures to continue or promptly resume supply in the event of a disaster or disruption, such as fire, flood, earthquake, pandemic, cyber incident, strike or other work stoppage, and must resume supply within the timelines agreed with Snabbit. Vendors that supply goods or services critical to Snabbit’s operations must test these plans periodically, share them with Snabbit on request, and notify Snabbit promptly of any event that may disrupt supply.

8.1 Confidential Information

Vendors must keep all confidential information of Snabbit, its Experts and its Customers strictly confidential, use it only to supply Snabbit, share it only with personnel who need to know it, and protect it with at least the care they use for their own confidential information, and in any event not less than reasonable care. This obligation continues after the Vendor’s engagement ends, as provided in the Terms.

8.2 Data Privacy and Localisation

• Where Vendors process personal data on Snabbit’s behalf, they must comply with the Digital Personal Data Protection Act, 2023 and the rules made under it, process the data only on Snabbit’s documented instructions and only for the agreed purpose, and keep it within India.
• Vendors must not sell, share or use such data for their own purposes, including profiling, analytics or marketing.

8.3 Information Security

• Vendors that access Snabbit’s systems or data must implement appropriate technical and organisational safeguards, including access controls, strong authentication, encryption and secure devices, and must comply with Snabbit’s information security requirements.
• Vendors must report any actual or suspected data breach or security incident to Snabbit without delay and within the timelines set out in the Terms, and must cooperate fully in its investigation and remediation.

8.4 Use of Artificial Intelligence

• Vendors must not input Snabbit’s confidential information or personal data into any artificial intelligence tool or service that may retain, disclose or use it, and must not use such information or data to train, fine-tune or improve any artificial intelligence model.
• Vendors must disclose to Snabbit any material use of artificial intelligence in creating deliverables, and remain fully responsible for the accuracy, originality and non-infringement of those deliverables.

8.5 Intellectual Property and Brand Protection

• Vendors must respect and protect Snabbit’s intellectual property, including the Snabbit name, logos and brand assets, and must use them only as authorised in writing by Snabbit and only for the purpose of supplying Snabbit.
• Goods, packaging and materials bearing Snabbit’s brand must be produced only in the quantities ordered. Overruns, samples and rejects must not be sold or given to anyone else, and must be destroyed or delivered to Snabbit as required by the Terms.
• Vendors must not infringe any third party’s intellectual property in supplying Snabbit, and are fully responsible for obtaining any licences needed for third-party materials they use.

8.6 Public Statements and Social Media

Vendors must not make any public statement, press release, social media post or marketing reference about Snabbit, their engagement with Snabbit, or any dispute with Snabbit, and must not use Snabbit’s name or brand, without Snabbit’s prior written consent.

9.1 Wages, Benefits and Labour Law Compliance

• Vendors must comply with all applicable labour laws, including the Code on Wages, 2019, the Code on Social Security, 2020, the Industrial Relations Code, 2020 and the Occupational Safety, Health and Working Conditions Code, 2020, and the rules made under them.
• Vendors must pay at least the applicable minimum wage, pay overtime at the statutory rate, pay wages on time and in full, provide equal pay for equal work, and pay all statutory contributions and benefits, including provident fund, employees’ state insurance, maternity benefit and gratuity, where applicable.
• Vendors must give workers clear written information about their terms of employment and the components of their pay before they start work, in a language they understand. Deductions from wages must be made only as permitted by law, and must never be used as a disciplinary measure.
• Manpower Vendors must, in addition: register all deployed personnel for the statutory social security schemes that apply to them; maintain employee’s compensation or equivalent insurance cover; report any accident or injury to their personnel in connection with Snabbit’s work to Snabbit within twenty-four (24) hours; pay all compensation and benefits due to injured personnel in accordance with law; and provide Snabbit with proof of statutory compliance, such as wage registers and contribution challans, on request.

9.2 Working Hours and Rest

Working hours, including overtime, must not exceed the limits set by applicable law. All overtime must be voluntary, and workers must receive the rest days, rest intervals and leave required by law.

9.3 Child Labour and Young Workers

• Vendors must not use child labour and must not employ any person below the minimum age prescribed under the Child and Adolescent Labour (Prohibition and Regulation) Act, 1986 or other applicable law, and must have effective age-verification procedures.
• Vendors must ensure that young workers above the minimum age are not assigned hazardous work or night work in breach of the law.
• No person below eighteen (18) years of age may be deployed by a Vendor at Snabbit premises or at any Customer’s home.

9.4 Forced Labour and Human Trafficking

• Vendors must not use forced, bonded, prison, indentured or trafficked labour of any kind. All work must be voluntary, and workers must be free to leave their employment on reasonable notice.
• Vendors must not charge workers any recruitment fee or cost, must not retain workers’ identity documents, passports or wages as security, and must not restrict workers’ freedom of movement.

9.5 Non-Discrimination, Dignity and Inclusion

• Vendors must not discriminate in hiring, pay, promotion, discipline or termination on the basis of caste, religion, gender, gender identity, sexual orientation, age, disability, medical condition, pregnancy or marital status, ethnic or social origin, political opinion, union membership, or any other ground protected by law.
• Vendors must treat workers with dignity and respect, and must not use or threaten corporal punishment, physical, mental or verbal abuse, bullying, coercion or intimidation.
• Vendors must have a written policy prohibiting discrimination, harassment and bullying, and must clearly communicate their disciplinary rules and procedures to workers.
• Snabbit encourages Vendors to promote diversity and inclusion in their workforce and supply chain.

9.6 Prevention of Sexual Harassment

Vendors must maintain a workplace free from sexual harassment and, where applicable, must comply with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, including by adopting and publicising a policy, constituting an Internal Committee, conducting periodic awareness programmes for their personnel and acting promptly on complaints. Vendors must cooperate with any inquiry by Snabbit’s Internal Committee involving their personnel.

9.7 Freedom of Association

Vendors must respect workers’ rights to freedom of association and collective bargaining in accordance with applicable law, and must not penalise workers for exercising these rights.

9.8 Health and Safety

• Vendors must provide a safe and healthy workplace, identify, assess and control workplace hazards (including electrical, chemical, fire and ergonomic hazards), and provide appropriate training and personal protective equipment free of charge.
• Vendors must provide, at a minimum, safe drinking water, clean sanitation facilities, adequate lighting and ventilation and, where they provide food or accommodation to workers, ensure it is safe, hygienic and adequate.
• Vendors must maintain emergency preparedness, first aid and fire safety arrangements, conduct periodic drills, and train workers on safety procedures when they join and whenever new equipment, materials or processes are introduced.
• Vendors must prohibit the use, possession, distribution or sale of illegal drugs in their operations and must address substance abuse among their personnel.
• Vendors must record and investigate workplace accidents and occupational illnesses, take corrective action, and report to Snabbit any serious incident connected with Snabbit’s work. Vendors are encouraged to adopt a health and safety management system aligned with recognised standards such as ISO 45001.

9.9 Grievance Mechanism

Vendors must maintain an accessible and transparent grievance mechanism through which workers and other affected stakeholders can raise concerns, including anonymously where possible, without fear of retaliation. Vendors must address grievances promptly and fairly and must protect whistleblowers.

• Vendors must comply with all applicable environmental laws and obtain and maintain all required environmental permits, including under the Environment (Protection) Act, 1986, the Plastic Waste Management Rules, 2016, the E-Waste (Management) Rules, 2022 and the Battery Waste Management Rules, 2022. Any extended producer responsibility obligations applicable to a Vendor remain its own responsibility.
• Vendors must identify, label, store, handle, transport and dispose of hazardous chemicals and materials safely and lawfully, and must monitor, control and treat air emissions, wastewater and waste before discharge or disposal.
• Vendors must endeavour to eliminate single-use plastic from the goods and packaging they supply to Snabbit, and to use recyclable, reusable or sustainable materials where practicable.
• Vendors are encouraged to measure and reduce their environmental impact, including greenhouse gas emissions, energy and water use, and waste, to increase their use of renewable energy, and to protect biodiversity.
• Vendors must respect the land, water and other rights of the communities in which they operate.

• Vendors must select and monitor their Sub-Vendors with care, communicate the requirements of this Code to them, and take reasonable steps to verify their compliance.
• Vendors must not subcontract any part of their work for Snabbit without Snabbit’s prior written consent, as required by the Terms, and must disclose their material Sub-Vendors to Snabbit on request.
• Vendors must source materials responsibly and lawfully, and must not knowingly source from any supplier that uses child, forced or trafficked labour or operates in breach of applicable law.

• Snabbit may verify a Vendor’s compliance with this Code before and during its engagement, including through self-assessment questionnaires, self-certification, document reviews, interviews with workers and audits, conducted by Snabbit or a third party it appoints, physically, virtually or in a combination of both, with or without notice, in accordance with the Terms.
• Audits may cover any matter in this Code, including labour and human rights, health and safety, environmental and ESG performance, information security, business continuity, statutory compliance and performance against contractual commitments such as service levels and quality.
• Vendors must cooperate fully and in good faith with any assessment or audit, provide accurate information and timely access to relevant records, premises and personnel, meet the audit timelines, and procure the same cooperation from their Sub-Vendors.
• Vendors must keep books, records and accounts that accurately and in reasonable detail reflect their transactions with Snabbit. Where an audit reveals any discrepancy, Snabbit may withhold payment of the affected amount in accordance with the Terms until the discrepancy is resolved.
• Where a gap is identified, the Vendor must agree and implement a corrective action plan, with supporting evidence, within the time Snabbit specifies, and Snabbit may monitor its progress. A corrective action plan does not limit any other right of Snabbit. Persistent non-compliance, or failure to cooperate with an audit or to implement corrective action, may lead to disengagement under Section 14.

• Vendors must report any actual or suspected violation of this Code or of applicable law in connection with their dealings with Snabbit, whether by the Vendor, another Vendor, a Sub-Vendor or any Snabbit Personnel, through the channels below. Reports should be made in good faith and on a reasonable basis.
  • General concerns, including bribery, fraud, conflicts of interest and improper conduct by Snabbit Personnel: legal@snabbit.com.
  • Sexual harassment complaints involving Snabbit Personnel or premises: Snabbit’s Internal Committee at posh@snabbit.com.
  • Data breaches and security incidents: legal@snabbit.com, within the timelines set out in the Terms.
  • Concerns involving senior management: legal@snabbit.com.
• Snabbit will treat reports confidentially to the extent possible, will assess them fairly, and will not tolerate retaliation against anyone who raises a concern in good faith. Retaliation includes any adverse action, harassment, discrimination or loss of business connected with a report. Vendors must likewise not retaliate against any of their own workers who raise concerns.
• Vendors must cooperate fully with any investigation by Snabbit or any authority into a potential violation of this Code or applicable law, preserve all relevant documents and information, and not obstruct or interfere with any investigation.
• Knowingly making a false or malicious report is itself a violation of this Code.

A violation of this Code is a breach of the Terms. Depending on its seriousness, Snabbit may, in accordance with the Terms and applicable law: require corrective action; withhold payment where the Terms permit; suspend or cancel purchase orders; terminate any or all purchase orders with immediate effect; suspend or blacklist the Vendor; recover its losses; and report the matter to the relevant authorities. These rights are cumulative and in addition to any other rights or remedies Snabbit may have.

• No waiver: Snabbit’s failure or delay in enforcing any part of this Code is not a waiver of that or any other part, or of any later violation.
• No third-party rights: This Code does not create any right enforceable by any person other than Snabbit and its affiliates.
• Survival: The Vendor’s obligations under this Code continue after its engagement with Snabbit ends, to the extent and for the periods provided in the Terms.
• Severability: If any part of this Code is held invalid or unenforceable, the remaining parts shall continue in full force.
• Language: This Code is issued in English. Any translation is for convenience only, and the English version prevails.

Snabbit may revise this Code from time to time by publishing a revised version, with a new version number and date, and notifying Vendors in writing. A revised version applies to Vendors as provided in Clause 8.10 of the Terms. Each version will remain accessible at its own permanent link.

Queries about this Code may be sent to legal@snabbit.com.

This quick guide summarises key points of the Code for easy reference. It does not replace or limit the Code or the Terms.