Asian Paints Hr Strategy

ASIAN PAINTS LIMITED reckon OF CONDUCT FOR EMPLOYEES rapscallion 1 of 11 Asiatic Paints hush-hush 14 January 2011 1. INTRODUCTION Asian Paints moderate (the Comp both) is committed to good corporate regulateance and has consistently maintained its organisational glossiness as a remarkable confluence of high standards of Professionalism, Growth, and Building shargonholder Equity with principles of Fairness, morals and Corporate Governance in spirit. 2. APPLICABILITY OF THIS CODE Ethical caper brook is critical to our crease.As an organisation, we clear taken it upon us to lay down this regulation of Conduct for only told our employees to uphold our payload to ethical conduct. all(prenominal) told the employees of the come with and the employees of its subsidiaries be therefore, expected to scan and take care this commandment, uphold these standards in day-to-day activities, and assent with all applicable laws rules and regulations and all applicable policies and procedures adopted by the Comp whatsoever that govern the conduct of its employees and to encounter that the various stakeholders of the Comp each are aware, understand and comply with these standards.Nothing in this Code or in both related communications (verbal or written) to it shall constitute or be construed to constitute a contract of mesh for a definite term or a guarantee of sustain employment. All the employees of the telephoner shall affirm compliance with the code on an one-year basis. 3. HONEST AND ETHICAL CONDUCT The Comp whatsoever expects all the employees to act in uniformity with the highest standards of personal and nonrecreational integrity, honesty and ethical conduct, whenever the break inys business is macrocosm conducted or at whatever place where much(prenominal) employees are repre directing the gild.The party considers honest conduct to be conduct that is freehanded from stratagem or deception. The Comp all considers ethical conduc t to be conduct conforming to the put uped professional standards of conduct. Ethical conduct accommodates ethical intervention of developed or apparent conflicts of spare-time activity between personal and professional familys. Page 2 of 11 Asian Paints Confidential 14 January 2011 4. alliance WITH THE COMPANY Conflict of Interest The employees of the caller shall non generally apply in some(prenominal) business, relationship or activity which tycoon harmfully conflict with the pursuance of the caller or any of its subsidiaries.The main areas of echt or potential conflicts of interest would include the following Financial interest of employees or his copulations, including the holding of an enthronization in the subscribed share detonator of any company or a share in any firm which is an actual or potential competitor, supplier, customer, distri nonwithstandingor, joint venture or another(prenominal)wise alliance partner of the Company. (The ownership of up to 1 per cent of the subscribed share capital of a prevalently held company shall non ordinarily constitute a financial interest for this end. ) A employee of the Company conducting business on behalf of his or her ompany, or being in a position to influence a decision with regard to his or her companys business with a supplier or customer of which his or her relative is a principal, officer or representative, terminationing in a benefit to him/her or his/her relative. all the alike that much(prenominal)(prenominal) or other instances of conflict of interest exist collect to any historical reasons, adequate and full disclosure by the interested employees should be made to the unrighteousness death chair Human Resources to begin with any business amounting to an actual or potential conflict of interest is conducted.It is in any case incumbent upon every employee to make a full disclosure of any interest which the employees or his/her immediate family relatives, (whic h would include parents, spo employment and dependent children) whitethorn have in a company or firm which is a supplier, customer, distributor or has other business dealings with the Company before any business is conducted with such a supplier, customer, distributor or business associate.every such disclosure as mentioned above shall be done in writing and shall be ingestted to the Vice prexy Human Resources, who in citation with the Company Secretary/ conformism Officer and the Managing Director & CEO, lead transmit to the concerned employee to take necessary action, as advised, to resolve/ avoid the conflict, if any. whatever employees duty to the Company demands that he or she generally avoids conflicts of interest. If a conflict of interest exists, the Company demands that he/she discloses actual and apparent conflicts of interest in the aforesaid manner.It is a conflict of interest to serve as a director of any Company that competes with the Company. The Companys indemnity requires that an employee obtain prior approval from the Board of Directors and the Companys examine Committee before accepting such a directorship. Prevention of cunning Policy This polity applies to any irregularity, or suspected irregularity, involving employees as tumefy as vendors, contractors, customers and/ or any other entities having a business relationship with the Company. The term fraud comprises the mathematical function of Page 3 of 11Asian Paints Confidential 14 January 2011 deception with the intention of gaining an advantage, avoiding an obligation or causing loss or has the potential to ca habituate loss to the company by one or more individuals viz. management, employees or third parties. Fraud may include such acts as deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation, false representation, leakage of confidential and sensitive training pertaining to the company, concealment of material facts and collusion.Any act of fraud or corruption in or against the Company or any abetment to such fraud/ corruption will not be tolerated. All employees are infallible to report frauds and suspicions of fraud. Knowing or wilful failure to report any such matter shall be construed as connivance and may see disciplinal action. All employees are also required to take the right of detecting and preventing fraud in their areas of work and co-operate fully in the ingrained checks and investigation of frauds. The Prevention of Fraud polity is purchasable on Egloo at My HR Applications HR Helpdesk.Receiving and Giving Gifts and Favours All employees (including their immediate family member) shall not accept or give a gift or favour of any nature from any supplier, vendor, dealer, contractor, customer, competitor or any business associate. This prohibition era does not apply to routine two way exchange of recipe business courtesies, which might reasonably be expected to be change in the ordinary course of business. These courtesies include business lunch/ dinner and exchange of company diaries and calendars, pens with company logo and the like that are not lavish in any way.If a gift is inadvertently original it should be promptly returned with a polite note explaining that it is contrary to the Company polity. Any favour which is inadvertently received or extended is to be brought to the notice of the Vice President Human Resources immediately. In case of any favour being received or extended in the condition of an emergency (e. g. medical emergency), the event of such a favour being received or extended is to be brought to the notice of the reporting passenger vehicle by the employee. A circular on policy regarding gifts has al gety been issued to all employees by Human Resources Department.The policy is available on Egloo at My HR Applications HR Helpdesk. All employees shall conform to the gift policy of the Company. Corporate Opportunities The employee s may not exploit for their own personal gain opportunities that are observe through the use of corporate property, cultivation or position, unless the opportunity is reveal fully in writing in the manner as prescribed under this policy. Recruitment of Relatives Employees are prohibited from influencing the hiring/ recruitment of their relatives in any position with or without remuneration in the organisation.In the event of any relative seeking an opportunity to be employed with the organisation, the concerned employee shall inform the Vice President Human Resources. The recruitment shall be done as per the rules place down therein by the Company in conformance with the standards decide for recruitment of employees in the Company. Page 4 of 11 Asian Paints Confidential 14 January 2011 Local Rules and Regulations Employees are expected to follow all the rules and regulations set(p) down at their respective workplaces with regard to discipline, workplace timings, dress code, etc.These rules and regulations are made available to the employees at their respective locations. Other Situations It would be impractical to attempt to list all possible situations. If a proposed transaction or situation raises any questions or doubts they mustiness be resolved aft(prenominal) consultation with the Vice President Human Resources. 5. HEALTH, SAFETY AND ENVIRONMENT The Company shall strive to provide a safe and healthy working environs and comply, in the conduct of its business affairs, with all regulations regarding the preservation of the environment of the territorial dominion it operates in.The Company shall be committed to prevent the wasteful use of rude(a) resources and minimize any hazardous impact of the development, production, use and disposal of any of its products and services on the ecological environment. Company policy prohibits sexual bedevilment, harassment establish on race, religion, national origin, ethnic origin, color, gender, age, c itizenship, veteran status married status or a disability unrelated to the requirements of the position or any other basis protected by the central, state or local law or ordinance or regulation.If you believe that you have been harassed, submit a complaint to your own or any other company manager. In addition, if you believe you have been sexually harassed, you may submit a complaint to the Vice President Human Resources. The policy on Prevention of Sexual Harassment is available on Egloo at My HR Applications HR Helpdesk. 6. RESPECT FOR HUMAN RIGHTS The Company reiterates its belief in and estimation to the principles of human rights as enshrined in the commonplace Declaration of Human Rights of the unify Nations and to act in conformance with the principles laid down in it.It will also respect and abide by the requirements, in this behalf, of the countries in which it operates. The Universal Declaration of Human Rights of the United Nations is available at the url http//www . un. org/en/documents/udhr/ 7. ACCOUNTING AND PAYMENT PRACTICES All proceedings should be fully and accurately put down in the Companys books and records in compliance with all applicable laws. All required selective reading shall be accessible to the companys auditors and other authorized persons and government agencies.False or delusory entries, unrecorded cash in hand or pluss, or payments without capture harbouring documentation and approval are strictly prohibited and bobble Company policy and the law. There shall be no willful omissions of any company transactions from the books and records. Any willful material legerdemain of and/or mis tuition of the financial accounts and reports shall Page 5 of 11 Asian Paints Confidential 14 January 2011 be regarded as a violation of the Code apart from inviting leave civil or criminal action under the relevant laws.Additionally, all documentation supporting a transaction should fully and accurately bring out the nature of the transaction and be processed in a well timed(p) fashion. Employees are required to hold that they claims of reimbursement of expenses are based on actual spends and are supported by valid documents as required. Any misrepresentation of facts, false claims or submission of invalid documents shall invite assign disciplinary action. 8. MAINTAINING AND MANAGING RECORDSThe purpose of this section is to set forth and convey the Companys business and ratified requirements in managing records, including all recorded tuition regardless of medium or characteristics. These records include paper documents, CDs, computer hard disks, email, floppy disks, microfiche, microfilm or all other media. The Company is required by local, state, foreign and other applicable laws, rules and regulations to retain certain records and to follow specific guidelines in managing its records. Company recordsThe results of operations and the financial position of the Company must be recorded in accordance with the requirements of law and generally accepted accounting principles. It is Company policy, as well as a requirement of law, to maintain books, records and accounts that in reasonable detail accurately and fairly ruminate the business transactions and disposition of assets of the Company. The integrity of the Companys accounting and financial records is based on the accuracy and completeness of the basic information supporting entries to the Companys books of accounts.The employees involved in creating, processing and recording such information are held responsible for its integrity. Every accounting or financial entry should reflect exactly what is described by the supporting information. There must be no concealment of information from (or by) management, or from the Companys internecine or independent auditors. No payment on behalf of the Company shall be approved or made with the intention or understanding that any part of such payment is to be used for any purpose other than that described by the documents supporting the payment.No false or misleading entries may be made in any books or records of the Company for any reason, and no fund, asset or account of the Company may be established, acquired or maintained for any purpose unless such fund, asset or account is the right way reflected in the books and records of the Company. No corporate funds or assets should be used for any unlawful or inappropriate purpose. Revenue and expenses should be properly recognized on a apropos basis. Assets and liabilities should be properly recorded and appropriately valued.Page 6 of 11 Asian Paints Confidential 14 January 2011 9. PROTECTING COMPANYS ASSETS AND CONFIDENTIAL tuition Protecting company assets The assets of the company should not be misused but employed for the purpose of conducting the business for which they are duly authorised. These include tactile assets such as equipment and machinery, systems, facilities, materials, resources as well as i ntangible assets such as patents, trademarks, proprietary information, relationships with customers and suppliers, etc.Confidential Information The Companys confidential information is a precious asset. The Companys confidential information includes product architectures formulations, trade secrets, manufacturing plans, names of vendors, stark(a) materials used, prices of raw materials, source codes product plans and road maps names and lists of customers, dealers, and employees and financial information and any other information This information is the property of the Company and may be protected by patent, trademark, copyright and trade secret laws.All employees are prohibited from disclosing such information. In case need arises, all confidential information must be used for Companys business purposes only. Every employee must safeguard it. This responsibility includes not disclosing the Company confidential information over the Internet or otherwise. The employees are also res ponsible for properly labeling any and all documentation shared with or correspondence sent to outdoor(a) counsel as Attorney-Client Privileged.This obligation extends to confidential information of third parties, which the Company has rightfully received under NonDisclosure Agreements. Obligations of the employees with respect to Company Confidential Information are Not to disclose this information to persons in spite of appearance the Company or outside of the Company without prior approval of the Compliance Officer or Vice President Human Resources. Not to use this information for the employees own benefit or the benefit of persons outside of Company. Not to disclose this information to other Companys employees except on a need to bang or need to use basis and then only with a strong statement that the information is confidential. Company confidential information is not always of a adept nature. Such information can also include business research, in the buff product pla ns, strategic accusatives, any unpublished financial or price information, employee, customer and vendor lists and information regarding customer requirements, preferences, business habits and plans.This list, while not complete, suggests the wide variety of information that needs to be safeguarded. If any employee, his or her obligation to protect Company confidential information continues. Page 7 of 11 Asian Paints Confidential 14 January 2011 All employees shall not use or proliferate information which is not available to the investing public and which therefore constitutes insider information for making or giving advice on investment decisions on the securities of the Company on which such insider information has been obtained.Such insider information might include the following acquisition and divestiture of businesses or business units financial information such as profits, earnings and dividends announcement of new product introductions or developments asset revalu ations investment decisions/plans restructuring plans major supply and delivery agreements raising pay The Code of Conduct for Prevention of Insider Trading is applicable to Designated Employees as per the SEBI (Prevention of Insider Trading) Regulations.Its objective is to ensure surety of unpublished price-sensitive information and to ensure that the insiders and those covered by the Code of Conduct for Prevention of Insider Trading, who are or are deemed to be in possession of such information, abstain from transacting in the securities of the Company before the same has been communicated in public. The Code of Conduct for Prevention of Insider Trading is available in Egloo at My HR Applications HR Helpdesk. All employees are expected to read and understand the policy.The Designated Employees are required to read, understand and comply with the said policy and are also required to make necessary disclosures and declarations as undertake in the policy. 10. DISCLOSURE TO THE ST OCK EXCHANGES AND PUBLIC It is the Companys policy to provide full, fair, accurate, timely and understandable disclosure in reports and documents that are to be filed with or submitted to the stock exchanges where the Companys shares are listed, statutory government activity and in our other public communications.Accordingly, employees must ensure the compliance with such disclosure controls and procedures. All employees must also respect the confidentiality of information acquired in the course of ones work except when authorized or otherwise levelheadedly obligated to disclose. 11. RESPONDING TO INQUIRIES FROM THE PRESS AND OTHERS The requests for financial or business information closely Company from the media, press, financial community, the Securities and Exchange Board of India or other regulators or the public must be referred to the Company Secretary/ Compliance Officer. Page 8 of 11Asian Paints Confidential 14 January 2011 12. COMPLIANCE WITH GOVERNMENT LAWS, RULES AND REGULATIONS All employees must comply with all applicable governmental laws, rules and regulations. The employees must acquire appropriate knowledge of the legal requirements relating to their duties sufficient to enable them to recognize potential dangers, and to know when to seek advice from the Legal Department. If the ethical and professional standards set out in the applicable laws and regulations are below that of the code, then the standards of the code shall prevail. 13.SHAREHOLDERS The Company shall be committed to enhance shareholder value and comply with all regulations and laws that govern shareholders rights. The Board of Directors of the Company will duly and fairly inform its shareholders somewhat all relevant aspects of the companys business, and disclose such information in accordance with the respective regulations. 14. FOSTERING COMPETITION The Company will fully support the development and operation of competitive open markets and will promote the rest of trad e and investment in each country and market in which it operates.The Company or its employee will not engage in suppressive trade practices, abuse of market dominance or similar foul trade activities in order to secure commercial gain or advantage. The Company will support the development of laws that promote, encourage or result in fair competition. The Company expects all the employees to conduct themselves in accordance with the companys commitment to foster competition. 15. WHISTLE BLOWER POLICYThe objective of this policy is to provide employees and moving in Associates a framework and to establish a formal mechanism or process whereby concerns can be elevated in line with the Companys commitment to highest standards of ethical, moral and legal business conduct and its commitment to open communication. The Company shall provide protection to the employees from unethical work practices and irregularities as well as prevent variation or retaliation against employees and busi ness associates who report irregularities and also the methods to encourage employees and Business Associates to report evidence of fraudulent activities.The employees can make Protected Disclosures to the Ethics Committee as per the procedure defined in the policy, on bonny aware of any wrongful conduct or activity at bottom 30 days after becoming aware of the same. The identity of the talk Blower shall be kept strictly confidential. The Whistle Blower policy is available on Egloo at My HR Applications HR Helpdesk. Page 9 of 11 Asian Paints Confidential 14 January 2011 16. VIOLATIONS OF THE CODE It is a part of the employees job, and his/her ethical responsibility to help enforce this Code.The employees should be alarm clock to possible violations and report this to the Compliance Officer or the Vice President Human Resources. The employees should cooperate in any internal or remote investigations of possible violations. Actual violations of law, this code, or other Company policies or procedures, should be promptly reported to the Compliance Officer or the Vice President Human Resources. The Company will take appropriate action against those whose actions are found to violate the Code or any other policy of the Company. 17.WAIVERS AND AMENDMENTS TO THE CODE The Company is committed to continuously reviewing and updating our policies and procedures. Therefore, this Code is reconcile to modification. Any amendment or waiver of any provision of this Code must be approved in writing by the Companys board of directors and promptly disclosed on the Companys website and in applicable regulatory filings pursuant to applicable laws and regulations, together with details or so the nature of the amendment or waiver. Ernest Louis Vice President Human Resources Page 10 of 11Asian Paints Confidential 14 January 2011 ACKNOWLEDGMENT FOR THE EMPOYEES I have received and read the Companys Code of Conduct and Ethics for employees. I understand and agree to comply with the standards and policies contained in the above mentioned Code of Conduct and understand that there may be additional policies or laws specific to my job. Name of the Employee Employee Code title Location Signature Date This form shall be made available online subsequently for you to acknowledge. Page 11 of 11 Asian Paints Confidential 14 January 2011