Effective Date: Effective for all customers entering into, or renewing, Order Forms with a Start Date on or after June 04, 2026
Current Version: 1.0
1. This policy specifies that the highest ethical and professional conduct is expected in all dealings with Wingify.
2. All applicable laws must be complied with, a safe and healthy work environment must be maintained, and any violent or threatening behaviour should not be engaged in for any dealings with Wingify.
3. Any kind of discrimination, bribery in any form, intolerance of any religious, political or cultural sentiments are unacceptable.
4. Retaliating against any person/s who report or raise complaints in respect of any business conduct or ethics shortcomings is not tolerated.
At Wingify, we ensure that we maintain the highest professional standards in all our dealings. Ethical conduct, Professionalism, Integrity, honesty, transparency, fairness, sustainable work practices, non-discrimination, equal employment opportunities, safe harassment free workplace, ensuring human rights, dignity, respect and, compliance with all rules, regulations, laws are the cornerstones of our business. All Wingify Customers, Vendors, Partners, Resellers, Partner Referrals, Service Providers etc. (Hereinafter together referred to as “Business Partners”) are expected to adhere to and maintain the same standards in all their professional dealings with Wingify. The required standards that our business partners are expected to adhere to are listed below:
1. Compliance with all applicable Laws, Rules, Regulations, Ordinances etc. All Business Partners must comply with all applicable laws, rules, regulations, and ordinances, including but not limited to anti-bribery laws, the U.S. Foreign Corrupt Practices Act (FCPA), laws against sexual harassment, modern slavery and human trafficking laws, child labour prohibitions, and data privacy regulations including GDPR and other applicable privacy frameworks.
2. Ethical conduct and Professionalism – We believe that our employees, as well as our Business Partners, must always ensure they conduct themselves professionally, keeping in line with Industry practices and conventions. This promotes a respectful workplace where business flourishes. Any form of verbal or physical abuse, threatening remarks, profanity, disrespectful communication, lewd comments, aggressive behavior etc., will not be tolerated. As we are a global organization, we expect everyone to keep cultural requirements in mind to ensure we are tolerant and do not hurt any religious, political or cultural sentiments.
3. Non-Discrimination and Equal Opportunity – Wingify does not tolerate discrimination of any kind on grounds of race, gender, age, religion, nationality, disability, sexual orientation, or any other characteristic. We expect all Business Partners to uphold the same commitment to fairness, honesty, and equal opportunity in their dealings with us and in the conduct of their own businesses. We provide a clean, safe, and healthy work environment for our employees and expect the same is maintained by our Business Partners. A safe and healthy workplace not only includes safety and health rules and practices, but also reporting accidents, injuries and unsafe conditions, procedures, or behaviors and having freedom of expression. We are very strict to action against complaints of Violent and threatening behavior and have set processes in places to ensure such complaints are addressed, verified, resolved and disciplinary action taken against employees for the same. For business partners, it may lead to a termination of our business engagement with them.
4. Safe and Healthy Work Environment – We are committed to providing a clean, safe, and healthy workplace and expect Business Partners to maintain equivalent standards within their own organisations. This includes adherence to health and safety rules and practices, timely reporting of accidents, injuries, and unsafe conditions, and ensuring employees have the freedom to raise concerns without fear of reprisal. Violent or threatening behaviour is treated with the utmost seriousness. For Business Partners, substantiated violations may result in termination of the business relationship.
5. Bribery and dealings with Government personnel- We are intolerant of any form of bribery and are compliant with anti-bribery laws including the U.S. Foreign Corrupt Practices Act, U.K. Bribery Act, and similar legislations in other countries prohibiting any form of bribery. Any dealings with Government personnel are strictly regulated and employees are guided by our Legal Department for ensuring legal regulations governing payments and gifts to governmental officials are met.
6. Finance record keeping- Wingify supports full, fair, accurate and timely maintenance of all financial transactions while adhering to all applicable laws and any internal organization controls and measures set up. We audit our internal processes and procedures annually and expect to be able to do the same for our Business Partners as regulated by the contractual arrangements with them.
7. Conflict of Interest – Business Partners are expected to disclose any actual or potential conflicts of interest that could compromise their obligations to Wingify or its users. We encourage proactive steps to avoid situations where personal, financial, or other interests whether your own or those of your family, friends, or associates may conflict with the interests of Wingify or those it serves.
8. Data Privacy and Information Security – Wingify handles personal and business data on behalf of its customers and expects all Business Partners to treat data with the same level of care and responsibility. Business Partners must comply with all applicable data protection laws including GDPR, CCPA, IN-DPDP and other relevant privacy regulations and must implement appropriate technical and organisational measures to protect personal and confidential information against unauthorised access, loss, or misuse. Any actual or suspected data breach involving Wingify data or systems must be reported to us promptly. Business Partners must not use Wingify data or systems for any purpose beyond what is strictly authorised under the applicable agreement.
9. Environmental Responsibility – Wingify is committed to conducting its business in an environmentally responsible manner and encourages its Business Partners to do the same. We expect Business Partners to comply with all applicable environmental laws and regulations, and where possible, to adopt practices that reduce environmental impact including responsible resource consumption, waste management, and minimising carbon emissions. We value working with partners who share our commitment to long-term sustainability and who are actively working to understand and reduce their environmental footprint.
10. Responsible Use of Technology and Artificial Intelligence – As a technology company, Wingify recognises the transformative potential and the associated responsibilities of emerging technologies, including artificial intelligence. We expect Business Partners who develop, deploy, or use AI tools and technologies in connection with Wingify products or services to do so responsibly and ethically. This includes ensuring that AI systems are used transparently, do not perpetuate bias or discrimination, respect individual privacy, and comply with all applicable laws and regulations governing automated decision-making. Business Partners should not use Wingify platforms or data to train AI models without explicit written consent.
11. Retaliation is not tolerated – Employees and Business Partners are encouraged to raise any questions, concerns or to report violations of this Code of Conduct with Executive Management or by dropping an email to [email protected]. We do not tolerate any form of retaliation against any person who raises a complaint or concern for an alleged violation of our Code of Conduct. The subject of the complaint, whether an employee or a Business Partner, is expected to cooperate with Wingify during the investigation of potential or alleged misconduct.
12. Human Rights, Modern Slavery, and Labour Standards – Wingify is committed to upholding fundamental human rights across all its operations and business relationships. We have zero tolerance for modern slavery, forced labour, bonded labour, debt bondage, human trafficking, child labour, or any other form of exploitation in our own organisation and across our supply chain.
All Business Partners are required to:
a. Ensure that all work within their organisation and supply chain is freely chosen. Workers must not be subject to coercion, deception, or threats of any kind.
b. Not employ or engage individuals below the applicable minimum working age, or below 15 years of age, whichever is higher in any capacity. Where young workers are legally permitted, their employment must comply fully with applicable laws and must not interfere with their education, health, or wellbeing.
c. Pay all workers at least the minimum wage required by applicable law, in a timely manner and without unlawful deductions.
d. Not withhold workers’ identity documents, passports, or any personal property as a means of control or retention.
e. Ensure that working hours comply with applicable legal limits and that workers are entitled to adequate rest periods.
f. Conduct reasonable due diligence on their own supply chains to identify and address risks of exploitation, particularly when operating in or sourcing from higher-risk geographies or sectors.
g. Promptly report to Wingify any identified or suspected instance of modern slavery or labour exploitation that may intersect with their engagement with Wingify.