At PCT, we acknowledge that we have a direct responsibility to the society and are committed to giving back to the communities in which we live and work. Through our support to Make in India initiative, we are contributing towards generating employment and maximizing localization.
We are also committed to the cause of skill development and have tied up with local ITI Colleges to conduct certification programs. Our key objective is to impart mobile manufacturing and industry relevant skills to enable livelihood opportunities for the youth in the manufacturing industry. We have also been focusing on giving employment to skilled labour from local institutions, including:
Pacific Cyber Technology Private Limited (“Pacific Cyber”) has always enjoyed good reputation and our values and standards have long been a source of pride for employees. Recognizing that we operate in a dynamic and rapidly changing business environment, we could easily lose our good name if we do not continually reinforce our values and standards. To ensure that integrity and values remains a continuing priority and that employees understand the Company’s expectation it was decided to compile the Company’s basic guidelines on business practices.
This Code of Business Conduct helps ensure compliance with legal requirements and our standards of business. All, senior management personnel, employees and trainees of the Company are expected to read, understand and follow this Code, uphold these standards in day-to-day activities, comply with all applicable policies and procedures, and ensure that all agents and contractors are aware of, understand and adhere to these standards.
This Code of Business Conduct is designed to give you a broad and clear understanding of the conduct expected of by you and to provide you with a mechanism for disclosure leading to informed decisions This Code aims to illustrate how our values are applied through standards of conduct with each of our key stakeholders— customers, employees, shareholders, suppliers and communities.
You should never assume that an activity is acceptable merely because others in the industry engage in it. Trust your instincts—if something does not appear to be lawful or ethical, it may not be. The requirements of this Code are mandatory. Employees will also be asked to sign an acknowledgment indicating that you have received, read, understand and agree to comply with the Code of Business Conduct. The signed acknowledgment form will be located in your personnel file with the HR Department. Failure to comply with this code will adversely affect the ethical environment on which Pacific’s success depends.
A. EXCELLENCE – STRIVE TO ACHIEVE HIGHEST STANDARDS OF QUALITY. PROMOTING CUSTOMER DELIGHT
B. INTEGRITY – HONEST, TRANSPARENT AND ETHICS IN OUR CONDUCT
C. COLLABORATION – BUILD CARING AND COLLABORATIVE RELATIONSHIP BASED ON TRUST AND MUTUAL RESPECT
D. INNOVATION – USING CUSTOMER INSIGHT IN DEVELOPING INNOVATIVE SOLUTIONS
I. STANDARD OF CODE :
We conduct our operations with honesty, integrity and openness, and with respect for the human rights and interests of our employees. We shall similarly respect the legitimate interests of those with whom we have relationships.
When representing our company, we shall act with professionalism, honesty and integrity, and conform to the highest moral and ethical standards. Our conduct shall be fair and transparent and be perceived as fair and transparent by third parties.
We shall not compromise safety in the pursuit of commercial advantage. We shall strive to provide a safe, healthy and clean working environment for our employees and all those who work with us.
We shall strive to balance the interests of our stakeholders, treating each of them fairly and avoiding unfair discrimination of any kind.
The statements that we make to our stakeholders shall be truthful and made in good faith.
II. OBEYING THE LAW :
Pacific Cyber and employees are required to comply with the laws and regulations of the countries in which we operate. With regard to those provisions of the Code that are explicitly dealt with under an applicable law or employment terms, the law and those terms shall take precedence. In the event that the standards prescribed under any applicable law are lower than that of the Code, we shall conduct ourselves as per the provisions of the Code.
The very suspicious of illegal conduct can alter public opinion, thereby adversely affecting the behaviour of our customers or stakeholders. Apart from direct financial damage, the company’s reputation may be harmed and as a result its market position may be jeopardized.
III. EMPLOYEES :
Pacific Cyber is committed to a working environment that promotes diversity and equal opportunity and where there is mutual trust, respect for human rights and no discrimination.
We provide equal opportunities to all our employees and to all eligible applicants for employment in our company. We do not unfairly discriminate on any ground, including race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin, disability or any other category protected by applicable law
We will recruit, employ and promote employees on the sole basis of the qualifications and abilities needed for the work to be performed.
a. Dignity and respect:
Everyone in our work environment must be treated with dignity and respect. We do not tolerate any form of harassment, whether sexual, physical, verbal or psychological. Pacific Cyber is committed to providing a work environment free of unlawful harassment. Pacific Cyber prohibits sexual harassment and harassment based on pregnancy, childbirth or related medical conditions, race, religious creed, colour, nationality, origin or ancestry, physical disability, medical condition, marital status, age, sexual orientation or any other basis protected by federal state or local law or ordinance or regulation.
We have clear and fair disciplinary procedures, which necessarily include an employee’s right to be heard. We are committed to safe and healthy working conditions for all employees. We will not use any form of forced, compulsory, trafficked or child labour. We are committed to working with employees to develop and enhance each individual’s skills and capabilities.
We respect our employees’ right to privacy. We have no concern with their conduct outside our work environment, unless such conduct impairs their work performance, creates conflicts of interest or adversely affects our reputation or business interests.
b. Conflicts of Interests :
All employees and others working for Pacific Cyber are expected to avoid personal activities and financial interests which could conflict with their responsibilities to the company. Employees must not seek gain for themselves or others through misuse of their positions.
Our employees and executive directors shall always act in the interest of our company and ensure that any business or personal association including close personal relationships which they may have, does not create a conflict of interest with their roles and duties in our company or the operations of our company. Further, our employees and executive directors shall not engage in any business, relationship or activity, which might conflict with the interest of our company or our group companies.
Should any actual or potential conflicts of interest arise, the concerned person must immediately report such conflicts and seek approvals as required by applicable law and company policy. The competent authority shall revert to the employee within a reasonable time as defined in our company’s policy, so as to enable the concerned employee to take necessary action as advised to resolve or avoid the conflict in an expeditious manner.
Notwithstanding such or any other instance of conflict of interest that exists due to historical reasons, adequate and full disclosure by interested employees shall be made to our company’s management. At the time of appointment in our company, our employees and executive directors shall make full disclosure to the competent authority, of any interest leading to an actual or potential conflict that such persons or their immediate family (including parents, siblings, spouse, partner, children) or persons with whom they enjoy close personal relationships, may have in a family business or a company or firm that is a competitor, supplier, customer or distributor of, or has other business dealings with, our company.
If there is a failure to make the required disclosure and our management becomes aware of an instance of conflict of interest that ought to have been disclosed by an employee or executive director, our management shall take a serious view of the matter and consider suitable disciplinary action as per the terms of employment. In all such matters, we shall follow clear and fair disciplinary procedures, respecting the employee’s right to be heard.
c. Employment/Outside Employment :
In consideration of your employment with the Company, you will give and devote the whole of your time exclusively to your duties with the company and while serving the Company shall not, without the prior consent in writing of the immediate Supervisor / Head of HR engage yourself directly or indirectly in any trade, business, occupation, employment, service or calling. Further during your employment with the Company, you are prohibited from taking up and employment or service or carry on any business either in partnership with others or on your own account similar to or in any way competitive with the business of the Company.
Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable company policies and law.
d. Integrity of Information :
Our employees shall respect and protect all confidential information and intellectual property of our company.
Our employees shall safeguard the confidentiality of all third party intellectual property and data. Our employees shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable company policies or law.
Our employees shall promptly report the loss, theft or destruction of any confidential information or intellectual property and data of our company or that of any third party.
"Confidential information" is information that is not generally known to the public about Company, its clients, or other parties with whom Company has a relationship and that have an expectation of confidentiality. The Company's confidential information is its valuable asset. The Company’s confidential information includes all intellectual property, business plans, trade secrets, confidential and privileged information, customer information, employee related information, strategies, administration, research in connection with Company and commercial, legal, scientific, technical data, unpublished financial information etc that are either provided to or made available to the employee by the Company to facilitate his work or that the employee is able to know or has obtained access by virtue of his employment or position with the Company. Protecting our proprietary and confidential information is critical to the Company's reputation for integrity and its relationship with its clients, and ensures compliance with the complex regulations governing the Company.
The loss of confidential information can be extremely damaging to our competitive position. Such information is the property of the Company and may be protected by patent, trademark, copyright and trade secret laws. All confidential information must be used for Company business purposes only. Every employee, agent and contractor must safeguard it. Unauthorized use or distribution of proprietary or confidential information violates this policy and could be illegal. Such use or distribution could result in negative consequences for both the Company and the individuals involved, including potential legal and disciplinary actions.
Your obligation to protect the Company’s proprietary and confidential information continues even after you leave the Company and you must return all such information in your possession upon your departure. Do not disclose non public information to anyone outside the company, except when disclosure is required for business purposes and appropriate steps have been taken to prevent misuse of the information. Confidential information shall be secured by displaying:
e. Protection of Company’s Assets :
Our employees shall use all company assets, tangible and intangible, including computer and communication equipment, for the purpose for which they are provided and in order to conduct our business. Such assets shall not be misused. We shall establish processes to minimise the risk of fraud, and misappropriation or misuse of our assets.
Company assets are meant for company, not personal, use. Company assets include your time at work and work product, as well as the company’s equipment and vehicles, computers and software, company information, and trademarks and name. Protecting the Company's assets is a key fiduciary responsibility of every employee, agent and contractor. Care should be taken to ensure that assets are not misappropriated, loaned to others, or sold or donated, without appropriate authorization. All Company employees, agents and contractors are responsible for the proper use of Company assets, and must safeguard such assets against loss, damage, misuse or theft. Employees, agents or contractors who violate any aspect of this policy or who demonstrate poor judgment in the manner in which they use any Company asset may be subject to disciplinary action or termination of the business relationship at the Company's sole discretion.
Computer and other Equipment: The Company strives to furnish employees with the equipment necessary to efficiently and effectively do their jobs. You must care for that equipment and use it responsibly only for Company business purposes. If you use Company equipment at your home or off site, take precautions to protect it from theft or damage, just as if it were your own. If the Company no longer employs you, you must immediately return all such equipment. While computers and other electronic devices are made accessible to employees to assist them to perform their jobs and to promote Company's interests, all such computers and electronic devices, whether used entirely or partially on the Company's premises or with the aid of the Company's equipment or resources, must remain fully accessible to the Company and, to the maximum extent permitted by law, will remain the sole and exclusive property of the Company.
General guidelines for the various communication tools include:
• Telephones: A quick call home is acceptable -- lengthy overseas calls are not acceptable.
• Faxes and Photocopiers: Personal use is acceptable provided it is infrequent and insubstantial. Photocopying your tax return is acceptable – copying announcements for your sports club is not acceptable.
• Internet and E-mail: Our personal use should not interfere with work productivity and not exceed a nominal cost to the Company. Checking e-mails during your lunch hour is acceptable – spending the afternoon “surfing the web” is not acceptable.
You are responsible for making fair and proper use of all electronic communications devices including computers, e-mail, connections to the Internet, intranet and extranet and any other public or private networks, voice mail, video conferencing, facsimiles, and telephones.
Please note that the following are some examples of inappropriate use of the Internet and e-mail and are strictly forbidden at all times:
• Downloading and transmitting pornographic, sexist, racially or ethnically insensitive material.
• Posting your personal opinions or views on any subject including with regard to the Company or the Company’s business in Internet newsgroups, chat rooms, bulletin boards, etc., unless you are specifically authorized by the Company to do so.
• Conducting private business activity on the Internet or E-mail Systems.
We shall comply with all applicable anti-money laundering, anti-fraud and anti-corruption laws and we shall establish processes to check for and prevent any breaches of such laws.
f. Gifts and hospitality :
Business gifts and hospitality are sometimes used in the normal course of business activity. However, if offers of gifts or hospitality (including entertainment or travel) are frequent or of substantial value, they may create the perception of, or an actual conflict of interest or an ‘illicit payment’. Therefore, gifts and hospitality given or received should be modest in value and appropriate, and in compliance with our company’s gifts and hospitality policy.
Employees, agents or contractors shall not accept any offer, pay, promise to pay, or authorise to pay any money, gift, or anything of value to / from customers, vendors, consultants, etc that is perceived as intended, directly or indirectly, to influence any business decision or any act or failure to act, any commitment of fraud, or opportunity for the commission of any fraud.
Gifts and entertainment may create an inappropriate expectation or feeling of obligation. You should refrain from any act that has the appearance of being a bribe, kickback or other illegal or improper payment, whether direct or indirect, to any person or entity for the purpose of (i) obtaining, retaining or directing business or (ii) affecting the conditions of doing business. Moreover you must report any offer of a bribe, kickback or illegal payment that you receive or learn to your Manager or the Compliance Committee. Never give, offer, or authorize the offer, directly or indirectly, of anything of value (such as money, goods or a service) to a customer or government official to obtain any improper advantage.
As part of building relationships, we may receive occasional gifts, provided that:
• Doing so is legal; and
• The gift is neither intended nor likely to be perceived by others to improperly influence our business decisions.
Employees may accept and offer nominal gifts which are customarily given and are of commemorative nature for special events. Socially acceptable gifts for occasions, such as Diwali, New year, anniversary gifts, provided they are of a reasonable amount. The nominal intrinsic value of the gifts that can be given / accepted on such occasions is limited to Rs. 3,000/-.
g. Freedom of association :
We recognise that employees may be interested in joining associations or involving themselves in civic or public affairs in their personal capacities, provided such activities do not create an actual or potential conflict with the interests of our company. Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable company policies and law.
We respect the dignity of the individual and the right of employees to freedom of association and collective bargaining. We will maintain good communications with employees through company-based information and consultation procedures. We will ensure transparent, fair and confidential procedures for employees to raise concerns.
h. Prohibited drugs and substances :
Use of prohibited drugs and substances creates genuine safety and other risks at our workplaces. We do not tolerate prohibited drugs and substances from being possessed, consumed or distributed at our workplaces, or in the course of company duties.
Use of illegal drugs and alcohol abuse create serious health and safety risks in the workplace. The possession, sale or use of illegal drugs on Company time or property or impairment from alcohol when conducting Company’s business or at Company sponsored events is also prohibited. It is important that cases of drug and alcohol abuse be brought to management’s attention immediately.
IV. CUSTOMERS :
a. Product & Services
Pacific Cyber is committed to providing products and services which consistently offer value in terms of price and quality, and which are safe for their intended use. Products and services will be accurately and properly labelled, and communicated. We are committed to supplying products and services of world-class quality that meet all applicable standards.
The products and services we offer shall comply with applicable laws, including product packaging, labelling and after-sales service obligations.
b. Dealings with customers
Our dealings with our customers shall be professional, fair and transparent. We respect our customers’ right to privacy in relation to their personal data. We shall safeguard our customers’ personal data, in accordance with applicable law.
c. Fair competition
We support the development and operation of competitive open markets and the liberalisation of trade and investment in each country and market in which we operate.
We shall not enter into any activity constituting anti-competitive behaviour such as abuse of market dominance, collusion, participation in cartels or inappropriate exchange of information with competitors.
Pacific Cyber believes in vigorous yet fair competition and supports the development of appropriate competition laws. Pacific Cyber and employees will conduct their operations in accordance with the principles of fair competition and all applicable regulations.
V. THE ENVIRONMENT AND THE COMMUNITIES :
a. Environment
Pacific Cyber is committed to making continuous improvements in the management of our environmental impact and to the longer-term goal of developing a sustainable business. Pacific Cyber will work in partnership with others to promote environmental care, increase understanding of environmental issues and disseminate good practice.
In the production and sale of our products and services, we strive for environmental sustainability and comply with all applicable laws and regulations. We seek to prevent the wasteful use of natural resources and are committed to improving the environment, particularly with regard to the emission of greenhouse gases, consumption of water and energy, and the management of waste and hazardous materials. We shall endeavour to offset the effect of climate change in our activities
b. Communities
Pacific Cyber strives to be a trusted corporate citizen and, as an integral part of society, to fulfil our responsibilities to the societies and communities in which we operate.
We are committed to good corporate citizenship, and shall actively assist in the improvement of the quality of life of the people in the communities in which we operate.
We engage with the community and other stakeholders to minimise any adverse impact that our business operations may have on the local community and the environment. We encourage our workforce to volunteer on projects that benefit the communities in which we operate, provided the principles of this Code, where applicable, and in particular the ‘Conflicts of Interest’ clause are followed.
VI. SUPPLIERS – OUR VALUE CHAIN PARTNERS :
Pacific Cyber is committed to establishing mutually beneficial relations with our suppliers, customers and business partners. In our business dealings we expect our partners to adhere to business principles consistent with our own.
We shall select our suppliers and service providers fairly and transparently. We seek to work with suppliers and service providers who can demonstrate that they share similar values. We expect them to adopt ethical standards comparable to our own.
Our suppliers and service providers shall represent our company only with duly authorised written permission from our company. They are expected to abide by the Code in their interactions with, and on behalf of us, including respecting the confidentiality of information shared with them.
We shall ensure that any gifts or hospitality received from, or given to, our suppliers or service providers comply with our company’s gifts and hospitality policy. We respect our obligations on the use of third party intellectual property and data.
VII. GOVERNMENT :
Pacific Cyber encouraged to promote and defend their legitimate business interests. The Company co-operate with governments and other organisations, both directly and through bodies such as trade associations, in the development of proposed legislation and other regulations which may affect legitimate business interests. We engage with the government and regulators in a constructive manner in order to promote good governance. We conduct our interactions with them in a manner consistent with our Code.
Pacific Cyber neither supports political parties nor contributes to the funds of groups whose activities are calculated to promote party interests.
We shall act in accordance with the constitution and governance systems of the countries in which we operate. We do not seek to influence the outcome of public elections, nor to undermine or alter any system of government. We do not support any specific political party or candidate for political office. Our conduct must preclude any activity that could be interpreted as mutual dependence/favour with any political body or person, and we do not offer or give any company funds or property or other resources as donations to any specific political party, candidate or campaign.
VIII. COMPLIANCE – MONITORNG – REPORTING :
Compliance with these principles is an essential element in our business success. The Pacific Cyber Board is responsible for ensuring these principles are applied throughout the Company. The Chief Executive Officer is responsible for implementing these principles and is supported in this by its Partners based in China, and the Legal Advisor.
Day-to-day responsibility is delegated to all senior management of the geographies, categories, and functions. They are responsible for implementing these principles. Assurance of compliance is given and monitored each year. Compliance is subject to review by the Board. Any breaches of the Code must be reported. The Board of Pacific Cyber will not criticise management for any loss of business resulting from adherence to these principles and other mandatory policies. Provision has been made for employees to be able to report in confidence and no employee will suffer as a consequence of doing so.
We encourage our employees, customers, suppliers and other stakeholders to raise concerns or make disclosures when they become aware of any actual or potential violation of our Code, policies or law. We also encourage reporting of any event (actual or potential) of misconduct that is not reflective of our values and principles.
Avenues available for raising concerns or queries or reporting cases could include:
• immediate line manager or the Human Resources department of our company.
• designated ethics officials of our company.
• the ‘confidential reporting’ third party ethics helpline (if available).
• any other reporting channel set out in our company’s ‘Whistleblower’ policy.
We do not tolerate any form of retaliation against anyone reporting legitimate concerns. Anyone involved in targeting such a person will be subject to disciplinary action. If you suspect that you or someone you know has been subjected to retaliation for raising a concern or for reporting a case, we encourage you to promptly contact your line manager, the company’s Ethics Counsellor, the Human Resources department, the MD/CEO or the office of the group’s Chief Ethics Officer.
IX. ACCOUNTABILITY :
This Code is more than a set of prescriptive guidelines issued solely for the purpose of formal compliance. It represents our collective commitment to our value system and to our core principles. Every person employed by us, directly or indirectly, should expect to be held accountable for his/her behaviour. Should such behaviour violate this Code, they may be subject to action according to their employment terms and relevant company policies. When followed in letter and in spirit, this Code is ‘lived’ by our employees as well as those who work with us. It represents our shared responsibility to all our stakeholders, and our mutual commitment to each other.
X. DISCIPLINARY ACTIONS / CONSEQUENCES OF VIOLATING THE CODE :
The matters covered in this Code of Business Conduct and Ethics are of the utmost importance to the Company, its stakeholders and its business partners, and are essential to the Company's ability to conduct its business in accordance with its values. We expect all of our employees, agents, contractors and consultants to adhere to these rules in carrying out their duties for the Company. Every employee is called upon to review his or her own behavior in light of the above standards and to determine where improvements are possible. Every supervisor must organize his or her area of responsibility in such a way that reports of legal violations can always reach him or her. Problems must be actively addressed. However, supervisors also must take the initiative to regularly monitor their subordinates’ activities and actively communicate with them. If you are an employee or officer, this Code forms part of the terms and conditions of your employment with Pacific Cyber Techology Private Limited. All employees are expected to cooperate in internal investigations of allegations of violations of the Code, and actual violations may subject you to the full range of disciplinary action by the Company. The Company may also report certain activities to its regulators, which could give rise to regulatory or criminal investigations. The penalties for regulatory and criminal violations may include significant fines, permanent bar from employment in the securities industry and, for criminal violations, imprisonment. Penalties for violations Employees who violate the spirit or letter of Company’s policies are subject to disciplinary action up to and including dismissal.
The following are examples of conduct that may result in disciplinary action:
- Actions that violate this Code or any Pacific Cyber policy
- Requesting others to violate a Pacific Cyber policy
- Failure to promptly raise a known or suspected violation of a Pacific Cyber policy
- Failure to cooperate in investigations of possible violations of a Pacific Cyber
- Retaliation against another employee for reporting an integrity concern
- Failure to demonstrate the leadership and diligence needed to ensure compliance with the Company policies and applicable laws. Violation of a the Company policy can also mean breaking the law, subjecting you or the company to criminal penalties (fines or jail sentences) or civil sanctions (damage awards or fines).
ANNEXURE – A
We encourage our employees, customers, suppliers and other stakeholders to raise concerns or make disclosures when they become aware of any actual or potential violation of our Code, policies or law. We also encourage reporting of any event (actual or potential) of misconduct that is not reflective of our values and principles.
You are Pacific's first line of defence against unethical business practices and violations of the law. If you observe or become aware of any conduct that you believe is unethical or unlawful— whether by another employee, a consultant, supplier, client, or other third party—you must communicate that information to without any hesitation and concern.
Sometime it is may seem difficult to raise such a concern. Some of us may even feel it is a breach of personal ethical standards to do so. If you experience that sense of conflict, it’s important to remember the tremendous harm that can be caused by not raising a concern, including:
• Serious damage to the health, safety and well-being of yourself, your fellow employees, the company as a whole, our customers and the communities in which we operate
• The loss of confidence in Pacific Cyber – by customers, governments and employees
• Huge fines, damage awards and other financial penalties against the company; fines and/or prison sentences for individual employees
Reporting
The violation of code of Conduct can be reported to
• Your direct Manager / Supervisor or
• Head of Unit / Plant Director / Factory Manager
• Head – Human Resources & Administration who has been designated as a “Compliance Officer” of Pacific Cyber Technology Private Limited
• Executive Director or member of senior Management
• Employees also may report violations, anonymously at email id reachus@pacificindia.com if they wish however proper details have to be provided
You can report suspected violations of the code without fear of reprisal or retaliation. Every effort will be made to maintain in confidence the identity of the person making the report of a suspected Code violation.
If an employee raises any concern in good faith that he/she believes to be true, but which following investigation proves to be unfounded, no action will be taken against such an employee. If, however, the investigation reveals that the employee has made a deliberately false allegation with the intention of discrediting a fellow employee, he/she will be investigated to determine whether disciplinary action should be taken against him/her. Such disciplinary action could (among other things) also result in dismissal from services.
Investigation
The Head of Factory & Head of Human Resources and Administration is responsible for all preliminary Code of Conduct investigations. He may take help from other officials as per the requirement of the situations.
The question whether the subject of the investigation receive notification of the investigation, will depends on the circumstances and the results of the preliminary investigation. If there is insufficient evidence of a Code violation, the investigation may be closed without notification. In the event it is determined that evidence of a violation exists, the individual will be notified, but that notification may not occur until after records have been reviewed and witnesses interviewed. The subject of an investigation will have the opportunity to respond to any allegations made against that person. At the discretion of the Compliance Officer, a person suspected of violating the Code can be suspended with or without pay while an investigation is conducted.
Decision
A preliminary determination, whether a violation of the Code has occurred will be made by the Head – Factory severally or jointly with other official supporting investigation. That preliminary determination will be communicated to the Manager of the alleged violator. Sole authority for making a final determination that a violation has occurred rests with the Compliance Officer / Head – Human Resources & Administration
The Head – Factory can seek a recommendation either from Compliance Officer and/or Head – Human Resources & Administration on appropriate disciplinary actions that can be taken.
The company uses a system of progressive discipline. The company strives to impose discipline for a Code violation after taking into account the gravity of the violation; the past service record and extenuating or aggravating circumstances.
The Company generally will issue warnings or letters of reprimand for less significant, first-time offences. Violations of a more serious nature may result in suspension without pay, demotion, loss or reduction of bonus or option awards or any combination. Termination of employment generally is reserved for theft or other violations amounting to a breach of trust, and for cases where a person has engaged in multiple violations.
The final decision on appropriate discipline will be made by the Compliance Officer or an Executive Director as the case may be. The Compliance Officer or an Executive Director shall communicate the decision.
Reporting and Recordkeeping
The documents concerning the violation, a notation as to the final decision as well as any letter of reprimand or other communication with the violator will be placed in that employee’s personnel file as part of his or her permanent record. .