Code of Conduct

Palhi Overseas Pvt. Ltd. Is an International recruitment agency (License no. 594/062/063) based in Nepal, licensed by the government of Nepal, Department of Foreign Employment (DOFE). Palhi is committed to implementing recruitment practices that are socially responsible, compliant with all applicable laws, and consistent with respect for the rights of job seekers. We are also committed to seeking out and working with our clients and partners pursuing these shared values through their business practices and standards.

Palhi Overseas is committed to upholding workers’ human rights and treating them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker.

Rights of Workers

1) Freely Chosen Employment

Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not be used. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company- provided facilities. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. As part of the hiring process, workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin. Employers or agents may not hold or otherwise destroy, conceal, confiscate or deny access by workers to workers’ identity or immigration documents, such as government issued identification, passports or work permits, unless the holding of work permits is required by law. Workers are not required to pay employers or agents’ recruitment fees or other aggregate fees in excess of one month’s salary. All fees charged to workers must be disclosed and fees in excess of one month’s salary must be returned to the worker.

2) Young Workers

We ensure that all workers are of legal age in the applicable venue, and free to choose their employment. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education. Workers under the age of 18 are not to perform hazardous work. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. In addition, workers under the age of 18 “Young Workers” shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.

We ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Also, participants shall provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similartasks.

3) Working Hours

Workers receive at least one day off every seven days. The time is usually 9:30 to 5 pm. Workweeks are not to exceed the maximum set by local law. Workers are allowed legally mandated breaks, holidays and vacation days to which they are legally entitled, including time off when ill or for maternity leave. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. An effective working hours policy and implementation mechanism is in place to accurately determine, record, manage and control working hours including overtime and days off.

4) Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Wages are not deducted or reduced for disciplinary reasons. Deduction or withholdings are calculated correctly and submitted to the appropriate government agency within the local law time frame. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed.

5) Humane Treatment

There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers. Adequate and effective policies and procedure on decent/humane working conditions and fair treatment of workers are established and communicated to all workers. Disciplinary actions are recorded, consistent with the procedures and reviewed by management.

6) Non-Discrimination/Equal Opportunity

The Company is committed to a workforce free of harassment and unlawful discrimination. Company has adequate and effective policies and procedure that ban discrimination and harassment. The Company shall not engage in discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages promotions, rewards, and access to training. Workers shall be provided with reasonable accommodation for religious practices. Health tests, pregnancy testing, or contraception are not used as a condition of employment (In some cases, local government requires health tests for foreign workers prior to issuance of work visas).

7) Freedom of Association

In conformance with local law, Company will respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Payroll, promotion, training, hiring, and termination records do not indicate any form of discrimination between workers. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

Health and Safety

1)Occupational Safety

Palhi Overseas Pvt.Ltd. is committed to providing a safe workplace for employees, customers and others on OPM property. We comply with the safety laws, standards and guidelines that apply to our business. Sound safety practices are important in all of our workplaces.

Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance, safe work procedures, and ongoing safety training. We have confined space entry, ventilation flow tests, and drinking water sampling test –report obtained and validated at least once in last 2 years.

2) Emergency Preparedness

Potential emergency situations and events are to be identified and assessed. All legally required fire safety and emergency preparedness permits are in places and available for review and are valid. Emergency response kits are easily located and accessible near muster points. We do have the facility of portable fire extinguishers and an alarm and notification system. Such plans and procedures shall focus on minimizing harm to life, the environment and property.

3) Occupational Injury and Illness

Facility and systems are to be in place to prevent, manage, track and report occupational injury and illness. Company provides necessary medical treatment to the workers at the time of emergency case, investigate cases and implement corrective actions to eliminate their causes and facilitate return of workers to work.

4) Physically Demanding Work

Company facilitate the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluate and controlled.

5) Sanitation, Food, and Housing

The Company provides access to clean toilet facilities, clean drinking water facility, sanitary food preparation, storage and eating facilities. Adequate heat and ventilation and reasonable personal space along with reasonable entry and exit privileges are provided by the company.

6) Health and Safety Communication

Health and safety related information are clearly posted in the facility and clearly announced by the company. We provide appropriate workplace health and safety training in the worker’s primary language.

Environmental

1) Hazardous Substance Management and Restriction

The Company implements a systematic approach to identify, manage, reduce and responsibly dispose of hazardous substances. Company maintains file for last 3 years or the time period, related to air emissions, process waste water discharge and hazardous materials storage and use.

2) Pollution Prevention and Resources Reduction

The use of resources and generation of waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as maintenance and facility processes, materials substitution, conservation, recycling and re-using materials. Written policies, processes, and requirements for environmental protection and pollution prevention/source reduction are in accordance with laws, regulations, and standards are maintained.

Ethics

1) Business Integrity

We have a formal policy on highest integrity business standards and zero tolerance on all forms of bribery, corruption, extortion and embezzlement. All business dealings are transparently performed and accurately reflected on our business books and records. We provide training for management and workers on policy on zero tolerance on all forms of bribery, corruption, extortion and embezzlement and conflict of interest process (including declaration of conflict of interest) is refreshed at least annually.

2) No Improper Advantage

We do not obtain undue or improper advantage by bribe or other means. This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.

3) Disclosure of Information

Information regarding The Company labor, health and safety, business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentations of conditions or practices in the supplychain are unacceptable.

4) Intellectual Property

We respect intellectual property rights and safeguard customer information. A formal policy and programs is in place to protect the information that received from customers as part of the contractingprocess. Such information includes

• Names and contact information of the customers
• Contract pricing and volumes
• Third party intellectual property

5) Protection of Identity and Non-Retaliation

Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained, unless prohibited by law. The Company has a communicated process for their personnel to be able to raise any concerns without fear of retaliation

6) Fair Business, Advertising and Competition

Public information must not make false or misleading statements about services and opportunities. We are always conscious to meet legal requirements. We conduct formal program to ensure public Audited statements are not false or misleading and they meet fair business and advertising legal requirements.

7) Privacy

The Company is to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. The Company is to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

Management System

1) Company Commitment

We will promote the ethical handling of information, so as to ensure respect for human rights and security, through the proper management of personal information based on our Personal Information Protection Policy. We will support flexible work styles and respect diverse values, creating workplaces that provide employees with a sense of accomplishment and personal growth, and we will promote the sustainable growth of the organization and individuals. We will help maintain international peace and security through compliance with all applicable laws and regulations and will operate appropriately according to our internal rules and policies. We will provide services that meet the needs and requirements of our candidates, complying with relevant laws and standards and ensuring quality and safety by setting additional standards of our own where necessary.

2) Management Accountability and Responsibility

The Company clearly identifies senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis. HR & Admin Senior Manager is the code of conduct management representative (Labor, Ethics, and Health & Safety)

3) Legal and Customer Requirements

The Company has a process to identify, monitor, understand, and implement applicable laws, regulations, and customer requirements, including the requirements of this Code. The company maintains documents and records to ensure regulatory compliance.

4) Risk Assessment and Risk Management

The Company develops and maintains a process to identify the legal compliance, environmental, health and safety, and labor practice and business ethics risks associated with Company’s operations. The Company determines the relative significance for each risk and implements appropriate procedures and physical controls to control the identified risks and ensure regulatory compliance. Evaluate information security and execute measures to improve Information security.

5) Improvement Objectives

Written performance objectives, targets and implementation plans to improve The Company’s social and environmental performance, including a periodic assessment of The Company’s performance inachieving those objectives.

6) Training

Programs for training managers and workers are established to implement The Company’s policies, procedures, and improvement objectives, and to meet applicable legal and regulatory requirements. Training is provided in accordance with changes in the laws of the Government pertaining to foreign employment. New staff undergoes training regarding the entire management of the Company and the rules they must adhere to as part of the Company.

7) Communication

The Company conducts performance evaluations to ensure clear and accurate communication of information about its performance, practices, policies, and expectations to its workers and candidates. Communication must be executed fluently, enabling both internal members and external individuals to easily understand and cooperate as per the requirement.

8) Worker Feedback and Participation

The Company has an ongoing process to obtain workers feedback related to this code. Evaluating worker’s feedback is important in the company in order to make improvement in companies. The Company implements a policy where worker’s participation is must and hence helps in improving a lotof changes in the business.

9) Audits and Assessments

The Company performs periodic evaluations of its facilities and operations, and the facilities and operations of its subcontractors and suppliers to ensure conformity to legal and regulatory requirements, the content of the Code, and customer contractual requirements related to social and environmental responsibility.

10) Corrective Action Process

The Company has a process for the timely correction of deficiencies or violations identified by internal or external assessments, inspections, investigations, and reviews. After evaluation and identification of the issues, necessary actions are taken to address them, ensuring that they do not impact future operations.

11) Documentation and Records

Creating and maintaining Company’s records and documents are managed well. Documents are managed in such a way where the privacy cannot be leaked nor the identity of anyone can be easily found. So, company protects everyone documents safely.

12) Supplier Responsibility

The Company has established a process to effectively communicate the requirements of the Code of Conduct to its suppliers and monitor their compliance. This ensures that all suppliers are well-informed about the ethical and operational standards expected from them and that their practices align with the Company’s guidelines. Regular monitoring and assessment are conducted to verify supplier adherence to the Code of Conduct, fostering a culture of responsible and ethical business practices throughout the supply chain.