a.    In this Policy, the mentioned terms shallmean the following:

i.     Theterms 'I' or 'you' may mean the Vendor or the User or the Client or a concernedcardholder, for this policy, unless stated otherwise. 
ii.     'Consultant'or 'Consultants' shall means Vilasani Ventures, the registered entity in theform of LLP (Limited Liability Partnership), OR under any other genre/type ofregistered entity under the Indian legislation. The said 'Consultant' or'Consultants' is/are engaged in providing various consultancy services in theirown capacity and network. 
iii.     'Website'shall mean a collection of interrelated, accessible web pages that are hostedon a specific domain or subdomain, typically containing text, images, videos,and other digital content, which can be accessed over the internet using a webbrowser. It is generally designed to provide information, services, products,or other functionalities to users, and may include interactive elements such asforms, e-commerce capabilities, or user-generated content. It is typicallyaccessible through a unique URL (Uniform Resource Locator) and is hosted on aserver, which allows users to connect and interact with the website via theWorld Wide Web.
iv.     'User'or 'Users' shall mean any human, person, entity, agency, establishment,proprietor, firm, individual, company, incorporation, human controlled bot(s),a collection of the mentioned subjects or any combination of them, or any otherliving entity capable of accessing a Website, and consume its data throughappropriate or any medium or any forms.
v.     'Vendor'shall mean any individual, entity, agency, incorporation, establishment, orthird-party supplier that provides goods, services, or products to theConsultant under a Vendor Agreement OR has already provided it. The Vendor maybe engaged by the Consultant to supply specific materials, resources, orservices that are necessary for the completion of a project or a Service or thefulfilment of the Consultant's obligations to its Clients or any otherindividual. The Vendor is responsible for delivering the goods or services inaccordance with the terms and conditions set forth in the relevant VendorAgreement, including but not limited to, quality standards, timelines, pricing,warranties, and compliance with applicable laws and regulations. The Vendor'srelationship with the Consultant is governed by the specific terms of theVendor Agreement and is distinct from the Consultancy firm's directrelationship with its clients.
vi.     'Client'shall mean any individual, corporation, partnership, agency, firm, individual,company, or other legal entity that engages the Services of the Consultantrespectively. The Client may be the recipient of advice, Services, orprofessional consultation, and may also include any authorized representativesor agents of the Client who are acting on behalf of the Client in connectionwith this engagement. It shall also include both the primary contracting partyand any third-party entities or individuals designated by the Client to receiveor benefit from the services provided by the Consultant.
vii.     ‘Conflictsof Interests’: A conflict of interest exists if you engage in any personal orbusiness related activity, including holding a Financial Interest, that (i) Couldactually or potentially interfere with your responsibilities or judgment onbehalf of the Consultant or its Clients, or (ii) Conflicts, or appears toconflict in any way, with the interests, or damages the reputation, of theConsultant.
viii.    ‘FinancialInterests’: Any ownership interest in publicly traded or private companies, orloans from outside organizations (except personal loans, mortgage loans, andsimilar loans from commercial or savings banks). However, it does not includestocks in mutual funds or exchange traded funds (ETFs), or other forms ofownership as may be pre-approved in writing by any Designated Partner of theConsultancy or their designee on a case-by-case basis. 
ix.     ‘Gifts& Hospitality’: There are  things ofvalue provided to a third party. A gift is something of value provided wherethere is no host. Hospitality includes things of value like meals or entertainmentwhere there is a host. If there is no host, then hospitality becomes a gift.
‍x.     ‘immediateFamily’: Is a User’s/Client’s/Vendor’s/individual’s spouse, domestic lifepartner or equivalent, dependent children or dependent parents. A separatedspouse, separated domestic life partner, or equivalent, will be considered partof the User’s/Client’s/Vendor’s/individual’s Immediate Family if the associatefiles a joint tax return with the separated spouse. 
xi.     ‘Relative’:Is a spouse or domestic life partner, parent, child, sibling, grandparent,grandchild, in-law, nephew, niece, cousin, aunt or uncle.
 xii.     ‘TradeAssociations’: Consist of businesses that operate in a specific industry. 
xiii.    ‘Associates’ maymean and include the Consultant’s employees, related workforce (director indirect), Vendor, Client, User or any other remotely connected individual.Please note, that the Consultant shall have the right to interpret thisdefinition to include or exclude any designation or individuals as and whenrequired, irrespective of whatever is mentioned here currently, AS PER thespecific Clause/Section of this Policy, as and when required, by the Consultantonly,

a.    Business decisions must be made withintegrity and not influenced by conflicts of interest. As an LLP known fordelivering actionable, objective insights to executives and their teams, it isimportant that the Consultant’s associates, employees, related workforce(direct or indirect), Vendor, Client, User or any other remotely connectedindividual, must recognize that sometimes personal interests may hinder theirobjectivity.
‍b.     AConflict of Interest occurs when the Consultant’s Associates, personalinterests - family, friendships, financial - compromise their judgment,decisions, or actions at work. Actual conflicts of interest are prohibited. Apotential conflict of interest exists when it appears that their interestsconflict with the Consultant’s interests, but disclosing that potentialconflict, seeking approval, and complying with guardrails implemented toeliminate the conflict address the situation.

a.     This policy applies to every Consultant’s Associates. In certain cases, it mayimpact the Consultant’s Associates’ Immediate Families and Relatives.

a.     AllAssociates with a conflict of interest (either an actual or a potentialconflict) must disclose the same to the Consultant. The said disclosure shallbe reviewed by relevant teams, including the Consultant’s Designated Partners,and approval (if any) will be provided based on this policy.

a. The following are examples ofcommon conflicts of interest; it is not an exhaustive list. Even if aparticular situation is not expressly mentioned, it may be a conflict ofinterest and Associates should self-report it accordingly to the Consultant. Here are the Finanical Interests:

i.     Competitors: Associates may not have aFinancial Interest in an entity that competes with the Consultant.
ii.     Companies in Industries Evaluated by the Consultant: Thefollowing Associates are subject to Financial Interest restrictions based ontheir roles:

1.     Operations: Associates of the Consultantinvolved in Operations (as decided by the Consultant) may not have a FinancialInterest in any entity that is evaluated by the Consultant or over which amember of such Operations may exert an influence by virtue of their role atGartner.
‍2.     Research & Advisory: Research &Advisory (R&A) Associates (if any) who evaluate products (if any) orServices or make product or Service recommendations, their Team Managers, andmembers of their Immediate Family, may not have a Financial Interest in anyentity within their research coverage area. If such a R&A Associate or TM’sRelative is employed by an entity in their research coverage area, the Associateor TM must promptly notify and disclose the same to the Consultant.
‍3.     Consulting: Consulting Associates (if any) whoevaluate products (if any) or Services as part of fulfilling engagements orsupervise such engagements, and members of their Immediate Families, may nothave a Financial Interest in any company whose products or Services theyevaluate in the engagements they participate in or supervise. If such aConsulting associate’s Relative is employed by an entity included, or an entitythat may be included, in the evaluation, the consulting associate must promptlyand disclose the same to the Consultant.

iii.     Vendors: If an Associate is in a position toinfluence the Vendor’s decisions (or can be perceived to influence the Vendor’sdecisions), neither that Associate nor members of that Associate’s ImmediateFamily may have a Financial Interest in any entity that does or seeks to dobusiness with the Consultant and must promptly and disclose the same to theConsultant. While Associates in Sales/Onboarding department (or anything oflike nature, and those who supervise them) are the Associates typicallyaffected by this rule, it applies to any Associate that participates indecisions related to Sales/Onboarding.

b.    Further, unless previously agreed upon, itis important that all Associates do not share, endorse, opine on, or become atestimonial for or otherwise disclose any of the Consultant’s Vendor’s. To doso could imply endorsement or disparagement, which could jeopardize theConsultant’s independence and objectivity.
‍c.     Withoutprior approval, Associates shall not enter into agreements on behalf of theConsultant with any outside entity if they know that the entity is a “relatedparty” to any Associate (that is, the contract would financially benefit,either directly or indirectly, an Associate or their Relatives).

a.     Givingand receiving Gifts, and exchanging other customary business courtesies andentertainment of nominal value with the Consultant’s Clients, providers, andorganizations, Vendors, Users, etc. covered in research are only allowed whenthey comply with the Consultant’s various related and all other policiesbecause the Consultant never makes, nor wants to give the perception that itmakes, business decisions based on the Gifts or entertainment Associates mayreceive. Giving and receiving lavish or excessive Gifts, as well as providingor accepting lavish or excessive Hospitality to or from the Consultantprospects, Clients, suppliers, Vendors, Users, etc. or other providers withwhom the Consultant conducts business may violate global or local anti-briberyand anti-corruption laws and the Consultant’s corporate policies. (See theAnti-Bribery Policy.)

a.     Participationin activities outside of work must be done at the Associates’ expense and ontheir own time. Associates may not use any Consultant’s products (if any),influence, facilities, Services, or other resources for their personal benefitor the benefit of any outside entity, company or organization. Other criteriamay apply based on the Associate’s role or anything of like nature.

i.     Authoring books or other publications (includingopen-source contributions): Associates may write books unrelated totheir work at the Consultant’s (for example, writing a children’s book or abook on sewing) without approval. However, while employed at the Consultant’s,Associates may not independently publish books, articles, or any otherpublications on topics evaluated by the Consultant. Open-source contributionsare permissible, as long as they:

1.     Havetheir own standalone source code repository.
‍2.     Don’treuse or rely on the Consultant’s code (if any).
‍3.     Don’tfacilitate illegal activities (for example, crypto mixers, etc.)

ii.     Non-profit Board of Directors / Advisory Board ofDirectors & Volunteer activities: Participating on non-profitboards and in non-profit volunteering activities do not require approval,except for non-profit industry/Trade Associations, in which case, theAssociates shall compulsorily promptly communicate and disclose the same to theConsultant.. Associates’ participation as officers, directors, advisors orcommittee chairperson/members of a non-profit organization are in theirindividual capacities, are not on behalf of the Consultant, and any viewsexpressed are their own (associates are responsible for ensuring the non-profitboards understand this). 
iii.     Any outside employment or joining a For-profit Board ofDirectors or Advisory Board of Directors: Associates seekingemployment outside of the Consultant’s domain or legal gambit, or those wishingto serve as officers, directors, advisors, partners, or owners with anyfor-profit entity, shall compulsorily have the written approval of theDesignated Partners of the Consultancy. The said approval shall not be given ifthe organisation/entity in question:

1.     Competes,directly or indirectly, with the Consultant or any of its products or services;for example, offers strategic, objective insight to executives and their teams,or writes research for consumers to make informed purchasing decisions;
‍2.     Manufacturers,markets, or distributes products or services that the Consultant evaluates tohelp Clients make decisions, or such coverage is planned soon;
‍3.     Conflicts,or appears to conflict, with the interests of the Consultant or damages theConsultant’s reputation; for example, the outside employment involves the sameskills or is closely related to the associate’s work at the Consultant’s; or
‍4.     Requiressignificant time during working hours, eventually becoming a hinderance at thework done/executed at the Consultant’s.

iv.     Associates engaged in any outside employment may not:

1.     Usethe Consultant’s resources; or
‍2.     Solicitother Associates, Clients, Vendors, Users, or prospects (i.e., nocross-pollination). Any other Associate/Vendor/User/individual, or theAssociate itself engaged in any outside employment, shall have theresponsibility to disclose the same to the Consultant. Failure of suchcommunication shall give the Consultant the right to take voluntary andunconditional retaliatory actions, if and when required, respectively.

a.     Associatesare not authorized to make or approve any contributions or expenditures of theConsultant’s funds or use the Consultant’s facilities, equipment, or suppliesto support or oppose political activity in any jurisdiction. While Associatesmay make personal political contributions, they should never be connected totheir work at the Consultant and there should never be a quid pro quo orsuggestion that it was made to influence any business decisions. This canviolate not only this policy, but also may violate, or appear to violate,anti-corruption laws. (See the Anti-Bribery Policy.)

a.     Prior to pursuing an elected or other appointed public office, Associates must obtainwritten approval for the same from the Designated Partners of the Consultancy.Unless required by law, the Consultant will not pay for time spent running forpublic office, serving as an elected official, or campaigning for a politicalcandidate. Associates are responsible for making it clear that their positionsare personal ones and are not made on behalf of the Consultant.

a.     SomeAssociates, including R&A Associates (if any, as decided by theConsultant), other Consultants (not the one defined in this Policy), ExecutivePartners, Managers and Leadership Partners, or any other like or similar concerneddesignation(s) create intellectual capital that is sold to the Consultant’sClients. For that reason, when they speak at public forums on topics evaluatedby R&A Associates (if any, as decided by the Consultant), their opinionsshould align with the respective published research. Associates in these rolesshould compulsorily submit a written request to speak publicly to the DesignatedPartners of the Consultancy. Associates in other roles have to adhere to thesame process mentioned above. Please note, that every Associate, in anyrole/designation, are responsible for making it clear that any opinionsexpressed are their personal views and do not represent the views of theConsultant.

a.     Associatesmay not condition the Consultant’s decision to purchase a Vendor’s goods orservices on that entity’s agreement to purchase the Consultant’s goods orServices. The Consultant’s Vendor may also be its Client, but the decision ofboth the Consultant and the Vendor to use each other’s goods and Services mustbe made independently.

a.    Personal or romantic relationships betweenAssociates in circumstances where one individual has direct or indirectinfluence or control over the other's hiring, firing, promotions, performancemanagement, compensation, or other conditions of employment create actualconflicts of interest and are therefore prohibited. Personal or romantic
‍b.     relationshipsbetween Associates who are not in a direct or indirect reporting relationshipare generally permissible as long as they are consensual and do not negativelyaffect the Consultant’s business, the participants’ working relationship, orassociate dynamics. The Consultant expects that Associates in a romanticrelationship will conduct themselves in a business-like manner at work andminimize the impact of the relationship in the workplace.

a.     Associatesmay have Relatives that work for the Consultant. No Associate may participatein the selection or hiring process of a Relative. The Associate may notdirectly or indirectly supervise a Relative or use their position to influenceor attempt to influence any aspect of a Relative’s employment at theConsultant’s.

a.    All the Sections and every single provisionin this Policy, are subject to the provisions of the Terms & Conditions(different document), AND the provisions of the 'Vendor Agreement' (differentdocument, if read by the Vendor), their respective MoUs  (as and when applicable), AND any otherlegally binding document, policy, agreement (if any) provided and madeapplicable by the Consultant respectively.
‍b.     The Consultant shall have the complete unilateral right and authorityto interpret this Policy and its various provisions, terms, sections, etc. asand when applicable.

a.     TheConsultant may update this Policy periodically. The same shall be  notified to the concernedUser/Client/Vendor/individual of any material changes by:

i.     Posting the new policy on the Consultant's website; or
ii.     Sending an email notification; or 
iii.     Displaying a prominent notice on the Consultant's Website; or
iv.     Through and by any other means which the Consultant deems fit and islegal.

a.     Ifany User/Client/Vendor/individual has an enquiry or a complaint about the waythe Consultant handles this Policy, or to seek any clarification for the same,then simply communicate the Consultant citing the same. The same shall bereplied to the concerned User/Client/Vendor/individual within a reasonabletime, at the total discretion of the Consultant. The address for the same is asfollows:

i.     Email Address: support@vilasaniventures.com   OR info@vilasaniventures.com
ii.     Postal Address: Unit - 542, 5th Floor, Tower A2, SPAZE ITECH PARK,Badshahpur Sohna Rd Hwy, Sector 49, Gurugram, Haryana 122018