CODE OF CONDUCT

Foreword

The values and principles which have governed the manner in which Prakash Iron Foundry and their employees have conducted themselves are first time formally articulated as the PIF Code of Conduct in 2017. This Code is intended to serve as a guide to each employee on the values, ethics and business principles expected of him or her in personal and professional conduct.

It is however important to consider the effect of the rapidly increasing footprint of Prakash Iron Foundry across nationalities and geographical boundaries on the Code. This emergent global presence requires an appropriate modification of the Code to ensure that it addresses and encompasses diverse cultural, business and related issues universally across the organization.

I urge each employee to read the current version of the PIF Code of Conduct and take pride in upholding the high standards of corporate and personal behavior on which the PIF’s reputation and respectability have been built over the past 2 years.

Swhetang Garg
Managing Director

Clause 1:

NATIONAL INTEREST

Prakash Iron Foundry is committed to benefit the net economic development of the region in which it operates. Prakash Iron Foundry shall not undertake any project or activity while is harmful to the wider interests of the communities in which it operates. PIF’s management practices and business conduct shall benefit the region, localities and communities in which it operates, to the extent possible and affordable, and shall be in accordance with the laws and economic development policies of the region.

Prakash Iron Foundry, in the course of its business activities, shall respect the culture, and traditions of region in which it operates.

Clause 2:

FINANCIAL REPORTING AND RECORD

Prakash Iron Foundry shall prepare and maintain its accounts fairly and accurately and in accordance with the accounting and financial reporting standards which represent the generally accepted guidelines, principles, standards, laws and regulations of the country in which the company conducts its business affairs.

Internal accounting and audit procedures shall reflect, fairly and accurately, all of the company’s business transactions and disposition of assets, and shall have internal controls to provide assurance to the company’s board and shareholders that the transactions are accurate and legitimate. All required information shall be accessible to company auditors and other authorized parties and government agencies. There shall be no willful omissions of any company transactions from the books and records, no advance-income recognition and no hidden bank account and funds

Any willful, misrepresentation of and / or misinformation of the financial accounts and reports shall be regarded as a violation of the Code, along with an appropriate civil or criminal action under the relevant laws. No employee shall make, authorize or collude in, any improper payment, commission or bribe.

Clause 3:

COMPETITION

Prakash Iron Foundry shall fully support the development and operation of competitive open markets and shall promote the liberalization of trade and investment in the region and market it operates in. Specifically, Prakash Iron Foundry shall not engage in restrictive trade practices and activities that generate or support the formation of monopolies, dominant market positions, cartels and similar unfair trade practices.

Prakash Iron Foundry shall market its products and services on their own merits and shall not make unfair and misleading statements about competitors’ products and services. Any collection of competitive information shall be made only in the normal course of business and shall be obtained only through legally permitted sources and means.

Clause 4:

EQUAL OPPORTUNITIES EMPLOYER

Prakash Iron Foundry shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, religion, colour, ancestry, marital status, sex, age, nationality, disability and veteran status.

Human resource policies should promote diversity and equity in the workplace, as well as compliance with all local labour laws and international best practices. Employees of a Prakash Iron Foundry shall be treated with dignity and in accordance with the PIF policy to maintain a work environment free of all sexual harassment, whether physical, verbal or psychological. Employee policies and practices shall be administered in a manner that would ensure that in all matters equal opportunity is provided to those eligible and the decisions are merit-based.

Clause 5:

GIFTS AND DONATIONS

Prakash Iron Foundry and its employees shall neither receive nor offer or make, directly or indirectly, any illegal payments, remuneration, gifts, donations or comparable benefits that are intended, or perceived, to obtain business or un-competitive favours for the conduct of its business. It shall participate in efforts to eliminate such forms of bribery, fraud and corruption. Even nominal gifts like diary, sweets are not accepted.

Clause 6:

GOVERNMENT AGENCIES

Prakash Iron Foundry and its employees shall not offer or give any company funds or property as donation to any government agencies or its representatives, directly or through intermediaries, in order to obtain any favourable performance of official duties. Prakash Iron Foundry shall comply with government procurement regulations, and shall be transparent in all its dealings with government agencies as applicable.

Clause 7:

POLITICAL NON-ALIGNMENT

Prakash Iron Foundry shall be committed to and support functioning democratic constitutions and systems with transparent and fair electoral systems. Prakash Iron Foundry shall not support directly or indirectly any specific political party or candidate for political office. The company’s conduct shall preclude any activity that could be interpreted as mutual dependence / favour with any political body and shall not offer or give any company funds to a specific political party, candidate or campaign.

Clause 8:

HEALTH, SAFETY AND ENVIRONMENT

Prakash Iron Foundry shall strive to provide a safe, healthy, and ergonomic working environment for its people. It shall comply with all health, safety and environment regulations in each jurisdiction in which it operates.

Prakash Iron Foundry shall be committed to adopt the best practice in minimizing its impact on the environment, prevent the wasteful use of natural resources, and safely control any hazardous aspects of its business.

Prakash Iron Foundry shall have policies and processes in place to address issue of safety, health and environment and also shall have a disaster management system to address any natural calamities or business contingencies that may arise.

Prakash Iron Foundry, in the process of production and sale of its products, shall strive for economic, social and environmental sustainability.

Clause 9:

QUALITY OF PRODUCTS AND SERVICES

Prakash Iron Foundry shall be committed to supply quality goods of highest quality standards consistent with the requirements of customers to ensure their total satisfaction. The quality standards of the company’s goods should meet the required national & international standards and the Company should endeavour to become world-class.

Prakash Iron Foundry shall illustrate adequate labels, caveats and other necessary information on its product packaging.

Clause 10:

CORPORATE CITIZENSHIP

Prakash Iron Foundry  shall be committed to good corporate citizenship, not only in the compliance of all relevant laws and regulations but also by actively assisting in the improvement of quality of life of the people in the communities in which it operates with the objective of making them self reliant. Such social responsibility would comprise, to initiate and support community development by the way of health and family welfare, water management, vocational training, education and literacy and encourage application of modern scientific and managerial techniques and expertise. This will be reviewed periodically in consonance with national and regional priorities. The Company would also not treat these activities as optional but would strive to incorporate them as an integral part of its business plan. Prakash Iron Foundry is encouraged to develop social accounting system, carry out social audit of their operations, and support public policies that promote social and economic development.

Clause 11:

THIRD PARTY REPRESENTATION

Parties which have business dealings with Prakash Iron Foundry but are not members of the company, such as suppliers, etc shall not be authorised to represent Prakash Iron Foundry, if their business conduct and ethics are known to be inconsistent with the Prakash Iron Foundry. Third parties are expected to abide by the Code in their interaction with the company.

Clause 12:

COMPANY POLICIES

Prakash Iron Foundry, Partners formulates and adopts the policies and guidelines

Clause 13:

ETHICAL CONDUCT

Every employee of Prakash Iron Foundry, which shall include Partners, shall deal on behalf of the Company with professionalism, honesty and integrity, as well as high moral and ethical standards. Such conducts shall be fair and transparent and be perceived to be as such by third parties.

Every employee of Prakash Iron Foundry shall preserve the human rights of every individual and shall strive to honour commitments.

Every employee shall be responsible for the implementation of and compliance with the Code of conduct in his / her professional environment. Failure to adhere to the Code of conduct could attract the most severe consequences, including termination of employment.

Clause 14:

REGULATORY COMPLIANCE

Employees of Prakash Iron Foundry, in his/her business conduct, shall comply with all applicable laws and regulations.

Clause 15:

Concurrent employment

An employee of Prakash Iron Foundry shall not, without prior approval of Partner, accept employment or a position of responsibility (such as a consultant or a Director) with any other company, nor provide “free-lance” services to anyone.

Clause 16:

Conflict of interest

An Employee or Partners of Prakash Iron Foundry shall not accept position of power / responsibility / board nomination in any profit organization.

The above shall not apply to (whether for remuneration or otherwise):
a) Memberships / positions of responsibility in educational / professional bodies, wherein such association will benefit the employee / Prakash Iron Foundry.

b) Nominations / memberships in government committees / bodies or organizations.

c) Exceptional circumstances, as determined by the competent authority.

An employee of Prakash Iron Foundry engages in a business, relationship or activity which might detrimentally conflict with the interest of his / her Company. A conflict of interest, actual or potential, may arise where, directly or indirectly (a) an employee of PIF engages in a business, relationship or activity with anyone who is party to a transaction with his/her Company, (b) an employee is in a position to derive a personal benefit or a benefit to any of his/her relatives by making or influencing decisions relating to any transaction, and (c) an independent judgments of the Company’s best interest cannot be exercised.

The main areas of such actual or potential conflicts of interest shall include the following:

Award of benefits such as increase in salary or other remuneration, posting, promotion or recruitment of a relative of an employee of Prakash Iron Foundry, where such an individual is in a position to influence decisions with regard to such benefits.

Acceptance of gifts, donation , hospitality and/or entertainment beyond the customary level from existing or potential suppliers, customers or other third parties which have business dealings with the Company.

Notwithstanding such or other instance of conflict of interest exist due to historical reasons adequate and full disclosure by interested employees shall be made to the company’s management. It is also incumbent upon every employee to make a full disclosure of any interest which the employee or the employee’s immediate family, including parents, spouse and children, may have in a company or firm which  is a  supplier, customer or distributor of or has other business dealings with his / her company.

Every employee who is required to make a disclosure as mentioned above shall do so, in writing, to his/her immediate superior who shall forward the information along with his/her comments to the person designated for this purpose to Partner, Upon a decision being taken in the matter, the employee concerned shall be required to take necessary action, as advised, to resolve / avoid the conflict.

If an employee fails to make the disclosure as required therein and the management of its own accord becomes aware of an instance of conflict of interest that ought to have been disclosed by the employee, the management would take a serious view of the matter and consider suitable disciplinary action against the employee.

Clause 17:

Securities transactions and confidential information

An employee of Prakash Iron Foundry and his / her immediate family shall not derive any benefit or assist others to derive any benefit, from access to and possession of information about the company which is not in the public domain and, thus, constitutes internal information.

An employee of Prakash Iron Foundry shall not use or proliferate information which is not available to the investing public, and  therefore constitutes internal information, for making or giving advice on investment decisions on the securities of Prakash Iron Foundry on which such internal information has been obtained.

Such internal information might include (without limitation) the following:     

• Acquisition and divestiture of businesses or business units.
• Financial information such as profits, earnings and dividends.
• Announcement of new product introductions or developments.
• Asset revaluations.
• Investment decisions / plans.
• Restructuring plans.
• Major supply and delivery agreements.
• Raising of finances.

An employee of a Prakash Iron Foundry shall also respect and observe the confidentiality of information pertaining to other companies, their patents, intellectual property rights, trademarks and inventions; and strictly observe a practice of non-disclosure.

Clause 18:

Protecting company assets

The assets of Prakash Iron Foundry should not be misused but employed primarily for the purpose of conducting the business for which they are duly authorized. These include tangible assets such as equipment and machinery, systems, facilities, materials and resources, as well as intangible assets such as information technology and systems, proprietary information, intellectual property, and relationships with customers and suppliers, etc…

Clause 19:

Citizenship

An employee of Prakash Iron Foundry shall in his / her private life be free to pursue an active role in civic or political affairs as long as it does not adversely affect the business or interest of the company.

Clause 20:

Integrity of data furnished

Every employee of Prakash Iron Foundry shall ensure at all times, the integrity of data or information furnished by him / her to the company.

Clause 21:

Reporting concerns

Every employee of Prakash Iron Foundry shall promptly report to the management, when she / he becomes aware of any actual or possible violation of the Code Of Conduct or an event of misconduct, act of misdemeanor or act not in the company’s interest, which could affect the business or reputation of his/her.