ABAC & Conflict of Interest

1. An Indian Company having its parent company incorporated in UK was bidding for a major Transport
contract. Without the knowledge of its Parent Company, one of their employees in India paid a bribe
to the awarding company to ensure they win the contract.
Which of the following statements is most accurate?
A. The company may be prosecuted for failure to prevent bribery
B. The employee may be prosecuted for giving a bribe
C. The company may be prosecuted for failure to prevent bribery and the employee may be
prosecuted for giving a bribe
D. Nobody is responsible as the bribe was not paid to Govt. officials.
2. A commercial organization will be liable if a "person associated" with it gives bribe to anyone.
An associated person is likely to include which of the following?

1. A contractor who performs services for the organization

2. An agent who deals with the organizations’ customers
3. A supplier from which the organization buys products only
4. An advocate engaged on behalf of the Company
A. 1 and 3
B. 1, 2 and 3
C. 2, 3 and 4
D. All of the above
3. Which of the following are examples of actual or potential conflicts of interest?

1. An employee approving a contractor that employs his brother

2. An employee is a silent director of one of his employer's contractors but receives no income for
his directorship
3. HR executive granting recruitment to a candidate from his family but based on the candidate’s
actual merits.
4. An employee has a substantial shareholding in a company that does business with his employer
A. 1 and 4
B. 1, 2 and 4
C. 2, 3 and 4
D. 1, 2, 3 & 4
4. On the news of your wedding, a Supplier has offered you an expensive gift. What will you do?
A. You will keep it as not linked with operation of the Company
B. You will accept it and report it to Legal Dept.
C. You will politely refuse to accept it.
D. Any of (B) & (C) is acceptable
5. If you are given a valuable gift by a Foreign Contractor during your visit to their Office and it is
customary to accept the gift in that country as returning the same shall be considered offensive, What
would you do:
A. You shall return the gift even if the host feels offensive.
B. You will keep the gift at your home and don’t take it office.
 C. You shall declare and submit the gift to the Compliance Officer of the Company
D. None of the above.
6. A Bauxite supplier XYZ Ltd comes to know that you are planning for a vacation in Sydney with your
family. It offers to arrange accommodation and hospitality at its expense, what will you do?
A. Refuse to accept any such offer.
B. It is ok as your company also offers Guest House for their stay at your location.
C. It is ok if you inform your reporting manager.
D. None of the above.
7. You see your Boss approve the payment of money to a Vendor to ensure faster clearances of Goods
stuck in Customs.
A. You think it is ok as he is your Boss and he is taking a decision in the interest of the company
B. You immediately report it under the whistleblower policy
C. You point it out to your Boss and then don’t report the same.
D. You will do nothing & mind your own business.
8. Which of the followings is not a violation?
A. Passive Bribery i.e. just receiving the bribe but not asking or requesting for the same.
B. Bribery of a foreign public official.
C. Failing to prevent bribery by any person associated with it
D. None of the Above
9. The company decided to distribute gifts to its employees on the occasion of Diwali. The procurement
team has invited quotation from different vendors and the agency run by a sibling of the Officer-in-
charge provides the best quote. Which of the followings is correct to follow?
A. There should be no concern for awarding the contract as the vendor provided the best quote.
B. The Officer-in-charge should disclose the conflict to the supervisor and Legal/secretarial dept.
before the final decision.
C. The officer-in-charge should disregard the quote and go for the vendor provided 2nd best quotation
D. You will ask one from your dept. to handle the rest of process as it would be conflict if you award
the contract.
10. A Company has contracted an Agent to obtain clearance from Authority. The invoice of the agent
includes miscellaneous expenses, but the overall amount is well within the budget. The Agent states
that the expense is pertaining to some out of pocket expenses in order to get the clearance from
Authority. Which of the following would be the correct course of action?
A. Payment may be cleared if approved by your reporting head.
B. Payment should be cleared as per the invoice as the Agent has successfully got the clearance for the
Company.
C. Establish the amount legally required to get the clearance and consider an in-depth audit of all the
charges with break ups of miscellaneous charge.
D. There should be no concern about the invoice amount as the same is adequately budgeted.
 PREVENTION OF SEXUAL HARASSMENT
1. If a male colleague habitually addresses his female co-workers with the term of endearment such
as “honey”, “love”, “sweety” and “dear”. Can this be construed as Sexual Harassment?
A. Yes. Except for “dear”
B. Yes. All such endearment words are not allowed at workplace.
C. No. Only verbal abuse can be construed as Sexual Harassment.
D. Yes. If these words are used inside office premises.
2. Sexual harassment is not limited to physical contact. It can occur any time that an individual is
__________ another person's approaches, comments or discussions.
A. Uncomfortable with
B. Irritated by
C. Getting angry on
D. Avoiding
3. Any complaint of sexual harassment can be emailed @
A. VALL.ICC@Vedanta.co.in
B. ALUMINA.LAN.ICC@Vedanta.co.in
C. VL.InternalCommittee@Vedanta.co.in
D. Vedanta.icc@vedanta.co.in
4. Which of the following fits proper for the person who can complain the incident of sexual
harassment on behalf of the aggrieved women where she is unable to complain due to physical
incapacity?
A. Only a Co-worker/friend/relative of an aggrieved women can file the complaint with written
consent of her.
B. Only family member/legal heirs of aggrieved women can file the complaint with written
consent of her.
C. Any person who has knowledge of the incident can file the complaint with written consent
of her.
D. All of the above
5. In case of sexual harassment complaint from a visitor, there is nothing that the Company is
expected to do about?
A. Yes. Vedanta’s POSH Policy is only for employees.
B. NO. The complaint is to be followed by investigation by IC of the Company.
C. The company should assist the complainant to file a FIR at Police Station
D. None of the above
6. What does a Quid Pro Quo Harassment means?
A. Harassment when there is a request or demand for sexual favors in exchange of
employment benefits.
B. Harassment caused by behavior which is humiliating, intimidating or irritating.
C. Harassment which caused by verbal abusing.
D. Harassment of this kind does not exist.
7. Dirty Jokes/Eve Teasing /Vulgar Languages may be construed as sexual harassment.
A. True. It is offensive, if it is in written form.
B. False. Sexual Harassment is only unwelcome sexual advance or physical conduct of a sexual
nature.
C. True. Any form of harassment whether physical or verbal or visual is prohibited if an
individual is uncomfortable.
D. False. Dirty Jokes/Eve Teasing/Vulgar Languages are just for fun, hence cannot be
construed as Sexual Harassment.
8. Which of the followings is the most ideal and effective 3 part strategy to deal with sexual
harassment?
A. Respond, Record and Report.
B. Record, Respond and Report.
C. Report, Reconsider and Record.
D. Respond, Report and Record.
9. As per Vedanta’s POSH Policy, the complaint regarding sexual harassment shall be made within a
period of _______________ and ICC shall endeavor to complete the entire investigation process
and its findings within a maximum period of _____________.
A. 6 Months || 90 days
B. 3 Months ||90 days
C. Committee can increase the limit of filing of complaint, if delay reporting of complaint is
found reasonable || 30 days
D. 3 Months || 30 days
10. What is the first recourse available for the filling complaint against sexual harassment?
A. Write to Internal Committee of the Company.
B. Lodge complaint in Local Police Station.
C. Complaint through Whistle Blower Mechanism.
D. Any of the Above.
 Insider Trading

1. Which of the following is not a violation under Vedanta Insider Trading Policy?
a. Exercise of stock options (ESOPs) under Cash method when trading window is closed.
b. Sale of shares allotted on exercise of stock options when trading window is closed.
c. Trading by an Insider without pre-clearance when trading window is not closed.
d. All of the above
2. Which of the followings is an example of Insider Trading?
(i) You sell your company's stock because you are privy to unpublished price sensitive
information.
(ii) After reading an article about Company Y in Financial Times, you bought its shares.
(iii) You buy the stock of Company X because you are privy to Board discussion about
acquisition of Company X.
(iv) Being CFO of Company Z, you ask your relative to dump its shares before its AGM.

a. (i), (iii) & (iv)

b. (i), (ii) &(iii)
c. (ii), (iii) & (iv)
d. (i), (ii), (iii) & (iv)
3. “Insider” includes;
a. Only Directors and Promoters
b. Immediate Relative of Designated Employees
c. Executive, Personal Secretaries/Assistants of Directors & KMPs
d. Both B & C
4. At a family party, you tell your brother-in-law that your Company is about to announce a big deal
with Rio Tinto, a mining and metals major company. Your brother-in-law purchases the shares of
your company. What are you guilty of?
a. Anti- Bribery
b. Insider Trading
c. Money Laundering
d. All of the above
5. Pre-clearance to trade with company shares & securities are required to be approved jointly by;
a. Group CFO & Group Legal Counsel
b. Company Secretary & Group Legal Counsel
c. Company Secretary & Chief Human Resource Officer
d. Group CFO & Compliance Officer
6. Which of the following is correct?
a. Non-insiders can trade without pre-clearance while trading window is closed.
b. Compliance Officer can trade by taking pre-clearance from Group CFO.
c. Designated person can trade without pre-clearance while trading window is open.
d. Compliance Officer can trade by taking pre-clearance from Insider Trading Monitoring
Committee.
7. Which of the followings is not correct w.r.t the “Chinese Wall Procedure” adopted under the
Vedanta’s Insider Trading Policy?
a. “Chinese Wall” is a provision to segregate the premises into inside areas and public areas.
b. In the event any person is required to be wall – crossed, prior approval of the Compliance
Officer must be sought.
c. Employees from the public areas may be brought “over the wall” without information to
Compliance Officer.
d. Only A & B
8. Which of the followings is true as per the Vedanta’s Insider Trading Policy?
a. An ex-employee, who was covered under the definition of designated persons, cannot
trade with the company securities for a period upto 6(six) months from date of cessation
of his/her employment.
b. Any person who ceases to be an Insider as per the Designated Person list shall be
considered as an Insider for a cooling period of 3(three) months.
c. Non-insider are required to take pre-clearance for trading with company securities while
trading window is open.
d. Only A & B
9. Trading window shall be opened not earlier than __________ after the UPSI made public.
a. 48 Hours
b. 72 Hours
c. 24 Hours
d. None of the above
10. Pre-clearance granted by the Compliance Officer shall be valid for ;
a. 30 Days
b. 90 days
c. 7 days
d. 15 days
 Competition Law

S. No. Question Options Correct Answer

1. Competition law do not prohibit anti-competition agreement which True / False False
are not in writing i.e. oral agreement / understanding.

2. A company is allowed to increase its price in accordance with True / False True
international price index.

3. Vedanta Group can refuse to sell its product to a company which is True / False False
a competitor in another business of Vedanta.

4. We are not allowed to talk to our competitors for increasing the True / False True
price of our products.

5. It is fair competition to reduce our prices lower than a competitor True/False False
even if we suffer loss because we have the cash reserve to sustain
the loss and survive but the competitor does not.

6. During bidding process we can ask our competitors not to bid for True / False False
mines/products in which we are interested and similarly we can
agree not be bid for the mines/products in which they are interested.

7. It is ok to discuss and fix prices as long as it’s in a Trade True/False False

Association Meeting where everyone from the industry is present.

8. We can download the publically available policies of a company True/False True

and use it to benchmark/improve our policies

9. I have arranged some confidential information of my True/False False

competitor/rival company and I want use the same to my
advantage.

10. My competitor calls me and asks for some price sensitive True/False False
information, I should share the same with him.