Code of Conduct and Ethics Policy

Code of Conduct and Ethics Policy

Our professional code of Conduct and ethics policy aims to give our stakeholders and partners guidelines on our business ethics and stance on various controversial matters.

We value your liberty and personal choice to take your own decision however, we wish to provide you with a concrete guide you can fall back on if you’re unsure about how you should act in a particular situation (in cases of controversies, conflict of interest and so on) or most of the time when you interact with us or discharge your duties on behalf of Infrex India.

1. Scope

This policy (Code of Conduct and Ethics) uniformly applies to everyone we employ or have business relations with. This includes individual people such as employees, partners, interns, and volunteers, but also business entities, such as vendors, enterprise customers and any or all stakeholders or venture capital companies.

The Code of ethics is may differ from the code of conduct. Code of conduct may include elements such as dress code, establishing good and clear communication, and social media use, whilst our code of professional ethics refers to legally or morally charged issues.

2. Definition of the terms used under the Code of Conduct and Ethics policy

Please refer to the below para to find the suitable definition of the terms used in the Code of Conduct and Ethics policy –

2 (a). Code of Conduct: These are the set of rules outlining the norms, rules, duties, and responsibilities or proper practices of an individual party or an organization in a business context. The code of Conduct plays an essential role in maintaining the legality of business and a healthy workplace.

2 (b). Ethics: Ethics refers to a sense of right or wrong. Business ethics includes the standards for morally right and wrong acts in the business. Law partially defines the conduct, but “legal” and “ethical” aren’t necessarily the same. It means some acts can be legally right but morally wrong, and similarly, an act can be morally right but legally wrong. However, Business ethics enhances the law by outlining acceptable behaviors beyond legal control or supervision.

Business ethics is an essential skill that drives employee behavior. Corporations establish business ethics to promote integrity among their employees and gain trust from key stakeholders, such as investors and consumers.

2 (c) Bribery: It is the offering, giving, or receiving of anything of value with the intention of inducing a person to act or to reward a person for having acted. Items of value can include, but are not limited to:

• Cash and cash equivalents
• Gifts, meals, entertainment, and travel
• Political contributions
• Charitable donations
• Job offers

2 (d). Corruption: Corruption includes the solicitation of a bribe, whether or not coupled with a threat of demand if refused.

2 (e). Harassment: It includes any type of Physical, Mental or sexual persecution or exploitation.

3. Conduct of Business

Members must comply with all applicable laws of India and their respective counties, rules, and regulations when conducting business. Members must conduct themselves with honesty, fairness, dignity, and integrity, and should avoid any conflict between private and business interests.

Members should take care that they conduct themselves in their private life in a manner that does not bring Infrex India / NCERT Infrexa into disrepute.

4. Components

Components of our code of professional ethics –

4 (1). Respect for others

It’s mandatory to respect everyone you interact with. Be kind, polite, and understanding. You must show your trust and respect others’ personal space, opinions, and privacy. Abetment, instigation, inducement and any kind of violence are strictly prohibited and will result in immediate termination. You’re also not allowed to harass or victimize others.

If someone, be it a customer, colleague or stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to your superior authorities. You are also given the full liberty to report rudeness and dismissiveness if they become excessive or frequent.

But please note if someone harassing you belong from your department or this company it is mandatory for you to report the incident with us in writing as soon as possible and receive a valid sanction against the offender before approaching the Court of Law or any other legal agency outside our organization.

4 (2). Integrity and honesty

First, always keep in mind our organization’s mission. We all work together to achieve specific outcomes. Your behavior should contribute to our goals, whether financial or organizational.

Be honest, impartial, and transparent when you act in ways that impact other people (e.g. taking strategic decisions or deciding on layoffs). We don’t tolerate hypocritic, malicious, deceitful, or petty conduct.

Lies and cheating are huge red flags and, if you’re discovered, you may face progressive discipline or immediate termination depending on the severity of the damage you did.

Stealing from the company, its members or other people is illegal. If you’re found to be involved, you will face repercussions depending on the severity of your actions.

For example –

  • if you steal office supplies, you may receive a reprimand or demotion (at a minimum)
  • if you steal money or data (e.g. engaging in fraud or embezzlement), you will get fired and face legal consequences.

The whole decision process is at OSD’s discretion by examining the direct and circumstantial evidence on a case-by-case basis.

4 (3). Justice

Don’t act in a way that exploits others, their hard work, or their mistakes, and also don’t demoralize them in such a way that lose their confidence and dedication. Give everyone equal opportunity and speak up when someone else doesn’t.

Be objective, compassionate, and flexible when making decisions that can impact other people, including when you’re deciding to hire, promote or fire someone.

Be sure that you can justify any decision with written records or examples. Seek and use the most objective methods in any case; for example –

  • when interviewing candidates, ask the same interview questions to all of them and avoid judging non-job-related criteria, like a dress, appearance, etc.

When exercising authority, be fair. Don’t show favoritism toward specific employees and be transparent when you decide to praise or reward an employee.

You’re also obliged to follow our employment of relatives policy, which forbids you from having a reporting relationship with a relative.

If you need to discipline an employee, be sure to have prepared a case that you can present to HR. You must not retaliate against employees or applicants (such as in cases when they’ve filed complaints) as this is forbidden by law.

Be just toward customers or vendors, too. If you think our company was in the wrong in a specific instance, don’t try to cover it up or accuse the other side. Discuss with your manager to find solutions that can benefit both sides.

4 (4). Non-Discrimination

Everybody is equal. Infrex India does not tolerate discrimination or harassment in the workplace, based on criteria such as age, disability, ethnic origin, gender, race, political attitude, workers’ representative activities, religion, or sexual orientation.

4 (5). Lawfulness

You are obliged to follow all laws which apply to our organization. Depending on your role and profession, there might be various laws you need to observe.

As a responsible citizen, it is your responsibility to be aware and updated on all or any laws enforced in your country and not breach them. For example, accountants and medical professionals have their own legal restrictions and they must be fully aware of them.

When you’re preparing contracts, clauses, disclaimers, or online copies that may be governed by law (such as consent forms), please ask for verification from the Legal Cell of Infrex India before finalizing anything.

4 (5) (a). No Corruption or Bribery

Following laws regarding fraud, bribery, corruption, and any kind of assault is a given. You are also obliged to follow laws on child labor and avoid doing business with unlawful organizations.

Infrex India does not tolerate any form of bribery or corruption. Irrespective hereof, situations may arise which do not constitute corruption or bribery but may allow the judgment of our members, clients, and business partners to be compromised.

Members are prohibited from accepting any gift that may influence their judgment on company matters as it pertains to the donor.

4 (5) (b). Confidentiality and Data Protection policy

The safeguarding of client-related data is an important foundation for the trust of our clients. You’re also covered by our confidentiality and data protection policy. You must not expose, disclose or endanger information of customers, employees, stakeholders, or our business.

Every employee or member before obtaining any kind of authority or data must duly sign the Confidentiality Com Non-Disclosure agreement and submit it to the respective authority.

Confidential and sensitive information and records of the Agency, be it private or corporate or with regard to the affairs of Infrex India / NCERT Infrexa or its employees, or subordinates organizations must be kept secret in a suitable manner from colleagues who do not require such data to properly perform their tasks.

This applies equally to third parties. If someone without clear authority consistently tries to obtain confidential information, the involved persons must notify Infrex India.

If you’re not sure what the law is in a specific instance, don’t hesitate to ask HR or our legal counsel.

4 (6). Conflict of interest

Conflict of interest may occur whenever your interest in a particular subject leads you to actions, activities, or relationships that undermine our company. This includes situations like using your position’s authority for your own personal gain or exploiting company resources to support a personal money-making business.

Even when you seemingly act to the company’s advantage, you may actually disadvantage it. For example, if an employee uses dubious methods to get competitor intel and raise their sales record, their action will have a positive impact on the company’s revenue, but it will put us at legal risk and promote unhealthy business practices.

If it turns out you have created a conflict of interest for yourself, you will be terminated. If the conflict of interest was involuntary (e.g. buying stocks from a company without knowing they’re a competitor), we will take action to rectify the situation. If you repeat the offense, you may be terminated.

4 (7). Competence and accountability

You must work hard and be responsible for your work.

We all need to put a healthy amount of effort in our work. Not just because we’re all responsible for the organization’s success, but also because slacking off affects our colleagues.

Incomplete or slow working might hinder other people’s work or cause them to shoulder the burden themselves. This comes in direct conflict with our respect and integrity principles.

We also expect you to take up opportunities for learning and development, either on the job or via educational material or training. If you are unsure how you can achieve this, have an open discussion with your manager.

Also, take responsibility for your actions. We all make mistakes or need to make tough decisions and it’s important we own up to them. Failing to be accountable on a regular basis or in important situations (e.g. a crucial mistake in our financial records) will result in termination and severe civil and criminal penalties. If you take responsibility and come up with ways to fix your mistakes where possible, you will be in a far better position.

4 (8). Leadership and Teamwork

Working well with a team is a virtue, rather than an obligation. You will certainly, be a hardworking member, get to work autonomously and be focused on your own duties, projects and responsibilities but, you should also be ready to lead and collaborate with and help others.

Be generous with your expertise and knowledge. Be open to learning and evolving. If days go by without you consulting or brainstorming with anyone, you are missing out on opportunities for excellence. Instead, work with others and don’t hesitate to ask for help when you need it.

4 (9). No Insider Trading

Confidential, price-sensitive information may only be acted on or passed on if the transfer of information is necessary for legitimate business reasons. Anyone who has such information may not recommend or initiate transactions with –

  • respect to any securities or other financial instruments
  • the price of which may be affected by such information

Infrex India must be informed immediately if a member has reason to believe information is being or has been shared that violates insider trading regulations.

4 (10). Communication

All communications of Infrex India are required to be full, fair, accurate, timely, and understandable in written format only (Eg. Emails and letters).

The dissemination of information to the public concerning authority is to be handled by authorized spokespersons only.

If a member appears in public or takes part in public discussion in a manner, that he/she might be considered as representative of Infrex India without being authorized to do so, then he/she should make clear that he/she acts as a private person.

4 (11). Client Information and Advice

Members must not seek to mislead the market or clients in any manner. When working with a client, appropriate care shall be taken so that the client receives information that is necessary for a reasonable decision by the client.

This includes product information and advice given. Members shall not provide
advice and/or recommendations regarding products in which they are not appropriately licensed to sell.

4 (12). Complaints Management

Infrex India / NCERT Infrexa must deal with complaints from all clients or former clients, students, and other members promptly and fairly, and in accordance with applicable laws and regulations.

Members are required to cooperate with any requests for statements or documentation. To know more read our Grievance Policy

4 (13). Financial Reporting

We’re dedicated to providing accurate, timely, and understandable financial statements. This is required by all who are responsible for the company’s and/or its entity’s finance, control, and accounting functions (Financial Professional).

Each Financial Professional is subject to and dependent on its specific professional role within Infrex India and responsible for establishing and maintaining effective disclosure controls and procedures and internal controls and procedures for financial reporting.

4 (14). Acceptance of Gifts and other Benefits

The acceptance of gifts and entertainment by members (including their family members) may present a conflict of interest. While members are permitted to accept gifts of nominal value, they are prohibited from accepting anything that might influence their judgment on company matters affecting the donor or that might be accompanied by any express or implied understanding that the recipient is in any way obligated to take some action that would benefit the donor, to the detriment of the company, in exchange for the gift.

Similarly, members may accept entertainment, but only insofar as it is reasonable in the context of the business at hand and facilitates the company’s interests. When practical and appropriate, hospitality should be reciprocated members are strictly prohibited from soliciting gifts, gratuities, or business courtesies for the benefit of any family member or friend.

4 (15). Gratuities to Representatives of Public Institutions

Holders of public offices, representatives of public institutions, members of public services, or authorities and politicians are mandated with the pursuit of public welfare. They should therefore not receive gifts, invitations, or other gratuities which might put their independence from business interests into question.

Before making any payment, or giving anything of value, to such a government official, members should consult with the company’s General Counsel.

4 (16). Protection of Company Assets

Safeguarding the company’s assets is the primary responsibility of all members. Theft, carelessness, and waste have a direct impact on the company’s profitability.

Assets should be used efficiently and maintain such assets with care and respect, while guarding against waste and abuse.

Look for opportunities to improve performance while reducing costs. The use of company time, materials, assets, or facilities for purposes unrelated to the company’s business, or the removal or borrowing of company property, is prohibited, except where such use or removal is for purposes of supporting the occasional community service activity that has been endorsed by the company and where such use or removal has been approved by a competent authority on Infrex India.

For those purposes, the company’s assets include cash, inventory, equipment, computer software, computer data, vehicles, records or reports, non-public information, intellectual property, or other sensitive information or materials, as well as telephone, voicemail, or email communication.

4 (17). Prevention of Money Laundering and Illegal Activities

Infrex India or NCERT Infrexa is fully committed to the international fight against money laundering and the financing of terrorism and applies a risk-based, “know-your-client” policy in line with applicable laws and regulations.

Members must neither be engaged in nor tolerate any illegal activity in connection with Infrex India in their workplace.

This applies in particular to any infringement of anti-trust regulations and any support of tax evasion, including but not limited to, any kind of complicity in tax fraud.

4 (18). Protection of Members in Case of Communication about Illegal or Questionable Activities

If a member becomes aware of any illegal or questionable activity in NCERT Infrexa, he/she shall inform the Infrex India. No member who communicates bonafide a concern shall be exposed to retaliation based on this communication, even if the concern eventually proves to be unfounded. Such communications may be made anonymously.

5. Consequences of Non-Compliance on Code of Conduct and Ethics policy

Failure to comply can expose members and Infrexa / NCERT Infrexa to reputational as well as legal and regulatory sanctions. Disciplinary proceedings by a regulatory body in the case of severe compliance misconduct may result in a reprimand, fine, withdrawal, or suspension of authorization to conduct business either for the entire unit or members.

Therefore, it is the responsibility of each member of Infrex India to adhere with the rules and regulations, orders and administrative instructions of the government along with this Code of Conduct and Ethics. Our policies have been drafted in such a way to best align these Government instructions hence compliance with them is compulsory.

Additionally, any failure to comply with these policies, or failure to comply, which constitutes a breach of members contractual obligations, may result in severe disciplinary actions by Infrex India.

5. Ethical Conduct of Business

The goals of this Code (Code of Conduct and Ethics) can only be achieved with the contribution of all.

It is everyone’s personal responsibility to adhere to this Code of Conduct and Ethics Policy. All members are encouraged to contact their higher authority when detecting that someone has done something improperly. This can help to prevent small problems from leading to big problems.