Prepared by Human Resources Dept.

Reviewed by Mr. Sohil Dabhoya

Approved by Mr. Faruk Patel
Revision date September 10, 2020
Version 1.1
Document This is a proprietary document owned by KP group. It’s use and
Distribution publication is restricted to K P Group companies only

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 INDEX

Sr. No. Description Page No.

1 Background & Scope 3
2 Applicability 3
3 Dress Code 3-4
4 Use of Group’s Property & Equipment 4
5 Non-Disclosure 4
6 Confidentiality 5
6a Maintaining Privacy 5
6b Talk in Elevator, Canteen & Public Places 5
7 Telephone Etiquette 5
8 Information Technology 5
8a Computer 5-6
8b Email 6
8c Internet 6-7
9 Conflict Of Interest 7
10 Substance Abuse/ Intoxication 7
11 Smoking & Tobacco Consumption 8
12 Bullying 8-9
13 Anti-social Activities 9
14 Practice And Procedures For Preventing Trading By Insiders 9
15 Abide By Policies 9
16 Misconduct 9-10
17 Breach of the Code of Conduct 10

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 CODE OF CONDUCT

1. Background and Scope:

The core values of Group include integrity, quality, commitment, teamwork and action oriented
approach. Employees are the Group’s representative to the external sphere and their
professional conduct reflects the value system of the Group. The code of conduct aims at
protecting the business and informs the employees of the Group expectations. The following
clauses are by no means exhaustive and inclusive of the circumstances an employee may
encounter during the course of their employment with the Group. An employee who is uncertain
of how to proceed when confronted with a particular situation must discuss the problem with
Human Resources Department prior to taking any action.
We believe that employees are our strength and they help us deliver values. Recognized
responsibilities of employees and associates are to undertake their duties and behave in a
manner that is consistent with the provisions of the Code of Conduct. They should be individually
responsible for their performance, behavior and attendance at the workplace. They should
comply with policies and procedures and promote a positive, safe and healthy environment.
2. Applicability:
This code is applicable to all Employees and Associates of KP Group.
3. Dress code:

Employees should remember that potential clients are often invited to visit Group offices.
Employees must therefore ensure that their appearance is neat and appropriate. Wherever
uniform is provided, it must be worn.
The following examples represent acceptable standards for male employees:

 Employees should wear Formal, wrinkle free uniform

 Well-groomed hair
 Formal shoes, athletic/walking shoes, sandals, tennis shoes, flats, rainwear and boots are
acceptable
 Mild perfume can be worn
 Nails to be trimmed
The following examples represent acceptable standards for female employees:

 Uniform should be ironed and dupatta should cover head

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 Should get rid of facial hair in any part of the body exposed (hands, legs, area around lips)
 Moderate jewelry and makeup may be worn
 Nails to be trimmed. Use of transparent or light color nail paint is permitted
 Mild perfume can be worn
 Tie hair in neat ponytail, bun or braid
 Shoes (Rubber shoes, athletic shoes, types of sneakers, trainers or gym shoes), pumps,
Ballerina Flats, Loafers are acceptable

The guidelines set forth above represent the minimum acceptable standards and may vary at
individual locations only to the extent that a location has more stringent standards. In addition,
deviations from this policy may be permitted on certain days such as Fridays or Theme days as
approved by Head - HR.

On the first violation, the employee will be advised in writing or verbally, however repeated
violations will result in progressive disciplinary action.

4. Use of Group’s property and equipment:

All employees are required to handle the Group’s property / equipment with due diligence and
care. They shall return all such property / equipment to the Group in good condition at the time
of separation from the Group or as and when directed by the Management.

5.Non-Disclosure:
Data is a valuable, special and unique asset of the Group and which is acquired at a considerable
expense to the Group and it is also confidential trade and business secret. Employees have an
ethical duty not to disclose any information gathered from business transactions and to protect
confidential relationships between the Group and its customers / suppliers and shareholders.
Business information that has not been made public (e.g. insider information) must not be
released to private individuals, organizations or government bodies unless demanded by legal
process such as a legal summons or court order. Employees shall not use confidential
information obtained in the course of their employment for the purpose of advancing any
private interest or for personal gain.

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6.Confidentiality:

a) Maintaining privacy:
Respect for privacy is necessary to build strong business relationships. Employees are required
to keep confidential any information that they might access in the course of their employment
and prevent data leakage. They should collect, use and disclose personal information only with
the knowledge and permission of the affected person unless otherwise permitted by local laws.
Personal information of the person collected by them while performing their duty may only be
used for purposes for which it was originally collected, unless otherwise permitted by local laws
or the affected person specifically authorizes them to use it in another way.

b) Talk in Elevator, Canteen and Public Places:

Employee should refrain from discussing organization practices on sensitive subjects like
compensation, specific incidents involving people and events in the organization or about
specific individuals in the organization, while using the elevator or while in the canteen or while
in public places or over mobile phones in such open places. Organizational issues should be dealt
within the organization’s premises.
7. Telephone Etiquette
Voice is everything that connects employees with a caller and the tone of their voice tells them
about their approach and intention. Therefore, employees should keep the tone of their voice
equal throughout the whole phone call. Do not shout, as it may disturb other employees.

8. Information Technology - Computer, Email, and Internet usage

a) Computer

 The Group purchases and licenses the use of various computer software/ hardware for
business purposes. Employees may only use software according to the business requirement.
The Group prohibits the illegal duplication of software and its related documentation.
 Equipment must not be attached to or removed from the Group network, or removed from
its normal location, without the approval of the IT in-charge / the person authorized by him.
This includes any equipment brought into the Company, for any reason by third parties.
 Modems must not be connected directly or indirectly to the Group network without the
approval of the IT in-charge / the person authorized by him/her.

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 Illegally acquired software must not be loaded on Group’s owned equipment to avoid risks
from viruses or other malicious devices and to prevent exposure to legal proceedings.
 Password to network access should not be shared or disclosed. If a workstation is shared by
more than one person, then each user should use his/her own user ID while accessing the
network. There should not be any written record of passwords.

b) Email

 The Group e-mail system is designed exclusively for business purposes. Personal use of the e-
mail system is not permitted. Employees provided with access to e-mail should use discretion
and professionalism when writing e-mail messages.
 Each e-mail user has a unique access login and password. The login allows access to messages
sent for the user. Use of passwords or other security measures does not in any way diminish the
Group rights to access materials on its system, or create any privacy rights of employee’s in the
messages and files on the computer/laptop. Any password used by employees must be revealed
to the Management, as emails may need to be accessed by the Group in an employee’s absence.
 Login facility will be issued by the e-mail administrator upon receipt of a request from the
user duly approved by HR department.
 Legally, e-mail messages are the same as written messages and, like written documents, can
be summoned and used in a court of law as evidence. Accordingly, confidential matters
should be marked appropriately and / or sent only via hard copy, where appropriate.
 E-mail is a Group asset and any misuse such as carrying/receiving pornography or any legally
prohibited communication may result in disciplinary action.
 The Group in its discretion as owner of the email system, reserves and may exercise the right
to monitor, access, retrieve and delete any matter stored in, created, received or sent over
the email system, for any reason and without the permission of employees.
 Employees should be aware that deletion of any e-mail messages or files would not truly and
eliminate the message from the system.

c) Internet
 The Group provides access to the information available on the Internet to its employees
specifically, for business related and other permitted purposes only.
 The Group is not responsible for material viewed or downloaded by Internet users. Users

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 are cautioned that many of pages include offensive, sexually explicit, and legally prohibited
material. Even innocuous search requests may lead to sites with highly offensive content and
having an e-mail address on the Internet may lead to receipt of unsolicited e-mail containing
offensive content. Users accessing the Internet do so at their own risk.
 Images, audio or videos may not be downloaded from the Internet using Company
facilities except for explicit business-related use. Permitted file transfers or video downloads
etc. which are communications-intensive should be scheduled for off-peak times.
9. Conflict of Interest:
Conflict of interest may occur whenever an employee’s interest in a particular subject may lead them
to actions, activities or relationships that undermine the Group and may place it to disadvantage.

This situation may take many different forms that include, but are not limited to, conflict of
interest examples:

 Employees’ ability to use their position with the Group to their personal advantage
 Employees engaging in activities that will bring direct or indirect profit to a competitor
 Employees owning shares of a competitor’s stock
 Employees using connections obtained through the Group for their own private purposes
 Employees using Group equipment or means to support an external business
 Employees acting in ways that may compromise the Group legality (e.g. taking bribes or bribing
representatives of legal authorities)

10. Substance abuse/ Intoxication:

The Group expects the employees to report in a state of mind and physical condition that will allow
them to perform their assigned responsibilities in a competent and safe manner. Therefore, no
employees should possess/ consume/ use/ be under the influence of alcohol, illegal drugs or controlled
substances in the Group premises.

Selling, possessing, using, delivering or receiving alcohol/ illegal drugs/ controlled substances at any
time during the workday or anywhere on the Group premises is strictly prohibited. Violators will be
subject disciplinary action, up to and including termination.

Any employee who must use a prescription drug that causes adverse side effects like drowsiness,
impaired reflexes or reaction time shall not be allowed to work during such period.

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11. Smoking and Tobacco Consumption:
Group does not promote or encourage smoking. It is not permissible to smoke in office premises. Passive
smoking can have negative effect on other employees, the community and create a poor image of the
company

All areas of the workplace are tobacco-free without exception. Tobacco use is not permitted anywhere
in the workplace, including all indoor facilities and company vehicles with more than one person
present. Tobacco use is not permitted in private enclosed offices, conference and meeting rooms,
cafeterias, lunchrooms, or employee lounges. Compliance with the tobacco-free workplace policy is
mandatory for all employees and persons visiting the company, with no exceptions. Employees who
violate this policy are subject to disciplinary action.

12. Bullying:
Bullying is defined as repeated, health-harming mistreatment of one or more people by one or more
perpetrators. It is abusive conduct that includes:

Threatening, humiliating or intimidating behaviors.

Work interference that prevents work from getting done.
Verbal abuse.

The following types of behavior are examples of bullying:

Verbal bullying: Slandering, ridiculing or maligning a person or his / her family; persistent name
calling that is hurtful, insulting or humiliating; using a person as the butt of jokes; abusive and
offensive remarks.
 Physical bullying: Pushing, shoving, kicking, poking, tripping, assault or threat of
physical assault, damage to a person's work area or property.
Gesture bullying: Nonverbal gestures that can convey threatening messages.
Exclusion: Socially or physically excluding or disregarding a person in work-related activities.

In addition, the following examples may constitute or contribute to evidence of bullying in the
workplace:

 Persistent singling out of one person.

Deliberately interfering with mail and other communications.
 Spreading rumors and gossip regarding individuals.

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Taking credit for another person's ideas.
Refusing reasonable requests for leave in the absence of work-related reasons not to grant leave.
Unwanted physical contact, physical abuse or threats of abuse to an individual or an
individual's property (defacing or marking up property).

Individuals who feel they have experienced bullying should report this to their supervisor or to
Human Resources Department before the conduct becomes severe or pervasive.

13. Anti-social activities:

No employee whether alone or in group, directly or indirectly engage/ participate/ involve in any legally
prohibited activities, including but not limited to communal, anti-social or anti-national activity or
such activities which are against the sovereignty and integrity of the nation.
14. Code of practice and procedures for fair disclosure of unpublished price sensitive
information and for regulating, monitoring and reporting of trading by insiders:

Please refer to http://www.kpenergy.in/kpedata/assets/uploads/612569.pdf

http://kpiglobal.kpgroup.co/upload/Policy%20&%20Disclosures/Code%20of%20Conduct%20t
o%20Regulate,%20Monitor%20and%20Report%20Trading%20by%20Insiders.pdf

15. Abide by policies:

Employees are expected to abide by the Group policies, procedures and law of the land.
16. Misconduct:
The following shall be construed as misconduct for the purpose of disciplinary proceedings as
outlined under Industrial Employment (Standing Orders) Act, 1946:

a) Theft, fraud, or dishonesty in connection with the employer’s business or property.

b) Taking or giving of bribes or an illegal gratification whatsoever in connection with the
employer’s business or his own interests.
c) Willful insubordination or disobedience, whether alone or in conjunction with another or
others, or of any lawful or reasonable order of a superior. The order of the superior should
normally be in writing.
d) Habitual late attendance and habitual absence without leave or without sufficient cause.
e) Drunkenness, fighting or riotous, disorderly or indecent behaviors while on duty at the place of
work.
f) Habitual neglect of work.

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g) Habitual indiscipline.
h) Smoking within the area in places where it is prohibited.
i) Causing willful damage to work in progress or to property of the employer.

j) Sleeping on duty.
k) Malingering or showing down work.
l) Acceptance of gifts from subordinate employees.
m) Conviction in any Court of Law for any criminal offence involving moral turpitude.
n) Continuous absence without permission and without satisfactory cause for more than eight days.
o) Giving false information regarding one’s name, age, father’s name, qualification or previous
service at the time of the employment.
p) Leaving work without permission or sufficient reason.
q) Threatening, abusing or assaulting any superior or co-worker.
r) Habitual money-lending.
s) Preaching of or inciting to violence.
t) Abetment of or attempt at abetment of any of the above acts of misconduct.
u) Going on illegal strike either singly or with other workers without giving 14 days’ previous
notice.
v) Disclosing to any unauthorized person of any confidential information in regard to the working or
process of the establishment which may come into the possession of the workman in the course
of his work.
w) Refusal to accepted any charge-sheet or order or notice communicated in writing.
x) Failure or refusal to wear or use any protective equipment given by the employers.

17. Breaches of the Code of Conduct:

Response to breaches in Code of conduct by any employee or associate may result in:

 Counselling / Advisory from HR or concerned dept.

 Disciplinary action
 Suspension pending enquiry
 Punishment commensurate with misconduct
 Termination
 Legal action or prosecution in accordance with law

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