The Company Name

Code of Conduct

Message from the Executive Committee............................................................................1

Introduction..........................................................................................................................2
General Principles................................................................................................................3
Employees........................................................................................................................3
Clients and Suppliers.......................................................................................................3
Shareholders....................................................................................................................3
Competitors......................................................................................................................3
Communities and the Environment.................................................................................3
Employees............................................................................................................................4
Mutual Respect................................................................................................................4
Equal Employment Opportunity......................................................................................4
Workplace Environment..................................................................................................4
Workplace Violence.........................................................................................................4
Safety...............................................................................................................................4
Alcohol and Illegal Drugs................................................................................................5
Confidential Information.................................................................................................5
Use of Company Assets...................................................................................................6
Soliciting and Accepting Gifts.........................................................................................6
Personal Grooming and Presentation...............................................................................6
Communication................................................................................................................7
Employee Development...................................................................................................7
Human Rights..................................................................................................................7
Suppliers..............................................................................................................................8
Bribes and Kickbacks......................................................................................................8
Proprietary Information...................................................................................................8
Choice of Vendors / Suppliers.........................................................................................8
Shareholders........................................................................................................................9
Return on Investment.......................................................................................................9
Protection of Assets.........................................................................................................9
Accuracy of Company Records.......................................................................................9
Competitors........................................................................................................................10
Gathering Competitive Information..............................................................................10
Antitrust.........................................................................................................................10
Communities and the Environment...................................................................................11
Corporate Citizenship....................................................................................................11
The Environment...........................................................................................................11
The Community.............................................................................................................11
Compliance........................................................................................................................12
Acknowledgment Statement..........................................................................................13

Message from the Executive Committee

To: Fellow Employees

Conducting our business in accordance with the highest ethical standards has always been
a primary concern to <company name>. In many aspects, both the successes we have
enjoyed and the future of the Company depend upon doing business in an ethical manner.
The <company name> Code of Conduct has been drafted to provide guidance in this
area. The Code deals with how we should interact with each other, as well as with our
customers, suppliers, competitors, the community and the environment.
The Code means little without the personal commitment of each of us. Every <company
name> employee is responsible for understanding and conducting themselves in
accordance with the Code.
Please read the Code carefully. If at any time you have a question or need further
clarification, do consult your supervisor or the Human Resources Department.
The reputation of <company name> rests on the judgment and good conscience of every
one of us. Our actions must demonstrate that we live by the values conveyed by the Code.

EXECUTIVE COMMITTEE
<company name>

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Introduction
The <company name> Code of Conduct is intended to provide <company name>
employees with guidelines for ethical and professional conduct.
The code governs the business decisions and actions of all <company name> employees,
and is crucial in ensuring the integrity, reputation, and profitability of our Company in its
various operating locations.
The Code of Conduct is aligned with our vision and mission statements.
Our Vision
<Company Vision>
Our Mission
<Company Vision>
Every employee bears an individual responsibility to uphold these guidelines.

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General Principles
<company name> is committed to the highest level of integrity in its dealings with
individuals and organizations wherever we operate. Our Code of Conduct provides
employees with clear guidelines with respect to dealing with other employees, our clients,
suppliers, shareholders, competitors and the communities where we work. The following
highlights our general principles:
Employees
We are committed to maintaining employment practices based on equal opportunities for
all employees. We will respect each others privacy and treat each other with dignity and
respect. We are committed to providing a safe working environment and an atmosphere
of open communication for all employees.
Suppliers
We are committed to providing quality products and services to our clients through
honest transactions. We will deal lawfully and ethically with all of our clients.
We will emphasize fair competition, without discrimination or deception, in dealings with
our vendors.
Shareholders
We are committed to providing a return to our shareholders that ranks among the highest
in our industry through ethical profit making. In doing so, we will protect and improve
the value of their investments through the prudent utilization of Company resources and
observe the highest standards of legal and ethical conduct in our business dealings.
Competitors
We are committed to competing vigorously and honestly for business. Our efforts will be
based on the merits of our competitive offerings.
Communities and the Environment
We are committed to being a responsible corporate citizen of the communities in which
we serve. We will abide by all national and local laws, and will strive to improve the
well-being of our communities and the environment.

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Employees
Mutual Respect
At <company name>, we emphasize the need for mutual respect. We respect the opinions
and questions of others and exhibit behaviour that is courteous and conducive to creating
a pleasant and productive working environment. A positive atmosphere of
professionalism is essential for everyone to perform to the best of his or her abilities.
Equal Employment Opportunity
<company name> values the unique perspectives and opportunities provided by a diverse
workforce. It is therefore our policy to provide equal employment opportunities to
qualified individuals regardless of race, religion, gender, national origin, age, or
disability. This applies in all aspects of the employment relationship, including
recruitment, hiring, training, promotion, compensation, benefits, transfer, and
termination.
Workplace Environment
<company name> is committed to providing its employees with a safe work environment
free from harassment or discrimination. The Company will not tolerate sexual advances,
actions, comments, inappropriate physical contact or any other conduct that is
intimidating or would create an offensive or hostile work environment.
Workplace Violence
<company name> has a zero tolerance policy on acts of violence and verbal or physical
behavior that could lead to workplace violence, whether committed by or against our
employees. Included in prohibited behavior are: making threatening remarks, causing
physical injury to someone else, intentionally damaging someone elses property, and/or
acting aggressively in a way that causes someone else to fear they could be injured.
If you observe behavior that could be dangerous, use good judgment and inform your
supervisor or manager.
Safety
The safety of <company name> employees and the safe operation of <company name>
equipment is always a primary goal. <company name> believes that no business activity
is of such urgency or importance that it may be carried out in an unsafe manner. All
employees are responsible for ensuring that all <company name> operations are
conducted safely. Employees are expected to observe all safety rules and practices and to
follow instructions concerning safe and efficient work practices.

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Employees must immediately report any work-related accident, illness, or unsafe

condition or practice to an appropriate supervisor or manager.
Alcohol, and Illegal Drugs & Lethal Weapons
Alcohol abuse, and illegal drug use and carrying of Lethal Weapon, threaten our ability to
serve our customers and compromises the safety of our employees, products / services,
and the public. As such, <company name> will not tolerate any illegal misuse of drugs or
alcohol while employees are engaged in Company business.
Confidential Information
Confidential and proprietary information are valuable <company name> assets. This
includes, but is not limited to,

pricing and cost data;

merger, acquisitions and divestment information;
business processes and procedures;
financial data and projections;
trade secrets and know-how;
computer programmes;
wage and salary information;
marketing and sales programmes; and
customer/supplier/subcontractor information.

All such information must be used solely for Company purposes and must never be used
for personal gain.
Inappropriate or unauthorized disclosure of confidential information may damage our
business and the business of our customers, suppliers, and subcontractors. In some cases,
unauthorized disclosure may also violate the law and could result in fines, penalties, or
legal action against <company name> and/or individuals involved.
Employees should also exercise caution to avoid inadvertently disclosing confidential
information. This includes:
keeping electronic and paper documents and files containing confidential
information in a safe place;
not discussing confidential matters where they could be overheard, for example,
in public places such as elevators, hallways, restaurants, airplanes and taxis;
exercising caution when discussing confidential matters over telephones;
transmitting confidential documents by electronic devices, such as by fax or email, only when it is reasonable to believe this can be done under secure
conditions; and
avoiding unnecessary copying of confidential documents.
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Use of Company Assets

The assets of <company name> are intended to be used in ways that benefit our
Company. We must preserve these assets and use them wisely. The use of Company time,
equipment, supplies, and facilities for personal use, or removal of Company-owned
equipment from Company premises for personal use is permitted only when approved in
advance by your supervisor or manager.
Soliciting and Accepting Gifts
Employees must never solicit gifts or favours from our business partners and vendors, or
accept gifts that would appear to undermine or influence good business judgment.
In principle, employees should not accept any gift, and all attempts must be made to
return the gift to the donor.
In practice, it may be discourteous or impractical to return the gift. Under such
circumstances, the recipient must declare the gift to Human Resource Department to seek
clearance from the designated approving officer.
The only type of gifts which may be accepted and retained by the employees without
declaration are mementos/ souvenirs that have no commercial value such as diaries,
calendars, memo pads, year planners etc.
An employee should report to his immediate supervisor if he is offered any inducement
or gratification. Gifts should also be refused when:
a) It is likely to result in unnecessary or undesirable indirect or direct publicity for
the company
b) It is intended to exert influence on or is likely to embarrass the company
c) The receipt of such gifts would place the recipient under any form of obligation
d) A gift in the form of cash must be refused.
e) An employee must not accept free trips from vendors/ contractors for the purpose
of evaluating products.
Personal Grooming and Presentation
As the first point of contact between <company name> and the public, projecting the
right image should be an employees first priority. Employees should observe the
following:

Wear well-pressed, clean and neat uniforms (for uniformed staff).

Dress neatly and appropriately when wearing civilian clothes.
Observe high standards of personal hygiene and grooming.
Maintain a good posture to project the right image.
Speak confidently, clearly, and in a friendly tone; and
Refrain from smoking when dealing with the public.

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Communication
<company name> is committed to providing communication channels that encourage
self-expression and open dialogue relative to responsible opinions, attitudes and
concerns.
Employee Development
<company name> is dedicated to promoting employee self-development and enhancing
work-related skills.
Human Rights
<company name> operations will respect basic human rights and accepted international
work practices. This includes not employing under-aged workers, not entering into any
contracts or arrangements where workers are exploited, ensuring reasonable working
hours and working conditions.

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Suppliers
Bribes and Kickbacks
We maintain the highest standards of integrity and objectivity in dealing with suppliers.
We should never ask for, take, offer, or give any form of bribe or kickback. Our choice of
suppliers should not be influenced by any promise of money or favour as a sweetener
to the deal.
Bribes or kickbacks in any form (money, commissions, fees, credits, gifts, favours, or
anything of value that is either directly or indirectly provided in return for favourable
treatment) will not be tolerated.
When dealing with offers of bribery, <company name> employees should politely turn
down the offer, and inform the person concerned that it is against our policies to accept
bribes. Any encounter with offers of bribery should be reported to the supervisor at the
earliest opportunity.
Proprietary Information
<company name> will respect the confidentiality of proprietary information and trade
secrets of our clients and vendors and will not disclose any client or vendor proprietary
information, unless the release or disclosure is properly authorized by the individual or
firm owning the information.
Choice of Vendors / Suppliers
<company name> will choose its vendors / suppliers based on considerations such as
competitive pricing, quality, technology leadership, after-sales support, delivery and leadtime performance, financial standing, and payment terms.
When negotiating with a vendor or potential vendor, we are fair and reasonable. We
follow all applicable laws and regulations and uphold good business practices.

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Shareholders
Return on Investment
One of our primary goals is to provide a return on our shareholders investment that ranks
among the highest in our industry through ethical profit making.
Protection of Assets
Every employee is responsible for the proper use, conservation and protection of the
Companys assets, including its property, vehicles, and equipment.
Accuracy of Company Records
Accuracy and reliability in the preparation of all business records is of critical importance
to the Companys decision-making processes and to the proper discharge of our financial,
legal and reporting obligations.
All transactions must be properly authorized and be completely and accurately recorded
on the Companys books and records in accordance with generally acceptable accounting
practices and established financial policies. No unrecorded cash funds or other assets will
be established or maintained for any purposes.

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Competitors
Gathering Competitive Information
Information about our competitors and customers is a valuable asset in a highly
competitive market.
Such information would be acquired through public, legal, and ethical meanssuch as
public documents, trade magazines, published journals, and other public information. We
never seek information through improper means, such as directly from a competitor,
burglary, or spying. We do not misrepresent ourselves, either directly or indirectly
through an agent or a representative, to obtain such information.
Pricing, terms, and other market information may be obtained from customers in the
course of normal discussions or negotiations. However, we cannot obtain pricing or
competitor information directly from our competitor.
We always respect the proprietary information and trade secrets of others, including
former employers. If we are aware of a confidentiality agreement, we never solicit or
accept information that would violate that agreement. We never disclose any client or
vendor proprietary information unless the individual or organization owning the
information properly authorizes such releases or disclosures. Newly hired employees are
not to be asked or encouraged to divulge proprietary information about their former
employers.
Antitrust
A dynamic and thriving economy is built upon open and fair competition. This means
every competitor has a fair opportunity and that all competitors compete under the same
rules. While all employees are expected to work vigorously to outperform our
competition, only legal and fair methods may be used to do so.
<company name> will compete ethically, and our employees must never exchange
information with competitors regarding prices, market share, or any other data in
violation of antitrust laws governing unfair practices.

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Communities and the Environment

Corporate Citizenship
As a responsible corporate citizen, <company name> aims to make a difference in the
world and communities we operate in. We are involved in the life of our communities
through our support for local charities and not-for-profit organizations.
The Environment
<company name> is committed to conducting business in a manner that safeguards the
environment. To do this we:

Use energy wisely and efficiently in our operations. For example, we would
conserve energy by turning computers and other office equipment off or switching
them to energy-saving mode when not in use, and by turning off the lights and airconditioners in unoccupied spaces.
Practise the conservation of resources through Reduce, Reuse, and Recycle. For
example, we would minimize paper wastage at the workplace by printing on both
sides and reusing scrap paper, recycle used paper, drink cans, and plastic bottles
by disposing these items in recycling bins. We should also avoid the wastage of
water in our operations.
Comply with all national and local environmental laws and regulations, company
policies, and professional standards of good industry practices in the countries
where we do business.
Use technologies and operating procedures designed to minimize health and
safety risks.
Encourage employees to report any condition that may pose an environmental,
health, or safety hazard.

The Community
<company name> is committed to creating strategic partnerships with community
organizations.

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Compliance
It is the responsibility of every <company name> employee to comply with the Code of
Conduct. Failure to comply with the Code will result in appropriate employee sanctions,
to be determined by management. If there is an evidence of failure to compliance with the
code by an employee, corrective counselling may be initiated. However, corrective
counselling is not a perquisite to disciplinary action or involuntary termination of
employment. Employment may be terminated at any time as per the provision of
applicable Indutrial Dispute Act.
Employees are encouraged to bring violations or suspected violations of the Companys
Code of Conduct to the attention of his or her supervisor.

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Acknowledgment Statement
I have received the <company name> Code of Conduct. By signing in the space below, I
understand its contents and agree to abide by the Code.

Name

_________________________________________________

Signature

_________________________________________________

Date

_________________________________________________

Site

_________________________________________________

Please pass signed copy to Human Resources Department to be filed in the employee
Personal File.

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