5.1 Commitment

1. All employees shall, in the course of their employment with the Company and in carrying out their duties and responsibilities in respect thereof, diligently and to the best of their ability to perform such responsibilities and responsibilities as may from time to time be assigned or designated to them.
2. All employees are expected at all times to promote and advance the interests of the Company and shall not do anything to bring disrepute to the Company.
3. All employees shall obey, comply with and observe rules, regulations, procedures, practices, orders, directives and policies of the Company, whether expressed or implied in law or by custom and practice.

5.2 Confidentiality

5.2.1 No employee is permitted whether during or after termination of their employment with the Company, to discuss or divulge confidential information relating or pertaining to the Company directly or indirectly to any person or company unless:

Such information has previously been made public knowledge; or Upon express direction or with the express approval of the company; or Required, compelled or obliged to do so by law.

5.2.2 Employees should not discuss whether among themselves or with others, within the workplace or outside the Company’s premises, confidential information regarding the Company, its business partners, its customers or clients, its employees or any other confidential information except in the course of carrying out the Company’s business.

5.2.3 It is the Company’s policy that any information pertaining to the Company in any way whatsoever and which is not generally available to the public shall be treated with the utmost confidence. Such information must not be shared or used by any employee whether directly or indirectly to influence an investment decision in connection with the purchase or sale of securities.

5.2.4 The first obligation of any employee who receives a subpoena or other request seeking the disclosure of confidential information pertaining to the Company is to contact his immediate supervisor or HR Manager for guidance.

5.3 Spreading any kind of Publication using the Social Media

All employees are strictly restricted from spreading any kind of pictures or caricatures or write-ups of any other employee of the Company in any social media that may cause or injure the reputation or the image of the employee concerned and or the Company itself unless written consent is obtained from the Management.

5.4 Insubordination and inefficiency

An employee shall not commit any act of wilful refusal, insubordination or disobedience of any lawful and reasonable instruction of his supervisor / manager including refusal to perform assign work, being inefficient and deliberately slowing down causing the quality of work and / or the quantity of work to be adversely affected

5.5 Conflict of Interest

1. An employee cannot during his employment with the Company, engage directly or indirectly in any other business or occupation whether as principal, agent, servant or broker while still in the employment of the Company.
2. He is also not permitted to engage in any activity, which can be detrimental, directly or indirectly, to the interest of the Company.
3. An employee may acquire or hold shares in any public quoted Company. However, he must seek prior approval from the Company if he intends to acquire substantial shareholding (s) in any such company (as defined in the Companies Act, 1995) or hold directorship (s) in the same Company.
4. An employee is not allowed to participate in or influence the purchase of goods and services from any company or person in which or through which that employee has or will obtain a direct or indirect interest or benefit.
5. Upon receipt of the Code, all affected employees must declare all such interests as described in the Declaration Form for Conflict of Interests and particular attention must be paid to the notes thereto, which explain the types of interests that must be declared.
6. Any proposal made by any employee for an unsolicited offer to purchase any or all of the equity interests of any of the companies in the Group will be viewed as an event which may give rise to a conflict of interest if such employee continues employment with the Group. Accordingly, such employee shall tender his resignation immediately.

5.6 Gifts or Favours

It is the policy of the Company that no employee or any member of their immediate family accepts any form of gifts or favours from contractors, suppliers, clients / customers, or any other party having business dealings with the Company.

Employees shall report all gifts received to their respective Head of Department or immediate superior and handover such gifts to the HR Manager or appointed Manager.

All employees shall, if in doubt as to the nature or purpose of the gift or favour consult the HR Manager who shall decide, in consultation either with or through his own accord, the course of action in respect of such gifts or favour. Gifts which cannot be accepted by the employee as stipulated above shall be:

1. Returned to the donor; or
2. If such return is not possible or impracticable (including food and perishable items goods) such gifts shall be retained by the appointed Manager of the Company for distribution to all employees or to recognized charitable organizations, or to other organizations / persons as the Company may deem fit.

Any employee found to have received gifts or favours in contravention to the above provisions shall be subjected to disciplinary action.

5.7 Graft and Invitation to Graft

An employee shall not in any manner or form offer on behalf of the Company or receive an offer of graft or a bribe for his own benefit, or the benefit of his relatives or spouse.