Introduction
This Code of Business Conduct and Ethics (the “Code”) has been adopted by our Board of Directors to guide our actions. While covering a wide range of business practices and procedures, these standards cannot and do not cover every issue that may arise, or every situation where ethical decisions must be made, but rather set forth key guiding principles that represent the Company’s policies and establish conditions for employment at the Company.
We must strive to foster a culture of honesty and accountability. All of our employees, officers and directors must conduct themselves according to this Code and seek to avoid even the appearance of improper behaviour. Even well intentioned actions that violate the law or this Code may result in negative consequences for the company and for the individuals involved.
Our most valuable assets is our reputation for integrity, professionalism and fairness. We should all recognise that our actions are the foundation of our reputation and adhering to this Code and applicable law is imperative.
Conflicts of Interest
Our employees, officers and directors have an obligation to conduct themselves in an honest and ethical manner and act in the best interest of the Company. All staff should endeavour to avoid situations that present a potential or actual conflict between their interest and the interest of the Company.
A “conflict of interest” occurs when a person’s private interest interferes in any way, or even appears to interfere, with the interest of the Company, including its subsidiaries and affiliates. A conflict of interest can arise when an employee, officer or director takes an action or has an interest that may make it difficult for him or her to perform his or her work objectively and effectively. Conflicts of interest may also arise when an employee, officer or director (or his or her family members) receives improper personal benefits as a result of their position in the Company.
Although it would not be possible to describe every situation in which a conflict of interest may arise, the following are examples of situations which may constitute a conflict of interest:
- Using SCCI”s members or showing the SCCI members to competitors or doing any other business with SCCI members for promoting personal business.
- Working, in any capacity, for a competitor, customer, supplier or other third party while employed by the Company. To be precise all staff of SCCI(P) are prohibited to take any outside employment, either full-time of part-time of part of any private business or service.
- Accepting gifts or receiving personal discounts (if such discounts are not generally offered to the public) or other benefits as a result of your position in the Company from a competitor, customer or supplier.
- Competing with the Company for the purchase or sale of property, products, services or other interests.
- Having an interest in a transaction involving the Company, a competitor, customer or supplier (other than as an employee, officer or director of the Company and not including routine investments in publicly traded companies).
- Receiving a loan or guarantee of an obligation as a result of your position with the Company.
- Directing business to a supplier owned or managed by, or which employs, a relative or friend.
In the event that an actual or apparent conflict of interest arises between the personal and professional relationship or activities of an employee, the company has to deal with them firmly with appropriate actions.
Compliance with Laws, Rules and Regulations
We are strongly committed to conducting our business affairs with honesty and integrity and in full compliance with all applicable laws, rules and regulations. No employee, officer or director of the Company shall commit an illegal or unethical act, or instruct others to do so, for any reason. The Company also disseminates information regarding compliance with the laws, rules and regulations that affect our business.
Trading on Inside Information:
Using non-public information to trade in securities, or providing a family member, friend or any other person with a “tip”, is illegal. All non-public information should be considered inside information and should never be used for personal gain. You are required to familiarize yourself and comply with the Company’s Code of Conduct for Prevention of Insider Trading, copies of which are distributed to all employees, officers and directors and are available on the Intranet or from the Company Secretary. You should contact the Company Secretary with any questions about your ability to buy or sell securities.
Protection of Confidential Proprietary Information
Confidential proprietary information generated and gathered in our business is a valuable asset. Protecting this information plays a vital role in our continued growth and ability to compete, and all proprietary information should be maintained in strict confidence, except when disclosure is authorised by the Company or required by law.
Proprietary information includes all non-public information that might be useful to competitors or that could be harmful to the Company or its customers if disclosed. Intellectual property such as trade secrets, patents, trademarks and copyrights, as well as business, research and new product plans, objectives and strategies, records, databases, salary and benefits data, employee medical information, customer, employee and suppliers lists and any unpublished financial or pricing information must also be protected.
Unauthorised use or distribution of proprietary information violates the Company’s 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. We respect the property rights of other companies and their proprietary information and require our employees, officers and directors to observe such rights.
Your obligation to protect the Company’s proprietary and confidential information continues even after you leave the Company, and you must return all proprietary information in your possession upon leaving the Company.
Quality of Public Disclosures
The Company has a responsibility to communicate effectively with shareholders so that they are provided with full and accurate information, in all material respects, about the Company’s financial condition and results of operations. Our reports and documents required to be filed with or submitted to the Reserve Company of India, other regulatory agencies and our other public communications shall include full, fair, accurate, timely and understandable disclosure.
Protection and Proper Use of the Company’s Assets
Protecting the Company’s assets against loss, theft or other misuse is the responsibility of every employee, officer and director. Loss, theft and misuse of the Company’s assets directly impact our profitability. Any suspected loss, misuse or theft should be reported to a manager/supervisor or the Chief Financial Officer.
The sole purpose of the Company’s equipment, vehicles, supplies and electronic resources (including, hardware, software and the data thereon) is the conduct of our business. They may only be used for the Company’s business consistent with the Company’s guidelines.
Corporate Opportunities:
Employees, officers and directors are prohibited from taking for themselves business opportunities that arise through the use of our registered SHG members, corporate property, information or position. No employee may use our borrower members, corporate property, information or position for personal gain, and no employee may compete with the Company. Competing with the Company may involve engaging in the same line of business as the Company, or any situation where the employee takes away from the Company opportunities for lending to our members or purchases of property, products, services or interests.
Fair Dealing
Each employee, officer and director of the Company should endeavour to deal fairly with customers, suppliers, competitors, the public and one another at all times and in accordance with ethical business practices. No one should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice. No payment in any form shall be made directly or indirectly to or for anyone for the purpose of obtaining or retaining business or obtaining any other favourable action. The Company and the employee, officer or directors involved may be subject to disciplinary action as well as potential civil or criminal liability for violation of this policy.
Compliance and Reporting of Any Illegal or Unethical Behaviour :
All employees and officers are expected to comply with all of the provisions of this Code. The Code will be strictly enforced and violations will be dealt with immediately, including subjecting persons to corrective and/or disciplinary action such as dismissal or removal from office. Violations of the Code that involve illegal behaviour will be reported to the appropriate authorities.
The Company recognises the need for this Code to be applied equally to everyone it covers. The Head, Corporate Legal Dept of the Company will have primary authority and responsibility for the enforcement of this Code, subject to the supervision of the Board Governance & Remuneration Committee.
The Company encourages all employees, officers and directors to report any suspected violations promptly and intends to thoroughly investigate any good faith reports of violations. The Company will not tolerate any kind of retaliation for reports or complaints regarding misconduct that were made in good faith. Open communication of issues and concerns by all employees without fear of retribution or retaliation is vital to the successful implementation of this Code. You are required to cooperate in internal investigations of misconduct and unethical behavior.
Employees, officers and directors should promptly report any concerns about violations of ethics, laws, rules, regulations or this Code to Corporate Legal Dept or to the Board Governance & Remuneration Committee.
In the operations level, any suspected fraudulent practices that appear to have been followed by at the branch level, Area Manager levels, State Office level should be immediately brought to the notice of the National Operations Head or the Managing Director directly, the contact address of them are : |
