Compliance Statement

Our commitment to regulatory compliance and corporate governance

Last Updated: 3 August 2025

Legal Compliance

Full adherence to Companies Act 2013, IT Act 2000, and all applicable Indian laws

Data Protection

Robust security measures and privacy practices as per SPDI Rules 2011

Ethical Standards

Zero tolerance for corruption with strong ethical business practices

1. CORPORATE COMPLIANCE OVERVIEW

BUFFERCODE PRIVATE LIMITED ("Company") is committed to maintaining the highest standards of corporate compliance as mandated by Indian laws and regulations. This Compliance statement outlines our adherence to: • Companies Act, 2013 and its Rules • Information Technology Act, 2000 • Income Tax Act, 1961 • Goods and Services Tax Act, 2017 • Labour Laws and Regulations • Environmental Laws (where applicable) • Data Protection Regulations • Foreign Exchange Management Act (FEMA) All compliance activities are subject to change based on regulatory updates.

2. COMPANIES ACT 2013 COMPLIANCE

As a Private Limited Company incorporated under the Companies Act, 2013, we ensure: STATUTORY COMPLIANCE: • Timely filing of annual returns (Form MGT-7) • Filing of financial statements (Form AOC-4) • Maintenance of statutory registers • Conduct of board meetings as per requirements • Proper maintenance of minutes books • Compliance with audit requirements • Adherence to related party transaction norms CORPORATE GOVERNANCE: • Board composition as per statutory requirements • Director identification and KYC compliance • Shareholder agreements and rights protection • Dividend distribution policies • Corporate Social Responsibility (if applicable)

3. INFORMATION TECHNOLOGY COMPLIANCE

Under the Information Technology Act, 2000 and related rules: DATA PROTECTION: • Implementation of reasonable security practices • Compliance with SPDI Rules, 2011 • Incident response and breach notification • Privacy policy maintenance and updates • Cookie compliance and user consent INTERMEDIARY GUIDELINES: • Due diligence requirements • Grievance redressal mechanism • Content monitoring (where applicable) • User agreement compliance • Takedown procedures CYBER SECURITY: • CERT-In compliance for incident reporting • Security audit requirements • Business continuity planning • Data localization (where mandated)

4. TAX COMPLIANCE

We maintain strict adherence to Indian tax laws: DIRECT TAXES: • Timely filing of income tax returns • TDS compliance and timely deposits • Advance tax payments • Transfer pricing compliance (if applicable) • Tax audit requirements INDIRECT TAXES: • GST registration and compliance • Timely filing of GST returns • Input tax credit reconciliation • E-way bill generation (where required) • GST audit compliance INTERNATIONAL TAXATION: • Withholding tax on foreign payments • DTAA benefit documentation • Form 15CA/15CB compliance • FEMA compliance for foreign transactions

5. LABOUR LAW COMPLIANCE

Our employment practices comply with: STATUTORY REQUIREMENTS: • Provident Fund Act compliance • Employee State Insurance (ESI) where applicable • Professional Tax registration and payment • Minimum Wages Act adherence • Payment of Bonus Act (if applicable) • Gratuity Act compliance • Shops and Establishments Act registration WORKPLACE POLICIES: • Sexual Harassment Policy (POSH Act) • Equal employment opportunities • Working hours regulations • Leave policies as per law • Maternity/Paternity benefits • Employee contracts and NDAs

6. INTELLECTUAL PROPERTY COMPLIANCE

We respect and protect intellectual property rights: • Trademark registrations and protection • Copyright compliance and notices • Patent applications (where applicable) • Trade secret protection measures • Software licensing compliance • Open source license adherence • Third-party IP respect and licensing • Employee IP assignment agreements • Vendor IP indemnities Any IP violations should be reported to [email protected]

7. ANTI-CORRUPTION AND ETHICS

We maintain zero tolerance for corruption: ANTI-BRIBERY MEASURES: • Prohibition of bribes and kickbacks • Gift and entertainment policies • Vendor due diligence • Financial controls and audits • Whistleblower protection • Investigation procedures ETHICAL STANDARDS: • Conflict of interest policies • Fair business practices • Transparent procurement • Honest marketing and advertising • Competitor respect • Community engagement ethics

8. ENVIRONMENTAL COMPLIANCE

Where applicable, we comply with environmental regulations: • E-waste management rules • Energy efficiency standards • Green building norms (for facilities) • Pollution control measures • Environmental impact assessments • Sustainable procurement practices • Carbon footprint monitoring • Compliance with local environmental laws Note: As a technology services company, our environmental impact is primarily through e-waste and energy consumption.

9. CONTRACTUAL COMPLIANCE

We ensure all contracts adhere to Indian Contract Act, 1872: • Valid offer and acceptance • Lawful consideration • Competent parties • Free consent • Lawful object • Written agreements where required • Stamp duty compliance • Registration where mandated • Dispute resolution clauses • Limitation period adherence • Force majeure provisions • Termination procedures

10. REGULATORY REPORTING

We maintain timely compliance with all reporting requirements: MANDATORY FILINGS: • ROC filings under Companies Act • Income tax returns and assessments • GST returns and reconciliations • Labour law returns • FEMA reporting for foreign transactions • Industry-specific compliances RECORD MAINTENANCE: • Books of accounts for prescribed periods • Board and shareholder meeting minutes • Statutory registers • Employee records • Tax documents and receipts • Contracts and agreements • Compliance certificates

11. AUDIT AND MONITORING

Regular compliance monitoring through: INTERNAL CONTROLS: • Compliance calendar maintenance • Regular internal audits • Process documentation • Training and awareness programs • Compliance dashboards • Violation reporting mechanisms EXTERNAL VERIFICATION: • Statutory audit requirements • Tax audits where applicable • Secretarial audit (if required) • GST audit compliance • Specialized compliance audits • Third-party certifications

12. DISCLAIMER AND LIMITATIONS

IMPORTANT LEGAL DISCLAIMER: • This compliance statement is for informational purposes only • It does not constitute legal advice or opinion • Compliance status may change with regulatory updates • We are not liable for reliance on this information • Specific compliance queries require professional consultation • Laws and interpretations are subject to change • This is not an exhaustive list of all applicable laws • Compliance is an ongoing process, not a one-time event Users must conduct their own due diligence for specific requirements.

13. COMPLIANCE CONTACTS

For compliance-related matters: Compliance Officer BUFFERCODE PRIVATE LIMITED Email: [email protected] Response Time: 2-3 business days Version: 1.0 Last Updated: 3 August 2025

Compliance Queries?

For specific compliance-related questions or concerns, please reach out to our compliance team.