PUBLIC DOCUMENT

GOVERNANCE & COMPLIANCE

DATATOBIZ PRIVATE LIMITED

Environmental, Social & Governance (ESG) Policy

Document Control

This ESG Policy sets out DataToBiz Private Limited’s (“DataToBiz,” “we,” “us,” or “our”) environmental, social, and governance commitments and aspirations. DataToBiz commits to implementing these commitments across its offices and operations in a phased, proportionate manner as our team and footprint continue to grow.

Document title Environmental, Social & Governance (ESG) Policy
Founder DataToBiz Leadership Team – Ankush Sharma (Co-Founder & CEO) and Parindsheel Singh Dhillon (Co-founder & COO)
Applies to All DataToBiz employees and all owned or operated offices, across the US & Canada, UK & Europe, Middle East, Australia, and India.
Classification Public – published at www.datatobiz.com
Version 1.0
Policy origination date April 1, 2025
Last reviewed April 1, 2026
Next review April 1, 2027

Revision History

Version Details Effective Date
1.0 First release April 1, 2025

1. About DataToBiz

This ESG Policy presents DataToBiz’s environmental, social, and governance commitments and aspirations. As a growing organization, we commit to implementing these commitments across our offices and operations in a strategic, phase-wise manner, and to setting increasingly ambitious targets as our ESG practices mature. This Policy applies to all offices and operations owned or operated by DataToBiz, and should be read alongside DataToBiz’s Human Rights & Modern Slavery Statement, Anti-Bribery & Anti-Corruption Policy and Supplier Code of Conduct, and Whistleblower Policy and Vigil Mechanism.

2. Purpose & Scope of this ESG Policy

This ESG Policy presents DataToBiz’s environmental, social, and governance commitments and aspirations. As a growing organization, we commit to implementing these commitments across our offices and operations in a strategic, phase-wise manner, and to setting increasingly ambitious targets as our ESG practices mature. This Policy applies to all offices and operations owned or operated by DataToBiz, and should be read alongside DataToBiz’s Human Rights & Modern Slavery Statement, Anti-Bribery & Anti-Corruption Policy and Supplier Code of Conduct, and Whistleblower Policy and Vigil Mechanism.

3. Guiding Principles

This Policy draws on the following frameworks:

  • The Ten Principles of the UN Global Compact (UNGC) — a principle-based framework guiding businesses toward sustainable and socially responsible practices, and integrating action on the UN Sustainable Development Goals (SDGs) into core business practice.

  • National Guidelines on Responsible Business Conduct (NGRBC) — issued by India’s Ministry of Corporate Affairs, guiding companies operating in India toward responsible business conduct aligned with national standards and norms.

DataToBiz commits to ensuring compliance with applicable environmental, social, and governance legal requirements on a proactive basis; adopting good industry practices that go beyond minimum compliance as we scale; and proactively engaging with employees, clients, and partners to ensure timely redressal of grievances through the channels set out in our Human Rights & Modern Slavery Statement and Whistleblower Policy.

4. Environmental Stewardship

As a knowledge- and technology-services business, DataToBiz’s direct environmental footprint is modest and runs primarily through our offices, IT equipment, and business travel. We commit to:

  • Resource Efficiency — promoting energy and resource efficiency across our offices, and encouraging hybrid and remote work patterns that reduce unnecessary commute-related emissions.

  • Waste & E-Waste — reducing avoidable waste in our operations and responsibly managing the disposal of IT equipment and electronic waste, consistent with the expectations we set for our suppliers.

  • Continuous Improvement — monitoring our environmental footprint as we grow, and setting more formal, measurable environmental targets as our operations and ESG practices mature.

5. Employee Health & Wellbeing

DataToBiz aims to provide a safe, non-discriminatory, inclusive, and healthy working environment for every employee. We are committed to caring for the mental and physical wellbeing of our people, maintaining open and confidential channels — including [email protected] — for employees to raise concerns without fear of retaliation, and to a culture of regularly recognizing employee contributions rather than treating wellbeing as an afterthought.

6. Diversity, Equity & Inclusion

DataToBiz is committed to equal opportunity employment and does not discriminate on the basis of gender, religion, nationality, disability, or any other status, consistent with the commitments in our Human Rights & Modern Slavery Statement.

  • Gender Balance — we aim to build and progress toward a gender-balanced workplace across levels and functions.

  • Disability Inclusion — we are committed to enabling employees with disabilities to work productively, including supporting remote work from their location where a role allows it, so that physical office access is never a barrier to employment.

  • Inclusion & Equity — we aim to ensure all employees, regardless of background, feel respected, valued, and able to grow at DataToBiz, and to incorporate equity into how we evaluate, promote, and pay our people.

7. Community & Social Impact

DataToBiz is committed to contributing positively to the communities in which we operate. As our social impact program develops, we intend to prioritize partnerships with organizations working on causes including the education and welfare of the girl child and access to healthcare, alongside other community and social initiatives as opportunities arise. We aim to build these partnerships thoughtfully and proportionately to our size as a growing organization.

8. Data Privacy, Security & Responsible AI

Data privacy and security sit at the core of DataToBiz’s business, given the nature of the data engineering and AI work we do for clients.

  • Data Privacy — we handle client and personal data in line with the data protection expectations of the jurisdictions we serve, including applicable requirements for clients based in the UK and Europe.

  • Data Security — we apply appropriate technical and organizational safeguards to protect the confidentiality, integrity, and availability of the data we handle, and train our team on data security practices.

  • Responsible AI — we are committed to developing and deploying AI responsibly — supporting our clients in using AI ethically, transparently, and in a way that considers the people affected by it.

9. Sustainable Procurement & Supply Chain

DataToBiz expects the suppliers, vendors, and subcontractors we work with to uphold ethical, responsible business practices, consistent with our Supplier Code of Conduct. We aim to give preference, where feasible, to suppliers who demonstrate responsible labour and environmental practices as we formalize our procurement processes.

10. Business Ethics & Corporate Governance

DataToBiz is committed to upholding integrity, transparency, and the highest ethical standards in how we govern our business. This commitment is implemented through our Anti-Bribery & Anti-Corruption Policy, and through the confidential reporting channel set out in our Whistleblower Policy and Vigil Mechanism, which is available to every employee and third party.

11. ESG Governance & Implementation

This Policy is owned by DataToBiz’s leadership team — Ankush Sharma and Parindsheel Singh Dhillon — who are responsible for its implementation. Given DataToBiz’s current scale, ESG oversight sits with leadership directly rather than a dedicated board committee; as our team and operations grow, we intend to formalize this governance structure, including broader stakeholder input into our ESG priorities.

12. ESG Data & Disclosure

DataToBiz will use its website, www.datatobiz.com, as its primary channel for ESG-related disclosures, and will update this Policy and related documents as our ESG practices and data mature.

13. Approval, Review & Revisions

This ESG Policy was approved by DataToBiz’s leadership on behalf of DataToBiz Private Limited, and is reviewed at least annually to ensure its continued relevance and effectiveness.

Ankush Sharma

Co-Founder & Chief Executive Officer, DataToBiz Private Limited   |   Date: April 1, 2026

Parindsheel Singh Dhillon

Co-Founder, DataToBiz Private Limited   |   Date: April 1, 2026

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