Code of Conduct - Swapnil Sahoo

Code of Ethical Business
Conduct
This is an abridged version of the Company’s Code of Conduct, specifically created for those who are getting
associated with the Company. You are expected to read the detailed document over next few days. Decisions
with respect to the Code of Conduct will be subjected to the detailed policy.
_______13th May 2015___________ _________ __________

Date (DD-MMM-YY) Signature
Page 1/10 of Code of Conduct
Code of Ethical Business Conduct
Objective
 Code of Ethical & Business Conduct is adopted by the Company as a testimony of its commitment to
adhere to the standards of loyalty, honesty, integrity and to avoid any kind of conflicts of interests.
 All associates of the Company, including but not limited to employees, consulting staff, trainees,
vendors, partners; are responsible for carrying out their duties in an honest, fair, diligent and ethical
manner, within the scope of authority conferred upon them in accordance with the laws, rules,
regulations, agreements, guidelines, standards and internal policies, including such requirements
which are incidental thereto.
 The rules and principles set forth in this Code are general in nature and the compliance with the
Code shall be read along with –
 Principles defined in other policies and procedures of the Company
 Applicable law of the land
Our Responsibilities – as an Associate

 Learn and understand all elements of the Code
 Comply with the Code and associated policies and guidelines
 Seek clarifications and assistance when in doubt
 Promptly report known or suspected violations
 Cooperate in investigations pertaining to Code violations
Failure to comply with the Code and above mentioned responsibilities may lead to appropriate
disciplinary action by the Company, including termination of services/contract.
Our Responsibilities – as a Manager

 Ensure our teams have read and understood the Code
 Build and maintain a culture of compliance to the Code
 Proactively identify and prevent potential violations of the Code
 Report issues of non-compliance to Code and facilitate investigations
 Follow the relevant guidelines defined in the Code
A Code violation in your team would be seen as a potential failure on your end to ensure adherence to
the Code
_______13th May 2015___________ _________ __________

Overriding Principles
 It is important to do the ‘right’ thing. But it is also very important to appear to be doing ‘right’ –
what gets perceived, gets followed by others
 Human dignity and respect should be maintained at all times and in all dealings
 Employees will be truthful and accurate in all their communication
 The Code is also applicable in outside office and in our personal lives - every Associate is a brand
ambassador of the Company and reflects what we stand for
 Not everything can be defined by policies, programs, norms and the Code. When in doubt, do
following checks and proceed only if the answer to all of them is a clear ‘Yes’
 Is it the ‘right’ thing to do from the Company’s point of view?
 Can this be discussed openly in public?
 Can this easily be discussed with superiors and juniors without setting a bad example?
 The action will not create an adverse impact on the image of the Company as an ethics
driven organization
 This action will not cause any embarrassment to the Company on such matters within and
outside the organization
 This will not create any adverse impact on the brand image of the Company or the business
group
 When in doubt seek guidance from your managers. And continue to do so with the higher levels till
the time you are completely satisfied
I We
Integrity, Accountable, Principled, Respectful, Fair Legal, Honest, Ethical
My decisions and actions will consistently reflect
our stated & implied principles and I will be We will conduct all our business in an honest &
accountable for them. ethical manner.
I will inform and seek suggestions in case of doubt. We will take a zero tolerance approach to
bribery and corruption and are committed to
I will act in an honest, open and fair manner; yet be acting professionally, fairly and with integrity.
sensitive towards maintaining confidentiality of
classified information. We will act in a manner that will enhance and
maintain the reputation of the Company.
I will do the right things for our business, staying
within legal and ethical boundaries. We will treat all colleagues, partners, vendors,
customers with dignity and shall not harass any
I will confront dilemmas and raise concerns on of them in any manner.
violations to the Code, policies and guidelines.
We will be a good corporate citizen.
I will respect diversity and keep our workplace, free
of prejudice and discrimination based on caste, We will imbibe & practice the Code in letter &
creed, gender, sexual orientation, race or spirit through personal conduct.
nationality.
_______13th May 2015___________ _________ __________

Conflict of Interest
 Pursuit of any personal business interest is not permitted – organized or unorganized. This is to
ensure focus and allegiance towards Mahindra Comviva
 Business is defined as an act of producing or trading goods or services with an intent of
profit involving self or others. This excludes personal financial & property investments
 Irrespective of the nature of vocation, if it has the slightest possibility of falling under definition of
‘business’; should be proactively declared by the Associate
 In case there was any possible involvement in the past, the same should be formally declared (in
writing) within five (5) days of commencement of association with the Company
 Exceptions may be granted, however they have to be sought pro-actively in writing – please refer
the detailed document
 An Associate should not be a part of an evaluation committee or be the decision maker for any
business contract or arrangement with any organization wherein his/her relatives or close friends
are involved in key positions. Such a conflict of interest should be immediately reported to
immediate manager and Human Resource representative and the Associate should refrain from
participating in any transaction involving family or friends including form of awarding benefits, such
as increase in salary or remuneration, posting, promotion or recruitment
 Associates should not use opportunities discovered through employment at Mahindra Comviva for
personal gains
 Acceptance of directorship on the Board of other companies which compete with Mahindra
Comviva amounts to conflict of interest. Associates will be expected to obtain prior approval from
the CEO, CFO and Global Head of HR before they accept any such position
 In event of any doubt pertaining to a possible conflict of interest, Associates are expected to
formally report the issue to their immediate manager and Human Resource representative
Sharing of Professional Expertise outside the Organization

 Sharing of knowledge outside the Company is promoted as it helps self development while also
promoting the brand of the Company. But the same should be done after due permissions (in
writing) are given by the managers, Learning Team and Human Resource representative
 For any such session/interaction, Associates cannot seek any cash remuneration. However, a token
memento (up to Rs. 1500 within SAARC countries and $150 for other countries) can be accepted. If
the value is higher, the same should be notified to the Human Resource representative and handed
over to the Company for employee auction/CSR
 Associates are encouraged to undertake such commitments outside the office hours. They should
also ensure that their involvement should not impact their work
 For any such session, which is undertaken beyond office hours, Associates can claim remuneration
from the third party/agency; provided the same is declared to the Company. Care should be taken
that this should not lead to conflict of interest for the Associate or create an obligation for the
Company towards the third party/agency
_______13th May 2015___________ _________ __________

 Unless the same is already available in public domain, an Associate cannot share data pertaining to
the Company or its current or past partners/customers/vendors/other Associates
Pursuit of Interests & Hobbies

 The Company appreciates that for personal fulfillment and as a mode of self – expression; associates
may pursue their interests and hobbies
 However such sharing should be done after due permissions and the activities are to be pursued
outside the office hours or when the associate is not actively or passively engaged in any official
activity
 Care should be taken to avoid any comments on the organization or its people, policies, programs
and processes
 The associates will also not share any details pertaining to the Company or its business groups other
than those available in the public spaces
Bribery, Kickbacks, Gift & Hospitality

 The Company is committed to being regarded as a transparent & best in class organization which
takes all decisions based on compliance to applicable law and its Code of Conduct
 The Company does not give and shall not accept any ‘facilitation payments’ or ‘kickbacks’
 All Associates of the Company shall not accept any gifts given to them because of their position or
role
 The Company and its Associates will neither accept nor give gifts which can possibly impact business
decisions of the receiving party
Events Organized by Customers, Vendors and External Agencies

 Though many times, events are relevant to us (from the Company or individual perspective), in most
situations, partners and external agencies organize events with direct or indirect focus on their
business interests
 In some situation such events may be organized at holiday/exotic locations, with an all expenses
paid trip
 Participation in such events is generally not permitted
 But in some rare situations, if the Associate believes representation will help the Company derive
strong value, the Associate can put in a formal request to his/her manager and HR (any HR member
at A11+) explaining the reasons. Such requests will be evaluated on a case to case basis and in line
with the principles defined in the detailed document
Non Alliance with Political Parties

 Company will comply with all applicable laws of the land
 Company will not to campaign, support and offer any funds or property as a donation or otherwise
to any political party or to an independent candidate contesting for a political office
_______13th May 2015___________ _________ __________

 Company strives to preclude any activity or conduct which could be interpreted as a favor to and
from any political party or person.
 Company does not make contributions to political parties which are so made to influence any
decision or gain a business advantage
Maintaining Confidentiality of Information

 All Associates are expected to maintain confidentiality such information (that they have access to
the same in normal course of business) relating to the Company’s and its customers Products,
Services, Policies, Processes, etc.; until and unless authorized or legally required to disclose such
information. Associates shall not use confidential information and other corporate opportunities for
their personal advantage
 Associates are prohibited from using material information pertaining to the Company before it is
made public, for financial or other personal benefit or conveying this information to others
 All Associates are prohibited from providing third parties (including friends and family) with inside
information
Human Dignity
 Company is committed to treating those engaged with dignity & respect
 The Company encourages open and honest communication at all times
 Associates are to maintain highest standards of dignity, decency, fairness and integrity at all times
Controllership
 Company is committed to comply with the right environment for disclosing timely, reliable and
accurate information to legitimate authorities
 Associates contributing to the financial and accounting matters, records and reporting, must strictly
comply with the financial policies and procedures
Participation in External Bodies (Social, Religious, Professional, Political)
 In their personal capacity, Associates are free to participate or seek membership of any Social,
Religious, Professional & Political Bodies and Interest Group or an organization which carries an
untarnished image in society in general and not unauthorized by law
 Company expects its Associates to immediately leave an organization if it is found indulging in
unlawful or unethical activities
 An Associate’s association and activities should be pursued outside office hours or when he/she is
not expected to be actively or passively engaged in an official activity. Such efforts should not hinder
effective discharge of Associate’s role and responsibilities
 Actions undertaken and views expressed by Associates would be entirely their own and not in
official capacity or as a representative of Mahindra Comviva. Mahindra Comviva will not be
responsible for the same or as an outcome of the actions or views of that individual. The whole sole
ownership would be with the individual in their personal capacity
_______13th May 2015___________ _________ __________

 However Associates will have to ensure that their actions or views should not cause or spread
discrimination, hatred or violence that leads to loss of life or property or causes disturbance of any
nature.
 In case if the external body has been notified as unlawful by the government; the Associate will be
expected to immediately sever all ties with the body
 All allegiance, views and actions must meet the overriding principles of the Code
Other Important Guidelines

 Irrespective of the legal position of the situation, recording of audio or video of any non-public
conversation or an event without the full prior knowledge of the involved parties is not an
acceptable behavior and is treated against the values of the Company. For any special
circumstances, prior written approval of HR would be essential
 During the course of an audio conversation, it is expected as a good corporate citizenship and
etiquette that receiving party pre-announces to the speaking parties before they are put on a
speaker phone. This is treated as opening of a conversation meant for private parties towards a
larger audience without the consent of the speaking party
 It is also expected that all Associates keep their personal & communication addresses provided to
the Company, updated along with other contact details at all times. In case of any change, the same
should be notified at least twenty four (24) hours in advance through a formal e-support request
 Associates claiming mobile phone benefits/reimbursements of any nature are obligated to share
and keep their mobile phone number updated on Outlook with the help of the Administration team.
Any phone number which is not updated, would be treated as Associate’s responsibility
 During many situations, we use office services like photocopier, phone, etc. A once in a while usage
for personal purposes is understood as segregation of the same from official activities is hard to
track and administer. However, it is expected that Associates will mandatorily declare such usage on
an approximate basis or seek prior permission when the usage is noticeable; and follow up the same
with adequate deductions and approvals. The onus of the same is on the Associate and failure to
comply can be treated as a violation of the Code. All Associates are expected to declare the same at
least on an approximate basis for the year or for the month/period, as the case may be
Online Forums & Platforms – Participation

 In today’s world, presence on online forums and platforms is quite common and it occupies
significant part of our life. Being in a technology focused industry, where mobile phone and the
Internet are life lines to our business, we can’t close our doors to them
 Unlike many Companies, we do not want to block out access to sites like Facebook, Linkedin,
Twitter, Google, etc. However, Associates are expected to handle this with responsibility and ensure
that it does not reduce productivity; and in fact leveraged to enhance the same. Each Employee will
be permitted to access such sites for a limited period of thirty (30) minutes per day using official
machine and network
_______13th May 2015___________ _________ __________

 However, both within or outside our work hours, all Associates are expected to exercise caution and
restrain by honoring the following:
 Actions undertaken and views expressed by them would be entirely their own and not in
official capacity or as a representative of Mahindra Comviva
 Mahindra Comviva will not be responsible for the same or as an outcome of the actions or
views of that individual. The whole sole ownership would be with the individual in their
personal capacity
 However employees would have to assure that their actions or views would not cause or
spread discrimination, hatred or violence that leads to loss of life or property or causes
disturbance of any nature
 Any matters, data or details pertaining to Mahindra Comviva or its business will not get shared by
the Associate without permission, other than those which are already available in public space
 Associates are expected to take additional precaution while using websites which reflect our existing
or past association with the Company. It is explicitly or implicitly understood that each one of us is
an ambassador of the Mahindra Comviva brand, and our actions and views would be seen in that
light
 All allegiances, views and actions must meet the overriding principles of the Code and the Data
Security Leakage & Prevention Guidelines of the Company
Protection & Use of Company Assets

 Associates shall protect all assets of the Company and ensure their efficient and proper use. All
Company assets should be used for legitimate business purposes
 Associates can use only a legal and authorized software version on the Company provided
laptop/desktop
 All Associates will protect the brand, physical, financial, product and intellectual assets of the
Company
 Company property, equipment and intellectual property rights such as patents, trademarks,
copyrights, designs, strategies, plans, trade secrets and similar items that are not in the public
domain, will be used only in the course of business with proper care and safeguards
 All ideas, submissions, documents, Invention Disclosure Documents and Patent Filings will be the
property of Company at all times. The Company or Associates will not infringe the intellectual
property rights of others
 Please refer to the Data Security Leakage & Prevention Guidelines for more details
Information Security
 All Associates will comply and adhere to the acceptable use of computer resources such as data
protection, information classification and protection, password usage & management and third
party access
 All Associates are expected to exercise high level of vigilance in keeping the Company’s information
secured in safe hands
 An Associate’s personal information and data is confidential and will be guarded strictly
_______13th May 2015___________ _________ __________

 Information should not be hidden or manipulated from those who have the right to know
 Care should be taken while sending the communication in email or paper form so that it is shared
only with the intended recipient
 Associates are obligated to maintain the confidentiality of sensitive data even after their tenure
 Please refer to the Information Security guidelines of the Company for more details
Fair Employment Practices

 All Associates are expected to help the Company in achieving the following
 Provide an inclusive culture and work environment, where every Associate will have the full
opportunity to achieve their potential
 Provide equal opportunities to all Associates without being biased towards their race,
religion, caste, region, color, ancestry, marital status, gender, sexual orientation, age,
nationality, ethnic origin or disability
 All decisions pertaining to recruitment, hiring, training, promotions, pay & benefits,
transfers and dismissal, participation in decision making, etc. are objective and based on
Associates qualifications, prior experience, expertise and abilities, local and constitutional
law mandate with recruitment (if any)
Harassment Free Workplace

 The Company has zero tolerance on any act of sexual harassment, discrimination and intimidation
based on sex
 The Company promotes a work environment that encourages mutual respect, congenial
relationships between Associates, harmonious and productive atmosphere in the work place
 All Associates are expected to conduct themselves in a manner which is not uncomfortable and
unwelcomed by others. Unwelcome behavior includes those that are humiliating, unsafe,
discriminatory, career limiting, intimidating and unhealthy
 Please refer to the Company’s Policy to Prevent and Deal with Sexual Harassment for more details
Customers
 The Company is committed to deal with customers fairly, ethically, honestly and with integrity
 Information provided to the customers should be accurate and complete to the best of the
knowledge
 No data and facts should be misrepresented to gain undue advantage or deal
 Confidentiality of customer data should be maintained at all times
 Customer entertainment should not exceed reasonable and customary business practices
Business Associates
 Mahindra Comviva deals with its business associates in a highly professional and ethical manner
 All Associates dealing with a business associate should carefully guard their objectivity
_______13th May 2015___________ _________ __________

 No Associate should solicit personal benefit from a business associate or a potential business
associate that might compromise or appear to compromise the objective assessment of business
associates products, prices and services
Community
 The Company will provide an infrastructure and support mechanism to help Associates contribute to
society in a meaningful manner
 While fulfilling social obligations, Associates will not impose donations to charities and NGOs of
personal preference on others
Administration of the Code

 The Code will be administered by the Ethics Office of Mahindra Comviva, who will provide all the
guidance, training, clarifications and ensure compliance
 Complaints can be reported to ethics@mahindracomviva.com
Whistle Blower Policy & Process

 The objective of this policy is to provide Associates (whether permanent or on contract), investors,
customers, vendors and other stake holders an avenue to raise concerns in line with our
commitment to highest possible standards of ethical, moral and legal business conduct
 The Corporate Ombudsperson is primarily responsible for overseeing all complaints received and
prevent retribution against anyone for raising or for helping to address integrity concerns
 The Corporate Ombudsman or the Redressal Committee constituted by him/her, administers a
formal process to review and investigate any concerns raised, and undertakes all appropriate actions
required to resolve the reported matter in an objective manner
 The Corporate Ombudsman will operate in a fully confidential manner and periodically report its
findings to the Board of Directors
 Complaints can be sent to corporateombudsperson@techmahindra.com
 Please refer to the Whistle Blower Policy for more details
Declaration
I have read and understood the Company’s Code Ethical Business Conduct. I also understand this document is
an abridged version provided by the Company for my ease and reference. I understand that I am expected to
read the detailed Code and all associated documents like Policy to Prevent and Deal with Sexual Harassment,
Data Security Leakage & Prevention Guidelines, Information Security Guidelines, Whistle Blower Policy, etc. on
my own over the next few days. Failure to do so would be completely my responsibility and the Company is free
to evaluate any non-compliance in light of the principles and guidelines defined in the detailed documents. I also
undertake to promptly report any breach that may come to my knowledge in future.
Name SWAPNIL SAHOO Date 13TH May 2015
Signature Swapnil Sahoo Place Bangalore
_______13th May 2015___________ _________ __________


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Code of Ethical Business

_______13th May 2015___________ _________ __________

Our Responsibilities – as an Associate

Our Responsibilities – as a Manager

_______13th May 2015___________ _________ __________

_______13th May 2015___________ _________ __________

Sharing of Professional Expertise outside the Organization

_______13th May 2015___________ _________ __________

Pursuit of Interests & Hobbies

Bribery, Kickbacks, Gift & Hospitality

Events Organized by Customers, Vendors and External Agencies

Non Alliance with Political Parties

_______13th May 2015___________ _________ __________

Maintaining Confidentiality of Information

Participation in External Bodies (Social, Religious, Professional, Political)

_______13th May 2015___________ _________ __________

Other Important Guidelines

Online Forums & Platforms – Participation

_______13th May 2015___________ _________ __________

Protection & Use of Company Assets

_______13th May 2015___________ _________ __________

Fair Employment Practices

Harassment Free Workplace

_______13th May 2015___________ _________ __________

Administration of the Code

Whistle Blower Policy & Process

_______13th May 2015___________ _________ __________

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