Code Of Conduct

CODE OF CONDUCT

1. National interest

The Company shall be committed to benefit the economic development of the countries in which it operates. It shall not undertake any project or activity to the detriment of the wider interests of the communities in which it operates. The Company’s management practices and business conduct must benefit the country, localities and communities served to the extent possible and affordable, and shall be in accordance with the laws and economic development policies of the government of each country.

The Company, in the course of its international business activities, shall respect the culture, customs and traditions of each country and region in which it operates. It shall conform to international trade procedures, including licensing, documentation, and other necessary formalities as applicable.

2. Financial reporting and records

The Company shall prepare and maintain its accounts fairly and accurately in accordance with the accounting and financial reporting standards which represent the generally accepted guidelines, principles, standards, laws and regulations of the country in which the Company conducts its business affairs.

Internal accounting and audit procedures shall reflect, fairly and accurately, all of the Company’s business transactions and disposition of assets, and shall have internal controls to provide assurance to the Company’s board and shareholders that the transactions are accurate and legitimate. All required information shall be accessible to company auditors and other authorized parties and government agencies. There shall be no wilful omissions of any company transactions from the books and records, no advance income recognition and no hidden bank account and funds.

Any wilful material misrepresentation of and/or misinformation on the financial accounts and reports shall be regarded as a violation of the Code apart from inviting appropriate civil or criminal action under the relevant laws. No employee shall make, authorize or collude in an improper payment, commission or bribe.

3. Competition

The Company shall fully support the development and operation of competitive open markets and shall promote the liberalization of trade and investment in each country and market it operates in. Specifically, The Company shall not engage in restrictive trade practices and activities that generate or support the formation of monopolies, dominant market positions, cartels and similar unfair trade practices.

The Company shall market its products and services on its own merits and shall not make unfair and misleading statements about competitors’ products and services. Any collection of competitive information shall be made only in the normal course of business and shall be obtained only through legally permitted sources and means.

4. Equal opportunities employer

The Company shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, religion, colour, ancestry, marital status, sex, age, nationality, disability and veteran status.

Human Resource policies should promote diversity and equity in the workplace, as well as comply with all Labour laws and international best practices. Employees of the Company shall be treated with dignity and in accordance with the Company policy to maintain a work environment free of sexual harassment, whether physical, verbal or psychological. Employee policies and practices shall be administered in a manner that would ensure that in all matters equal opportunity is provided to those eligible and the decisions are merit-based.

5. Gifts and donations

The Company and its employees shall neither receive nor offer or make, directly or indirectly, any illegal payments, remuneration, gifts, donations or comparable benefits which are intended to or perceived to obtain business or uncompetitive favours for the conduct of its business and shall participate in efforts to eliminate such forms of bribery, fraud and corruption. However, the Company and its employees may accept and offer nominal gifts which are customarily given and are of commemorative nature for special events.

6. Government agencies

The Company and its employees shall not offer or give any company funds or property as donation to any government agencies or their representatives, directly or through intermediaries, in order to obtain any favourable performance of official duties. The Company shall comply with government procurement regulations, and shall be transparent in all its dealings with government agencies as applicable.

7. Political non alignment

The Company shall be committed to and support functioning democratic constitutions and systems with transparent and fair electoral systems. The Company shall not support directly or indirectly any specific political party or candidate for political office. The Company’s conduct shall preclude any activity that could be interpreted as mutual dependence / favour with any political body and shall not offer or give any company funds or property as donations, directly or indirectly, to any specific political party, candidate or campaign.

8. Health, Safety and Environment

The Company shall strive to provide a safe, healthy and ergonomic working environment for its people. It shall comply with all health, safety and environmental regulations in each jurisdiction, in which it operates.

The Company shall be committed to best practice in minimizing its impact on the environment, prevent the wasteful use of natural resources, and properly and safely control any hazardous aspects of its business.

The Company shall have policies and processes in place to address issues of safety, health and environment, and shall also have a disaster management system to address any natural calamities or business contingencies that may arise.

The Company, in the process of production and sale of its products and services, shall strive for economic, social and environmental sustainability.

9. Quality of products & services

The Company shall be committed to supply goods and services of the highest quality standards backed by efficient after-sales service consistent with the requirements of customers to ensure their total satisfaction. The quality standards of the Company’s goods and services should at least meet the required national standards and the Company should endeavour to become world-class.

The Company shall illustrate adequate labels, caveats and other necessary health and safety information on its product packaging.

10. Corporate citizenship

The Company shall be committed to be a good corporate citizen not only in compliance with all relevant laws and regulations but also by actively assisting in the improvement of the quality of life of the people in the communities, in which it operates with the objective of making them self-reliant. Such social responsibility would comprise, to initiate and support community initiatives in the field of community health and family welfare, water management, vocational training, education and literacy and encourage application of modern scientific and managerial techniques and expertise. This will be reviewed periodically in consonance with national and regional priorities. The company would also not treat these activities as optional ones but would strive to incorporate them as integral part of its business plan. The company would also encourage volunteering amongst its employees and collaboration with community groups. The Company shall encourage development of social accounting systems, carrying out social audit of its operations, and support public policies that promote social and economic development.

11. Third party representation

Parties which have business dealings with the Company such as consultants, agents, sales representatives, distributors, contractors, suppliers, etc. shall not be authorized to represent the Company if their business conduct and ethics are known to be inconsistent with the Code. The third parties are expected to abide by the Code in their interaction with the Company.

12. Group policies

The Company shall recommend to its Board of Directors the adoption of policies and guidelines periodically formulated by its joint venture shareholders.

13. Shareholders

The Company shall be committed to enhance shareholder value and comply with all regulations and laws that govern shareholders’ rights. The Board of Directors of the Company shall duly and fairly inform its shareholders about all relevant aspects of the Company’s business and disclose such information in accordance with the respective regulations and agreements.

14. Protecting company assets

The assets of the Company should not be misused but employed for the purpose of conducting the business for which they are duly authorized. These include tangible assets such as equipment and machinery, systems, facilities, materials, resources as well as intangible assets such as information technology and systems, proprietary information, intellectual property rights, relationships with customers and suppliers, etc.

15. Citizenship

An employee of The Company shall in his private life be free to pursue an active role in civic or political affairs as long as it does not adversely affect the business or interests of the Company or the Group.

16. Integrity of data furnished

Every employee of the Company shall ensure, at all times, the integrity of data or information furnished by him to the Company.

17. Ethical code

Every employee of the Company, which shall include whole-time Directors and the Managing Director, shall deal on behalf of the Company with professionalism, honesty, integrity as well as high moral and ethical standards. Such conduct shall be fair and transparent and be perceived to be as such by third parties.

Every employee of the Company shall preserve the human rights of every individual and shall strive to honor commitments.

Every employee shall be responsible for the implementation of and compliance with the Code in his professional environment. Failure to adhere to the Code could attract the most severe consequences including termination of employment.

18. Regulatory compliance

Every employee of the Company shall, in his business conduct, comply with all applicable laws and regulations, both in letter and in spirit, in all the territories in which he operates. If the ethical and professional standards set out in the applicable laws and regulations are below that of the Code then the standards of the Code shall prevail.

19. Concurrent employment

An employee of the Company shall not, without the prior approval of the Managing Director of the Company, accept employment or a position of responsibility (such as a consultant or a director) with any other company, nor provide “free-lance” services to anyone. In the case of a Whole-time Director or the Managing Director such prior approval must be obtained from the Board of Directors of the Company.

For all queries pertaining to the Code of Conduct, please feel free to contact the Ethics Counsellor at Head office.