Policy

Policy

We shall always maintain high standards of ethical conduct and shall not tolerate bribery or corruption in any form either directly or by those who work on our behalf. We strictly prohibit corrupt practices at all levels, by adhering to the ethical conduct and complying with the laws of the land.

Policy Adherence

Making sure the standards of ethical conduct are followed is the overall responsibility of Name of Company s’ leadership and of each individual employee. The compliance and ethics programs requires the commitment and support of everyone who work for Name of Company to ensure that the code of conduct lives and breathes in everything we do

We are under obligation to maintain High ethical standards, maintain our reputation among our clients. Name of Company Ethical Conduct Policy specifically follows Business Principles as under:

  • We maintain integrity, fairness and transparency in our operations so as to give our clients desired comfort.
  • Name of Company promotes Integrity and Honesty across all of our operations. Our reporting requirements allow us to measure and monitor our performance on a periodic basis and we shall ensure that our workforce adhere to these strict reporting standards at all times.
  • We shall always maintain legal, regulatory and statutory compliances.
  • We shall always adhere to the license requirements as may be required by the statutory authorities.
  • Corruption in any form, whether direct or indirect shall be prohibited.

Policy Applicability

This policy shall be applicable to every employee, director or officer of Name of Company Contract personnel working for Name of Company shall also follow this Policy. Contractors and consultants are required to act consistently with this Policy while working for Name of as our agent, on our behalf or in our name, on any business activity including when delivering outsourced services.

We apply this Policy in all joint operations where Name of Company is party.

We shall adopt the policies that may be laid down by our clients with regards to Ethical Conduct and Anti Corruption.

Breach of Name of Company Policy or Client's policy as the case may be shall result in disciplinary action, up to and including dismissal. Contracted personnel who fail to comply with this Policy may have their contract terminated, not renewed, or be subject to other appropriate action including punitive and compensatory inaction. Name of Company reserves the right to amend or update this Policy as required from time to time or for the reasons to bring it in conformity with Client's requirement.

In accordance with the expansive scope of global anti-corruption laws, including the FCPA and the U.K. Bribery Act, Name of Company prohibits all bribes from being paid or promised, regardless of whether the recipient is a foreign government official or a private individual (commercial bribery). Name of Company personnel are also prohibited from accepting or agreeing to accept improper benefit or bribe.

Any potential violations will be deemed significant, and as with all Code of Integrity concerns, must be immediately reported to an appropriate person within Name of Company , such as a supervisor in Finance, Legal or HR. Further, it is important to remember individuals can be charged personally for violations of these laws.

Those who supervise others have additional responsibilities under the policy. They must:

  • Promote compliance and ethics by example – in other words, show by their behavior what it means to act with integrity.
  • Make sure that those who report to them understand the policy’s requirements and have the resources to meet them.
  • Use reasonable care to monitor third parties acting on behalf of to ensure that they work in a manner consistent with the code.Enforce the policy consistently.
  • Support employees who, in good faith, raise questions or concerns.

Policy Implementation

To maintain high standards of ethical conduct, Name of Company shall:

  • Ensure the compliance with the Ethical Conduct Policy from all employees, contractors, consultants working for Name of Company and they will be responsible for such compliance in their area of operation.
  • Name of Company employee must report any breaches or potential breaches of compliance and ethics commitments of which he/she becomes aware whether those relate to him/her, direct reports or others. He/she must similarly seek advice if he/she is unsure about the proper course of action.
  • Any employee, who in good faith seeks advice, raises a concern or reports misconduct is following this code – and is doing the right thing. BS will not tolerate retaliation against that person. Claims of retaliation shall be taken seriously. Allegations of retaliation will be investigated and appropriate action shall be taken. Anyone responsible for reprisals against individuals who report suspected misconduct or other risks to the business will be subject to disciplinary action up to and including dismissal of wrong doer.
  • All transactions involving Company funds or assets, or transactions conducted on behalf of the Company by any Intermediary, must be timely recorded in reasonable detail and accurately and completely reflect the transactions.
  • Review and promote consistent disciplinary procedures for breaches of the policy and the incorporation of compliance and ethics into performance appraisal processes.
  • Continuously assesses compliance risks and ensures that internal controls are responsive to these risks.
  • Circulate and provide awareness training on the Ethical Conduct Policy.
  • Provide support and guidance to personnel on the Ethical Conduct Policy.
  • Follow and implement such procedures so as to prevent bribery and maintain an anti-corruption/ethical conduct compliance programme whereby malpractices are identified and deterred.
  • To manage the risk of corruption and other unethical conduct that may arise during the course of the business.
  • Follow and implement such procedures so as to identify and prevent fraud or theft from Name of Company
  • Carry out appropriate due diligence assessment of potential and existing business relationships.
  • Seek to incorporate anti-bribery provisions into all contracts with third parties.
  • Use our influence with contractors and joint venture partners to:
    • A) Implement adequate policies and procedures to prevent bribery
    • B) Promote high ethical standards throughout the supply chain.

Roles and Responsibilities

Everyone is personally responsible :

  • Their ethical and professional conduct generally and for compliance with the Policy and for Procedure.
  • Obtaining advice and guidance where necessary.
  • Reporting all breaches of the Policy and Procedure, and/or any ethical or professional misconduct, whether committed personally or by others.

Managers and supervisors are personally responsible for:

  • Monitoring compliance in respect of all business matters they are managing or supervising.
  • Monitoring compliance by everyone involved in matters they are managing or supervising -this includes third party agents, joint ventures, suppliers and contractors engaged by or working on behalf of Name of Company .

In addition to the above, those in management or leadership roles must lead by example:

  • Showing commitment to compliance;
  • Remaining alert to bribery and corruption risk;
  • Promoting awareness and compliance within Name of Company and amongst those they manage or supervise.

While working for Name of Company, personnel must:

  • Familiarize themselves with this Ethical Conduct Policy.
  • In case of conflict of interest avoid any real or perceived conflict of interest between the performance of their duties for NAME OF COMPANY Group and their private interests. If any actual or perceived conflict arises, personnel should promptly notify their line manager so that steps can be taken to manage that conflict.
  • Under no circumstances shall any officer, director, or employee of Name of Company or any Intermediary acting for or on behalf of the Company.

A) corruptly give, pay, or offer or promise to pay, or authorize the giving or payment of anything of value, directly or indirectly, to any Covered Person to obtain or retain business, direct business to another person or entity, or obtain an improper advantage; or

B) Give, pay, or offer or promise to pay, or authorize the giving or payment of anything of value to any business partner (such as a joint venture partner or Intermediary) while knowing, including having knowledge of facts that would allow a reasonable person to know, that the payment or promise to pay will be or is likely to be passed on to any Covered Person in order to obtain or retain business, direct business to another person or entity, or to obtain an improper advantage.

C) Refrain from accepting gifts of any kind, either directly or through any of their family members, from any of our business associates or potential business associates (supplier / vendor, customers, business partners etc).

D) Employees are advised not to accept any gifts at their residence.

E) However, keeping in mind the Indian culture of gift giving, the only exception to this would be gifts of perishable nature such as sweets, chocolates etc., or stationery items such as corporate diaries, calendars etc., which are of symbolic value. Ensure that pre-employment screening is undertaken to identify if potential new employees are connected to public officials, and consult with Legal for guidance before employing or contracting with individuals who are connected to public officials.

F) Seek to incorporate anti-bribery provisions into all contracts with third parties.

G) Use their influence with contractors and joint venture partners to:

  • Implement adequate policies and procedures to prevent bribery.
  • Promote high ethical standards throughout the supply chain.
  • Promptly report any suspected non-compliance with the Ethical Conduct Policy or Standards.