Supplier & Business Partner Code of Conduct.

Code of Conduct

SARVAYA TRADEX LLP

Effective Date: 10 July 2024
Last Updated: 26 October 2026
Website: www.sarvaya.co.in

1. Introduction

SARVAYA TRADEX LLP (“SARVAYA”, “we”, “our” or “us”) believes that reliable business relationships are built on trust, integrity, accountability and mutual respect.

Our work in freight forwarding, Customs Consultancy & Clearance, logistics, transportation, ODC and project cargo involves working with customers, suppliers, transporters, overseas agents, service providers, consultants and other business partners.

This Supplier & Business Partner Code of Conduct (“Code”) sets out the standards of professional behaviour and responsible business practices that we expect from parties working with SARVAYA.

We aim to maintain business relationships that are commercially sound, legally compliant, transparent and respectful of the people and organisations involved.

2. Purpose and Scope

The purpose of this Code is to communicate our expectations regarding ethical conduct, legal compliance, fair business practices, confidentiality, workplace standards, safety and responsible service delivery.

This Code applies to suppliers and business partners who provide goods or services to SARVAYA, support our operations or represent us in an agreed business capacity.

These parties may include:

Freight forwarders, shipping agents and overseas logistics partners.
Transporters, fleet operators and delivery service providers.
Customs service providers, consultants and documentation service providers.
Warehouses, container freight stations, terminals and cargo-handling service providers.
Inspection agencies, laboratories and other technical service providers.
Vendors, contractors, professional consultants and outsourced service providers.
Commercial agents, representatives and other approved business intermediaries.

We encourage business partners to communicate these standards to their relevant employees, representatives and subcontractors involved in work performed for SARVAYA.

This Code should be read alongside applicable laws, purchase orders, quotations, service agreements, confidentiality commitments and other contractual requirements. Where a specific agreement establishes additional lawful requirements, those requirements should also be followed.

3. Legal and Regulatory Compliance

Business partners are expected to conduct their activities in accordance with all laws and regulations applicable to their business and the services they provide.

Depending on the nature of the assignment, relevant requirements may include:

Applicable customs, import-export and foreign trade regulations.
Transport, shipping, port, warehousing and cargo-handling requirements.
Applicable licensing, registration, permit and certification conditions.
Tax, invoicing, accounting and record-keeping requirements.
Occupational health, workplace safety and environmental requirements.
Data protection, confidentiality and information security obligations.
Applicable labour, employment and anti-discrimination laws.

Business partners must maintain any licences, registrations, approvals and qualifications required for the services they undertake.

Where a licence, approval, authorisation or other legal requirement is relevant to an assignment, the partner should provide supporting information when reasonably requested and legally permissible.

Any actual or suspected legal non-compliance that may materially affect SARVAYA, a customer, a shipment or an agreed service should be reported promptly through the appropriate business contact.

4. Integrity and Ethical Business Conduct

SARVAYA expects business partners to act honestly, fairly and professionally in all business dealings.

Business partners must not engage in fraud, deception, falsification, misrepresentation or any other dishonest practice.

Information supplied to SARVAYA, customers, government authorities, carriers, insurers or other relevant parties must be accurate to the best of the provider’s knowledge and must not knowingly conceal material facts.

Business partners should maintain professional communication, honour their agreed commitments and promptly disclose circumstances that may affect service delivery, costs, timelines or compliance.

No business opportunity, commercial advantage or personal benefit should be pursued through unlawful, dishonest or unethical conduct.

5. Anti-Bribery and Anti-Corruption

SARVAYA does not support bribery, corruption, kickbacks or improper payments in business dealings.

Business partners must comply with applicable anti-bribery and anti-corruption laws and must not directly or indirectly offer, promise, give, request or accept an improper payment, gift, favour or other advantage to influence a business decision or obtain an unfair benefit.

This expectation applies to dealings with private organisations, public officials, government departments, customers, suppliers, intermediaries and other relevant parties.

Facilitation payments or unofficial payments must not be made where prohibited by applicable law or inconsistent with lawful business requirements.

Where a payment or request appears improper, the business partner should seek clarification through an appropriate channel and avoid participating in conduct that may violate applicable law.

6. Gifts, Hospitality and Business Courtesies

Gifts, meals, hospitality and other business courtesies must be reasonable, transparent and consistent with applicable law and the parties’ policies.

Business partners must not offer or accept gifts, hospitality, cash equivalents, personal benefits or entertainment intended to improperly influence a commercial decision or official action.

Cash gifts and concealed benefits must not be used to secure orders, preferential treatment, approvals or other advantages.

Any gift or hospitality that could create a conflict of interest, affect impartiality or raise concerns about the integrity of a decision should be declined or disclosed to the appropriate business contact.

7. Conflicts of Interest

Business partners should avoid situations in which personal interests, financial relationships or outside activities could improperly influence business decisions involving SARVAYA.

Potential conflicts may include:

Personal or financial relationships with individuals involved in supplier selection or procurement decisions.
Undisclosed commissions, referral payments or financial interests in a transaction.
Use of confidential information to benefit a related business or individual.
Personal interests that interfere with the proper performance of agreed services.

Any actual, potential or reasonably perceived conflict of interest that could materially affect an engagement should be disclosed promptly.

Disclosure allows the parties to assess the circumstances and determine appropriate measures. A disclosed conflict does not automatically mean that a business relationship must end.

8. Fair Competition and Responsible Commercial Practices

Business partners are expected to compete fairly and conduct commercial negotiations honestly.

They must not engage in unlawful collusion, bid-rigging, price-fixing, market allocation, fraudulent tender practices or other anti-competitive conduct.

Quotations, freight rates, service charges, invoices and commercial proposals should accurately reflect the services offered and the applicable commercial arrangements.

Business partners must not knowingly provide misleading pricing information, fabricate competing quotations, manipulate procurement processes or make unauthorised commitments on behalf of SARVAYA.

All parties should respect applicable competition laws and maintain appropriate independence in their commercial decisions.

9. Government Authorities, Customs and Public Procurement

Business partners involved in customs-related assignments, regulatory matters, public procurement or government tenders must conduct their activities lawfully and transparently.

They must not:

Submit false, altered or misleading documents or declarations.
Offer improper payments or benefits to influence an official decision.
Misrepresent licences, registrations, certifications, experience or technical capabilities.
Attempt to obtain confidential tender information through unauthorised means.
Conceal material information required for a lawful declaration, application or tender submission.

Any documents prepared or submitted in connection with an assignment should be accurate, appropriately authorised and supported by relevant records.

Business partners must respect the authority of customs officials, regulatory bodies, port authorities and other government agencies and must not obstruct lawful inspections or procedures.

10. Accuracy of Documents and Business Records

Accurate records are essential to responsible logistics, customs consultancy, freight forwarding and financial administration.

Business partners are expected to maintain complete and reliable records relevant to their services and transactions.

These may include quotations, purchase orders, invoices, receipts, transport documents, shipment instructions, delivery records, expense statements, permits, certificates and other supporting documents.

Business partners must not knowingly falsify, manipulate, backdate or destroy records to conceal an error, improper payment, non-compliance or other material issue.

Where an error is identified, the relevant party should promptly notify the appropriate contact and cooperate in making any lawful correction.

Records should be retained for the period required by applicable law and relevant contractual obligations.

11. Confidentiality and Protection of Business Information

Business partners may receive confidential or commercially sensitive information while working with SARVAYA.

Such information may include:

Customer and supplier names, contacts and commercial arrangements.
Freight rates, quotations, margins, pricing and payment terms.
Shipment details, cargo descriptions and operational instructions.
Commercial invoices, packing lists and customs-related documents.
Business plans, internal procedures and non-public company information.
Personal information relating to employees, customers or business contacts.

Business partners must use confidential information only for the agreed business purpose and must not disclose it to unauthorised parties.

Access should be restricted to individuals who reasonably need the information to perform their assigned responsibilities.

Confidential information must not be used to compete unfairly, divert business, solicit customers through misuse of non-public information or obtain an unauthorised personal advantage.

These expectations are subject to applicable law, legitimate disclosure obligations and any confidentiality agreement in force between the parties.

12. Data Protection and Information Security

Business partners who handle personal information or access SARVAYA’s business systems must protect that information in accordance with applicable law and agreed security requirements.

They should take reasonable measures to prevent unauthorised access, disclosure, alteration, loss or misuse of information.

Depending on the services provided, appropriate measures may include:

Using authorised systems and accounts for business communications.
Restricting access to documents and systems according to business need.
Protecting passwords, devices and confidential files.
Verifying recipients before sending sensitive documents.
Avoiding unauthorised storage or transfer of business information.
Reporting suspected data loss, unauthorised access or information security incidents promptly.

Business partners must not access, copy, retain or disclose SARVAYA’s information beyond what is permitted for the relevant assignment.

Where additional data-processing or security obligations apply, the parties should document those requirements separately.

13. Labour Practices and Human Rights

SARVAYA expects business partners to respect the dignity, safety and lawful rights of the people engaged in their operations.

Business partners must comply with applicable employment and labour laws, including requirements relating to wages, working hours, employment conditions and legally required benefits.

They must not use forced labour, bonded labour, human trafficking or unlawful child labour.

Workers should be engaged on lawful terms and should not be subjected to threats, physical punishment, harassment, coercion or degrading treatment.

Business partners should respect workers’ lawful rights to raise workplace concerns and should not retaliate against individuals for making good-faith reports.

Where subcontractors or labour providers are used, the business partner should take reasonable steps to ensure that the relevant parties follow applicable labour requirements.

14. Equal Opportunity and Respectful Workplace Conduct

Business partners are expected to maintain professional and respectful working environments.

Discrimination, bullying, intimidation, sexual harassment and other unlawful or abusive conduct are not acceptable.

Employment and work-related decisions should be made in accordance with applicable law and relevant qualifications, responsibilities and legitimate business requirements.

Business partners should provide appropriate channels for workers to raise concerns and should handle complaints fairly and confidentially to the extent reasonably possible.

No individual should face retaliation for raising a concern honestly or participating in a lawful investigation.

15. Health, Safety and Operational Responsibility

Business partners must comply with applicable workplace, transport, cargo-handling and occupational safety requirements relevant to their activities.

They are expected to maintain safe working practices, use suitable equipment and ensure that personnel performing assigned tasks have appropriate training and authorisation.

Where relevant, safety responsibilities may include:

Safe loading, unloading, lifting and movement of cargo.
Proper use and maintenance of vehicles, machinery and handling equipment.
Compliance with applicable hazardous-goods and dangerous-goods requirements.
Use of appropriate personal protective equipment.
Safe storage and handling of chemicals and other regulated cargo.
Reporting accidents, injuries, unsafe conditions and significant near misses.

Business partners must disclose known hazards that may materially affect personnel, cargo, facilities or transport operations.

Work should not proceed where a serious safety risk cannot be reasonably controlled, subject to applicable legal and operational requirements.

16. Environmental Responsibility

Business partners are expected to comply with applicable environmental laws, permits and regulatory requirements.

They should take reasonable steps to prevent pollution, manage waste responsibly, avoid unlawful disposal of materials and reduce unnecessary environmental impacts arising from their activities.

Where relevant to the service, business partners should follow appropriate procedures for handling spills, hazardous substances, emissions and other environmental risks.

Any significant environmental incident connected with an assignment involving SARVAYA should be reported promptly to the appropriate contact and handled in accordance with applicable law.

17. Cargo Integrity and Prohibited Activities

Business partners must handle cargo, shipment information and supporting documents responsibly.

They must not knowingly assist with unlawful shipments, smuggling, false declarations, concealment of prohibited goods, fraudulent invoicing or other activities that violate applicable law.

Business partners should promptly raise concerns where cargo descriptions, quantities, packaging, documentation or instructions appear inconsistent or suspicious.

Goods subject to restrictions, licensing requirements or special handling conditions must be handled only in accordance with the relevant legal requirements and agreed service scope.

Where a material compliance concern arises, SARVAYA may request clarification, supporting documents or appropriate corrective action before proceeding with the affected assignment, subject to contractual obligations and applicable law.

18. Quality of Service and Professional Conduct

Business partners are expected to deliver services with reasonable care, competence, diligence and professionalism, consistent with the agreed scope and applicable requirements.

They should:

Meet agreed service standards and operational commitments.
Communicate promptly about delays, disruptions or changes affecting delivery.
Provide accurate updates and supporting documents.
Use appropriately qualified personnel for specialised tasks.
Maintain professional behaviour when dealing with customers, authorities and other service providers.
Address service failures and agreed corrective actions in a timely manner.

If a partner anticipates that an agreed commitment cannot be met, it should notify the appropriate contact as soon as reasonably practicable and provide relevant details.

19. Subcontracting and Use of Other Service Providers

Business partners must ensure that subcontracting arrangements comply with applicable law and the relevant contractual requirements.

Where prior approval is required under an agreement, subcontractors must not be engaged without that approval.

A business partner should use competent and appropriately authorised subcontractors and take reasonable steps to communicate the relevant requirements of this Code to them.

The use of a subcontractor does not automatically remove the business partner’s obligations under its agreement with SARVAYA.

Any transfer of confidential information to a subcontractor must be lawful, necessary for the assignment and appropriately protected.

20. Gifts, Commissions and Referral Arrangements

Commissions, brokerage fees, referral fees and other commercial payments must be transparent, properly documented and consistent with applicable law and the parties’ agreements.

No payment should be concealed, falsely described or used to disguise a bribe, kickback or improper benefit.

Business partners must disclose any material financial arrangement that could create a conflict of interest or affect an impartial business decision.

Where a commission or referral arrangement is proposed, the parties should agree on its basis and relevant terms in writing before implementation, where practicable.

21. Reporting Concerns and Violations

Business partners are encouraged to report suspected misconduct, bribery, fraud, document falsification, safety violations, confidentiality breaches or other material non-compliance connected with work involving SARVAYA.

Concerns should be raised through the relevant SARVAYA business contact or by emailing sales@sarvaya.co.in for appropriate internal referral.

Reports should provide sufficient factual information to allow the concern to be assessed. Supporting documents may be included where lawfully available.

SARVAYA will aim to review reported concerns fairly and take reasonable steps to assess the information provided.

Reports made in good faith should not result in retaliation by SARVAYA. Anyone submitting a report should avoid knowingly making false or malicious allegations.

The sales email is a general contact channel and is not represented as a dedicated or confidential whistleblowing hotline.

22. Cooperation and Corrective Action

Where a potential breach of this Code is identified, the business partner is expected to cooperate reasonably with relevant enquiries and provide accurate information.

Depending on the circumstances, corrective measures may include clarification of facts, correction of records, additional training, improved controls, replacement of an unsuitable process or other appropriate action.

The nature and timing of corrective action should be proportionate to the issue, applicable law and any relevant contractual obligations.

SARVAYA may request reasonable evidence that agreed corrective action has been completed.

23. Monitoring and Business Partner Assessment

Where appropriate to the nature and risk of an engagement, SARVAYA may assess a business partner’s relevant qualifications, licences, service capability, compliance practices and performance.

Such assessment may take place during supplier onboarding, quotation evaluation, tender participation, service delivery or periodic business reviews.

Business partners may be asked to provide relevant information or supporting documents, subject to applicable law and confidentiality requirements.

Any assessment will be based on the requirements relevant to the particular business relationship. Publication of this Code does not, by itself, establish a formal audit programme or certification process.

24. Breach of This Code

A breach of this Code may lead to a review of the relevant business relationship, depending on the nature, seriousness and circumstances of the matter.

Where appropriate and legally permissible, possible responses may include:

A request for clarification or corrective action.
Additional compliance checks or supporting documentation.
Suspension of a specific assignment while a material concern is assessed.
Declining new work or discontinuing a business relationship.
Termination of an agreement in accordance with its terms.
Referral to the relevant authorities where required or appropriate under applicable law.

Any action will remain subject to applicable law, contractual commitments and any relevant procedural requirements.

Nothing in this Code creates an automatic right to terminate a contract where such termination would be inconsistent with the governing agreement or applicable law.

25. Responsibilities of SARVAYA

SARVAYA aims to conduct its own business dealings professionally and responsibly.

We seek to communicate business requirements clearly, treat business partners fairly, protect confidential information appropriately and address legitimate concerns in a reasonable manner.

We expect our business partners to raise questions where a requirement is unclear and to seek clarification before proceeding with an action that may be unlawful, unsafe or inconsistent with an agreed commitment.

The standards in this Code support our approach to responsible business relationships. They do not replace the specific rights and obligations established by applicable law or binding agreements.

26. Acknowledgement and Acceptance

SARVAYA may request a supplier or business partner to acknowledge this Code as part of onboarding, procurement, tender participation or a specific service engagement.

Where acknowledgement is requested, the partner should confirm that it has reviewed the Code, understands the relevant expectations and will make reasonable efforts to comply with the requirements applicable to its activities.

Any formal undertaking, certification or contractual acceptance should be documented separately where required.

Publication of this Code on the SARVAYA website does not, by itself, establish that every supplier or business partner has formally acknowledged it.

27. Review and Updates

SARVAYA may review and update this Code from time to time to reflect changes in its business operations, supplier relationships, industry practices or applicable legal requirements.

The latest version will be published on this page, together with an updated date where appropriate.

Business partners should review relevant updates when notified or when required as part of an ongoing contractual relationship.

Any change that affects an existing contract will be subject to the amendment provisions of that contract and applicable law.

28. Relationship With Other Policies and Agreements

This Code should be read alongside applicable SARVAYA policies, including the Privacy Policy and Terms & Conditions, as well as any relevant purchase order, quotation, service agreement, confidentiality agreement or other binding document.

Where specific contractual obligations apply to a business relationship, the parties should review the relevant documents together.

Nothing in this Code is intended to waive statutory rights, override mandatory legal requirements or replace an express contractual obligation.

29. Contact Information

For questions about this Code or to raise a business conduct concern, please contact SARVAYA TRADEX LLP using the details below.