CODE OF BUSINESS CONDUCT
1. Introduction
("the Company") is committed to conducting business with the highest standards of ethics,
integrity, and professionalism. As a leading company in the Equipment and Asset Leasing
industry across PAN India, our reputation depends on the actions and decisions taken by
each employee and representative of the Company.
This Code of Business Conduct ("the Code") serves as a guide to ethical decision-making
and outlines the standards of behavior expected from all individuals associated with the
Company. It reflects our commitment to uphold our core values in all business activities and
relationships.
2. Purpose and Scope
Purpose
The purpose of this Code is to:
● Establish clear guidelines for ethical business conduct
● Promote integrity and ethical behavior in all business activities
● Ensure compliance with applicable laws and regulations
● Protect the Company's reputation and assets
● Create a positive work environment based on mutual respect
Scope
This Code applies to:
● All directors, officers, and employees of the Company (whether permanent,
fixed-term, or temporary)
● Third parties including but not limited to consultants, contractors, trainees,
volunteers, interns, agents, and any other person associated with the Company
● All operations, dealings, and transactions conducted by or on behalf of the Company
throughout PAN India
3. Core Values and Principles
Our business conduct is guided by the following core values and principles:
Integrity
We conduct our business with honesty and transparency. We are truthful in our
communications and actions.
Excellence
We strive for excellence in all aspects of our business operations and service delivery.
Customer Focus
We are dedicated to understanding and meeting the needs of our customers and exceeding
their expectations.
Respect
We treat all individuals with dignity and respect, valuing diversity and promoting inclusion.
Accountability
We take responsibility for our actions and decisions, and we are accountable to our
stakeholders.
Innovation
We embrace innovation and continuous improvement to enhance our products, services,
and processes.
Teamwork
We foster collaboration and teamwork, recognizing that our collective efforts lead to superior
results.
4. Compliance with Laws and Regulations
The Company is committed to complying with all applicable laws, rules, and regulations in
the jurisdictions where it operates. This includes, but is not limited to:
● Prevention of Corruption Act, 1988
● Companies Act, 2013
● Indian Penal Code
● Reserve Bank of India (RBI) Guidelines applicable to NBFCs
● Labor laws and regulations
● Environmental laws and regulations
● Tax laws
● Data protection and privacy laws
Employees and third parties are expected to:
● Be familiar with laws and regulations applicable to their work
● Seek guidance from the Legal Department or Compliance Officer when uncertain
about legal requirements
● Report any suspected violations of laws and regulations
● Cooperate fully with any internal or external investigations
5. Workplace Conduct
Equal Employment Opportunity
The Company is committed to providing equal employment opportunities to all individuals
regardless of race, color, religion, gender, age, national origin, disability, sexual orientation,
or any other characteristic protected by law. This commitment extends to all aspects of
employment, including:
● Recruitment and hiring
● Training and development
● Promotion and transfer
● Compensation and benefits
● Discipline and termination
Anti-Harassment and Discrimination
The Company prohibits any form of harassment, bullying, or discrimination in the workplace.
All employees have the right to work in an environment free from harassment and
discrimination. Examples of prohibited conduct include:
● Offensive jokes, slurs, or epithets
● Verbal or physical conduct of a threatening, intimidating, or hostile nature
● Display of offensive or derogatory materials
● Any conduct that interferes with an individual's work performance or creates an
intimidating, hostile, or offensive work environment
Health and Safety
The Company is committed to providing a safe and healthy work environment for all
employees and visitors. Employees are expected to:
● Comply with all safety policies, procedures, and guidelines
● Report any unsafe conditions, accidents, or injuries immediately
● Not engage in activities that pose a risk to themselves or others
● Complete required safety training
● Participate in safety initiatives and improvements
Drug and Alcohol Use
The Company prohibits the use, possession, distribution, or sale of illegal drugs on
Company premises or while conducting Company business. The consumption of alcohol
during working hours is prohibited except at authorized Company events where alcohol may
be served in moderation.
6. Business Ethics
Anti-Bribery and Anti-Corruption
The Company has zero tolerance for bribery and corruption. Employees and third parties
must comply with the Company's Anti-Bribery and Anti-Corruption Policy, which prohibits:
● Offering, promising, giving, requesting, agreeing to receive, or accepting a bribe
● Making facilitation payments
● Engaging in kickback schemes
● Any other form of corrupt practice
Conflicts of Interest
Employees must avoid situations where personal interests conflict, or appear to conflict, with
the interests of the Company. Potential conflicts of interest must be disclosed promptly to the
Compliance Officer or Human Resources Department. Examples of conflicts include:
● Having a significant financial interest in a supplier, competitor, or customer
● Receiving personal benefits from a third party due to your position with the Company
● Engaging in outside business activities that compete with the Company
● Hiring or supervising family members or close personal friends
● Using Company information for personal gain
Gifts and Entertainment
Employees must comply with the Company's policy on gifts and entertainment as detailed in
the Anti-Bribery and Anti-Corruption Policy. In general:
● Gifts and entertainment must be reasonable, appropriate, and transparent
● Cash or cash equivalent gifts are prohibited
● Gifts or entertainment must not be given or received with the intention of influencing
business decisions
Fair Competition
The Company is committed to fair and open competition. Employees must not engage in
anti-competitive practices, including:
● Price fixing
● Bid rigging
● Market allocation
● Exchange of competitively sensitive information with competitors
● Abuse of market position
● Deceptive or misleading marketing practices
7. Company Assets and Information
Confidential Information
Employees must protect confidential information of the Company, its customers, suppliers,
and business partners. Confidential information includes:
● Business strategies and plans
● Financial information
● Customer and supplier data
● Pricing information
● Trade secrets and proprietary information
● Employee personal information
Confidential information must not be disclosed to unauthorized individuals, either during or
after employment with the Company.
Intellectual Property
The Company's intellectual property is a valuable asset that must be protected. This
includes:
● Patents
● Trademarks
● Copyrights
● Trade secrets
● Proprietary software
● Business processes
Employees must respect the intellectual property rights of others and not infringe upon valid
patents, trademarks, copyrights, or other protected intellectual property.
Use of Company Assets
Company assets should be used responsibly and for legitimate business purposes.
Employees must:
● Protect Company assets from theft, damage, and misuse
● Use Company resources efficiently and avoid waste
● Not use Company assets for personal gain
● Follow Company policies regarding the use of technology, equipment, and facilities
Limited personal use of Company resources, such as telephones and computers, is
permitted as long as it does not interfere with job responsibilities, violate any Company
policies, or result in significant additional costs to the Company.
Data Privacy and Security
The Company is committed to protecting the privacy and security of personal data.
Employees must:
● Collect, process, and store personal data in accordance with applicable laws and
Company policies
● Use personal data only for legitimate business purposes
● Implement appropriate security measures to protect personal data
● Report any data breach or security incident immediately
8. Financial Integrity
Accurate Records
The Company is committed to maintaining accurate and complete financial records.
Employees must:
● Record all transactions honestly and accurately
● Ensure that financial statements and reports are prepared in accordance with
applicable accounting principles
● Not maintain off-the-book accounts or make false or misleading entries
● Cooperate fully with internal and external auditors
Document Retention
Employees must retain documents and records in accordance with the Company's document
retention policy and applicable legal requirements. Documents relevant to actual or
anticipated litigation, audits, or investigations must not be destroyed.
Prevention of Money Laundering
The Company is committed to complying with all applicable anti-money laundering laws and
regulations. Employees must:
● Verify the identity of customers and business partners
● Be alert to suspicious transactions or activities
● Report any suspicions of money laundering to the Compliance Officer
● Not engage in any transaction designed to conceal the source of funds or avoid
reporting requirements
9. Third-Party Relationships
Customer Relationships
The Company is committed to dealing fairly and honestly with its customers. Employees
must:
● Provide accurate and complete information about products and services
● Honor commitments and contractual obligations
● Protect customer information and privacy
● Respond promptly and professionally to customer inquiries and complaints
● Not make false or misleading statements about competitors
Supplier Relationships
The Company selects suppliers based on merit, quality, price, and reliability. Employees
must:
● Conduct due diligence on potential suppliers
● Make procurement decisions objectively, based on the best interests of the Company
● Not accept improper personal benefits from suppliers
● Respect and protect supplier confidential information
● Ensure suppliers comply with applicable laws and Company policies
Lender Relationships
The Company maintains transparent and professional relationships with its lenders.
Employees must:
● Provide accurate and timely information to lenders
● Honour loan agreements and covenants
● Maintain appropriate records of all lending arrangements
● Disclose potential conflicts of interest involving lenders
● Ensure all lending arrangements comply with applicable laws and regulations
10. Environmental and Social Responsibility
Environmental Protection
The Company is committed to minimizing its environmental impact. Employees must:
● Comply with all applicable environmental laws and regulations
● Use resources efficiently and minimize waste
● Report any environmental incidents or concerns
● Support the Company's environmental initiatives
● Consider environmental impacts in business decisions
11. Reporting Violations
Reporting Channels
Employees and third parties are encouraged to report any suspected violations of this Code,
Company policies, or applicable laws. Reports can be made through:
● Direct report to the immediate supervisor
● Human Resources Department
● Compliance Officer
● Dedicated whistleblower hotline:
● Written communication addressed to the Compliance Officer
Non-Retaliation Policy
The Company prohibits retaliation against anyone who, in good faith, reports a suspected
violation or participates in an investigation. Retaliation is a violation of this Code and will
result in disciplinary action, up to and including termination of employment.
12. Disciplinary Actions
Violations of this Code, Company policies, or applicable laws may result in disciplinary
action, which may include:
● Verbal or written warning
● Performance improvement plan
● Suspension
● Termination of employment or business relationship
● Legal action
The nature of the disciplinary action will depend on the nature and severity of the violation,
the individual's history of previous violations, and other relevant factors.
13. Training and Communication
The Company will provide regular training on this Code to all employees. Training will cover:
● The requirements of this Code
● Relevant laws and regulations
● Ethical decision-making
● How to report concerns
This Code will be communicated to all employees and relevant third parties through:
● Publication on the Company's intranet and website
● Inclusion in employee handbooks and contracts
● Regular reminders and updates
● Incorporation into third-party contracts
14. Implementation and Monitoring
The Board of Directors is ultimately responsible for overseeing the implementation of this
Code. The Compliance Officer is responsible for the day-to-day implementation and
monitoring of compliance with this Code.
The Company will conduct regular audits and assessments to evaluate compliance with this
Code and identify areas for improvement.
15. Amendments and Waivers
This Code may be amended from time to time by the Board of Directors. Any amendments
will be communicated to all employees and relevant third parties.
Waivers of this Code for executive officers or directors may be made only by the Board of
Directors and will be promptly disclosed as required by law or regulation. Waivers for other
employees may be granted only in exceptional circumstances and must be approved by the
Compliance Officer.
16. Acknowledgment
All employees are required to acknowledge that they have read, understood, and agree to
comply with this Code. This acknowledgment will be obtained:
● Upon initial employment
● After any significant amendments to the Code
● Annually as part of the compliance certification process
17. Contact Information
For questions, concerns, or reports regarding this Code, please contact:
Compliance Officer: Piyush
Compliance Officer: Rahul Srinavas
