Investors Desk

Code of Conduct

The Code of Conduct defines what the Company expects of its businesses and people regardless of the location or background. It provides guidance in key areas.

The Code cannot address every situation. Nor does it serve as a substitute for an individual's accountability for exercising good judgment and common sense.

Definitions

“Director” includes any person occupying the position of a Director by whatever named called and includes the Managing Director.

“Board of Directors” means all Directors of the Company who together constitute a Board of Directors of the Company.

“Senior Management” means those Personnel of the Company who are members of the Core Management Team excluding the Board of Directors and would normally comprise of all members of management one level below the Executive Directors of the Company including all Functional Heads.

“Company” means Walchand PeopleFirst Limited.

 

Code

All Directors and Senior Management should adhere to the standards contained in this Code and should consult the Code for guidance when acting on behalf of the Company. The Code of Conduct for Directors & Senior Management includes but is not limited to the following:

The Senior Management has additional responsibilities under the Code. They are:

All breaches or potential breaches of the Company's compliance and ethical commitments of which one becomes aware of – whether these relate to him /her directly should be reported.

It may seem easier to keep silent or look the other way. But the commitment to compliance and ethics means that one should never ignore a legal or ethical issue that needs to be addressed.

Compliance & Ethics programme

The Code of Conduct is more than just a description of the business conduct standards. It is the centerpiece of compliance and ethics Programme supported by the Board of Directors and Senior Management to promote a positive, ethical work environment for all employees.

Health, safety, security and the environment

This means no accidents, no harm to people and no damage to the environment. All are committed to the protection of the natural environment, to the safety of the communities in which it operate, and to the health, safety and security of our people.

Company assets & financial integrity

The Directors & Senior Management have a responsibility as well as a legal duty to protect the physical, intellectual property and financial assets of the Company. The Directors & Senior Management should be forthright and transparent about their operations and performance, accurate in the recording and reporting of data and results and exercise care in the use of its assets and resources.

Compliance

The Company expects compliance of the Code of Conduct from both the Directors & the Senior Management. However, the Senior Management in addition would also be required to follow the Code of Conduct which has been laid down for all Employees of Walchand PeopleFirst Ltd.