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Anti-Corruption & Anti-Bribery Policy

 

INTRODUCTION

The Company’s philosophy is to conduct all business in an honest and ethical manner. It is illegal to directly or indirectly offer a bribe or receive a bribe. It is also a separate offence to bribe a government/ public official. The Company considers bribery and corruption as serious offences and recognizes that these can result in the imposition of severe fines and/or custodial sentences, exclusion from tendering for public contracts and damage the reputation of the Company.

The Company is committed to act in a professionally and fairly manner in all its business activities, dealings and relationships, wherever it operates and to take all the steps necessary to counter bribery and corruption.

As per the Company’s Code of Conduct for Board Members and Senior Management, the Board of Directors of the Company has an overall responsibility for ensuring the implementation of a suitable framework with regard to prevention of corruption and bribery. Towards this end this Anti-Corruption and Anti-Bribery Policy has been approved by the Board of Directors and comes into immediate effect. The concerned heads of all departments of the Company also have a primary and day-to-day responsibility for ensuring implementation of this policy.

OBJECTIVE

The objective of this policy is:

  • To set out responsibilities of all the employees working in the company, and those associated with the Company; and
  • To provide information and guidance to those working for the Company on how to recognise and deal with bribery and corruption issues.

Those associated with the Company include clients, customers, suppliers, distributors, business contacts, agents, advisors, business associates and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

SCOPE & APPLICABILITY

This policy applies to all individuals working for the Company anywhere within India or out of India and at all levels and grades, including but not limited to senior managers, officers, directors, employees (whether permanent or temporary), consultants, contractors, trainees, casual workers, agents, or any other person associated with the Company.

DEFINITION - BRIBE & CORRUPTION

“Bribe” is an inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. A bribe may be anything of value and not just money - gifts, inside information, sexual or other favours, corporate hospitality or entertainment, offering employment to a relative, payment or reimbursement of travel expenses, charitable donation or social contribution, abuse of function -- and can pass directly or through a third party.

“Corruption” includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery.

GIFTS AND HOSPITALITY

This policy does not prohibit normal, reasonable and bona fide corporate hospitality (given and received) to or from any person or associated parties if its purpose is to improve the company’s image or for establishing cordial relationship.

It is recommended that the purpose behind any hospitality or entertainment is properly assessed. Hospitality or entertainment with the intention of improperly influencing anyone's decision-making or objectivity, or making the recipient feel unduly obligated in any way, should never be offered or received. It should always be considered how the recipient is likely to view the hospitality. Invitations or offers of hospitality or entertainment when made with the actual or apparent intent to influence decisions must be declined. The giving or receiving of gifts can in some cases influence, or appear to influence, decision-making, for example by persuading the recipient to favour the person who made the gift over his own employer. Careful consideration should be made before giving or receiving gifts.

Gifts can occasionally be offered to celebrate special occasions (for example religious festivals like Diwali, or New Year) provided such gifts are moderate in value, occasional, appropriate, totally unconditional, and in keeping with local business practices and traditions. No gift should be given or accepted if it could reasonably be seen improperly to influence the decision-making of the recipient. In addition, some types of gifts will clearly never be acceptable including gifts that are illegal or unethical, or involve cash or cash equivalent (e.g. loans, stock options, etc).

UNACCEPTABLE ACTIVITIES

The activities are not acceptable such as:

  • To give, promise to give, or offer, a payment, gift or hospitality to secure an improper business advantage or to reward a business advantage already given;
  • To give, promise to give, or offer, a payment, gift or hospitality to an agent or representative to "facilitate", expedite or reward a routine or other procedure;
  • To accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
  • To induce another individual or associate to indulge in any of the acts or omissions mentioned in this clause;
  • To threaten or retaliate against one who has refused to commit a bribery offence or who has raised concerns under this policy; or
  • To engage in any activity that might lead to a breach of this policy.

DONATIONS

The Company does not make contributions to political parties which are so made to influence any decision or gain a business advantage. The Company only makes charitable donations that are legal and ethical under local laws and practices.

RESPONSIBILITIES OF EMPLOYEES

Employees of the Company must ensure that they have read and understood this policy and, must at all times comply with the terms and conditions of this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under the control of the Company. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees must notify their reporting manager or consult the Nodal Officer (under Whistle Blower Policy) as soon as possible if they believe or suspect, or have a reason to believe or suspect, that a breach of this policy has occurred, or may occur in the future. A failure to report an actual or suspected breach of this policy is itself, a breach of this policy.

Anyone who breaches any of the terms of this policy may face disciplinary action, which could result in dismissal for gross misconduct.

RAISING A CONCERN/COMPLAINT

Employees and others associated with the Company are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If an employee is unsure whether a particular act constitutes bribery or corruption, he/she should raise the matter with his/her reporting manager or consult the Nodal Officer (under Whistle Blower Policy). Concerns should be reported by following the procedure set out in the Whistleblower Policy which is available on the website of the Company.

ACTION CAN BE TAKEN BY THE VICTIM OF BRIBERY OR CORRUPTION

It is the responsibility of the employee to inform/report it to their respective Managers and the Nodal Officer (under Whistle Blower Policy) as soon as possible if he/she is offered a bribe by a third party, or is asked to make one, or suspect that this may happen in the future or believe that he/she is a victim of another form of corruption or other unlawful activity. The employee must refuse to accept or make the payment from or to a third party, explain the Company’s policy against accepting or making such payment and make it clear that the refusal is final and non-negotiable because of this policy. If any difficulty is encountered in making this refusal, the employee should seek assistance from their Manager.

PROTECTION

Persons who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

The Company is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any employee believes that he/she has suffered any such treatment, he/she should inform his/her reporting manager or a member of the Personnel Department of the Company immediately. If the matter is not remedied, he/she should raise the matter as per the procedure laid out in the Whistle Blower Policy.

MONITORING AND REVIEW

The concerned head of Personnel Department will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvement identified will be made and incorporated as soon as possible.

Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Company. This policy may be amended at any time by the Company.