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Code of Business Conduct and Ethics

Organization: Cloudnaut Technologies LLP
Classification: Internal
Document status: Effective
Version: 1.0
Effective date: 2026-10-15
Owner: Management
Applicability: All employees, consultants, contractors, and personnel acting on behalf of Cloudnaut Technologies LLP
Review cycle: At least annually and upon material changes to applicable legal, regulatory, contractual, or business requirements

Document control

Role Name
Prepared by Management (Cloudnaut)
Reviewed by Sandeep AC
Approved by Sandeep AC

Revision history

Version Date Summary Reviewed by Approved by
0.9 2026-10-06 Initial draft. Sandeep AC —
0.9 2026-10-15 Links to AI governance, incident response, and HR security policies. Sandeep AC —
1.0 2026-10-15 Initial effective release. Sandeep AC Sandeep AC

1. Purpose

Cloudnaut Technologies LLP (“Cloudnaut”) is committed to conducting business ethically, professionally, transparently, and in compliance with applicable laws, contractual obligations, and customer requirements.

This Code of Business Conduct and Ethics (“Code”) establishes the standards of conduct expected from all Cloudnaut personnel when interacting with customers, business partners, suppliers, colleagues, government authorities, and other stakeholders.

All personnel are expected to exercise sound judgment, act with integrity, and avoid conduct that could adversely affect Cloudnaut, its customers, partners, or other stakeholders.

2. Scope

This Code applies to all Cloudnaut employees, consultants, contractors, and other personnel acting on behalf of Cloudnaut.

Personnel working on customer or partner engagements must also comply with applicable customer and partner policies, codes of conduct, security requirements, confidentiality obligations, and contractual requirements communicated as part of the engagement.

Where customer or partner requirements impose a higher standard than this Code, personnel are expected to comply with the applicable higher standard, subject to applicable law.

3. Compliance with Laws and Regulations

Cloudnaut personnel must comply with applicable laws and regulations in the jurisdictions in which they perform their duties.

Personnel must not knowingly participate in, facilitate, conceal, or encourage unlawful or unethical activities.

Where personnel are uncertain about the applicability of a legal, regulatory, contractual, or customer requirement, the matter should be escalated to Cloudnaut management before proceeding.

4. Integrity and Ethical Business Conduct

Cloudnaut expects personnel to conduct business honestly, fairly, and in good faith.

Personnel must:

  • provide accurate and truthful information in business communications and records;
  • avoid intentionally misleading customers, partners, suppliers, colleagues, or other stakeholders;
  • accurately represent their qualifications, experience, authority, and responsibilities;
  • perform assigned responsibilities professionally and with appropriate care; and
  • promptly disclose material errors or issues that could affect a customer, partner, engagement, or Cloudnaut.

Falsification of records, deliberate misrepresentation, fraud, theft, or other dishonest conduct is prohibited.

5. Anti-Bribery and Anti-Corruption

Cloudnaut does not tolerate bribery, corruption, kickbacks, facilitation payments, or other improper inducements.

Personnel must not directly or indirectly offer, promise, authorize, request, accept, or provide anything of value for the purpose of improperly influencing a business or governmental decision.

Gifts, entertainment, hospitality, or other business courtesies must be reasonable, lawful, infrequent, and must not create or appear to create an improper obligation or influence.

Personnel must exercise particular care when interacting with government officials or representatives of public-sector organizations.

6. Conflicts of Interest

Personnel must avoid situations in which personal, financial, family, or other interests improperly influence—or could reasonably appear to influence—their professional judgment or responsibilities.

Potential or actual conflicts of interest must be disclosed promptly to Cloudnaut management.

Personnel must not use their position, customer relationships, confidential information, or Cloudnaut resources for improper personal benefit.

7. Confidentiality and Customer Information

Cloudnaut personnel must protect confidential and proprietary information belonging to Cloudnaut, customers, partners, suppliers, and other third parties.

Confidential information must:

  • be accessed only when required for authorized business purposes;
  • be used only for the purpose for which access was granted;
  • not be disclosed to unauthorized individuals or organizations;
  • be stored, transmitted, and processed using approved systems and methods; and
  • be handled in accordance with applicable contractual, customer, information-security, and data-protection requirements.

Confidentiality obligations continue after an engagement or employment relationship ends where required by law, contract, or the nature of the information.

8. Information Security and Acceptable Use

Personnel are responsible for protecting information systems, credentials, devices, source code, customer information, and other technology resources entrusted to them.

Personnel must comply with applicable Cloudnaut and customer information-security requirements, including requirements concerning:

  • authentication and access control;
  • passwords and multi-factor authentication;
  • endpoint and device security;
  • secure software development;
  • handling of source code and repositories;
  • vulnerability and patch management;
  • protection of credentials, secrets, and cryptographic material;
  • approved software and services; and
  • reporting of suspected security incidents.

Personnel must not intentionally circumvent security controls or use unauthorized systems, applications, repositories, storage locations, or communication channels to process customer information.

When customer-provided devices or environments are required for an engagement, personnel must comply with the customer's applicable security and acceptable-use requirements.

9. Data Protection and Privacy

Cloudnaut respects the privacy of employees, customers, partners, and other individuals.

Personal data must be collected, accessed, processed, disclosed, retained, and disposed of only for legitimate and authorized purposes and in accordance with applicable legal, contractual, and customer requirements.

Personnel must limit access to personal data to what is necessary for their assigned responsibilities and must promptly report suspected unauthorized access, disclosure, loss, or misuse.

10. Intellectual Property

Cloudnaut respects the intellectual-property rights of customers, partners, suppliers, employees, and third parties.

Personnel must comply with applicable licensing, copyright, trademark, patent, confidentiality, and contractual requirements.

Customer source code, documentation, designs, configurations, data, credentials, and other intellectual property must not be copied, reused, disclosed, or transferred outside the authorized engagement environment unless expressly permitted.

Open-source software and third-party components must be used in accordance with applicable licenses and customer requirements.

11. Fair and Respectful Workplace

Cloudnaut is committed to maintaining a professional workplace in which individuals are treated with dignity and respect.

Discrimination, harassment, bullying, intimidation, retaliation, violence, or other abusive conduct is not acceptable.

Employment and professional decisions should be based on legitimate business considerations, qualifications, performance, skills, and applicable legal requirements.

Cloudnaut expects personnel working at customer or partner locations, whether physically or remotely, to comply with applicable workplace-conduct requirements.

12. Human Rights and Labor Practices

Cloudnaut supports internationally recognized principles relating to human rights and fair labor practices.

Cloudnaut does not knowingly tolerate:

  • forced, bonded, or involuntary labor;
  • human trafficking;
  • unlawful child labor;
  • discriminatory employment practices; or
  • working conditions that violate applicable employment, health, or safety laws.

Cloudnaut expects its personnel and, where applicable, suppliers and business partners to conduct business in a manner consistent with these principles.

13. Health, Safety, and Environment

Cloudnaut seeks to provide a safe and healthy working environment and expects personnel to comply with applicable occupational health and safety requirements.

As a technology and professional-services organization, Cloudnaut also seeks to reduce unnecessary environmental impact through responsible use of technology resources, digital-first processes, appropriate handling of electronic equipment, and other reasonable sustainability practices.

14. Customer and Partner Relationships

Cloudnaut personnel must act professionally and ethically when representing Cloudnaut to customers and partners.

Personnel must:

  • comply with agreed contractual and engagement requirements;
  • respect customer and partner policies applicable to the engagement;
  • protect customer assets and information;
  • accurately report project status, risks, issues, and work performed;
  • avoid unauthorized commitments on behalf of Cloudnaut, customers, or partners; and
  • escalate material security, compliance, ethical, or delivery concerns through appropriate channels.

Personnel must not misuse customer or partner access, systems, information, facilities, or relationships.

15. Accurate Business Records

Business, financial, operational, project, time, expense, and other records created or maintained by Cloudnaut personnel must be accurate and complete.

Personnel must not knowingly create false records, conceal material information, submit inaccurate time or expense information, or alter records for an improper purpose.

Records must be maintained and disposed of in accordance with applicable legal, contractual, customer, and Cloudnaut requirements.

16. Responsible Use of Artificial Intelligence and Technology

Personnel must use artificial intelligence, automation, cloud services, and other technologies responsibly and in accordance with applicable Cloudnaut and customer requirements.

Confidential information, customer data, source code, credentials, personal data, or other restricted information must not be submitted to unauthorized public or third-party AI services.

Use of AI-assisted tools for customer engagements must comply with customer requirements, contractual restrictions, intellectual-property obligations, information-security requirements, and applicable laws. See the AI Governance and Acceptable Use Policy.

17. Reporting Concerns and Violations

Personnel are expected to promptly report suspected violations of this Code, applicable laws, contractual obligations, customer requirements, or information-security requirements.

Concerns may be raised with Cloudnaut management or through other designated internal reporting channels.

Security incidents or suspected unauthorized disclosure of customer information must be escalated promptly in accordance with the Incident Response and Management Policy and applicable customer-notification requirements.

Personnel are expected to cooperate with legitimate investigations and must not intentionally conceal relevant information.

18. Non-Retaliation

Cloudnaut does not tolerate retaliation against personnel who, in good faith, raise concerns, report suspected misconduct, participate in an investigation, or seek guidance regarding ethical or compliance matters.

Knowingly making false or malicious allegations is itself inconsistent with this Code.

19. Violations and Enforcement

Violations of this Code may result in corrective or disciplinary action, including removal from a customer engagement, termination of access, termination of employment or contractual relationships, and, where appropriate, referral to relevant authorities.

The action taken will depend on the nature and severity of the violation and applicable legal and contractual requirements.

20. Responsibilities

All Cloudnaut personnel are responsible for understanding and complying with this Code.

Managers and engagement leads have additional responsibility to promote ethical conduct, respond appropriately to concerns, and ensure that applicable customer, partner, contractual, and security requirements are communicated to personnel under their supervision.

Cloudnaut management is responsible for maintaining this Code and periodically reviewing it for continued suitability.

21. Review and Continuous Improvement

Cloudnaut will periodically review this Code and related policies, standards, and processes considering changes to the organization's operations, applicable laws and regulations, contractual obligations, customer requirements, and recognized industry practices.

Updates will be communicated to relevant personnel as appropriate.

22. Acknowledgement

Personnel are expected to familiarize themselves with this Code and comply with its requirements while performing activities on behalf of Cloudnaut Technologies LLP.

Questions regarding interpretation or application of this Code should be raised with Cloudnaut management.