Code of Ethics and Business Conduct Guidelines

RIDSAM HR-Tech Solutions Pvt. Ltd. (“RIDSAM”) is committed to maintaining the highest standards of ethical conduct and professionalism. This Code of Ethics and Business Conduct serves as a foundation for building trust with clients, candidates, employees, and other stakeholders. It reflects our values of integrity, accountability, transparency, and respect.

RIDSAM Pledge

  • We consider our Code to be the foundation of our ethical culture and we are committed to promoting integrity, respect, and fairness;
  • We take steps to protect anyone who raises a concern in good faith;
  • We have a zero-tolerance approach to retaliation against those who raise concerns or cooperate with an Investigation;
  • We stand strongly against any form of unfair treatment, harassment, discrimination, or abuse;
  • We comply with all applicable laws and regulations, including those designed to prevent Corruption, Fraud, Bribery, Money Laundering, Terrorist Financing, Insider Trading, anti-competitive behaviour, and also those which are intended to ensure compliance with international Trade Controls and Sanctions;
  • We disclose any potential Conflicts of Interest to ensure that they are managed appropriately;
  • We protect our assets against misuse by ensuring that we have the appropriate controls and by observing established financial and record keeping practices;
  • We choose who we do business with carefully and ensure that they commit to complying with international best practice throughout our relationship with them;
  • We respect the Personal Data of all those whose information we are in possession of, and take all appropriate measures to protect it in accordance with applicable Data Protection Laws;
  • We protect all Confidential Information, whether belonging to RIDSAM or to any Business Partners or Third Parties, including Intellectual Property;
  • We use our IT assets responsibly and take appropriate measures to protect them;
  • We support the principles of international human rights standards and we are strongly opposed to any form of child labour, human trafficking, and modern slavery;
  • We are committed to providing a safe, healthy, and secure workplace for all of our people, and we minimize our impact on the environment

What We Stand For

Integrity and Professionalism

The Principles: Integrity is the key principle that guides our activities and ensures that we operate to the highest standards of ethics and compliance. We lead by example to create a culture that encourages others to do the right thing.
Our Responsibilities:
  • Honest Representation: Provide accurate and truthful information to clients and candidates about roles, compensation, qualifications, and expectations.
  • Confidentiality: Safeguard the personal and professional data of clients and candidates. Do not disclose information without proper authorization.
  • Fair Practices: Avoid favouritism, discrimination, or any practices that could compromise the integrity of the hiring process

Respect and Fairness for All Individuals

We respect and value everyone’s differences and treat everyone with dignity, respect and fairness.

The Principles: We value diversity and are committed to ensuring that everyone associated with our organisation work in a supportive environment. We treat everyone with respect and dignity and never threaten, humiliate, or use inappropriate or insulting language or actions. We adopt zero tolerance on unfair treatment, harassment of any kind (including sexual harassment), discrimination and abuse such as bullying, intimidation, and physical violence.
Our Responsibilities:
  • Equal Opportunity: We promote inclusivity and diversity in recruitment and ensure equal opportunities regardless of race, gender, religion, disability, age, or other protected characteristics.
  • Dignity and Respect: We treat all clients, candidates, and colleagues with respect, professionalism and avoid harassment or inappropriate conduct in any form

Speak Up

Raising concerns where we suspect wrongdoing

The Principles: We strongly promote raising concern in good faith without any fear if there is a suspicion on any wrong doing or breach of law. We have a zero-tolerance approach to any form of retaliation against anyone reporting a concern or cooperating with an Investigation. Any such retaliation will be subject to disciplinary action. We take all concerns raised seriously and address them appropriately and confidentially.
Our Responsibilities:
  • Compliance Monitoring: All employees and associates are responsible for understanding and complying with this Code of Conduct.
  • Reporting Violations: Encourage employees, associates, clients, and candidates to report any unethical conduct without fear of retaliation.
  • Consequences: Violations of this Code may result in disciplinary action, including termination of employment or business relationships.

Compliance with Laws and Regulations

Strictly adhering to legal and regulatory frameworks to maintain trust of our stakeholders and uphold the integrity of our operations

The Principles: We are committed to operating in full compliance with all applicable laws, regulations, and industry standards in every region where we conduct business. This includes, but is not limited to, laws governing employment practices, data protection, anti-discrimination, immigration, and corporate governance.
Our Responsibilities:
  • Employment and Labour Laws: Adhere to all local and international labour laws, including fair hiring practices, anti-discrimination statutes, and wage and hour regulations. Ensure that candidates and clients are informed about their legal rights and obligations during the recruitment process.
  • Data Protection and Privacy: Comply with data protection laws and ensure that the personal information of clients, candidates, and employees is collected, stored, and used responsibly and securely.
  • Immigration and Work Authorization: We ensure that all placements comply with immigration laws and visa requirements. We verify that candidates possess the necessary work authorizations and inform clients of any associated requirements
  • Anti-corruption and Anti-Bribery: All forms of bribery, corruption, and unethical inducements are strictly prohibited in our business transactions. We ensure full transparency in dealings with clients, candidates, and government authorities.
  • Non- compliance Reporting: We encourage any suspected or actual non-compliance with laws or regulations to be reported immediately to the appropriate company authority. The company will investigate all reports thoroughly and take corrective actions where necessary.
  • Continuous Monitoring and Update: We regularly review and update internal policies and procedures to align with changes in applicable laws and regulations. We provide employees with training and resources to ensure ongoing compliance and understanding of relevant legal requirements.

Transparency and Accountability

Fostering a culture of openness, honesty, and responsibility in all aspects of our business.

The Principles: Transparency and accountability are critical to building trust with our clients, candidates, employees, and other stakeholders
Our Responsibilities:
  • Clear Communication: Provide transparent information about fees, services, and processes to clients and candidates.
  • Conflict of Interest: Disclose any potential conflicts of interest and avoid situations that could compromise decision-making.
  • Feedback Mechanism: Encourage feedback from clients and candidates to continuously improve our services.

Social Responsibility

Dedication to making a meaningful and sustainable impact

The Principles: We recognize our role in contributing positively to society and are committed to practices that promote the well-being of our communities, the Human Resource industry, and the environment.
Our Responsibilities:
  • Technology Advocacy: Promote the responsible use of technology and innovation within the IT industry.
  • Community Engagement: Support initiatives that enhance skills development and workforce readiness in local communities.
  • Sustainability: Integrate environmentally sustainable practices into our business operations

How We Conduct Our Business

Conflicts of Interest

Any Conflict of Interest have the potential to affect our judgement, our workplace objectivity and our responsibilities

The Principles
  • A Conflict potentially arises when you, your family members, friends, or associates have a personal or external interest or relationship that interferes with your judgement regarding your duty
  • Financial, business, and social relationships, or activities (including board positions), can give rise to Conflicts that have the potential to affect your objectivity
  • RIDSAM resources should not be used for your own personal interests or in the interests of any other person or entity outside of RIDSAM activities, unless otherwise approved in accordance with the Conflicts of Interest Policy.
Our Responsibilities
  • Avoid activities that may create Conflicts, or even the appearance of a Conflict, between your personal interests and the interests of RIDSAM.
  • If Conflicts do arise, always disclose them to the Ethics & Compliance Office.

Anti-Bribery & Corruption

We have a zero-tolerance approach to Bribery, Corruption, and Fraud, and although we allow the exchange of modest Gifts, Hospitality, and Entertainment, these must not constitute or give rise to any suspicion of Bribery or Corruption.

The Principles
  • Bribery and Corruption may appear in many forms. They can be obvious, such as a cash bribe, or subtle, such as job offers, commissions, or excessive Gifts, Hospitality or Entertainment.
  • Bribery and Corruption are illegal worldwide and the term “bribe” is broadly defined under international anti-corruption laws. These laws can be far reaching and have a serious impact on us as an organisation regardless of where we operate.
  • Be cautious when dealing with Public Officials to avoid even the perception of Bribery, as dealing with Public Officials is subject to further scrutiny by relevant authorities.
  • The exchange of Gifts, Hospitality and Entertainment is permissible in certain circumstances, but is never acceptable when combined with an attempt to improperly influence a business-related decision
Our Responsibilities
  • Do not offer, promise, or give a Bribe or other improper payment in order to gain a business or personal advantage.
  • Never ask for or accept a Bribe, and immediately report any direct or indirect offerings of a Bribe to the Ethics & Compliance Office.
  • Never make or request a Facilitation Payment, except where making such a payment is required to avoid personal injury or risk to life (in respect of making such a payment).
  • All Gifts, Hospitality, and Entertainment must be modest, reasonable, and disclosed in accordance with the requirements of the Anti-Bribery & Corruption and Anti-Fraud Policy.

Anti-Money Laundering and Counter – Terrorist Financing:

Criminals and terrorists conceal the source of their funds through the process of Money Laundering. We adopt a zero-tolerance approach to Money Laundering and Terrorist Financing and implement controls to prevent them.

The Principles
  • It is important that we know who we do business with, where the funds we accept come from, and where we transfer our funds to.
  • We must ensure that we safeguard our business from being used by others for unlawful purposes, therefore we have Anti-Money Laundering and Counter-Terrorist Financing measures in place.
Our Responsibilities
  • Comply with the Anti-Money Laundering and Counter Terrorist Financing Policy and any procedures or controls implemented by the Business.
  • Do not engage in any Money Laundering or Terrorist Financing activities.
  • Verify the source of funds received and the ultimate beneficiary of funds we transfer.
  • Be aware of Money Laundering and Terrorist Financing risks and report any suspicions or concerns to the Ethics & Compliance Office

Knowing our Business Partners

We appoint Business Partners based on suitability and merit, and by properly evaluating them we avoid working with those that fail to subscribe to our standards of ethical business conduct.

The Principles
  • Our Business Partners’ conduct can have serious legal and reputational consequences for us. Thorough due diligence on our Business Partners reduces our exposure to Third Party risk.
  • Due diligence should be appropriate, risk-based and conducted throughout our relationship with each Business Partner.
  • We ensure that our Business Partners provide a contractual commitment to behave in an ethical and compliant manner, in line with our Business Partner Code of Conduct.
Our Responsibilities
  • Ensure that a risk based “Know Your Customer” due diligence check is carried out on potential Business Partners before formally engaging with them. This involves verifying the identity of the Business Partner using reliable sources of information. This risk assessment should establish whether you need to perform further due diligence.
  • Undertake Sanctions Screening on all potential Business Partners to ensure that we are not engaging in business with Sanctioned entities.
  • All relationships with Business Partners and other third parties should be documented through a written contract drafted or reviewed by your Legal Counsel

Sanctions and Trade Controls

RIDSAM is committed to complying with all applicable Sanctions and Trade Controls.

Our Principles
  • Sanctions are set by Governments or international organizations that place restrictions on economic activity, including trade, with specific countries, entities, and people.
  • Many countries impose Trade Controls on the import, export, transfer, re-export, and re-transfer of military goods and Dual-Use Items. The rules are complex and capture the transfer of software and data, as well as the movement of physical goods.
  • We will conduct business that would otherwise be restricted by Sanctions or Trade Controls only after obtaining requisite permits, approval and Licenses.
  • Both Sanctions and Trade Controls have far reaching effects that impact our activities around the world.
Our Responsibilities
  • Understand and comply with the requirements of the Sanctions and Trade Controls Policy and the Business Partner Due Diligence Policy.
  • Ensure that Business Partners are subject to Sanctions Screening before any agreements are signed, entered into, or renewed.
  • Do not have any dealings with any Sanctioned Persons.
  • Make sure that a risk-based assessment has been completed, taking into consideration the location of the potential Business Partner, before any import, export, transfer, re-export, and re transfer of any goods, software or data takes place. If any Sanctioned Countries are involved, you must obtain prior written approval from the Legal Department and the Ethics & Compliance Office

Anti-Competitive Behaviour

We abide by all applicable Antitrust Laws, which are designed to promote fair competition and prevent anti-competitive behaviour

The Principles
  • Antitrust Laws promote fair competition and prohibit anti-competitive behaviour which includes abuse of a dominant position, price fixing, market division, group boycotts, exclusive dealing arrangements, any agreement or sharing of Confidential Information (formal or informal) which may restrict or limit trade.
  • Agreements with our Competitors, Suppliers, distributors, and Customers could work in a way that hinder fair competition, and potentially breach Antitrust Laws.
  • Antitrust Laws also prohibit the abuse of a dominant market position. We may be permitted to hold a dominant position, but we must not abuse it.
  • Commercial information should only be obtained in a legal and ethical manner, and should never be collected through improper means, such as theft, misrepresentation, or manipulation.
Our Responsibilities
  • Do not discuss any sensitive commercial information or form any agreements with Competitors or Business Partners that could be seen as attempts to fix prices with the intent to manipulate markets, or influence market conditions in an unfair manner. If you receive such information from or about a Competitor, you should immediately report it to the Legal Department and the Ethics & Compliance Office.
  • If you are communicating with a RIDSAM colleague or a Third Party (whether such communication is casual or formal), and there are any indications of direct or indirect attempts to share, discuss, or extract sensitive commercial information that could be used in an anti-competitive manner, you must make it explicitly clear that the discussion is inappropriate and leave the meeting, or end the conversation (depending on the circumstance). You also need to immediately report it to the Legal Department and Ethics & Compliance Office.
  • Always make sure that you consider Antitrust Laws whenever a merger or acquisition is being explored in order to prevent the creation of a monopoly, or a dominant market position, where it would be in violation of Antitrust Laws

What We Care For

Community and the Environment

We operate, and minimize our environmental impact by investing in sustainable energy to power a brighter future and serve the communities where we operate.

The Principles
  • We proactively get involved in and support the communities in which we work.
  • We support fundamental human rights principles and are firmly against any form of child labour, human trafficking, and modern slavery.
  • We prioritize long-term sustainability and aim to limit waste and carbon emissions protecting our environment.
  • We comply with all applicable environmental laws and regulations of the countries in which we conduct our business.
Our Responsibilities
  • We respect, engage, and support the local communities where we operate within.
  • We ensure our team and all affiliates immediately report any actual or potential environmental incidents, so that appropriate steps can be taken to control, correct, and prevent any harm to the environment.
  • We understand and comply with all local environmental regulations in the locations in which we operate.

Health and Safety

We are committed to providing a safe, healthy, and secure environment for all our stakeholders.

The Principles
  • We make safer workplace for all.
  • We comply with all applicable occupational health and safety laws and regulations.
  • We establish and maintain robust health and safety management systems and procedures designed to keep all employees, contractors, and visitors safe.
  • We strictly prohibit substance abuse or working under the influence of alcohol whilst performing your duties and responsibilities. Any violation will result in disciplinary action. Those who need support with alcohol or substance abuse should contact the Ethics & Compliance Office.
Our Responsibilities
  • Work and behave in a safe manner at all times.
  • We follow all health and safety procedures and instructions.
  • We support all our stakeholders by being aware of our surroundings and any relevant incident management and emergency response procedures, alerting others to potential risks, and ensuring that those we are working with, including contractors and visitors, follow applicable procedures and instructions.
  • We immediately report any accidents, injuries, or unsafe working conditions to respective health and safety officer

We Safeguard Information

Confidentiality and Data Privacy

We take full accountability and responsibility in protecting confidential information and personal data that we hold and manage.

The Principles
  • We manage highly sensitive Confidential Information relating to the critical infrastructure that we are responsible for, therefore, we have a duty to safeguard and protect this information at all times.
  • We Process Personal Data only for legitimate purposes and in accordance with applicable Data Protection Laws.
  • We take measures to ensure that all our Business Partners take adequate steps to handle any Confidential Information or Personal Data that we share in accordance with our standards. This should start with the Business Partner or Third Party signing a non-disclosure agreement.
  • We always take steps to protect all Confidential Information whether in physical or electronic form. Never share or discuss Confidential Information, particularly that which relates to ongoing procurement with anyone who is not authorized to have that information
Our Responsibilities
  • Only share Confidential Information when it is absolutely necessary, and always think about what you share before you share it.
  • Any Confidential Information or Personal Data in our possession that belongs to us or any Third Party should be safeguarded at all times and should not be shared without a signed non-disclosure agreement.
  • Be familiar and comply with the Data Protection Policy and any other policies implemented by the Business you work for.
  • Immediately report any actual or suspected Confidential Information or Personal Data breaches, or violations of the Data Protection Policy, to the Ethics & Compliance Office

Information Technology

We are extra careful in using our information technology (IT) assets that are critical to the work we do.

The Principles
  • All RIDSAM IT equipment and infrastructure must be used in accordance with our IT security policies and procedures.
  • Any work content produced using RIDSAM IT equipment and infrastructure is the property of RIDSAM, and we may monitor all activity using such IT assets to ensure their use is legal and appropriate.
  • We have a shared responsibility to prevent cyber-attacks as they are a significant risk to our organization
Our Responsibilities
  • We always protect the IT assets we are responsible for from unauthorized access or theft, and safeguard all passwords of such equipment. We should never leave an unlocked device unattended, and ensure that RIDSAM information is not visible to others when working in public.
  • We should limit the use of IT assets for personal use, and should never use them to access material or websites that contain offensive, inappropriate, or illegal content.
  • You should flag phishing links, screen external storage devices, and attend cyber security training and awareness sessions to proactively prevent cyber-attacks. You must report any concerns relating to IT to the information security team

Communication and Document Control

Success of any organization depends on effective communication and information management. Poor communication expose us to un-necessary risk and can result in reputational harm.

The Principles
  • All regulatory documents are retained for a prescribed period of time.
  • All external communications on behalf of RIDSAM will be responsible, accurate, timely, and pre-approved (in accordance with the RIDSAM External Communications Policy, or any updated equivalent).
  • Any personal social media activities will not interfere with our duties to RIDSAM and our personal views should always be presented as distinct from those of RIDSAM.
Our Responsibilities
  • All records shall be retained as per applicable law.
  • Never speak on behalf of RIDSAM unless authorized to do so.
  • Put measures in place to classify documents in terms of confidentiality, sensitivity, and retention requirements.
  • Never use RIDSAM resources in our personal or political activities

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