i. The purpose and our values

The Code of Conduct (hereby referred to as ‘Code’) sets forth Feeding India’s core values, and shared responsibilities into practice. It is built around the recognition that everything we do in connection with our work at Mahesh Foundation will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical, as well as aspirational reasons. Our commitment to the highest standards helps us hire great people, build great products, and attract loyal users.

The Code sets out the values and integrity levels of business conduct that Mahesh Foundation expects all employees to abide by during the course of their employment at Mahesh Foundation and in all business relationships.

The Code cannot possibly address every situation we face at work. Therefore, you are expected to exercise good judgment and seek help for guidance or clarification.

This Code should be read in conjunction with relevant Mahesh Foundation policies and procedures and applicable laws.

ii. Your responsibilities

You will receive a copy of this Code at the time of joining Mahesh Foundation and each year thereafter. You are required to confirm your acceptance to adhere to the principles enumerated in this Code. Additionally, complete all the requisite training in a timely manner. You must remember that under no circumstances does your failure to:

• read the Code

• sign an acknowledgement or certify online

• exempt you from your obligation to comply with the Code

Employees are mandated to:

• Read and understand the importance of the Code and follow it consistently

• Complete all required training(s) related to the Code and other Feeding India policies and procedures in a timely manner

• Know that violation of the Code will result in disciplinary action (and may include, but not limited to termination of employment)

• Use good judgment and demonstrate a high degree of personal and professional integrity and honesty at all times, even in situations that are not specifically addressed by this Code

• Follow the Code as a guideline for decision making that is paired with integrity

• Lead by example, by modeling ethical decision making

• Consider conduct in relation to the Code and other Mahesh Foundation policies

• Seek advice or clarification whenever unsure of the right thing to do

• Report known or suspected violations to appropriate channels, as soon as you become aware of it.

iii. Responsibilities of People Managers:

As a people manager, you should at all times model appropriate conduct.

• Promote a culture of ethics and compliance

• Ensure that your team members are aware of applicable laws, regulations, and Feeding India policies and procedures that govern the respective areas of responsibility/ work and receive adequate guidance and training to perform their jobs the ethical way, as prescribed in the code

• Create an environment of openness and trust where your team members feel secure and comfortable in asking questions and raising concerns, without fear of retaliation

• Discourage your team from achieving business results at the expense of compromising ethical conduct or compliance with the Code or the law

• Escalate any issues or concerns to the appropriate reporting channels in a timely manner.

iv. Speak up: Seek help or report

If you have a concern and/or in doubt regarding any provision of the Code, you should seek clarification, from any of the below reporting channels:

• Your manager

• Your Skip-level manager

• Human Resources

• If you wish to raise a concern about actual or suspected violation of the Code, you are required to write to any of the below reporting channels, as you deem appropriate:

• Human Resources, in case of any violation which relates to personal grievances or your employment, such as (i) superior- subordinate relationship, (ii) relationship with peers, (iii) performance evaluations, and alike

• Mahesh Foundation@maheshfoundation.org, if you believe you have faced any form of sexual harassment

• Mahesh Foundation@maheshfoundation.org, if you believe there is a violation of the Code (such as suspected fraud, bribery or corruption) which may be considered as a Reportable Matter

• Reporting Manager or Human Resources, in case the concern does not fall in any of the above

i. Compliance with Laws and Regulations

Mahesh Foundation is committed to full compliance with the laws, rules and regulations of the countries in which it operates. You must conduct business as responsible corporate persons, and must comply with all applicable governmental laws, rules and regulations. You should avoid any activity that could involve or lead to involvement in any unlawful or illegal practice or cause any harm to Mahesh Foundation's reputation or image or interest. You must acquire appropriate knowledge of the legal requirements relating to your duties/work/business to recognize potential non-compliances/ dangers. In case of doubt, you must seek help for guidance and clarification from the Compliance/ Legal team.

ii. Free and fair competition

• It is in Mahesh Foundation’s best interest to promote free and open competition.

• You are obligated to deal fairly with merchants, suppliers and other Third parties engaging/dealing with Mahesh Foundation. You should not take unfair advantage of anyone through manipulation, concealment, or abuse of privileged information/position, misrepresentation, or any other unfair-dealing practice.

• Mahesh Foundation expects you to maintain a commitment to comply with the antitrust legislations and competition laws applicable to the purpose of Mahesh Foundation.

• As a rule of thumb, you must not:

a. Directly deal with, contact or engage with competitors that may create a potential conflict with the provisions of competition law

b. Share or part with Feeding India specific information in an industry forum or enter into agreements with competitors on any matter, unless done after due consultation with the legal department in advance; and

c. Enter into agreements that may be constructed as abuse of dominance or restrictive trade practices, such as price fixation, exclusive tie-in arrangements, limiting the supply of goods or services, collusive bid rigging or predatory pricing.

iii. Anti-Bribery and Anti-Corruption

Mahesh Foundation strictly prohibits bribery and corruption in any form. You must comply with all applicable laws relating to gifts, bribery, corruption, facilitation payments and other improper payments. However, even in countries where the local law does not prohibit such conduct, it is strictly prohibited by the internal policy of Mahesh Foundation for you to make any payment/s to any person or persons, including public officials, customers, merchants or consultants or any other Third party dealing with Mahesh Foundation, to obtain or retain business, influence business decisions or secure an unfair advantage. This includes bribes, kickbacks and facilitation payments.

We uphold all laws relevant to countering bribery and corruption applicable to us in the conduct of our business across all the jurisdictions in which we operate including, wherever applicable, the Prevention of Corruption (Amendment) Act, 2018 and its amendment (PCA); and the Foreign Corrupt Practice Act, 1977 (FCPA);

iv. Anti-Money Laundering and Anti-terrorist financing

Money laundering is the process by which funds generated from criminal activity such as drug trafficking are moved through legitimate businesses in order to hide their criminal origin. Terrorist financing refers to funding for terrorist activities and can come from legitimate or criminal sources.

Mahesh Foundation only associates with entities and individuals involved in lawful business activities with funds derived from valid sources and not with those who may be involved in criminal activities or are part of any sanction list. Mahesh Foundation is committed to complying fully with all anti-money laundering and anti-terrorism laws throughout the world.

You shall not engage in or aid or abet any other person to engage in the following prohibited transactions:

• Any financial transaction that promotes or results from criminal activity

• The receipt, use, diversion or concealment of the proceeds of any criminal activity

• Any act of terrorism, including providing financial support or otherwise sponsoring or facilitating any terrorist, activity or organization

• Any arrangement or dealing with a Third party, that is or has connection with a Politically Exposed Person (PEP) and/or sanctioned individual/entity

• Any arrangement that would result in a violation of this Code or other Mahesh Foundation policies.

• Some forms of payments and payment related activities that have become associated with money laundering include:

• Payments using monetary instruments that appear to have no identifiable link to the customer or merchant or vendor

• Payments in cash

• Unusually complex deal structures, payment patterns that reflect no real business purpose, or unusually favorable payment terms

• Fund transfers to or from countries unrelated to the transaction or not logical for the customer

• Transactions involving locations identified as secrecy havens or areas of known terrorist activity, narcotics trafficking or money laundering activity

• Payment structures that appear to evade record keeping or reporting requirements (for example, multiple transactions below the reportable threshold amounts)

• Requests to transfer money or return deposits to a third party or unknown or unrecognized account.

v. Avoiding Conflict of Interest

Mahesh Foundation is committed to conducting business in a manner that ensures one’s business judgment and decision making is not influenced by undue personal interests. Conflict of Interest (COI) may arise when a Mahesh Foundation employees places his or her personal interests above the interests of Mahesh Foundation and where such personal interests unduly influence business judgment, decisions, or actions.

Mahesh Foundation respects each one`s rights and choices and does not wish to interfere with their personal lives, however, avoidance of conflict is an important part of maintaining integrity and sustainability of our business and builds trust and support with our key stakeholders.

Feeding India employees in client facing roles including but not limited to Sales, Sales Support, Neutrality, Media Content and Client Servicing across all transaction/ business/function at Feeding India are prohibited from writing reviews and/or giving ratings or experiences in Feeding India from either their personal or Feeding India accounts. They are also not permitted to influence others to write biased reviews or give ratings.

A conflict situation could be actual or perceived and may be an event or circumstance when a person does or consciously fails to do an act which allows the person to derive personal gains.

If any of the key principles of COI are applicable to you, then you must disclose such interest to the Human Resource team here. It is pertinent to note that, disclosure must take place as soon as one identifies the conflict and whenever possible, but before engaging in the conduct in question. Business and relationships are dynamic and when circumstances change, existing disclosures may no longer be accurate or complete. When this happens, it is your responsibility to freshly disclose the conflict of interest.

This clause should be read in conjunction with the Conflict of Interest policy.

vi. Dealing with Third parties

Mahesh Foundation is committed to the highest ethical standards in dealing with Third parties. Dealing with Third parties (including but not limited to, service providers, consultants, merchants, distributors, contractors, vendors, suppliers, or other Third party, whether an individual or an entity, who is employed on a contract basis, or retained to assist Feeding India in any function of the business) should be in a fair and ethical manner.

You must adhere to the following:

• Safeguard the confidentiality of all Third party intellectual property and data and shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable Mahesh Foundation policies or law.

• Understand the business rationale, including its business reputation, and select them on merit basis fairly and transparently.

• Maintain accurate and complete official records with the utmost integrity. All agreements and transactions should be documented. Ensure all Third parties (e.g. merchants) are made aware of the need to comply with the applicable Feeding India policies and guidelines and report any violation thereof.

• Disclose any personal relationship with a potential Third party to your reporting manager and HR POC to ensure they are not involved in the selection process and negotiations.

• Mahesh Foundation would not be responsible for any misconduct or misbehavior on your part in an interaction with any Third parties (customers, merchants, vendors). It shall be your responsibility to ensure they do not exhibit any such behavior.

Mahesh Foundation is committed to provide a work environment that is open, mutually supportive and free of inappropriate behaviour of all kinds and harassment, including but not limited to, harassment based on pregnancy, childbirth, medical conditions (such as HIV positive), race, religious creed, colour, sex, gender (including transgender), gender identity, national origin or ancestry, physical disability, medical condition, marital status, age, sexual orientation, or any other basis protected by federal, state, local law, ordinance or regulation.

Mahesh Foundation maintains professionalism through exercising high standards of integrity and honesty at work, mutual respect towards other individuals in building cordial relationships, good business practices and maintaining a high level of competence.

Mahesh Foundation is an equal opportunity employer and employment decisions are solely based on merit and business needs.

i. Diversity and Inclusion (D&I)

Mahesh Foundation recognizes that diversity is found in any social identity, such as gender, age, culture, nationality, ethnicity, physical abilities, political and religious beliefs, sexual orientation, and other attributes. Inclusion is the process of involving, accepting, and valuing all people in the workplace regardless of their differences and social identity. Mahesh Foundation believes that D&I at the workplace is an instrument for growth and we value and celebrate the uniqueness of every individual by fostering an environment of inclusion and empowerment. Our policies and practices are gender agnostic. We value all of you and each one of you.

ii. Health and Safety in the workplace

Mahesh Foundation promotes your well-being and is committed to provide good and safe physical working conditions. You should exercise high standards of safety, hygiene and housekeeping. Health and safety are of paramount importance.

• You must comply with Mahesh Foundation health and safety norms, as communicated to them from time to time and should bring to the Management’s attention any workplace safety or health hazard.

• It is mandatory on your part to eschew unsafe and dangerous practices or measures, even if these are considered appropriate for business interest reasons. You should attend safety training sessions (as and when organized by Mahesh Foundation for increasing safety awareness and adoption of safe working methods.

• Mahesh Foundation sets expectations for social responsibility in our partner chain and endeavors to select Third parties (e.g. vendors, suppliers and business partners) who- demonstrate a commitment to the health and safety of their workers and comply with laws regulating wages, hours and working conditions; do not use forced labor, or raw materials or finished goods produced by forced labor; and implement programs to ensure no materials come from sources that are responsible for human rights violations.

iii. Human Rights

Mahesh Foundation will not use any form of child, forced, bonded, indentured or prison labour or any form of human trafficking. All work must be voluntary, and you shall be free to leave work or terminate the employment with reasonable notice, as applicable under local law and in compliance with the Mahesh Foundation policy.

The term “child” refers to a person younger than 14 years old or such other minimum age as the local law provides in each geography. This standard does not apply to work or service of performers or recording artists or that otherwise by its nature is reasonably necessary to be procured from a child, to the extent permitted by local law (for example, a child actor/ actress).

iii. Zero tolerance for workplace and sexual harassment

• Mahesh Foundation is committed to creating a healthy and safe workplace for Mahesh Foundation, where they can work without fear of prejudice, gender bias or sexual harassment. We have zero tolerance for harassment, intimidation or humiliation of any kind in the workplace, whether sexual, physical, verbal or psychological.

• Sexual harassment is a serious offence and is therefore, punishable. The objective of the Code and Sexual Harassment policy is to provide a conducive work environment and intolerance to any verbal or physical conduct of sexual nature towards any Mahesh Foundation employee that harasses, disrupts, or interferes with, ones’ work performance or that creates an intimidating offensive, or hostile environment.

• We have clear and fair disciplinary procedures, which necessarily include a FI employees' right to be heard.

This clause should be read in conjunction with the Sexual Harassment Policy

v. Substance abuse and weapons

Mahesh Foundation has strict standards regarding substance abuse and weapons. Mahesh Foundation strictly prohibits use, sale, possession, or being under the influence of illegal drugs or alcohol or controlled substances while working with Mahesh Foundation or at Mahesh Foundation sponsored events, whether consumed during working hours or in the Mahesh Foundation premises. Only designated areas shall be used for smoking.

• You will not possess, conceal or use weapons, including firearms, knives, clubs, ammunition, explosives or other devices that are primarily used to inflict injury (including recreational weapons, such as hunting rifles or crossbows) while on Mahesh Foundation property or when conducting Mahesh Foundation.

• Please note, it is your responsibility to report any case of substance abuse to the specified reporting channel.

i. Protection of confidential information

You should exercise enough safeguards and protect confidentiality of Mahesh Foundation’s information, which includes everything from plans, financial projections, strategy, contracts, contacts, relationships and personal information. Mahesh Foundation information should be shared only on a ‘need-to-know’ basis, that is, to the extent the information is needed to perform their job/work responsibilities.

ii. Payroll information

All compensation matters are privileged and to be kept confidential. You must ensure that information about salaries, appraisals and bonuses are not disclosed to other people within or outside Mahesh Foundation.

iii. Unauthorized use of confidential information

You shall not disclose or use any confidential information gained in the course of employment or association with Mahesh Foundation for personal gain or for the advantage of any other person. No information either formally or informally, shall be provided to the press, other publicity media, or any other external agency, except by the authorized representative. It is strictly forbidden to trade confidential information or insider’s information for individual gain, or to benefit or to put Mahesh Foundation’s interest in jeopardy.

iv. Use of Mahesh Foundation Assets

• You are responsible for protecting and taking necessary steps to prevent the theft or misuse of, or damage to Mahesh Foundation’s assets and property. The assets include all kinds of physical assets, movable, immovable and tangible property, corporate information and intellectual property, such as inventions, copyrights, patents, trademarks and technology.

• Mahesh Foundation’s assets and property should be used only for the benefit of Mahesh Foundation and in the manner intended. Certain Mahesh Foundation policies may allow additional personal use of certain assets, such as a Mahesh Foundation provided phone. In using such assets, you are expected to exercise prudent judgment and avoid excessive personal use.

• You are solely liable for any losses incurred by Mahesh Foundation in case of damage/loss/theft of these assets.

• Any suspected incident of fraud, misuse or theft should be immediately reported for investigation.

v. Email, Internet and Information Systems

Mahesh Foundation's information technology systems constitute a critical component of our business operation and are provided for authorized business purposes only. Use of these systems must comply with our internal policy and acceptable use standards.

You may engage in reasonable incidental personal use of phone, email and the internet, as long as such usage does not:

• Consume a large amount of time or resources.

• Interfere with your work performance or that of others.

• Involve illegal, sexually explicit, political, discriminatory or otherwise inappropriate material

• Relate to outside business interests.

• Violate our Code or any Mahesh Foundation policy.

While it is generally not our practice to monitor Mahesh Foundation’s employee use of our information systems, Mahesh Foundation reserves the right to monitor, record, disclose, audit, and delete without prior notice the nature and content of any Mahesh Foundation Employee’s activity using Mahesh Foundation’s email, phone, voicemail, internet, and other systems, to the extent permitted by local law.

i. Upholding Financial Integrity and Record keeping a. Mahesh Foundation shall prepare and maintain its accounts fairly in accordance with the generally accepted accounting principles, guidelines, financial accounting standards and applicable regulations from time to time. All business and financial transactions must be authorized and recorded in accordance with the internal approved finance document. b. All books of account, financial records, reports and other financial documents of Mahesh Foundation must be accurate and preserved in good order and may be disposed of by the Finance Department as per Information storage, archival policy. You are expected to demonstrate integrity, professionalism and due diligence in maintaining accurate records of all financial transactions (e.g., expense reimbursement forms, disclosure forms etc.

ii. Interaction and cooperation with Auditors Our outside auditors have a duty to review our records in a fair and accurate manner. We must cooperate with them in good faith and in accordance with the law. We must never mislead them in any manner regarding financial records, processes, controls or procedures or other matters which they may enquire about.

iii. Interaction and cooperation with Regulators We must fully and truthfully cooperate with any examination or request for information from a regulator or law enforcement agency or other investigation consultant/ agency, if any, as appointed by the management. Only authorized representatives from the legal team will be the point of contact for any communication or flow of information to the regulator, law enforcement agency or others, if any.

i. External Communication and Media

Mahesh Foundation does not prohibit Mahesh Foundation employee’s to use social media, however, it is recommended that you use it meticulously and responsibly, in order to avoid damaging the brand`s image and reputation or disclosing any confidential information of Mahesh Foundation.

All your communication and expression on social media should be followed by a social media disclaimer, as below, in order to give an impression that you are not speaking or posting on behalf of Mahesh Foundation.

a. All views, posts and opinions shared are my own;

b. All views are obviously just mine; and

c. All views are personal.

Mahesh Foundation shall carefully review the public disclosures, such as press release(s), financial statements, annual reports, and external website content, before they are released to the external parties (media, stock exchanges, investors, lenders, business partners and others ) and public to ensure they are truthful, accurate, appropriate, and compliant with applicable laws and regulations.

All inquiries or calls from any external parties should be referred to the Corporate Communications team.

ii. Marketing

Marketing is an essential instrument for effective brand building and communicating with all stakeholders. We strive to ensure that our marketing activities are truthful, accurate and are done ethically.

Our marketing activities, displays, and promotions must always be appropriate and sensitive to the culture public in the country in which they are is shown and should avoid political or religious remarks, that may be offensive or defamatory.

In case of doubt regarding the marketing activity, displays, and promotions, that it may be construed as misleading or hurt sentiments, you must seek help for guidance and clarification from the Legal team.

ii. Political activities

Mahesh Foundation is an apolitical organization

Mahesh Foundation respects your right to engage in political activities in personal capacity, provided you do not act, or give the impression of acting, as a representative of Mahesh Foundation and do it solely in your personal capacity. You are prohibited from directly or indirectly utilizing any Mahesh Foundation resources for personal political activities, including but not limited to funds, facilities or any property, or the working time of any FI employees, except as authorized by relevant local policies or procedures. You must not be a part of or join an extremist’s organization.

Mahesh Foundation’s outlook towards driving social change is governed by two key principles:

Mahesh Foundation is an apolitical organization, and has no political affiliations/ aspirations whatsoever; and Mahesh Foundation cares for the society, but also strongly believes in the saying, “your opinions don’t matter, your actions do”.

As a Mahesh Foundation, you are prohibited from making, sharing, criticizing or endorsing any politically flavored statement on any of your social profiles. In case you post any such message you should clearly state that views are personal and not of Mahesh Foundation.

Mahesh Foundation believes that its employees will act with utmost integrity, however, if at times, the Investigation team has reasonable cause to believe that a employee has failed to comply with the requirements of this Code or other Mahesh Foundation policies and procedures, they shall inform him/her of the basis for such belief and afford him/her an opportunity to explain the reasons for the same.

FI employee must know:

• We take every concern seriously and our Investigation team (or a delegate for locally-managed or other matters) will investigate it thoroughly to determine whether it is qualified for further investigation;

• If yes, the Investigation team shall conduct such investigation in a timely manner and shall submit a written report containing the findings and recommendations in the shortest time possible, not later than 60 days from the date of receipt of the concern;

• The Investigation team will treat all complaints in a confidential and sensitive manner.

• All investigations conducted will be concluded by way of an investigation report.

This clause should be read in conjunction with the Vigil Mechanism &Whistleblower or Sexual harassment policy, as applicable.

i. Action For Non-observance

If the Investigation team arrives at the conclusion that the allegation has been proved, it shall recommend actions, which may include one or more of the following:

• Written apologies

• Warnings

• Reprimand or censure

• Withholding of promotion

• Withholding of pay increments

• Termination of employment

• Recovery

• Legal action

• And any other action, the investigation team deems fit.

ii. Confidentiality

Upon the request of the complainant, the Investigation team will use its best efforts to protect the confidentiality of the complainant for any good faith report. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

ii. Prohibition against retaliation

Mahesh Foundation strictly prohibits any reprisal, threats, retribution or retaliation against any employee who has in good faith reported a violation or a suspected violation of law, this Code or other policies or practices of Mahesh Foundation, or against any person who is assisting in any investigation or process with respect to such a violation. Any employee who retaliates against someone who has reported a violation in good faith will be disciplined, which can include termination of employment.

ii. Acting in good faith

Any good faith report, concern or complaint is fully protected by this Code, even if the report, question or concern is, after investigation, not substantiated. Anyone filing a complaint concerning a violation/ misconduct or suspected violation/ misconduct must act in good faith and have reasonable grounds for believing that the act reported indicates a violation of the Code or other policies. Any allegations that are proven to

be unsubstantiated and found to be malicious in nature, will be treated as a serious disciplinary offense.

No waiver and amendments of any of the provisions of this code shall be valid unless they are specifically approved by the Head of Mahesh Foundation.