Code of Conduct

THE MEHTA GROUP

 INDIAN CEMENT OPERATIONS

 SAURASHTRA CEMENT LIMITED

 CODE OF CONDUCT

(For internal circulation only)

 Updated June 14 

Code of Conduct

(For “employees” in Management staff grade M1 - O3) 

Preamble

The Mehta Group is committed to conduct its business in all respects in accordance with highest ethical, professional and legal standards. The group is also committed to create a workplace, at all its locations, where all management staffs are well-respected and encouraged for good performance and conduct.

The code of conduct is set out to achieve business success through ethical behaviors. We expect all management staffs to follow them and act with integrity and maintain highest ethical standards.

1.  Compliance to Company / Group policies:

All Management Staff must comply with Company’s policies, systems and procedures as stated from time to time.

Do’s –

• Familiarizing and understanding Company policies, systems and procedures.

• Review all your actions in the light of Company Policy.

• Report non-compliance noticed anywhere in the Company.

• Implement Company Policy objectively and in its spirit.

Don’ts –

• Do not continue with the action contravening Company policy just because it has been traditionally followed.

• Do not give / follow instructions contravening Company rules.

• Do not interpret / bend the rules to favor someone.

2. Ethical and Honorable conduct

All Management Staff shall deal with all stakeholders with professionalism, honesty, integrity as well as high moral and ethical standards. Such conduct shall be fair and transparent and be perceived to be as such by third parties.

Management Staffs are expected to deal with other colleagues in an honorable and respectful manner, without any gender bias/ harassment. All employees, vendors and service providers should be selected on merit, without any conflict of interest or favoritism. Appropriate disclosures should be made wherever required to maintain transparency.

Do’s -

• Have honest communication with every stakeholder.

• Resolve differences through discussions.

• Accept and immediately report any mistake committed.

• If you notice or suspect your boss of any wrong doing, report the issue to the next superior or MD.

Don’ts –

• Do not be secretive

• Do not criticize person behind his back.

• Do not shout/ yell at the employees.

• Do not withhold information in relation to any unethical practice known.

• Do not accept any favor from others nor extend any favor for personal gain.

 3. Legal Compliance

All Management Staff shall at all times ensure compliance with all the relevant laws of the land and regulations affecting operations of the Company. They shall be abreast of the latest amendments /developments in relevant laws, rules and regulations related to their area of work.

Do’s -

• Understand all applicable laws and its nuances.

• Seek legal opinion in case of ambiguity about any regulations.

• Report any unlawful activity/ practice and immediately to your superior.

Don’ts –

• Do not accept any product/ services rendered through illegal means.

• Do not participate in any illegal deal / activity.

• Do not take shortcut to legal compliance.

4. Accountability:

Management Staff member will be guided by the responsibility / accountability attached to his role / position and by virtue of being a member of the management team.

Do’s -

• Take responsibility of the actions taken by you and for subordinates unless he/she acted in contravention to your instructions.

• Be committed to timelines and targets agreed.

Don’ts –

• Do not share Company’s information with anyone unless authorized to do so.

• Do not shift blame on others for the consequences of the actions/ decisions taken by you.

• Take your assignments in its entirety, do not shirk responsibility by saying, “I have done my part, someone has not done his/her”.

•  Do not make your subordinates sign documents, which rightfully you are  authorized to sign

 5. Conflict of Interest

Management Staff shall not engage in any business, relationship or activity, which might conflict with the interest of the Company. All are expected to devote full attention to the business interests of the Company, and are prohibited from engaging in any other activity that interferes with their official performance of responsibilities to the Company or is otherwise in conflict with or prejudicial to the Company’s interest.

In case of doubt about the conflict or potential of conflict, the Management Staff must disclose to higher management in writing and seek appropriate guidance and action.

Do’s -

• Award contracts/jobs purely on merits

• Disclose your financial interest or relationship with parties dealing with Company.

Don’ts –

• Do not use your position / power to get business out of Company to your relative / friend or known persons.

• Do not engage brokers/ suppliers related to you.

• Do not work in any capacity for competition / customer / supplier or any other third party while working for the Company.

• Do not engage in any commercial activity or business with customer / supplier / vendor or any business associate, for the personal purpose including taking loans, dealing in shares or properties etc.

 6. Appropriate behavior in public:

Management staff will behave in a courteous and professional manner at all times and in all circumstances while dealing with employees, Company / Group associates, suppliers, customers etc.

Do’s -

• Presenting positive aspects of the group while conversing with an outsider.

• Always maintain decency and decorum in public.

Don’ts –

• Do not act under influence of alcohol/ drug in public.

• Do not involve yourself in any illegal or immoral activity even outside workplace.

• Never reprimand your team members in public.

7.  Open Environment:

The Company creates an open environment for facilitating management staffs to interact and contribute towards continuous betterment of the Company's / Group's Operations.

Do’s -

• Encouraging an open environment of information sharing, discussion and feedback.

• Encouraging and accepting ideas generated by the junior.

• Discouraging loose talk, foul mouthing and not indulging in them.

• Maintain transparency in your actions.

Don’ts –

• Do not discriminate employees while sharing information.

• Do not indulge in or encourage gossip.

• Do not suppress constructive criticism from your subordinate / colleagues.

8. Gifts and Entertainment

No Management Staff will offer or receive any gifts, favors or entertainments that are:

• Inconsistent with customary business practice.

• Excessive in value and / or could be construed as a bribe.

• In violation of applicable laws or ethical standards.

• Such that public disclosure could embarrass the Group/ Company or oneself.

Do’s -

• Disclose any favor or any activity which seems advancement of favor from suppliers/ customers/ vendors etc to your superior.

Don’ts –

• Do not pay money to anyone that tantamount to bribe or corruption.

• Do not accept gifts with whom you are doing a business.

• Do not invite any customer / vendors / suppliers for any of your personal functions.

9. Equal Opportunities and Fair treatment.

At The Mehta Group, we respect human rights and encourage fair dealing (non discriminatory) across all levels and to all stakeholders. There shall be no discrimination on grounds of race, religion, gender, and place of origin or caste. Employees will demonstrate a measure of equity and fair treatment to all employees and other stakeholder.

Do’s -

• Provide equal opportunities to all applicants, retainers, suppliers, vendors etc without prejudice to their race, caste, religion, color, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin or disability.

• Notify all vacancies, contracts other requirements in public.

Don’ts –

• Do not discriminate or humiliate any person at workplace.

• Do not canvass a relative for employment / contracts.

• Do not misuse Company facilities and human resource. 

10. Sexual Harassment

The employee shall not indulge in the acts of sexual harassment and shall co-operate with the management in taking preventive steps and eliminating sexual harassment of its employees at workplace.

Do’s -

• Do support a coworker who complaint about the sexual harassment experienced personally or by others in workplace.

• Do raise issue of sexual harassment with Internal Committee as per the provisions under the Sexual Harassment Act.

Don’ts –

• Do not indulge in sexual harassment/ disrespect toward colleagues.

• Do not ignore/tolerate any act of sexual misbehavior/mischief.

11. Company Records

The Company records should be maintained in full compliance with all rules, laws and regulations. Adequate precautions should be taken to avoid access to wrong person, which could harm Company’s business interests. They should be kept up to date and free from any misleading or wrong information. Important records should be stored in a fire proof and safe place and properly marked.

Management Staff shall be accountable for safety and preservation of all the records (physical or electronic) in their area of work.

Do’s -

• Maintain documents in accordance with all applicable laws and regulations.

• Maintain record in orderly and systematic manner.

Don’ts –

• Do not misrepresent material facts in books of records or in any internal or external correspondence, memoranda, or communication of any type, including telephone or electronic communications. 

• Do not destroy any records unless its usage becomes irrelevant and approved by the superior in accordance with the company policy.

 12. Confidentiality

Employees come across a number of confidential information. They must take proper care of such information and ensure that it is not misused in any way, which is detrimental to the Company’s business or used for own commercial benefit. They must also not disclose actions or activities relating to our business operations to outsiders, unless they are relevant to business deals.

Management Staff who has access to proprietary and confidential information must take precaution to keep it confidential.

Do’s –

• Use information only for the intended purpose and never for personal or third party’s gain.

• All the electronic data should be maintained with proper password.

• Don’ts –

• Do not disclose any confidential information to the third party.

• Do not attempt to access files of confidential nature.

• Do not hack / attempt to hack any data.

• Do not trade in stocks or other securities of the Company if employees have inside information.

13. Health, Safety and Environment

The company shall provide a safe, healthy, clean and ergonomic working environment for its people and guests. It is expected that employees demonstrate their concern by supporting participating in causes like protection of health, safety and environment.

Do’s -

• All activities should be carried out with the highest regard for the health and safety of employees.

• Provide good physical working conditions and encourages high standards of hygiene and housekeeping

• Display instructions pertaining to safety at work place.

• Report any unsafe practices noticed.

Don’ts –

• Do not waste natural resources.

• Do not smoke in the restricted areas.

• Do not disregard any of safety rules even if they are causing some inconvenience.

14. Usage of Group’s / Company’s assets

Protecting the Group’s/ Company’s assets is a prime responsibility of every Management Staff. Utmost care should be taken to ensure that assets are not misused, misappropriated, loaned to others, or sold or donated or mortgaged, without appropriate authorization. Management Staff shall not use Group/ Company assets for personal use, nor allow any other person to use Group/ Company assets.

Every employee is personally responsible for all Company funds over which they have control. Company funds must be used only for business purposes.

Do’s -

• Assets should be employed primarily and judiciously for the purpose of conducting the business for which they are duly authorized.

• Carry out regular maintenance of the assets.

Don’ts –

• Should not use, transfer, or dispose of funds or assets for the unlawful and illegitimate business purposes.

• Do not use Internet or email facility for personal use.

• Assets of the Company shall not be misused.

15. Media Interaction

Management Staff should refrain from interaction/ communication with the print and electronic media on matters, which are likely to have an impact on the image of the Group.  Such communication and interaction will be dealt by designated Media Officer only.

Management Staff shall not post any malicious, misleading or unfair content about the organization and its stakeholders. Management staffs should refrain from posting any obscene, defamatory, discriminatory or threatening content towards the colleagues or other employees.

Do’s –

• Any query for media should be directed to Media Officer.

Don’ts –

• Do not misrepresent information about the Company.

• Do not present / give / post views which are detrimental to Company’s image in social media.

• Do not speak to an outsider on behalf of Company unless authorized to do so.

We appeal to the employees to strictly abide by the code of conduct mentioned above in its letter and spirit.