This Policy applies worldwide to the Eastern Software Solutions Private Limited Ltd(ESS) and all its subsidiaries, Joint ventures and other business affiliates that are effectively controlled by ESS, directly or indirectly, (hereinafter collectively referred to as, “Company”) and to all Directors and Employees of the Company (hereinafter collectively referred to as, “Employees”). This policy is to ensure that the Company conducts its business in an ethical manner in all the countries in which the Company does business. The top management, ”Management” at the Company is committed to conducting its operations honestly and ethically and in compliance with all applicable laws. We have a “Zero Tolerance” approach to the practices of bribery and corruption. The Management and the Company are committed to work in a professional and fair manner in all its dealings.
This policy applies to the Company and the Employees and a strict adherence to this policy has to be ensured.
It’s the Company’s policy that all business be conducted at all times in strict compliance with all applicable laws and regulations of the countries and jurisdictions within which the Company conducts its business. The Employees are prohibited from
• Providing any kind of bribes/favour, directly or indirectly, for the purpose of soliciting business from Company’s existing Customers/Potential Customers;
• Providing bribes/favours, directly or indirectly, to any Government employee(s) for any kind of Government related work;
• Providing any bribes/favours, directly or indirectly, to any third parties like Banks, Trade associations etc for any kind of work;
• Accepting any kind of bribes/favours, directly or indirectly, from Company’s existing vendors/Potential vendors to promote their Products/Services in the Company ;
• Accepting any bribes/favours, directly or indirectly, from any third parties like Banks, Trade associations etc for any kind of work.
This policy is an integral part of the Company’s Business Code of Conduct. Employees must take necessary care to ensure compliance with the above as well as the necessary laws and regulations in each country that the Company operates in. It is the responsibility of all the Employees who deal with the Customers/Vendors/Government to be familiar and comply with the Policy. Failure to comply with this Policy will result in appropriate disciplinary action to the extent of termination or any other legal action depending upon the severity of the Violation.
The Company understands that there are differences between Hospitality and Bribery. The Company doesn’t stop Hospitality expenses as long can be justified that such expenses are made to improve relationships or promote Company’s products/services without seeking/providing any kind of favours. For the Hospitality, following are the broad guidelines :
• All Hospitality expenses must be approved and recorded properly in the Books of Accounts of the Company.
• The purpose of any such expense should not be to influence the decision making.
• Promotional gifts are allowed e.g. Gift Packs, Pens, Household items etc.
• Cash, Stocks, Family Trips funding etc are not allowed as a part of the Hospitality.
• Sponsorship for certain events is permitted with the approval of the Management only.
• In certain cultures, the individuals treat is as an insult if gifts are not given/taken. Hence in these cultures, the gifts can be given/taken. However in case the gifts are of high value then the concerned employee must report the same to the reporting manager.
Company’s Compliance Officer, “CO” is responsible for monitoring this Policy. The CO in collaboration with the Management will ensure implementation of the Policy. The CO together with the Management may identify the individuals in each Departments/Regions/Units who are responsible for such compliance. The CO in collaboration with the Management will do the necessary revisions to the Policy to comply with changes to applicable laws or bring in the best practices. The CO will take the necessary steps to communicate the changes to the Policy, as and when they happen, to the necessary employees. Any questions/doubts regarding the Policy should be addressed to the CO by the employees.
The Training Manager is responsible for conducting trainings from time to time on the policy for the employees with focus on
• What can be treated as Bribes/Favours/Influence and the Company’s policy on the same
• Implications of Bribery as an offence.
• Keeping a watch on Partners/Affiliates for suspected violations
• Encouraging employees for reporting suspected violations.
• Protection of employees who report suspected violations.
Complaints and Redressal : Employees should inform the CO of any suspected violations of this Policy. All such communication will be treated as confidential by the CO. The suspected violations may also reach the CO through a Third Party or any of the Audits. The CO will investigate the matter further and take the necessary action. There will be no retaliatory action against Employees for reporting such matters even if there is no violation found post the investigation. However the CO can take action against any such reporting where the CO sees a proven malintent by an employee. If any employee feels that there has been an unjust action against him/her as a result of such reporting, the employee can report such matter to the Head-HR. Similarly if any employee who has been found guilty of the non-compliance by the CO and the employee isn’t satisfied with the investigation, employee may report this to the Head-HR. In either case the Head-HR will take up the matter with the CO and the Management who may together review the matter and take the necessary action decided amongst themselves.
The complainant may send a communication through email or directly in writing through a letter to:
The Compliance Officer ESS
B-65, Sector 63, Noida, Uttar Pradesh -201301
E-mail ID : compliance@essindia.com.