Ethics Charter & Code of Conduct

Contents
Preface

1. Purpose
2. Coverage

Ethics Charter & Code of Conduct

1. Ethics for Executives and Employees

2. Fair Competition and Trade
3. Realization of Customer Value
4. Respect for Executives and Employees
5. Commitment to Sustainability

Management System

Appendix

1. Contact Information for Whistle Blowing / Grievance

2. Reference
Preface
1. Purpose
Company vision is creating an infrastructure conglomerate by providing quality lifestyle
to inhabitants, improving human asset and cherishing stakeholders of the company. As
the practice of ethical management is the keystone of such a goal, Company has
amended its Ethics Charter and code of conduct to become a reliable partner for diverse
stakeholders and increase value for our customers. All members of Company should
comply with this ethics charter and code of conduct.

2. Coverage
This Ethics Charter and Code of Conduct applies to Company, including corporate
bodies at home, subsidiaries, affiliates, joint venture all partners (including
subcontractors and / or suppliers), and the executive and employees of Company act in
accordance with this Ethics Charter and code of conduct when dealing with suppliers
and sales/service organizations. Executives and employees who work for organizations
covered under the scope of this Ethics Charter and Code of Conduct should comply with
local laws and perform their duties in accordance with Ethics Charter and Code of
conduct. Moreover, all stakeholders holding contractual relationships with Company,
hereinafter referred to as the “Company” should respect the content and spirit of this
ethics charter and code of conduct.

All person and organization who fall under the scope of this document shall perform
their duties in accordance with the regulations, policies and rules that guide this Ethics
Charter and Code of Conduct. Where this Ethics Charter and code of Conduct, and
related regulations, policies and rules contradict local law, the local laws shall prevail. In
such cases, the Company may amend this document to reflect local legal and industrial
obligations, and if necessary, may specifically establish detailed policies in response.
Any organization that wishes to adopt this ethics charter and Code of Conduct should
obtain prior consent from Company.
Ethics Charter & Code of Conduct

[Five Guiding Principles at Company]

1. We shall perform our duties based on clear and transparent

standards, and do our utmost to fulfil our responsibilities
with integrity.

2. We shall compete fairly in the market and conduct business

ethically with parties that engage in contractual
relationships with us.

3. We shall provide safe products, exceptional services and

accurate information, and we rigorously protect personal
information to increase customer value.

4. We shall respect our members as independent individuals,

and to this end, we provide fair working conditions and safe
working environments.

5. We shall contribute to sustainable development by fulfilling

our social & environmental responsibilities as a member of
society so that diverse stakeholders can prosper together in
harmony.
 1. Ethics for Executives and Employees
We shall perform our duties according to clear and transparent standards, and do our
utmost to fulfil our responsibilities with integrity.

Bribery We shall not receive any form, monetary or non-monetary, of illegal or unethical
benefits and bribery from our stakeholders, nor do we provide or promise thereof.

Improper We prohibit improper solicitation externally between executive and employees and
stakeholders, as well as internally between executives and employees.
Solicitation

Principle of Zero- All corruption crimes committed during the performance of all duties relating to the
operation of the Company are not tolerated in any case.
tolerance

Conflicts of Interest In cases where conflicts of interests between the Company and individuals are
unavoidable, we act in the best interests of the Company and our customers, within the
scope allowed by the law.

Insider Trading We shall not leak insider secrets, knowledge or information obtained either directly or
indirectly in the course of employment, nor use such illicit gains for the purpose of
pursuing individual interest.

Workplace Ethics Executives and employees shall do their utmost to fulfill their responsibilities in the
course of employment, regardless of time or place, and use the Company’s assets and
facilities only for the purposes of fulfilling their duties.

Abuse of Power We shall not abuse our power or status to exert undue influence or pursue illicit
benefits for the Company or individuals.

Documentation & We shall not create misleading documents by hiding, reducing, exaggerating or
falsifying information, nor shall we report such documents or share them with internal
Reporting and external stakeholders.

a) Bribery refers to all forms of benefits that provide or are provided for monetary
or non-monetary purposes, including money, services, entertainment, gifts,
donations, sponsorship, preferential treatment, provision of conveniences, and
etc.
b) Insider trading involves in abusing a company’s secrets, knowledge, sales
information, organizational information such as a merger and acquisition, stock
price information, and internal decision-making.
 2. Fair Competition and Trade
We shall compete in the market fairly and conduct business ethically with parties that
engage in contractual relationships with us.

Anti-trust We shall not engage in activities that would disrupt fair competition through the pursuit of
unfair transactions, such as abusing our market dominance or trading position.

Collusion We shall not engage in activities with other businesses that would restrict fair competition
in terms of the prices (bidding), volume, area and terms of products and services,
including, but not limited to, price fixing, bid rigging, or improper market allocation.

Unfair Competition We shall not improperly obtain information from competitors, partners, or any other
organizations, nor use or disclose information obtained illicitly by the Company or third
parties.

Money Laundering We shall not engage in money-laundering activities involving customers, partners,
suppliers, or other organizations and individuals.

Intellectual Property We shall protect the trade secrets of suppliers in engaged in contractual relationships with
the Company, and shall not infringe on the intellectual property rights of other companies
or individuals.

Tax Compliance For transparent and fair compliance with our tax obligations, we shall comply with the tax
laws of each and every country where we have business operations, and shall not avoid
legitimate tax obligations.

Procurement We shall seek fair and mutually beneficial relationships with our suppliers, and will not
engage in unfair competition.

3. Realization of Customer Value

We shall provide safe products, exceptional services and accurate information, and we
rigorously protect personal information to increase customer value.

Customer Safety We shall not make decisions that compromise customer safety, covering all processes
from research and development, to raw material procurement, manufacturing, sales and
distribution, and after-sales service.

Product/Service We shall not engage in any activities that would compromise the quality standards
necessary to provide our customers with exceptional quality products and services in a
Quality stable manner.

Complete We shall help our customers make informed decisions by providing them with correct
and useful information regarding our products and services, and shall not provide
Information falsified or exaggerated information.
Privacy We shall comply with the laws and regulations applicable to protecting customers’
personal information, and shall not engage in activities that would illicitly infringe upon
Protection their rights to data privacy.

Customer We shall listen carefully to customers’ feedback on our products and services, and are
committed to accepting reasonable demands and recommendations in this respect.
Communication

Product/Service We shall take any appropriate measures necessary to prevent discrimination against
customers who are treated unfairly in terms of access to our products and services based
Accessibility on gender, age, disability, language, etc.

Product Liability We are committed to providing any information necessary to prevent damages and risks
to customers, and shall implement appropriate measures to ensure the safety and quality
of our products and services.

4. Respect for Executives and Employees

We shall respect our members as independent individuals, and to this end, we provide
fair working conditions and safe working environments.

Human Rights We respect executives and employees as independent individuals, and shall take
affirmative action to respect the human rights universally pursed by society.

Child Labor and We shall comply with the labor laws of the countries where we have business
operations, and ban child labor and forced labor in workplace.
Forced Labor

Discrimination We forbid discrimination, without reasonable reasons, against all executives and
employees based on gender, race, ethnic group (minority), nationality, religion,
disability, age, family status, social status, political views, or any other factors.

Equal Opportunity We shall provide executives and employees with equal opportunities for training and
capacity development, assess them fairly based on performance, and give them fair
compensation.

Harassment We ban any and all activities, online and offline, that may insult or damage human
dignity, such as verbal abuse, sexual harassment, mental or physical coercion, corporal
punishment, ostracization, and threats.

Safety and Health We are committed to taking all measures necessary to ensure the safety and well-being
of our executives and employees, and to maintain working environments safe from
occupational accidents, injuries, disasters, disease and contagion.

Work-Life Balance We shall endeavor to provide a working environment that promotes work-life balance
for our executives and employees.

5. Commitment to Sustainability
 We shall contribute to sustainable development by fulfilling our social & environmental
responsibilities as a member of society so that diverse stakeholders can prosper
together in harmony.

Sustainable Through our management decision-making processes, we shall endeavor to fulfill our
responsibilities concerning the sustainable development goals, with the aim of ending
Development the environmental and social problems facing humanity.

Environment We understand that the environment is an invaluable asset to be preserved for future
generations, and are committed to implementing responsible actions to minimize any
negative impacts on the environment in all management areas.

Philanthropy We are committed to identifying the social problems facing our society and humanity,
and to finding solutions for these issues.

Stakeholder By proactively identifying stakeholders who may impact, or be impacted by, the
company’s decision-making, we are committed to communicating and taking action
Engagement with regard to important matters concerning sustainability.

Contribution and We shall comply with all relevant regulations, internal standards and rules relevant to
fairly processing charitable donations and sponsorships, and ban donations and
Sponsorship sponsorships of a political nature.

Political Neutrality As executives and employees of the Company, they maintain political neutrality in
performing their duties and do not intervene in any political activities.

Shareholder Value We shall promote corporate and shareholder value by implementing sustainable
management practices.

Information We shall make financial and non-financial information publicly available, in accordance
with all applicable laws and regulations.
Disclosure

Management System

Manager’s Managers responsible for ensuring compliance with this Ethics Charter and Code of
Conduct shall be committed to supporting and managing all relevant executives,
Responsibility employees and stakeholders, in the implementation of this Ethics Charter and Code
of Conduct.

Governance Organizations implementing this Ethics Charter and Code of Conduct shall establish
appropriate organizational and reporting systems to prevent ethical risks and
and Reporting conduct due diligence, as well as clearly determine roles and responsibilities in this
respect.

Monitoring and Organizations implementing this Ethics Charter and Code of Conduct shall regularly
monitor ethical risks and establish programs to review these risks.
Due Diligence

Internal Control Organizations implementing this Ethics Charter and Code of Conduct shall develop a
reporting system that is internally and externally accessible 24 hours a day, as well
as introduce appropriate internal control systems such as regular or occasional
auditing.
 Whistleblower Organizations implementing this Ethics Charter and Code of Conduct shall protect
the identity of whistleblowers and take any and all measures necessary to protect
Protection them from unreasonable treatment, discrimination and retaliation.

Revision This Ethics Charter and Code of Conduct should be reviewed and amended on a
regular basis.

Training Organizations implementing this Ethics Charter and Code of Conduct shall provide
appropriate training to assist executives and employees in respecting and
implementing the content and spirit of this Ethics Charter and Code of Conduct.

Measures against Organizations implementing this Ethics Charter and Code of Conduct shall, in case
of violations of this Ethics Charter and Code of Conduct, promptly take necessary
Violation measures in accordance with internal regulations.

Disclosure of Organizations implementing this Ethics Charter and Code of Conduct shall develop
Information on appropriate mechanisms to prevent further violations and make them publicly
available.
Violation

Appendix
1. Contact Information

For Grievance & Counseling relating to an ethical issue

 Email:
 Phone:
 Fax:
 Mail: Eagle Nest, B.K. No. 758, Plot No-16, Behind Chopra Court, Ulhas Nagar- 421003, Maharashtra,
India
For whistleblower (Report of unethical issues)
 Hot-line (Phone):
 Fax:
 Cyber Audit Office:
 Mail: Eagle Nest, B.K. No. 758, Plot No-16, Behind Chopra Court, Ulhas Nagar- 421003,
Maharashtra, India

2. Reference
This Ethics Charter and Practice Guideline follows the spirits and values defined by
applicable laws concerning human rights, and is enacted based on the following
international declarations and agreements.

 The Prevention of Corruption (Amendment) Act, 2018

 Disaster Management Act, 2005
 Whistle Blowers Protection Act, 2011
 Right to Information Act, 2005
 Central Vigilance Commission Act, 2003