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BILT
is committed to promoting honesty, integrity, respect
for people and in maintaining high standards of ethical
conduct in all its activities. Each of us is expected
to demonstrate these key beliefs in our work.
Purpose of the Code
of Conduct
This is a guide to help us live up
to BILT's high ethical standards-and our own. It summarizes
many of the rules that BILT and all of us are required
to live by. The Code goes beyond the legal minimums,
however, by describing the ethical values we share.
This Code is neither a contract nor a comprehensive
manual that covers every situation we might experience.
It is a guide that highlights key issues and identifies
policies and resources to help us reach decisions.
Accountability
As part of BILT, each of us
has the personal responsibility to make sure that our
actions abide by this Code and the laws that apply to
our work. If you have any questions or concerns about
illegal or unethical acts, check with your Head of the
Department (HOD) or Mr. B Hariharan, Group Director
Finance or Ms Neerja Sharma – Company Secretary
or Mr. Lav Kumar Shelat, Sr. Vice President-HR.
Please keep in mind that failure to abide by
this Code and the law will lead to disciplinary measures
appropriate to the violation, up to and including dismissal.
Everyone is expected to read the entire Code and to
abide by it. No code can guarantee ethical behavior
though. Only we can.
We are expected to lead according to our standards of
ethical conduct, in both words and actions. All of us
are responsible for promoting open and honest two-way
communications. We must be positive activists and role
models who show respect and consideration. We must be
diligent in looking for indications that unethical or
illegal conduct has occurred. If you ever have a concern
about unethical or illegal activities, you are expected
to take appropriate and consistent action, and inform
your HOD, or Mr. B Hariharan, Group Director Finance
or Ms Neerja Sharma – Company Secretary or Mr.
Lav Kumar Shelat, Sr. Vice President-HR.
APPLICABILITY
The Code applies
to all BILT Directors and all employees in L-7 and above.
RESPONSIBILITIES UNDER
THE CODE
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Honesty
& Integrity |
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All shall act in accordance with high standards
of personal and professional integrity, honesty
and fairness and in the best interests of the
Company. Officers / Directors are expected to
act in good faith, responsibly, with due care
and diligence, without allowing their independent
judgment to be subordinated.
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Workplace
free of harassment |
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BILT is committed to providing a work environment
free of harassment based on caste, colour, sex,
race, religion, medical condition, marital status,
age, sexual orientation, ethical belief or on
any other basis. All such harassment is unlawful.
This is applicable to all persons involved in
the operation of the Company and prohibits unlawful
harassment by any employee of the Company towards
other employees including juniors, supervisors,
outside vendors, clients etc.
We will treat people fairly and with respect
and we will promote a culture where diversity
is valued and full capabilities of individuals
are harnessed and developed to the benefit of
customers, employees and the business.
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Conflicts of interest |
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We will make business decisions based on the best
interests of BILT.
General Guidance
Business decisions and actions must be based on
the best interests of BILT, and must not be motivated
by personal considerations or relationships. Relationships
with prospective or existing suppliers, contractors,
customers, competitors or regulators must not
affect our independent and sound judgment on behalf
of BILT. General guidelines to help us better
understand several of the most common examples
of situations that may cause a conflict of interest
are listed below. However, everyone is required
to disclose to their HOD any situation that may
be, or appear to be, a conflict of interest. Also,
please follow the specific policies of the Company
viz., for Gifts, entertainment etc when faced
with certain situations as enumerated below.
Directors should disclose any conflicts faced
by them, to the Board of Directors.
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Employment
/ Outside Employment. |
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None
of us will work for or receive payments
for services from any competitor, customer,
distributor or supplier of BILT without
prior and express approval of our HOD. Any
outside activity must be strictly separated
from BILT employment and should not harm
job performance at BILT. We must make sure
that the skills we learn and use at BILT
are not used in such a way that could hurt
the business of BILT or be prejudicial to
BILT. |
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Business
Interests |
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We
will not allow our investments to influence,
or appear to influence, our independent
judgment on behalf of BILT. This could happen
in many ways, but it is most likely to create
the appearance of a conflict of interest
if anyone has an investment in a competitor,
supplier, customer, or distributor and his/her
decisions may have a business impact on
this outside party. If there is any doubt
about how an investment might be perceived,
it should be disclosed to your HOD.
Everyone is prohibited from directly or
indirectly buying, or otherwise acquiring
rights to any property or materials, when
we know that BILT may be interested in pursuing
such an opportunity. |
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Related
Parties |
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We
will not use personal influence to get BILT
to do business with a company in which our
family members or friends have an interest.
However, if a related party transaction
is unavoidable, we must fully disclose,
in advance, the nature of the related party
transaction to the Company. |
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Corporate
opportunities |
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Opportunities
that are discovered through the use of corporate
property, information or position, should
not be exploited for personal gain. |
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Board Membership |
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Serving
on the Board of Directors or a similar body
for an outside company or government agency
requires the advance approval of your Vice
Chairman & Managing Director / Chairman.
(This clause is not applicable to the Non-Executive
Directors of BILT). |
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Gifts |
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Gifts
are not always physical objects--they might
also be services, favors or other items
of value.
Gifts
to us
We don’t accept kickbacks, lavish
gifts or gratuities. We can accept items
of nominal value, such as small promotional
items bearing another company's name. We
will not accept anything that might make
it appear that our judgment for BILT would
be compromised.
In some rare situations, it would be impractical
or harmful to refuse or return a gift. When
this happens, discuss the situation with
your HOD.
Gifts
Given by BILT
Some business situations call for giving
gifts. BILT's gifts must be reasonable,
and approved by your HOD.
We understand that gift-giving practices
vary among cultures. Discuss such situation
with your supervisor/manager. We will not
provide any gift if it is prohibited by
law or the policy of the recipient's organization.
If in doubt, check first. |
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Entertainment |
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We
consider "entertainment" to include
a representative of both parties at the
event.
Entertainment
of BILT
We may accept entertainment that is reasonable
in the context of the business and that
advances the Company's interests. For example,
accompanying a business associate to a local
cultural or sporting event, or to a business
meal, would in most cases be acceptable.
Entertainment that is lavish or frequent
may appear to influence one's independent
judgment on behalf of BILT. If an invitation
seems inappropriate, we must turn down the
offer or pay the true value of the entertainment
ourselves. Accepting entertainment that
may appear inappropriate should be discussed
with your HOD, in advance if possible.
Entertainment by BILT
We may provide entertainment that is reasonable
in the context of the business. If we have
a concern about whether providing entertainment
is appropriate, we will discuss it with
our HOD in advance.
Entertainment of government officials may
be prohibited by law. Get approval from
your HOD in each instance. |
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Travel |
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Acceptance
of Travel Expenses
We may accept
transportation and lodging provided by a
BILT supplier or other third party, if the
trip is for business and is approved in
advance by the employee's supervisor/manager.
All travel accepted must be accurately recorded
in our travel expense records.
Providing
Travel
Unless prohibited
by law or the policy of the recipient's
organization, BILT may pay the transportation
and lodging expenses incurred by customers,
agents or suppliers in connection with a
visit to a our facility or product installation.
The visit must be for a business purpose,
for example, on-site examination of equipment,
contract negotiations, or training.
All travel by government officials that
is sponsored or paid for by BILT must be
approved in advance by the Unit Head/General
Manager and above. |
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