Organizational ethics, values and vision combine the core of its conscience and act as operating boundaries for each member of the organization. As part of defining this core, I am happy we are bringing out a new Code of Conduct. The Code of Conduct of GCPL has been created to foster and maintain trust and confidence in the professionalism and the integrity of all Employees, Senior Managers and the Directors of GCPL. This Code is an ethical framework for our day-to-day actions and provides guidance to all about the manner in which GCPL – and its employees, officers, managers irrespective of their grades should conduct themselves when they are undertaking business on behalf of the Company.
As a member of the organization, it is important that you read, understand and fully comply with GCPL Code of Conduct and ensure that your behaviour and decisions live up to the ideals and values as enshrined herein without exception.
GCPL Code of Conduct is legally binding and complies with Indian law and its provisions are applicable to every Employee. However, it is pertinent to note that while this is a useful reference, the Code cannot address or anticipate all situations. It is your bounden responsibility to bring to the attention of your manager /superior any situation you have reason to believe is in conflict with our Code of Conduct.
GCPL’s reputation is entrusted in each of us. The real challenge is not only knowing what is right, but knowing how to act on ethical convictions within an organization.
Your commitment to integrity and ethical leadership are vital to GCPL’s continued business success.
Sunil K. Chaturvedi
Chairman & Managing Director
Gainwell Commosales Private Ltd (GCPL)
GCPL is committed to ensuring that its business is conducted, according to rightful, ethical, professional and legal standards in every respect, and always.
The Company (referred hereafter as GCPL or the Company) is committed to creating a workplace, across all its working locations which is free from harassment and discrimination, where co-workers are respected and provided with an appropriate environment so as to encourage good performance and conduct.
To achieve this goal, every GCPL employee is expected to:
Employees (the term for the purpose of this Code of Conduct shall include management, non- management, contractual, unionized, trainees), Officers, Senior Managers and Directors are expected to:
Reputation and goodwill of GCPL is founded on the ‘commitment to acting with integrity’ throughout the organization. GCPL, under any circumstance, does not accept or solicit bribery of any kind. Any employee of GCPL shall not pay nor offer bribes [cash or kind] or illicit payments to government officials or candidates, political parties, customers or suppliers in order to obtain, retain or protect business. Employees working with the Company must avoid any activity that may involve acceptance and giving of personal gifts, hospitality or any favour to or from GCPL stakeholders including Customers, Suppliers, Principals, Service Providers, Shareholders and Investors.
At GCPL, engaging in bribery and corruption constitutes the severest violation of its Code of Conduct. If proven guilty, the employee/employees run the risk of suspension from service, stoppage or withdrawal of increments or incentives, reduction in rank and pay and even dismissal from service / termination of contract as also, at the sole discretion of the Company, exposure to legal proceedings –civil or criminal in nature. Implementation and monitoring of anti-bribery and corruption policy and principles remain within the domain of the Chairman & MD of GCPL who shall, report to the Board of Directors on a quarterly basis every incident of material violation and the actions taken by him for such violation of the Code.
GCPL diligently follows the competition laws, both in relation to transactions and commercial behavior and strictly prohibits any competitive practice including abuse of dominance. The Company promotes and sustains fair competition in the market, protects customer and stakeholder interest at large, respects and ensures freedom of trade by other participants in the market.
Employees are expected not to:
* Value not exceeding INR 1000/-
GCPL aims is to deal ethically with suppliers and customers.
We view our suppliers and customers as partners and believe in honest dealing with them in order to have a sound and lasting relationship. We give all potential suppliers fair and uniform consideration. Decisions are based on objective criteria such as price and quality as well as a vendor’s reliability and integrity.
All employees of GCPL are responsible for protecting and taking reasonable steps to prevent theft or misuse of, or damage to Company’s assets. This includes the Company’s tangible and physical assets such as equipment, machinery, systems, facilities, materials etc., or intangible assets such as goodwill and intellectual property such as corporate information, relationships with customers and suppliers, inventions, copyrights, patents, trademarks, company logo and technology used in carrying out their responsibilities. Company’s property must not be borrowed, loaned, or disposed of, except in accordance with appropriate Company’s policies.
GCPL maintains the confidentiality and security of employee Personal Data very seriously. Every employee, including department(s) responsible for this specific job must be scrupulously attentive to the protection of all employee-related paper and computer files. Particular attention is required to avoid casual comments where personal information might be shared even if specific details are not included. Leakage, direct or indirect, of Personal Data of employees shall constitute a severe violation of this Code and shall be ground for disciplinary action at the discretion of the Company.
Our trade secrets, other proprietary information including customer details, leads about their potential business plans and purchases and much of internal data are valuable assets of the Company. Protection of these assets, including maintaining their secrecy, plays a vital role in our continued growth and ability to compete. Every employee of GCPL carries a bounden obligation with respect to the Company’s trade secrets and other proprietary information and is required:
In the event of leaving the Company, it is inalienable obligation of every employee to protect the trade secrets and other proprietary information until the information becomes publicly available or the Company no longer considers it a trade secret or proprietary. Employees must also remember that correspondence, printed matter, electronic information, documents or records of any kind, specific process knowledge, procedures – whether confidential or not – are all the property of the Company and must remain with GCPL.
Every employee must use GCPL’s Information Technology resources responsibly and in a manner consistent with the Code and all other Company Guidelines. The following types of usages are strictly prohibited:
* IT Policy document is separately notified
GCPL’s corporate image is of paramount importance to the Management. To protect GCPL’s image, all statements made to the public must be carefully controlled and are coordinated as follows:
It is critical that no one should respond directly to any such inquiry or contact press/media because any inappropriate or inaccurate response, even a denial or disclaimer of information, may result in adverse publicity and could otherwise adversely impact the Company’s operations or its legal position on an issue.
This policy does not apply to requests for already published financial information, such as Annual Reports and Quarterly Results, or promotions and publicity activities of the Company.
Requests for interviews with any GCPL member or individual relating to the Company or its affairs and/or the issuance of any Company press releases and/or statements must be reviewed and approved in advance by the Chairman & MD and Head – Corporate Communications, and routed through them. Company-initiated interviews similarly must be approved before they are scheduled with the media.
GCPL is committed to recruiting, employing and promoting employees on the sole basis of qualifications and abilities as needed for the role, with no regard to race, age, sex, caste, national origin or any other category. Any allegations of discrimination are taken seriously and investigated vigorously. Our employees contribute a diverse range of talents, experiences and viewpoints that add value to our business. We recognize the fact that diversity of our Company adds to the organizational excellence, makes our Company stronger and helps us to compete more effectively in the markets we operate. GCPL shall always strive to maintain such diversity in its workforce.
The use or possession of alcohol, illegal drugs, and other controlled substances in the workplace and being under the influence of these substances on the job and during working hours is strictly prohibited. In Company-sponsored events where management approves the serving of alcoholic beverages, all appropriate laws of the land must be followed, including laws regarding the prohibition of serving of alcohol to those under the legally permissible age. However, under all such cases, excessive drinking, intoxication and misbehavior at these events or after them are strictly prohibited and will be dealt with severely.
Fraud – or the act or intent to cheat, trick, steal, deceive, or lie – is both dishonest and, in most cases, carries criminal implications. Intentional acts of fraud are subject to strict disciplinary action, including dismissal and possible civil and/or criminal action against the concerned GCPL employee. Some examples of Fraud include:
GCPL does not tolerate any form of sexual harassment**. All employees, irrespective of gender, must be aware of how such situations are characterized and the consequences of engaging in such behavior. Inappropriate behavior in terms of a person’s words or actions, unwanted advances, display of inappropriate objects, photos or images, whether intentional or unintentional come under the purview of sexual harassment in the workplace. If a person deems something as ‘objectionable’ due to the nature of its inappropriate content and makes that objection known, then it is, by definition, inappropriate and its continuation may be considered as harassment. Strict action will be taken against any such offensive conduct
[**Sexual harassment includes any one or more of the following unwelcome acts or behavior : Physical contact or advances, a demand or request for sexual favors, showing pornography, any other unwelcome physical, verbal or non-verbal conduct of sexual nature.]
For the purpose of information of all employees, ‘The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 is a statute to provide protection against sexual harassment to women at workplace and for the prevention and redressal of complaints of sexual harassment. The law takes into account all women employees of GCPL across all grades – temporary, permanent, full-time or part-time, as well as trainees and interns. The act of harassment can occur in the workplace and also if a woman is harassed while visiting a place arising out of or during the course of employment including transportation provided by the office, a complaint can be filed under this Act. This Act is only applicable to women and women only.
All complaints relating to the above shall be handled by the Internal Complaints Committee [ICC] of GCPL
Policy for Prevention of Sexual Harassement
GCPL attaches great importance to good physical working conditions and high standards of hygiene. Safety awareness and adoption of safe working methods are encouraged amongst the employees to prevent any serious accidents. The Company is also committed to take initiatives for the preservation of environment.
The EHS Policy of the Company shall at all times be the guiding document in this regard.
*Detail of the policy is separately notified
Non-observance of this Code of Conduct shall be considered as misconduct that could warrant varying degree of disciplinary action, including dismissal / termination in deserving cases. The decision in this regard will lie with the Management, and the Appropriate Authority and shall be binding in terms of the employment terms and conditions.
The Code may be amended, expanded or modified from time to time with the approval of the Board of Directors. Any waiver from any provision of this Code of Conduct must be placed for approval before the Company’s Board of Directors, as appropriate.
All queries and clarifications on the policy and procedures may be referred to – the Company Secretary /Legal department/ Corporate Communications /Internal Audit/ Human Capital Management (HCM).
The Chairman & MD of GCPL shall be the ultimate Compliance Officers. The Company Secretary shall assist them in this task.
It will be the responsibility of all Senior Managers/HODs to report any violation of the Code of Conduct in the respective department/functions to the Compliance Officer. No individual shall be allowed to suffer for reporting violation of this Code of Conduct. The Company has separately notified a Whistle Blower Policy that guarantees complete protection to employees sharing information about such violations.