MASTER OF BUSINESS ADMINISTRATION LAW

Programme: 2022-2024

Ethical Management, Society &

Governance Assignment on-
“Critical Analysis of Ethical and
Governance Policies of LTIMindtree”

Submitted to Submitted by-

Prof. Bala Krishnamoorthy (Group 5)

Unnati Arora (A025)

Oshin Kumari (A026)

Tejaswini Mujumdar (A027)

Akshali Rane (A029)

Ayushman Nag (A031)

Rashmi Agarwal (A032)
 Critical Analysis of Ethical and Governance Policies of
LTIMindtree

LTIMindtree is a technology consulting and services company that provides information

technology solutions to clients across various industries. LTI Mindtree is a subsidiary of Larsen
& Toubro Infotech (LTI), which is a global technology consulting and digital
solutions company.
LTIMindtree adheres to a robust governance framework and ethical policy that ensures the
company operates with integrity and in compliance with legal and regulatory requirements.
Some of the important ethical and governance policies have been briefly mentioned below:
The Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive
Information (UPSI) Policy is an important regulatory framework aimed at ensuring fairness
and transparency in the disclosure of sensitive information by companies. While the code
serves a crucial role in maintaining market integrity and protecting investor interests, a critical
analysis reveals both strengths and potential areas for improvement.
One of the key strengths of the code is its emphasis on preventing selective disclosure. By
requiring LTI to promptly and uniformly disclose UPSI to the stock exchanges, it helps to
ensure that all investors have access to the same information at the same time. This reduces
information asymmetry and promotes a level playing field, which is vital for maintaining fair
and efficient markets.
Another positive aspect of the code is the provision for the establishment of a robust internal
mechanism for handling UPSI within LTI. This mechanism includes the formulation of a clear
policy, the designation of a senior officer responsible for overseeing the implementation of the
policy, and the maintenance of a structured digital database of UPSI. These measures can
enhance corporate governance practices and help prevent inadvertent leaks or misuse of
sensitive information.
Next, LTIMindtree’s Whistle Blower Policy provides a comprehensive overview of the
whistleblower framework at LTIMindtree. It demonstrates a commitment to creating a
supportive environment for reporting concerns and protecting whistleblowers like the purpose
of the policy, definitions, scope, reporting mechanisms, investigation process, protection
measures, and non-retaliation.. While the policy covers essential aspects of a whistleblower
framework, there are a few areas where further elaboration or clarification could enhance its
effectiveness, such as providing specific timelines for investigations, outlining whistleblower
protection measures, and detailing the scope of the policy across the organization's entire
ecosystem.
Moving on to its Integrity policy, it emphasizes conducting business in accordance with the
highest standards of integrity and ethics. Employees are expected to adhere to principles of
conduct and encouraged to exercise sound judgment in unprecedented situations. The company
encourages employees to utilize the whistleblower process to report integrity breaches. Their
policy lays down detailed process highlighting the authorities to investigate, investigation
process and consequence of breach.
LTIMindtree also has Diversity, Equity and Inclusion Policy which aims to create an
environment of equal opportunity to all candidates, employees and partners where they can
achieve their full potential, feel valued and appreciated for who they are. It primarily focuses
on Ethnicity/Nationality, persons with disability, gender and LGBTQ+ Inclusion. The
organization is strictly against Discrimination, Harassment and Bullying as it believes on the
sole fact that each human being is equal & no one is superior than any other. LTIMindtree
encourages employees to report in good faith any possible violation of this Policy. There are
certain core principles which LTI lays emphasis on for the purpose of inclusion of its employees
like value and respect diverse approaches, support flexibility for employees, advocate pay
equity Fair and equal remuneration policy of all diverse group and fair performance
management process.
Next is the Non-Discrimination Policy which demonstrates a commitment to ethical
management practices by promoting equal opportunity, prohibiting discrimination, fostering a
respectful work environment, and providing mechanisms for reporting and investigation. The
policy aligns with ethical principles of fairness, diversity, accountability, and integrity, setting
a foundation for an inclusive and ethical workplace culture.
LTIMindtree’s Anti-Money Laundering Policy exhibits a robust commitment to maintaining a
business environment that prioritizes ethics, integrity, and compliance. By extending the
policy's reach to all employees and third parties, regardless of their roles, and actively
emphasizing its dedication to adherence, LTIMindtree positions itself as a responsible
corporate entity dedicated to preventing money laundering and promoting clean business
practices.
Lastly, LTIMindtree’s Anti-Bribery and Anti-Corruption Policy stands as a robust framework
to prevent corruption and unethical practices within the organization and its affiliates. By
applying this policy universally and incorporating clear reporting mechanisms, confidential
investigations, and stringent consequences for violations, the company aims to foster a culture
of honesty and integrity at all levels, safeguarding its reputation and ensuring compliance with
legal and ethical standards.

Questions:
1. Considering the importance of whistleblower protection, the LTIMindtree Whistle
Blower Policy states that whistleblowers will be protected from retaliation. However,
the policy does not explicitly outline the steps taken to ensure the protection and well-
being of the whistleblower during and after the investigation. How does LTIMindtree
plan to address this gap and provide comprehensive safeguards for whistleblowers?

2. In the event that a case of money laundering arises within the company, despite its
compliance with regulatory laws and provisions, how does the company's Anti-Money
Laundering (AML) policy address such scenarios and what steps does it outline to
effectively handle and mitigate the risks associated with money laundering?