THE WAY WE RISE

Name: _________________________

Signature: ______________________

Date: __________________________

Mahindra & Mahindra Limited © 2018

All rights reserved
CODE OF CONDUCT
THE WAY WE RISE
 A message from

Mr. Anand Mahindra

When our Company first went public, K. C. Mahindra set aside some shares for the Company’s
employees. When several employees wrote to thank him, he acknowledged their affection and
thanked them in a memo which stated, “It’s nice to have money, but it’s nicer to have the things
that money can’t buy.” So, from very early in our history, Mahindra has stood for many things that
money can’t buy. And the most important among the things that money can’t buy, is reputation.
It was not by coincidence that Forbes has listed us among the world’s 200 most reputed
companies. Reputation and good governance have been part of the DNA of the Company from
its inception. There are many times when we have chosen to be transparent, despite there being
no mandate on us. For example, our Company has been reporting back to its shareholders on
corporate governance, long before the law made it mandatory. There are many ways by which
we have institutionalised the highest benchmarks of corporate working and behaviours in our
processes. We have articulated a set of Core Values and Corporate Governance Policies that are
open for anybody to see and we have structures like the Corporate Governance Council firmly in
place to ensure that all governance issues are effectively and transparently addressed.
All this is not just airy fairy ‘feel good stuff’. It pays business dividends. Business partners trust
us, because we are clear on how we work and what we stand for. Foreign collaborators prefer us
because they know that our expertise is supported by ethics. Our shareholders know that this is a
Company that will always do the right thing and will never let them down. Our people feel a sense of
pride in working for Mahindra.
Corporate governance and values become even more important during periods of rapid growth of
the kind we are experiencing today. The more we grow, the more essential it is for each of us to be
the embodiment of ethics and good governance. Doing things is important – doing them the right
way is even more important.
This Code of Conduct sets out what all of us need to understand and do, to ensure the highest
standards of corporate behaviour. Please do study these principles, and more importantly, practise
them in word and deed. If each and every one of us see ourselves as a role model for good
governance, our Mahindra Group will continue to be rich in the things that money can’t buy.

Anand Mahindra,
Chairman & Managing Director
Mahindra & Mahindra Limited
 A picture is worth a thousand words

On the evening of 16 December 1997, a small group of people gathered in Anand Mahindra’s
office. Two of them had spent almost a year researching and creating Core Values and a Core
Purpose statement; and the next morning, these ideas were to be shared with the senior
management of the organisation. They talked and debated but could not come up with a simple and
satisfactory way of communicating what these very important ideas meant.
One of the team members went home that evening and spoke to his ten year old granddaughter
about his vision. She took out her crayons and got down to work. And this was the picture drawn
by that little girl, which Anand Mahindra presented to the top management the next morning. It
simply and succinctly captures the meaning of our Core Values and Core Purpose.
The 5 points of the star represent the 5 Core Values. The star lights the path below, showing the
road you must take, and equally important – the boundaries beyond which you may not venture.
The milestones on the path are the goals that businesses set for themselves. The milestones
change and as one goal is achieved, another goal is set; as the path gets steeper, achieving the
milestones require more effort. And beyond the mountains is the rainbow that is the Core Purpose,
the reason why we come to work in the morning, which beckons us ever onwards and upwards.
This is the Mahindra Group Core Values and Core Purpose picture – drawn by a ten year old child,
and now a part of our history.
Our Core Purpose: We will challenge conventional thinking and innovatively use all our resources to
drive positive change in the lives of our stakeholders and communities across the world, to enable
them to Rise.
Values are our core beliefs since our inception
Our first advertisement in the Times of India dated 8 November 1945, explained in detail to the public the
principles that the new Company stood for. As the advertisement says, the support of the public is important
to the Company, so the public should know the principles that inspire the Company. This was long before it was
necessary to disclose anything, long before we went public. Ever since then, a strong belief in transparency and
values has been a part of our working. It arises out of a concern for our stakeholders, and a desire to do the
right thing.
Many things have changed in the Mahindra Group over the years; but this advertisement clearly
demonstrates what has not changed.
It reflects many of the principles that we later articulated as our Core Values:
• Professionalism - “ability is the sole test of merit and advancement”
• Good Corporate Citizenship - “anxiety to further the industrial and agricultural development of the country”
• Ethics - “belief in the ability of corporate institutions to oppose antisocial trends” and above all
• Fairness and Dignity of the Individual - “in cooperative working lies the dignity of human toil” and “ability is the
sole test of merit and advancement and neither colour, creed nor caste should stand in the way of harmonious
working”
It is good to know that even today, almost 70 years later, the ideals of our founders shine brightly, and the
DNA of our Company has not changed.

CORE PURPOSE
We will challenge conventional thinking and innovatively use all
our resources to drive positive change in the lives of our stakeholders and
communities across the world, to enable them to Rise.

BRAND PILLARS

ACCEPTING ALTERNATIVE DRIVING POSITIVE

NO LIMITS THINKING CHANGE
We will think big and look beyond We will apply alternative thinking We will deeply understand the
conventional boundaries. We will and new approaches in our needs of our customers and offer
encourage our people to be everyday work-life. We will seek out them quality products and services
adaptable and agile, benchmark fresh, diverse perspectives and that will not only delight them, but
beyond global best in class, and reward those who deliver improve and transform their lives.
take well-reasoned risks to deliver alternative thinking. We will direct We will put our customers at the
breakthrough products, services our intellect towards customer - centre of our business and build
and solutions for our customers. focused innovation and will use our strong relationships with them.
ingenuity to add value to our We will act with the highest stand-
stakeholders. ards of integrity. We will strive to
bring about positive change in our
own lives, and enable our custom-
ers and communities to Rise.

CORE VALUES

Professionalism | Good Corporate Citizenship

Customer First | Quality Focus | Dignity of the Individual

House of Mahindra
THE TIMES OF INDIA
8 November 1945

MAHINDRA & MOHAMMED

A significant combination, which represents what might well be termed a co-operative effort to
secure for India that industrial development so indispensable to the full realisation of her future
dreams.
You have heard of plans, many plans, in this connection. Now comes a positive, concrete and co-
ordinated scheme to develop India’s resources and raise the standard of living of the masses.
Devised by an Indian business man after a careful three-year study of American wartime
achievements, it has secured the support and ready assistance of a group of business men with long
experience and a firm faith in their country’s destiny.
In their anxiety to further the industrial and agricultural development of this country, the founders of
this co - operative organisation believe that they must have the support of those who will benefit most
- the general public - and to secure that support it is essential that their aims and objects should be
generally acceptable.
Here, then, are the principles which will guide their future activities -
FIRSTLY, encouragement of private enterprise and the initiative of the individual.
SECONDLY, belief in the ability of corporate institutions to oppose anti-social trends, such as
monopolies and cartels.
THIRDLY, recognition of the fact that the labourer is worthy of his hire and that in co-operative
working lies the dignity of human soil.
FOURTHLY, confidence in the ultimate success of their ventures and in the capacity and aptitude of
the people to give effect to them.
FIFTHLY, acceptance of the fact that ability is the sole test of merit and advancement and that
neither colour, creed nor caste should stand in the way of harmonious working.
What, you will have asked yourself, does MAHINDRA & MOHAMMED propose to do, whom do they
represent, and what has all his business moralising got to do with me?
Well, MAHINDRA & MOHAMMED are concerned with what might be termed basic engineering
- providing the foots with which to finish the job of India’s industrial and agricultural rehabilitation.
That rehabilitation, of course, has a great deal to do with you - for it holds out the promise of a better
land for you to live in and a healthier and happier life for you to enjoy.
As to the moralising, it is intended to place on record that MAHINDRA & MOHAMMED, though a
business firm, are imbued with a national purpose and a new outlook.
When do they represent? As the name implies, this is a joint venture of Hindus and Muslims. The
Chairman is Mr. K. C. Mahindra, who has just returned after three years abroad as Head of the
Government of India Supply Mission in America.
 01.
Rationale for the
Code of Conduct

Trust is fundamental to What is the Code of Conduct?

The Code of Conduct is our central policy document, outlining
everything we do. the requirements that every single person working for and
with the Company must comply with, regardless of location.
Working by the Mahindra philosophy means we must We may also have additional policies that we need to adhere
always act with integrity to ensure that we are trusted to which are specific to role or location.
by our customers, colleagues, business partners, and the
communities in which we operate. Our Code of Conduct sets To whom does the Code of Conduct apply?
out what we expect from every single person working for and
The Code is for everybody working for or on behalf of the
with the Mahindra & Mahindra Limited (‘Company’ or
Company. We expect everyone who represents the Company
‘Mahindra’). It also underlines our responsibilities to our
to uphold the same standards and to abide by our Code and
people, partners, and shareholders. The Code of Conduct
policies. In addition, individual business units issue policies
(‘Code’) helps us make informed decisions and tells us where
that provide more specific guidance about certain business
to go for more information.
practices. If we need help finding or understanding a policy, or
in case we need any clarification or guidance on the Code, we
should speak to the Chief Ethics Officer.

The Company What does this mean for us?

Philosophy The Company expects us to:
• Behave in an ethical manner, taking pride in our actions
The Company philosophy sets out our Core Values in terms and decisions.
of how we work, so we can be admired by our customers, • Comply with the principles and rules in our Code, and fulfil
shareholders, the people we work with, and the communities our legal and regulatory obligations.
we work within. • Seek guidance wherever required if we feel a working
practice is not ethical or safe.
• Report non-compliance or breach of our Code
immediately.
Our Values
Professionalism Good corporate Customer first Quality focus Dignity of the
citizenship individual
We have always We exist and Quality is the key
sought the best As in the past, we prosper only to delivering value We will value individual
people for the job will continue to seek because of the for money to our dignity, uphold the
and given them long-term success, customer. We will customers. We right to express
the freedom and which is in alignment respond to the will make quality disagreement, and
the opportunity with the needs changing needs and a driving force in respect the time
to grow. We will of the countries expectations of our our work, in our and effort of others.
continue to do so. we serve. We will customers speedily, products, and in our Through our actions,
We will support do this without courteously, and interactions with we will nurture
innovation and well- compromising on effectively. others. We will do it fairness, trust, and
reasoned risk taking, our ethical business ‘First Time Right.’ transparency.
but will demand standards.
performance.

01 Initials: ______________________
 02.
Ethics decision tree

The ethics decision tree is a simple but powerful tool would be if they either became public, or were reviewed by
designed to make sure we appropriately assess the our colleagues. If we are uncomfortable with the answer, we
soundness and impact of our business decisions. We should should not do it. The following are the questions we should
ask ourselves what the impact of our conduct or actions ask ourselves before taking any decision to act:

Not Sure? No
Contact the Chief Ethics The action may have serious
Is it legal?
Officer consequences.
Do not do it.

YES

Not Sure? No
Contact the Chief Ethics Does it comply The action may have serious
Officer with our policies? consequences.
Do not do it.

YES

Not Sure? No
Does it comply The action may have serious
Contact the Chief Ethics with our values
Officer and culture? consequences.
Do not do it.

YES

The decision to move forward

seems appropriate

02
Initials: ______________________
03. Code of Conduct
Gifts and entertainment

We do not permit acceptance or offering of gifts (refer The underlying principal under the CoC is ‘no gifts’.
Appendix 1, Glossary 6 for definition) from past, current, However practical exceptions can be considered.
or prospective customers, suppliers, distributors, dealers,
consultants or fellow employees of the company (except Permitted deviations and processes to be followed are
on the occasion of a marriage – from fellow employees; being indicated through the Gift Policy which should be
or upon retirement). We may accept an invitation to a read in conjunction with this clause.
meal, entertainment or a sports event which is within the
scope of social formality and not excessively extravagant,
expensive or frequent. Such invitations should ideally be
pre-cleared by the Line Manager (who should ensure that
such an invitation meets the above criteria, and is unlikely
to create a Conflict of Interest). Acceptance of such
invitations by an employee (or his or her relatives [defined
in Appendix 1, Glossary 3]) or attendance at any such
event, should be reported on the Ethics and Governance
Portal (under the Gift Reporting tab).

A detailed policy on ‘Gifts and entertainment’ is

listed on the intranet.

Q. Dhiraj, a Manager in the Finance department, received a gift voucher from a vendor on the occasion of his
wedding. The voucher is convertible into cash. What should Dhiraj do?

A. As per our Code, an employee cannot accept a gift voucher from a vendor. Hence, he should return the gift
voucher to the supplier as soon as possible.

05 Initials: ______________________
Q. Kim, a Manager who is involved in selection of ‘direct selling agents’ was offered a ticket for a cricket match
(Market value: INR 40,000) from one of the agents as a gift. Kim refused the gift promptly considering the high
market value. The agent persisted with the gift by saying that his brother was entitled to tickets for family and
friends free of cost and hence the ticket had not cost him anything. Kim accepted the gift. Is Kim right in doing so?

A. Kim should not accept the offer as this invitation seems to be excessively expensive. In case he does decide to
accept the offer, he should obtain his Line Manager’s pre-approval, and report the same on the Gifts reporting tab
of the Ethics and Governance Portal.

Q. Kiran, a Procurement manager on official duty is offered a taxi by a supplier, to visit the supplier’s office in Morocco
as a gesture of hospitality. Will this be considered as ‘gift and entertainment’?

A.
No, as per the Code, routine business courtesies offered as a gesture of hospitality may not be considered as ‘gift
and entertainment’. However, Kiran should ensure that the hospitality does not lead to any obligation or favor. This
acceptance of hospitality should be reported on the Ethics and Governance Portal under the Gifts reporting tab.

Q. James, a supplier relationship manager, has been invited to attend a supplier conference (all expenses paid) in
London. Is this acceptable? James wants to extend his stay by 3 days and call his spouse to plan a vacation
around London. What should James do?

A.
James can attend the supplier conference. However, he should not allow the supplier to pay for his ticket,
hotel accommodation etc. Yes, James can call his spouse and plan a vacation provided all expenses related to
the extended stay, for him as well as for his spouse, are borne by him. James’ spouse should however not be
permitted to participate in the Conference events.

06
Initials: ______________________
 03b.
Commitment to business
associates, suppliers,
customers, and
environment

“ The goal as a Company is to have customer service that is not just the best but
legendary.

Ensuring product quality

Sam Walton, Businessman and Entrepreneur

Responsible marketing
“
We compete vigorously and effectively with fairness and
honesty of purpose. Honesty is our guiding principle in all our
sales, marketing, and advertising pursuits. We ensure that
only complete, factual, and truthful statements about the
Company and its products and services are made in all our
advertising or marketing campaigns.

Quality is our most valued asset and it remains at the core of Commitment to our customers
our business policy. We seek to satisfy our customers’ high We must treat our customers ethically, fairly, and in
quality and safety standards, despite the ever-increasing compliance with all applicable laws, and earn our business
complexity of products and systems. on the basis of superior products, customer service, and
competitive pricing. We do not enter into any kind of unfair
A detailed policy on ‘Quality’ is listed on the or deceptive trade practices to win any deal or customer.
intranet. Customer complaints and concerns should be attended to
the fullest satisfaction of the customer.

A detailed policy on ‘Dealings with Dealers and

Customers’ is listed on the intranet.

Q. Jessica (quality in-charge) recently conducted a quality check on a vehicle and observed non-compliance of safety
norms with the car that is about to be launched. Her reporting of the same would have caused significant delay of
the launching of the product and caused significant loss of profit to the Company. Jessica decided not to report
the same in the interest of the Company. Is this a violation of the Code?

A. Yes, Jessica violated the Code and will be subject to disciplinary action. Jessica’s job is to reject when called
for, and report any kind of quality issue to her Line Manager irrespective of it being a rare exception or not. Any
product safety or quality issue is very important regardless of how small the matter may appear and the impact
it might have on the Company. By not reporting such an issue she will show a sense of misplaced loyalty. Such
issues should be reported and resolved.

07 Initials: ______________________
Commitment to our suppliers and Antitrust and competition law
business associates • We seek to compete fairly, ethically, and within the
framework of all applicable competition laws. Anti-
• Just as the Company competes fairly, we should make competitive practices can damage the business and
sure that all our decisions are based solely on the ability reputation of the Company.
to add value to the Company’s products or services, or
help fulfil the strategic growth plans of the Company. • The competition laws protect competition by prohibiting
anti-competitive behaviour. This behaviour may include:
• Only such persons shall be selected to be our business
partners where there is a match in the business partners’ –– Entering into anti-competitive agreements with
Code of conduct of business, Core Values, and other competitors, including price-fixing, bid-rigging, market
business principles as well as processes, with that of the allocation and agreements to restrict supply.
Company. –– Exchanging sensitive information (refer glossary 7 for
• We select goods and services that best contribute to the definition) with competitors.
long-term well-being of the Company. • We should not seek information about competitors using
• We choose our suppliers based on competitive price, theft, deception, misrepresentation, or any other illegal or
quality, delivery, service, reputation, environmental, and unethical means.
business practices. We also expect our suppliers to
support our core labour standards and abide by all
applicable local and international laws.
• We treat our suppliers and subcontractors with fairness
and integrity. We respect the terms and conditions of our
agreements with suppliers and honour our commitments.

A detailed policy on ‘Dealings with Suppliers

and Vendors of Products and Services’ is

Q. Mallik (Procurement head of Farm division) is approached by a vendor who is ready to extend special discounts to
the Company to get empanelled as a listed vendor. Market study reveals that the vendor had significant number of
children working as labourers, which is against the labour law of the country. Should Mallik award the contract to
the vendor and make profit for the Company?

A.
We choose our suppliers based on price, quality, delivery, service, reputation, environmental and business
practices. We also expect our suppliers to support our core labour standards and abide by all applicable local and
international laws. Considering this, Mallik should not award the contract to the vendor.

Q. Rakshita, who works with the R&D team, recently hired an employee who previously worked for one of the
Company’s competitors. Can Rakshita ask the employee for non-public confidential information about this
competitor which will give the Company a competitive edge?

A. Every employee has an ethical and legal responsibility to keep their previous employer’s non-public information
confidential. By asking the newly hired employee to reveal information that violates his/her professional integrity,
Rakshita will be placing the new employee and the Company in an embarrassing position. Such behaviour is
inconsistent with the Company’s values and is a violation of the Code.

08
Initials: ______________________
 Commitment
to the
Our policy is that environment We are committed to work for
the upliftment and betterment
operations, products
of the communities we
and services, while
operate in. We consider the
meeting regulatory
impact on biodiversity in our
requirements should
business activities. Our CSR
also accomplish their The technology used programmes use responsible
functions in a manner in the manufacturing business practices and social
that protects health and of our products shall investments to create long-
the environment. not result in effluents term value.
or toxic waste being
released unless it is
treated in accordance
with the prevalent
pollution control
laws. Every possible
effort shall be made
by us to maintain the
ecological balance,
conserve scarce
natural resources,
and avoid pollution.
A detailed policy on ‘Environment and
Pollution’ is listed on the intranet.

Q. Vivek, an employee who is a machine operator at the Kandivali plant, has observed that the effluent treatment
norms are not monitored properly, which poses a health hazard to labourers and nearby surroundings. Vivek is
not sure whether or not he should report such matter.

A.
The technology used in the manufacture of our products shall not result in effluents or toxic waste being
released unless treated in accordance with the prevalent pollution control laws. Vivek is responsible for reporting
environmental hazards or other unsafe working conditions to the Chief Ethics Officer as this is a serious violation
of the Code.
09 Initials: ______________________
 03c.
Commitment to
stakeholders

“ The golden rule for every business man is this: Put yourself in your customer’s
place.

Compliance with the law

Orison Swett Marden, Inspirational Author
“
• We should always ensure that we are conducting
business with reputable customers, for legitimate
business purposes, with legitimate funds in compliance
with anti-money laundering principles.
• The Company transfers goods, services and technologies
across national borders, and hence our business
transactions are subject to various trade controls
and laws that regulate export and import. We should
always comply with these laws. Where there is a conflict
between the local and international law, we should always
• We are expected to conduct business as responsible
apply the local law.
corporate citizens, and follow the applicable legal
framework of the country in which we operate in spirit • Violations of applicable government laws, rules, and
and by letter of the law. All of us are expected to know regulations may subject us to individual criminal or
and understand the legal obligations that apply while civil liability. Such individual violations may also subject
executing our duties and responsibilities on the job. the Company to civil or criminal liability, or the loss of
Ignorance cannot be an excuse for violation of law. Where reputation or business, and both these events may
any provision of the Code conflicts or is inconsistent with attract disciplinary action by the Company.
applicable law, the provisions of that law must be complied
with and would override this Code.

10
Initials: ______________________
Books, records, and public
disclosures

• We must ensure that the Company’s accounting and

financial records meet the highest standards of accuracy
Insider trading and corporate
and completeness. We should record and report all
financial and non-financial transactions and information
confidentiality
honestly, accurately, and objectively for stakeholders’ • There are provisions governing Insider Trading which
(refer glossary 8 for definition) perusal. include Securities and Exchange Board of India
(Prohibition of Insider Trading) Regulations, 2015 and
• The records must be managed securely throughout their Code of Conduct for Prevention of Insider Trading
life cycle in line with their importance to the Company and in Securities of Mahindra & Mahindra Limited. It is
in compliance with legal, tax, regulatory, accounting, and incumbent upon every employee to comply with the
business retention requirements. same. Any non-compliance thereof should be reported
• If we have a reason to believe that any of the Company’s to the Compliance Officer under the Insider Trading
books, records, or disclosures are inaccurate, irregular, Regulations.
or misleading, we should immediately report to the Chief
Financial Officer and the Chief Ethics Officer, citing the Assist in audit and investigation
nature of such an issue.
• During our employment with the Company, we may be
• Those authorised to make disclosures of the Company’s asked to participate in an audit or internal investigation
information must ensure that information provided to conducted by the Company’s external auditors or
the public is true, accurate, and complete. No disclosure other audit agencies. We should cooperate fully and
should be misleading. communicate honestly when participating in such efforts.
• We may also receive a request for documents or a
request to meet with regulators or lawyers in connection
with a legal proceeding or government investigation. If we
receive such a request, we should immediately contact
the Line Manager and the Company’s Legal department
for information and guidance.

A detailed policy on ‘Insider Trading’ is

listed on the intranet.

Q. Richa’s (a management trainee) reporting manager has asked her to record an unconfirmed sale in the quarterly
report to meet the target and is offered an out of turn promotion to do the same. Should Richa record this sale?

A.
No, it is important to record all the costs and revenues in the correct time period. Reporting a sale that is not yet
complete could be misrepresentation of financial statements. Richa should decline to accept her manager’s offer
and also report this to the Chief Financial Officer and the Chief Ethics Officer immediately.

11 Initials: ______________________
 –– Take adequate precaution to ensure that we are
Fraud and misconduct not disclosing any confidential information about the
• Any fraudulent (refer glossary 10 for definition) Company; and
behaviour, misrepresentation or misconduct is liable to
–– Refrain from using any Company or third party logos
be investigated and the employee(s) concerned is liable
or trademarks without express permission of the Chief
to face appropriate disciplinary and/or legal action. Acts
Ethics Officer.
of commission or omission which are detrimental to the
business of the Company i.e. bribery, fraud, pilferage,
theft, unrecorded sales or purchase, partial recording of
income, etc. are termed as misconduct.
Investor relations
• We are all responsible for reporting fraud, falsification,
and manipulation of data and information. • The Company recognises the rights of its investors to
information and it shall always be sensitive to this need.
The relevant information will be speedily disseminated and
shall be as informative as it is required to be, subject to
External communication considerations of confidentiality and applicable legislation.
We should respect the rights of investors to express their
• If we are contacted and requested to discuss Company views during investor meets, including General Meetings
business with any member of the press, investors, of the Company, on matters forming part of the agenda
market analysts, or any other outside parties, we should and on the performance of the Company. We should
refrain from doing so and instead, refer the request respond to their observations and queries to the best
to the designated spokesperson. For further guidance extent possible.
on such external communications, contact the Group
• No information shall be made available on a selective
Communications Department.
basis to specified groups of investors in a manner that
• Our communication about our competitors and their places them at an advantage over other groups of
products should be correct and accurate and should in no investors. We shall always respond speedily and with
way be influenced by rumours. courtesy to the Company’s investors on matters relating
to securities held by them in the Company. Any concern
• Similarly, when using social media, we should not speak on
or violation should be reported to the Chief Ethics Officer
behalf of the Company. We should always:
immediately.
–– S
tate that the materials and opinions that we are
posting are our personal views and not those of the
Company; Detailed policies on ‘Investor Relations’
and ‘Investor Grievances’ are listed on
the intranet.
A detailed policy on ‘Group Communications’
is listed on the intranet.

Q. Rahul recently identified that his procurement manager has been fraudulently awarding contracts to his preferred
vendors in return for kickbacks. When he confronted him about this, he threatened him with ‘bad consequences’.
What should Rahul do?

A.
Rahul should immediately report this matter to the Chief Ethics Officer without any fear or hesitation. The
Company management will ensure that he is not a victim of retaliation. The Code clearly states that any type of
retaliation or bullying will not be tolerated and will invite disciplinary action.

Q. Ravi, an employee of the Automotive and Farm Division, was in possession of the design of the Company’s next car
which he wanted to discuss with his friends on Facebook. He posted pictures of the car on his personal account
and invited comments from his friends. This model was not yet disclosed in the public domain and was known to
only select employees of the Company. Has Ravi violated the Code?

A.
Yes, Ravi has violated the Code. Employees are expected to maintain strict norms for social networking sites
even for their personal accounts especially, if it involves any topic related to the Company’s confidential business
information. No employee should reveal any information that is confidential or sensitive in nature, and should
always remain professional in their communications.

12
Initials: ______________________
 03d.
Behaviour at the
workplace

“ Try not to become a man of success. Rather become a man of value.

Equal employment opportunity and

Albert Einstein, Physicist and Philosopher of Science
“
respecting diversity and human
rights
• We take pride in saying that we provide equal opportunity • We respect employees’ right to freedom of speech and
and inclusion for all employees through our employment provide safe and humane working conditions.
policies and practices. We recognise that a mix of
• We strictly prohibit forced labour and child labour.
backgrounds, opinions, and talents enriches the
organisation and helps us achieve success. • We respect the individual and create a culture of trust
and respect that promotes a positive work environment.
• We celebrate the importance of diversity in our
workplaces and hence, we strive to be as diverse as the • We never discriminate or treat employees or job
customers we serve. applicants unfairly and are committed to provide equal
opportunity in employment. No decisions should be made
• We recognise the importance of maintaining and
on the basis of gender, race, colour, nationality, ancestry,
promoting fundamental human rights in all our operations.
religion, physical or mental disability, medical condition,
We provide fair and equitable wages, benefits, and other
sexual orientation, or marital status.
conditions of employment.

Detailed policies on ‘Employee Relations’,

‘Human Resources’, and ‘Human
Rights in Economic Decision Making
Process’ are listed on the intranet.

Q. Aamir is required to shortlist candidates for an interview for a vacancy in his department which involves a lot of
travel. Is it okay if he rejects candidates who are single parents as they are not an ideal fit for the said job profile?

A. Aamir is obliged to interview all candidates whose qualifications meet the requirements of the job, and hire the
most deserving candidate irrespective of whether he/she is a single parent as long as the requirement of the job
is clearly explained to the candidate. Discriminating between candidates for reasons like this violates the Code. At
the same time the Company may even lose a talented candidate because of personal bias or prejudice.

13 Initials: ______________________
Conduct at the workplace Freedom from harassment

• We should ensure that our behaviour with our • “Harassment” is behaviour that creates an offensive,
fellow colleagues does not give an unprofessional intimidating, humiliating, or hostile work environment.
impression about us at the workplace. Touching others Harassment may be physical or verbal, and may be
inappropriately or in a way that can be regarded as done in person or by other means (such as harassing
vulgar should be avoided. We should always be humble, messages or emails). Examples of such harassment
courteous, and behave in a decent and professional way. include unwelcome sexual advances or remarks, offensive
jokes and disparaging comments, sexually explicit
• We are expected to be properly groomed and neatly
graphics, pictures, videos, animation, etc. It is important
dressed while at work, both when inside or outside the
to remember that harassment, sexual or otherwise, is
office premises.
determined by our actions and how they impact others,
• The Company does not encourage insinuations, half-truths, regardless of our intentions.
rumours and gossip, all of which attack the self-respect of
• The Company sets a standard of ‘zero tolerance’ for
the individual and/or attempt to divide the employees into
harassment. We are all responsible for ensuring that we
groups.
avoid actions or behaviour that are, or could be, viewed as
harassment.
• We view all incidents of ‘sexual harassment’ very seriously
and encourage each employee to report any incidents of
sexual harassment to the Internal Complaints Committee.
The Company management may initiate strict disciplinary
action against any employee found guilty of any kind of
sexual harassment.

A detailed policy on ‘Sexual Harassment’ is

listed on the intranet.

Q.
Tina’s (junior executive) manager made a comment on her dress that made her feel uncomfortable and
embarrassed in front of her other colleagues. Being a junior employee in the organisation she could not object in
front of her superiors. What should she do?

A.
Tina is entitled to work in an environment free from intimidation, hostile, or offensive behaviour. If she is
uncomfortable with any comment made by anybody in the organisation, then she is entitled to report the same to
the Human Resource representative of her function and the same will be investigated keeping the identity of the
complainant confidential. Appropriate action will be taken against her manager if the behaviour is proved to be a
sexual harassment.

14
Initials: ______________________
Ensuring health and safety Adhering to anti-violence guidelines
• We value each individual as an important asset of the • With respect to the Company’s commitment to providing
organisation and are committed to high standards of a safe work environment, we never engage in or tolerate
safety and protection. any form of violence or bullying irrespective of the
designation of the employee involved. We want to foster
• Each one of us has the responsibility to follow the
the kind of environment where people feel safe and are
Company’s safety and security procedures, as well as
treated with respect and professionalism at all times.
applicable laws and regulations at all times. We should
intervene and report immediately, if health and safety is • We are prohibited from engaging in any act on Company
compromised. premises that could cause another individual to feel
threatened or unsafe. This includes verbal assaults,
• We own and operate facilities with the necessary permits,
threats, or any expression of hostility, intimidation,
approvals, and controls that are designed to protect
aggression, or ragging. We are also prohibited from
health, safety, and the environment. Our contractors and
possessing weapons at our workplace.
other third parties are expected to commit to the same
levels of health and safety protection.

Drugs and alcohol

• We are not permitted to use, possess, sell, transfer,
manufacture, distribute, or be under the influence of illegal
drugs or alcohol on Company workplace premises, while
at work during working or non-working hours. In addition,
we should not report to work while under the influence
of, or impaired by, alcohol or illegal drugs or substances.
Alcohol use at Company sponsored official lunch/dinner
events with business partners is allowed only with the
approval of the Line Manager.

A detailed policy on ‘Safety and Occupational Health’

is listed on the intranet

Q. One of Bharat’s colleagues regularly arrives at work under the influence of alcohol. Bharat knows that he is
undergoing mental trauma in his personal life but by working under such the influence of alcohol, he can pose a
risk to himself as well as his co-workers. What should Bharat do?

A.
The use of alcohol is likely to be affecting the colleague’s well-being and the quality of his work. It is obligatory on
Bharat’s part to report the same to the Chief Ethics Officer who will deal with this matter sensitively.

15 Initials: ______________________
 03e.
Protection of assets
and information
management

“ Information technology (IT) assets must be protected from external and internal
activities detrimental to effective and efficient functionality.

Protection and responsible use

Robert E. Davis, Information Technology Author
“
of corporate assets and
information technology
• Everyone at the Company is personally responsible for • Company assets must be used only for business
safeguarding, securing, and protecting the Company’s purposes and to advance our strategic objectives. We
assets and information technology from theft, destruction, are allowed occasional personal use of Company assets
misappropriation, wastage and abuse. Our assets include and information technology, as long as it does not
property, time, proprietary information, corporate compromise Company’s interests, adversely affect our job
opportunities, Company funds, and Company equipment. performance or result in undue abuse of the Company’s
resources.

Detailed policies on ‘E-Business Security’,

Intranet’, and ‘Internet Usage’ are listed on
the intranet

Q.
Sheeba (an executive working with the Legal department) sometimes uses her Company provided data card to
access the internet for downloading high volumes of movies and songs. Is it okay to use the data card for such
personal use?

A.
We are allowed occasional personal use of Company assets and information technology as long as it does not
compromise Company’s interests, adversely affect our job performance, or result in an undue abuse of the
Company’s resources. Using the Company provided data card for downloading high volume movies and songs will
be considered as abuse of Company resources and hence a violation of the Code.

16
Initials: ______________________
Protect confidential information of processes and techniques
–– Software, risk models, tools, and other systems or
the Company, its employees, and its technology developments
business associates –– Names, contact addresses, email addresses,
government IDs, credit cards, bank account details,
photos, videos, or any combination of that information
belonging to customers, vendors, and/or employees.
• We should disclose confidential information only to:
–– Fellow Company employees or third parties who have
a legitimate clearance, on a ‘need-to-know basis’
–– Those who have a clear duty or obligation to keep the
information confidential
• During the course of work, we may have access to
–– Those who have a legal obligation to disclose this
confidential information about the Company. ‘Confidential
information as required.
Information’ is generally non-public and/or personally
identifiable information (refer glossary 11 for definition)
that employees may be aware of as a result of their
position with the Company and that might be of use to
competitors or harmful to the Company if disclosed.
Intellectual property and
Common examples include: trademarks
–– Customer lists We must respect the intellectual property (IP) (refer
glossary 12 for definition) belonging to third parties, and
–– Financial or non-financial information known as a result
may never knowingly infringe upon the IP rights of others.
of one’s position with the Company
We should be cautious when preparing advertising
–– Terms, discount rates, or fees offered to particular or promotional materials, using the name or printed
customers or suppliers materials of any other Company. When using a licensed
software, only a software which is adequately licensed by
–– Marketing or strategic plans
the publisher should be used on Company computers or to
–– Trade secrets, including manufacturing and marketing perform Company work.

A detailed policy on ‘Trade Marks’ is listed

on the intranet.

Q. A former Company employee and ex-boss of Vivaan (Executive in Finance department), has requested Vivaan
to extract certain confidential Company reports on which they worked together. Vivaan also discovered that his
ex-boss is being favoured by his other colleagues in the Finance department, for similar requests. What should
Vivaan do?

A. Under no circumstances should Vivaan give the former employee the information he has asked for, which may be
confidential. Vivaan should also pro-actively stop his peers from violating the Company’s Code by sharing Company
confidential information with a former employee. Vivaan is also obliged to report this to the Chief Ethics Officer
immediately and appropriate action needed to protect the Company’s information in this case will be taken by the
Chief Ethics Officer.

17 Initials: ______________________
 04.
Administering our Code
and reporting violations

–– Inform the employee of accusations reported against

Issuance of and amendments to him/her at a time when such a disclosure will not
our Code jeopardise the investigation, typically when the
information is complete and clarification need to be
• The Board of Directors of the Company has set up the
sought from employee;
Corporate Governance (CG) Cell reporting to the Board
of Directors, which will oversee the implementation of –– Where permissible, allow employees to review and
the Code, policies, and their compliance. It is also the rectify the information reported.
responsibility of the CG Cell to review the efficacy of
these policies and suggest amendments to make them
relevant to changing times. The CG Cell is responsible for
monitoring compliances with the provisions of this Code. Obligations of Line Managers and
Systems and policies should be clear and transparent,
and shall be documented in manuals that serve as a
others receiving reports of potential
valuable tool for learning and governance. The Corporate Code violations
Governance Cell shall review the provisions of the Code
Line Managers and others who receive reports of potential
from time to time and suggest such amendments
Code violations play a very important role in upholding
as it considers necessary, to be relevant in changing
the Code. Our Company encourages us to talk to the Line
circumstances.
Managers about our concerns. Line Managers and members
• In case of any clarification, consultation, or any discussion should:
required on any matters relating to the Code, we are
• Make sure that they comprehend the Code, and ensure
encouraged to approach the Chief Ethics Officer for the
their behaviour is consistent with the Code
same.
• Let team members know that they are available to discuss
and support them in their concerns

Investigation of reported Code • Act to stop violations of the Code or the law by any team
member
violations • Raise all concerns to the appropriate level and function
• The Company takes all reports of potential violations
• Never let team members feel that their concerns are
seriously and is committed to confidentiality and a full
being ignored
investigation of all allegations by designated teams.
• Ensure that no retaliation occurs against someone for
• We are obliged to co-operate in internal investigations
reporting a suspected violation of the Code
and failure to do so may result in disciplinary actions.
• The Company strives to:
–– Protect confidentiality of individuals involved, to the
extent practical;

18
Initials: ______________________
Reporting violations • The disciplinary action will be decided depending upon the
facts of the case and may include penalties, suspension,
The Board of Directors of the Company and the CG Cell or even termination of employment. In addition, if deemed
will be responsible for ensuring that these principles are necessary by the management, appropriate regulatory
properly communicated and understood by all to whom these authorities will be informed and involved as required and
are addressed. The Company promotes open and honest criminal or civil legal action may be initiated.
communication. If we become aware of a breach or potential
breach of our Code or of other legal requirements, we must
report, whether it relates to us, our manager, or anybody else.
• We should seek guidance from the Chief Ethics Officer Signature and acknowledgement
for any matter relating to the Code. Any violation of the All new and existing employees must sign an
Code should be reported either to the Chief Ethics Officer, acknowledgement form on a periodic basis, confirming that
Human Resource Representative of the function, Line they have read the Code and agree to abide by its provisions.
Manager of the function or Board of Directors as laid Failure to read the Code or sign the acknowledgement form
down in the Approval Matrix as appended on page number does not excuse an employee from compliance with the Code.
22 of this Code. In addition to the above, a detailed
Whistle Blower Policy is available on the intranet and may
be invoked if required. Some examples of these issues
include: Waivers
–– Accounting or auditing irregularities or Waiver of any provision of this Code, for officers of the
misrepresentations Company, must be approved by the Chief Ethics Officer.
–– Fraud, theft, bribery, and other corrupt business
practices
–– Antitrust or insider trading violations Non-retaliation
–– Significant environmental, safety, or product quality The Company does not tolerate any form of retaliation
issues against any person who reports a suspected violation in good
–– Illegal discrimination or harassment faith. In addition, no one who participates or cooperates
honestly and completely in our Company’s investigation
–– Actual or potential conflicts of interest will be subjected to retaliation for doing so. Anyone who
–– Guidance on any national, regional, tribal, state retaliates against a person for making a good faith report or
or municipal legal requirements that apply to the for participating in the investigation of a report, as described
Company or to our job above, will be subject to disciplinary action.

Disciplinary action
• To maintain the highest standards of integrity, we must
dedicate ourselves to comply with the Code, Company
policies and procedures, as well as applicable laws and
regulations. Individuals who fail to do so will be subject to
disciplinary action.

A detailed ‘Whistle-Blower Policy’ is

listed on the intranet.

19 Initials: ______________________
 05.
Appendix to the Code

Appendix 1. Glossary
1. Who is a ‘Line Manager’? • They are members of a Hindu Undivided Family.
‘Line Manager’ means an employee’s reporting manager/ • They are husband and wife; or
supervisor who is at the level of at least a Vice President
of the function or above. For employees who are at the • One person is related to the other in such manner as
level of Vice President or above, their immediate reporting under:
manager will be considered as the ‘Line Manager’ for this –– Father (includes step-father)
purpose.
–– Mother (includes step-mother)
–– Son (includes step-son)
2. Who is considered to be a ‘related party’ under the –– Son’s wife – daughter-in-law
Code? –– Daughter (includes step-daughter)
Parties are considered to be related if at any time one –– Daughter’s husband – son-in-law
party has the ability to control the other party or exercise
–– Brother (includes step-brother)
significant influence over the other party in making
financial and/or operating decisions. –– Sister (includes step-sister)

‘Control’ –– Any person deriving >50% of their subsistence

from the Company’s employee
• Ownership, directly or indirectly, of more than one half
of the voting power of an enterprise, or
• Control of the composition of the Board of Directors 4. What does ‘bribery’ and ‘corruption’ mean?
in the case of a Company, or of the composition of the A ‘bribe’ is anything of value, including money, gifts and
corresponding governing body in case of any other entertainment, other business courtesies, hospitality, or
enterprise, or personal gratification given, offered, or received in an
• Holder of substantial interest in voting power and the attempt to influence a person’s behaviour, in order to
power to direct, by statute or agreement, the financial obtain or retain business, or to secure an unfair benefit or
and/or operating policies of the enterprise. advantage.

‘Significant influence’ ‘Corruption’ is dishonest behaviour by those in positions

of power, such as managers or Government Officials.
Participation in the financial and/or operating policy Corruption can include giving or accepting bribes or
decisions of an enterprise, but not control of those policies. inappropriate gifts, under-the-table, diverting funds,
laundering money, and defrauding investors.

3. Who is considered to be a ‘relative’ under the Code?

‘Relative’, in general will mean individual, Company, 5. What are ‘facilitation payments’ and ‘kickbacks’?
associate, or firm with whom we, either directly or Facilitation payments are small expediting or ‘grease’
indirectly, may have a relation or interest, which can payments made to Government Officials to facilitate or
influence or even appear to influence our decisions made expedite the performance of a routine, non-discretionary
on behalf of the Company. governmental action that a Government Official is already
With reference to any person, it means anyone who is obligated to perform, such as issuing certain permits,
related to another, if: licenses, visas and mail. Facilitation payments do not
include any decision by a Government Official to award new
business or to continue business with a Company.
20
Initials: ______________________
 A kickback is a form of negotiated bribery in which a 10 . What is ‘fraud’?
commission is paid to the bribe-taker as a Quid Pro
‘Fraud’ in relation to affairs of a Company or any body
Quo for services rendered. Generally speaking, the
corporate, includes any act, omission, concealment of any
remuneration (money, goods, or services handed over) is
fact or abuse of position committed by any person or any
negotiated ahead of time. The kickback varies from other
other person with connivance in any manner, with intent
kinds of bribes in that there is implied collusion between
to deceive, to gain undue advantage from, or to injure
agents of the two parties, rather than one party extorting
the interests of, the Company or its shareholders or its
the bribe from the other. The purpose of kickback is usually
creditors or any other person, whether or not there is any
to encourage the other party to cooperate in the illegal
wrongful gain or wrongful loss.
scheme.
‘Wrongful gain’ means the gain by unlawful means of
property to which the person gaining is not legally entitled.
6. What does ‘gifts and entertainment’ mean? ‘Wrongful loss’ means the loss by unlawful means of
‘Gifts and entertainment’ include anything of monetary property to which the person losing is legally entitled.
value offered/received by an individual either directly
or indirectly for the purpose of expressing gratitude.
Gift includes cash and non-cash items, some examples 11. What is personally identifiable information (“PII”)?
of which are: artwork, watches, jewellery, equipment,
PII is defined as any information that identifies an
services, prizes, gift vouchers, donations to charities, use
individual such as name, physical address, email address,
of vacation facilities, stocks or other securities, home
government IDs, credit cards or bank account details,
improvements, tickets/invitation to sports, cultural or any
photo, video, or any combination of that information that
other event. However, this does not include reasonable
might identify an individual.
expenditure incurred on account of routine business
courtesies offered to or received by any business
partner as a customary trade practice (e.g. providing
transportation, meals, accommodation, etc.). 12. What is ‘intellectual property’?
‘Intellectual property’ includes any Company owned
information like:
7. What is ‘sensitive information’?
patented inventions, designs, copyright materials,
‘Sensitive information’ can include legal agreements, trademarks and service marks, trade secrets and know-
technical specifications, or any other information which how, sales, marketing and other corporate databases,
is unlikely to be publicly known and may have commercial marketing strategies and plans, research and technical
value. data, business ideas, processes, proposals or strategies,
new product and/or package design, and development
software bought or developed by the Company, or
8. Who is included in the term ‘stakeholder’? information used in trading activities including pricing,
marketing, and customer strategies.
‘Stakeholder’ includes:
Shareholders, bankers, dealers, media, government,
business partners, competitors, approving agencies,
service centres, society, outsourcers, auto analysts, legal
advisors, professionals, consultants, auditors, courts,
analyst, and rating agencies.

9 . Omitted

23
21 Initials: ______________________
Appendix 2. Disclosure and Approval matrix
Human Resource Board of
Chief Ethics Officer Line Manager Representative of the Directors
function
Subject of concerns Disclosure Approval Disclosure Approval Disclosure Approval Approval
Maintaining ethical business standards

Outside employment a a*
Note 1

Dealings with relatives a*

Note 1

Engaging vendors, customers, or a

any other business partners for
personal use

Outside investments a a*
Note 1

Anti-bribery and corruption a

Contributing to political parties a
Gifts, entertainment, or hospitality a*
received/offered above threshold Note 1

Commitment to business associates, suppliers, customers and environment

Reporting issues and violations a a

Commitment to stakeholders
Reporting inaccurate, irregular, and a
misleading maintenance of books (and CFO)
and records

Reporting insider trading violations a

Assisting in audit and internal a
investigation (and legal)
Use of the Company or third-party a
logos or trademarks in external
communication

Investor relations a
Behaviour at the workplace

Use of alcohol at Company - a*

sponsored events Note 1

Reporting behavioural violations a

Protection of assets and information management
Reporting issues and violations with a a
respect to protection of assets and
information technology
Administering the Code
Reporting any other violations of a
the Code

Waivers to the Code a

* Note1: Refer appendix 5 for disclosure and approval format for any of the above clauses of the Code.
* Note2: Any of the above mentioned approvals granted by any Line Manager or Human Resource representative should be reported to the Chief Ethics Officer on a quarterly basis
22
Initials: ______________________
Appendix 3. Our Code at a glance
Do’s Don’ts

• Seek approval for any outside jobs and • Hire relatives in the same chain of
affiliations. command or function.
• Comply with requirements for giving • Accept favours from vendors,
and receiving gifts and entertainment. customers or suppliers.
Maintaining ethical business
standards • Seek approval for any dealings with • Hold significant investment in business
relatives/related parties/related associates of the Company.
party of relatives.
• Bribe or offer/receive kickbacks.
• Follow anti-bribery and anti-corruption
practices.

• Treat customers fairly, ethically, and • Flout product quality and safety
comply with all applicable laws. standards, laws, and regulations.
• Treat suppliers and subcontractors • Participate in acts that violate
Commitment to business with fairness and integrity. competition laws.
associates, suppliers, customers, • Respect terms and conditions of • Overstate or misrepresent product
and environment agreements with suppliers, and quality.
honour commitments.
• Meet regulatory requirements with
respect to health and environment.

• Comply with all applicable laws and • Falsify any document, record, or
regulations. transaction, whether it is financial or
non-financial.
• Understand and follow the Company’s
record retention policy. • Disclose confidential information.
Commitment to stakeholders
• Maintain accurate records. • Communicate on behalf of the
Company unless authorised.
• Recognise and report fraud,
falsification, and manipulation.
• Respect the rights of investors.

• Comply with all the required laws. • Discriminate.

• Immediately report any violation of • Entertain any type of harassment.
Code.
• Perform unsafe activities.
Behaviour at the workplace • Respect the diversity of people.
• Work under the influence of illegal
• Respect Human Rights. drugs or alcohol.
• Indulge in violence.
• Employ child labour.

• Safeguard, secure, and protect • Provide confidential data or non-

Company assets and information public information to anyone inside
technology. or outside of the Company without
Protection of assets and ensuring that it is appropriate to do so.
• Understand and follow the Company’s
information management
IT security policy. • Infringe upon Intellectual Property
rights of others.
• Abuse Company resources.

23 Initials: ______________________
 Appendix 4. List of existing policies related to Governance available on
the intranet for reference
• Maintaining ethical business standards • Behaviour at the workplace
–– Policy on Corporate Representation in Trade and –– Policy on Employee Relations
Industry Fora
–– Policy on Human Resources
• Commitment to business associates, suppliers,
–– Policy on Human Rights in Economic Decision Making
customers, and environment
Process
–– Policy on Quality
–– Policy on Sexual Harassment
–– Policy on Dealings with Dealers and Customers
–– Policy on Safety and Occupational Health
–– Policy on Dealings with Suppliers and Vendors of
• Protection of assets and information management
Products and Services
–– Policy on E-Business Security
–– Policy on Environment and Pollution
–– Policy on Intranet
• Commitment to stakeholders
–– Policy on Internet Usage
–– Policy on Insider Trading
–– Policy on Trade Marks
–– Policy on Group Communications
• Administering our code and reporting violations
–– Policy on Investor Relations
–– Whistle-Blower Policy
–– Policy on Investor Grievances

Initials: ______________________ 24
Appendix 5. Disclosure and approval format

Employee information

Name:

Designation:

Department and
Location:

Office Phone:

Office E-mail:

Particular matter

Particular matter: Please describe the particular matter, the aspects of the Code being/likely to be violated and
disclosure/approval required:

In addition to the
above, describe
financial interest
and implication (in
Rupee value), if any.

Employee signature:

Date:

25 Initials: ______________________
Appendix 6. Approval granted and/or disclosure received format

Concerned authority information

Name of Concerned
Authority:

Designation:

Department and
Location:

Office Phone:

Office E-mail:

Decision taken by the authority and/or disclosure noted

Decision by the I have reviewed the particular matter and the financial interest identified above by the employee.
concerned authority:

Mark a ‘a’ _____________________________ I am noting the disclosure made by the employee on the
to indicate your abovementioned request. My comments on the matter are as stated below.
selection.

_____________________________ I approve/disapprove the abovementioned request.

My comments on the matter are as stated below.

Concerned Authority
signature:

Date:

Comments:

Attach additional pages if necessary.

Each Line Manager is supposed to attach each individual approval/disclosure form to a consolidated list to be prepared on a
quarterly basis to be filed with the Chief Ethics Officer.

26
24
Initials: ______________________