Introduction & Administration of Code of Ethics

Message from the Chairman

Over the years we have worked together to build and create opportunities, which have evolved in to the Amara Raja Group of Companies. We are all proud of what we have achieved. In the process of building and nurturing this organization, we have laid down guidelines, rules and regulations that have enabled us to run our organization and our business in a fair, just and ethical manner. Some of these rules and guidelines, which I am referring to, are not always set down in writing, but have been established or perpetuated through practice and example.

It is very likely that you have come across situations wherein you were not able to take a decision or react to a particular subject or event. This may be due to the absence of specifically laid down rules and guidelines that govern our day-to-day thoughts and actions. While we have not faced any serious setbacks in the absence of such guidelines, the time has come where I felt it appropriate that these should be enshrined in a formal document, which will be referred to as the Amara Raja Code of Ethics.

All of us at Amara Raja are part of a national and international corporate environment. Other than this, we are also governed and influenced by the proud heritage and culture of our country, our social value systems and our education and upbringing. We have always believed that we should develop our organization in a manner that best suits our value systems, business culture and practices.

In order to provide each one of us with clear-cut and well-defined guidelines I have authorized the Amara Raja Code of Ethics, which will cover a variety of subjects.

Each one of you is expected to read and understand the Amara Raja Code of Ethics and ensure that they are reflected in our actions and transactions within the organization as well as with our business associates across the globe. The Amara Raja Code of Ethics reflects in the true sense, the spirit and conscience of our organization and it is therefore imperative that the Code of Ethics continues to govern and influence all our actions and decisions.

Every member of the Amara Raja family is duty bound personally and professionally to abide by the Amara Raja Code of Ethics and to stand committed to it every moment of our lives.

We are Amara Raja employees round the clock at work and at home.

If at any point of time, you are confronted with a situation or an issue that runs against the spirit and letter of our Code of Ethics you should not hesitate in the slightest to bring it to the notice of a competent executive of the Company, a member of the Code of Ethics Committee or to me directly.

I look forward to your unwavering support and commitment in upholding and practicing the values and principles laid down in our Code of Ethics.

- Dr. Ramachandra N Galla

Custodians and Administrators of the Amara Raja Code of Ethics

The Amara Raja Code of Ethics will be governed and administered by a committee appointed by the Chairman. The President (Group HR & New Business Development) will chair the committee consisting of two other members nominated by the Chairman.

This committee will be the custodian of the Amara Raja Code of Ethics.

Procedure to notify breach of our Code of Ethics:

Every employee in the Amara Raja Group of Companies, associates, customers and business partners of the company are free to bring to the notice of the Code of Ethics committee any act or action which in their opinion constitutes a breach of the Code of Ethics. They may do so by either writing a letter, a message on the e-mail addresses of the committee members or meet / telephone any one of them in person with the details and evidence in support of their complaint or apprehension.

The committee will evaluate and act on any complaint brought to their notice if in their opinion they are convinced that the matter has to be investigated. They will protect and keep confidential the identity of the complainants or aggrieved persons. Similarly, complainants must carefully evaluate the ramifications and the impact their complaint may have and should do so after they have adequate proof or firm reason to believe that a breach of the Code of Ethics has taken place.

Investigation into cases reported to the committee:

The committee will regularly meet once every quarter and as and when required to evaluate and investigate matters reported to the committee. The frequency of meetings will depend on the gravity of the matters reported. In the event a complaint is not found sustainable or baseless, the committee will notify and advise the complainants accordingly. In the event a complainant is required to testify or place evidence before the Code of Ethics Committee, the same shall be acted upon by the committee.

Reporting findings of investigations and recommended action:

The Chairman of the committee will report the outcome and findings of all investigations directly and only to the Chairman. The committee constituted under the Code of Ethics may recommend suitable action and such action will be executed in keeping with the general policies and rules of the Company and appropriate laws that may govern such action or actions.

Powers of the Code of Ethics committee:

The Code of Ethics Committee is empowered to:

  • Conduct an enquiry in a manner they deem fit.
  • Recommend suspension of an employee(s) involved in the case even before completion of the enquiry if in their opinion their presence on the premises of the Company is detrimental to the investigation or interests of the Company at large.
  • Recommend blacklisting or stoppage of supplies by a vendor, conduct independent quality tests, and interrogate or seek information and clarification from other employees and non-employees and business and non-business associates of the Company.
  • In case of a serious breach of the Code of Ethics recommend termination of a guilty employee (s) or any other appropriate sanctions or punishment and censure it deems fit.
  • Recommend review, amendments or temporary suspension of an existing business / company policy, practice or system prevalent / being practiced in the Company.
  • Any other action they deem fit under the circumstances.
Re-constitution of the Committee:

The committee will be re-constituted as and when there are changes to the existing committee and the members will be nominated by the Chairman.

Review of the contents and scope of the Code of ethics:

This is a document that is dynamic and will therefore undergo changes, amendments and additions depending on the circumstances and the need of the hour. Different subjects, examples and illustrations will be added on from time to time. This is not an exhaustively illustrated document.

The Amara Raja Code of Ethics Committee

Chairman of the committee

Mr. Jaikrishna B

President (Group HR & New Business Development)

TERMINAL A
1-18-1/AMR/NR, Nanakramguda Gachibowli,
Hyderabad – 500 032. India.

Office Telephone: 91-40-2313 9360

Email: jkb@amararaja.co.in

Members of the committee

Mr. Vijayanand S

Chief Executive Officer, Amara Raja Batteries Ltd

TERMINAL A
1-18-1/AMR/NR, Nanakramguda Gachibowli,
Hyderabad – 500 032. India.

Office Telephone: 91-40-2313 9220

Email: vnand@amararaja.co.in

Dr. Ramadevi Gourineni

Co - Founder & Managing Director, Amara Raja Infra Pvt Ltd &
Amara Raja Industrial Services Pvt Ltd

Karakambadi, Tirupati, Andhra Pradesh, India.

Office Telephone: 91–877–2265 000

Email: rg@amararaja.co.in

Undertaking of the Code of Ethics Committee

It is indeed an honor and our privilege to hold office on the Amara Raja Code of Ethics Committee.

We hereby pledge to uphold the integrity and prestige of the Amara Raja Code of Ethics and in doing so strive to keep our organisation, our relationships and our actions clean and above board at all times.

The Ethics Committee will provide the lead and clarifications as and when they are solicited. The role the committee is expected to play is not reactive in nature. It is a proactive body set up to provide advice, clarity and assistance to those actively involved and entrusted with the responsibility of implementing, practicing and monitoring the Code of Ethics. Every employee, and especially the Heads of Department are directly responsible to ensure that the Code of Ethics is followed in letter and spirit at all times.

The Code of Ethics document is not a rulebook.

The Code of Ethics does not supercede or replace the rules and Laws of the Land constituted by the government of our country. The Code of ethics cannot and has no intention of guiding our actions, which may in any way contravene or contradict the laws of our country and international laws our country chooses to recognize.

It is a reference document which provides the guiding principles and some illustrative examples to amplify or clarify a point. It is therefore a “conscience-keeper” document. It is a very dynamic document that will undergo changes and amendments as required from time to time to keep it tune with the changing times, circumstances and environments in which we live and work.

The Amara Raja employee is an employee of the company twenty-four hours a day. Therefore, the scope of the applicability of the Code of ethics is not confined to all of us only during working hours. It crosses and goes beyond this boundary. Our actions at work or at home and in society in general should be above board. We must adhere to and respect the norms and mores set down by our society irrespective of what caste creed color or religion we choose to follow as individuals. We must assure at all times that our professional and personal values are not on a collision path.

We seek your support and trust in enabling us to dispense our responsibilities under the Code of Ethics.

Please read this document carefully word for word. Thereafter, we would appreciate if you sign and return the undertaking attached herewith on the last page as a token of your acceptance and commitment to the Code of Ethics.


Jaikrishna B
Vijayanand S
Dr. Ramadevi Gourineni

The Amara Raja Group of Companies has invested heavily in the process of developing, inventing, changing and influencing the development of technology and its application to a wide range and variety of products being manufactured and sold. Some of these applications are put to use in critical and important government and private sector projects

This investment also extends to products and technology under development in the Research & Development facilities and Research and Engineering Centers in the Company in India as well as in the facilities of our partners.

Investment in R&D activity and projects involves investments in terms of money and well as training efforts and investments in developing employees. The company provides opportunities and exposure to employees at all levels to various technologies and developments and also exposes them to the business strategies of the company.

Consequently, the terms of employment of all employees, specified in their appointment orders or as clarified in this ethics policy, prohibits and restrains them from exploring, entertaining and obtaining employment with the competition either directly or indirectly with such employers or their agents and representatives.

This chapter on the Ethics Policy clarifies issues related to prospective employment with the competition and other institutions or associates that would result in jeopardizing the business interests of the company by existing and future employees taking up employment with the competition.

All employees in the Amara Raja Group of companies are expected to adhere to this ethics policy governing employment with the competition and such other employers.

In the event any section or portion of this ethics policy requires clarification or amplification employees are requested to forward their queries to the Vice President – Human Resources at the Corporate Operations Office in Hyderabad.

Definitions under this chapter of the ethics policy;

1. 'Competitors' and 'competition' means and includes companies and corporate entities, business ventures set up by corporate entities, a group of entrepreneurs or an individual or group of investors and other research based or business entities etc which are permitted to conduct business under the law of the land and whose business interests and pursuits, whether for commercial or non-profit goals and objectives is likely to adversely affect the Amara Raja group of companies by virtue of the fact that they deal with the same technology applications, product patents and discoveries and products directly or indirectly similar to the technology applications, patents and products and inventions and discoveries developed by the companies in the Amara Raja Group of companies.

2. 'Employment' means and includes the act of searching, obtaining or accepting employment offers or contracts with the competition either by the direct or indirect efforts of the competitors or through employment agencies, agents, contacts and associates appointed by them whether for remuneration, fees, royalty payments, whether for direct or indirect financial gain or not.

Acts and intentions of an individual or a group of employees that would tantamount to a breach of terms of employment and / or a breach of this ethics policy.

  • Entertaining or soliciting or exploring or accepting employment offers and employment from the competition.
  • Circulating to and encouraging other employees to share and / or accept information leading to employment with the competition.
  • Non-disclosure to the Head of Human Resources or any other competent officer any efforts by the competition or their agents if approached or contacted by the competition offering employment opportunities or proposals.
  • Non-disclosure to the Head of Human Resources or any other competent officer information pertaining to other employee(s) making efforts to obtain employment with the competition.
  • Applying to or responding to employment advertisements / proposals offered by the competition through the print media, electronic media or through other means.
  • Responding to employment offers without properly and thoroughly ascertaining whether prospective employment would result in a clash of interest under this ethics policy.
  • Using or permitting competition to use or access the company’s infrastructure and facilities like telephones, fax, e-mail or courier facilities to pursue explore and obtain or accept employment with the competition.
  • Coercing or forcing or using the services and or the good offices and references of existing employees in seeking and obtaining employment with the competition.
  • It is the duty of every employee to report to the Head Human Resources any activity that would result in an employee(s) seeking and / or accepting employment with the competition.
  • The security and the well being of the company’s business interests rests with every employee and they are expected to be alert, abide by and adhere to this ethics policy.

All employees in the Amara Raja Group of Companies are entitled to a working environment, which is free of harassment of any nature. The company will endeavor to ensure and provide our employees a working environment in which they can work and perform to the best of their abilities.

The Amara Raja does not and will not tolerate harassment of any employee(s) at the workplace.

Definition and scope of the term 'harassment';

The term "harassment" includes, but is not limited to slurs, jokes, and other verbal, graphic or physical conduct relating to an individual’s race, color, sex, sexual orientation, religion, caste, creed, color, national origin, citizenship, age disability, physical disability, physical abnormality or other protected categories of citizens. Any harassment of this nature violates this policy, and is not consistent with our corporate creed and beliefs.

Sexual harassment is prohibited by this ethics policy. It includes sexual advances, requests for sexual favors, unwelcome or offensive touching and other verbal, graphic, or physical conduct of a sexual nature.

The following are examples of behaviors, which constitute sexual harassment:

  • Verbal: Making sexual innuendoes / comments, insults, threats, jokes, or sexual propositions.
  • Non-verbal: Making suggestive or insulting noises, leering, whistling, or making obscene gestures, or displaying calendars, cartoons or posters that are derogatory on the basis of the employee’s sex.
  • Physical: Touching, pinching or brushing the body or any other physical contact and conduct of a sexual nature.

All employees are strictly prohibited from sending electronic messages during work hours using the infrastructure and equipment of the Company at any time, which contains offensive material related to sex, race, caste, religion, ethnicity or other protected categories of employees.

Similarly, employees who have access to the Internet (provided by the Company or a personal connection) are strictly prohibited from using the Internet during work time or while using Company equipment to access Internet sites, which contain offensive materials, jokes, pictures and articles related to pervert sex, race, or other protected categories of citizens.

Reporting of harassment at the workplace:

  • While any employee should feel free to simply ask another employee to stop an offensive behavior, there may be situations when this is not a comfortable initial step. In that case, any employee who believes he or she has been the subject of harassment should report the alleged conduct immediately to a member of the Code of Ethics Committee and or his / her Head of Department.
  • Employees are strongly encouraged to notify the appropriate person they are comfortable with, if they feel that they have been subject to harassment. On reporting the incident immediately, a complete investigation will be made and appropriate action taken.
  • Any employee found to have harassed another employee or otherwise to have violated this policy will be subject to appropriate disciplinary action including termination of services or serious censure.
  • The Company will not in any way permit retaliation against an employee, potential employee, or former employee who, in good faith, makes a complaint or report of harassment, or participates in the investigation of such a complaint or report. Any employee who retaliates or harasses any individual for reporting in good faith a claim of harassment or co-operating in the investigation of the same will render himself open to appropriate disciplinary action.
  • Amara Raja is committed to provide a harassment-free work environment and will conduct awareness-training program for all employees in the process of enforcing this policy.
  • Amara Raja recognizes that the issue of whether harassment has occurred requires factual determination based on all the evidence received. Amara Raja also recognizes that false accusations of harassment can have serious effects on innocent men and women.

We trust that all employees will continue to act in a responsible and professional manner to establish a harassment-free work environment. Employees found to be making false accusations and allegations will be subject to appropriate disciplinary action including termination.

Understanding and interpretation of the policy on No Harassment at the workplace

Employees are requested to seek clarification or interpretation of policy clauses when in doubt. The appropriate authority is the General Manager – Human Resources another committee member or the concerned Head of Department.

Employees should not refrain from bringing matters to the notice of the management because of clarity in understanding the policy. At the same time the grievances or complaints made on the basis of this policy should be carefully evaluated as improper understanding or lack of clarity could harm innocent employees against whom a grievance is registered.

In addition to the above, please refer to the policy on Prevention of Sexual harassment

It is important that every employee in Amara Raja understands what tantamounts to a conflict of interest.

A conflict of interest could arise in the following circumstances;

  • Between an employee(s) and the Company
  • Between two employees or a group of employees in the Amara Raja Group Companies.
  • Between our company and other companies and / or individuals
  • Between an employee and other companies and / or individuals

The following acts would constitute and lead to a conflict of interest:

Any act or acts indulged in or carried out or contemplated in an individual capacity done willfully or under coercion from others persons or parties and which consequently directly or indirectly affect or compromise on the interests of the company and its well being and security would constitute an act(s) tantamounting to a conflict of interest.

The following are some examples (not an exhaustive list) that illustrate what acts constitute and tantamount to a conflict of interest;

Indulging in business practices or deals with friends and relatives which directly or indirectly result in financial gain while in employment with Company.

  • However dealing in shares which is a legitimate activity would not constitute a breach of ethics provided an employee is not pursuing this activity during working hours and is not using the company’s infrastructure like communication infrastructure, manpower and time.
  • It is advisable that employees who have incomes [from family owned agriculture, rent from property, family owned industry etc] other than income by way of salary etc. from the Company should divulge the same to the Head of Human Resources.
  • Lending money and / or borrowing money from other employees whether with or without interest / other gain is a serious breach of ethics under this chapter. Collecting money and or distribution using fellow employee funds through formal / informal channels like chit funds etc. is strictly prohibited.

Lending and borrowing money, accepting or giving gifts of unusually high value stands in the way of healthy professional relationships in the organization and can lead to other undesirable practices in the organization. Similarly, lending money to individuals outside the organization for gain is a practice not encouraged by the company and is a breach of ethics under this chapter.

While receiving or giving gifts from fellow employees on birthdays, weddings and other social and religious ceremonies it would be prudent to restrict the value of these gifts to reasonable amounts. Every effort should be made to ensure that such transactions are kept transparent and free of controversy.

Collection drives for cash funds for buying gifts for birthdays , marriages of employees without the specific approval and permission of the Head of Human Resources of respective businesses is strictly prohibited.

Employees who have relatives and close friends working with the competition must voluntarily / freely divulge this information to the Company.

Appointing friends and relatives as suppliers and vendors is prohibited / strongly discouraged by the company. However, exceptions can be made provided such relationships are discussed with the top management prior to appointing them as vendors, suppliers or business partners.

  • In India social relationships are complex and it is possible that it is not always easy or clear as to who is directly or indirectly related to you. It is therefore advisable to check this out specifically with prospective vendors and suppliers and make this indemnity clause part of supplier / vendor terms and contracts.

Accepting remuneration in cash or kind for professional services, consultancy or / and advice rendered, accepting invitations for delivering lectures at seminars and training programs and educational institutions for remuneration / fees or ex-gratis without the prior written approval from the Company is a breach of ethics under this chapter.

Sharing financial information about the Company, shares related information, dealing in large amounts of the shares of the Company without the knowledge of the Company and other such or similar information for personal gain is a breach of ethics.

Attending business meetings and conferences with the competition, trade and other commercial and non – commercial bodies without prior approval or specific knowledge of the management. At such meetings the agenda and key issues to be discussed or agreed to at these forums must have the prior clearance of the management in writing.

Soliciting or providing vital information on manufacturing practices, R&D related information, pricing of products, sharing of drawings and patents and other such sensitive information from competition or any other organization or individuals without the consent or permission of the management.

Inviting members of the competition, trade and other institutions, equipment manufacturers and existing and / or prospective vendors and suppliers and taking them round our premises either at the head Office, COO and Field Offices without prior and specific approval constitutes a serious breach of ethics under this chapter.

Unfair distribution of business opportunities, favoritism, and clearly biased personal preferences in doing business with acquaintances, friends and relatives.

Formation of employee associations, groups, clubs, collecting funds from employees for whatever purpose, participating in demonstrating for public and social causes without prior specific knowledge and approvalfrom the management.

As part of business protocols, practices or transactions it is likely that we are required to entertain or be entertained for a business dinner or meal or meet in a public restaurant, hotel room, hotel or public place of entertainment.

However, great care must be exercised before extending or accepting an invitation of this nature.

Corporate entertainment is defined as entertainment, which is clearly part of business protocols and or practices. Hosting dinners or being part of such entertainment that is linked to corporate functions, part of business meetings etc will be deemed to be corporate entertainment.

Indulging in business entertainment that is unwarranted or not crucial / intrinsic to a business transaction will be viewed as an unethical practice for personal self-fulfillment.

Guidelines to accept and extend invitation for business entertainment:

  • Always obtain prior and specific consent and approval before accepting or extending invitations for Corporate entertainment. It is highly advisable to obtain prior written approval. Clearly establish the need and importance of such entertainment irrespective of the cost and who foots the bill for such entertainment. Entertaining corporate clients or being entertained by them on a casual basis, for fun or to kill time is strongly discouraged.
  • Avoid corporate entertainment on a one to one basis involving other fellow employees, corporate clients, business associates and partners. To the extent possible always entertain in a group.
  • If alcoholic beverages are to be served at such meetings obtain prior approval. Refrain, unless unavoidable, from entertaining in your hotel room. Always entertain in a public place.
  • Do not involve or invite other employees not associated with the corporate / business process at such occasions.
  • Do not invite friends and family members or other persons not associated directly with the corporate / business process unless an official invitation is extended to them to attend such occasions.
  • Do not entertain or accept invitations from corporate clients, business associates, vendors and suppliers at your or their residences for corporate entertainment. Strictly avoid business entertainment at home unless un-avoidable. Keep the Head of Department informed of such entertainment.
  • Frequent entertainment without a clear business or corporate objective will be viewed as a breach of this ethics policy.
  • Always ensure that you entertain within sanctioned budgets. The place and choice of entertainment should be in a reasonable and dignified place.

Strive to achieve business and corporate goals and create a business environment that is, to the extent possible, independent of corporate entertainment.

It is our Corporate as well as our social responsibility to protect our environment.

Our Corporate philosophy goes much beyond this thinking.

As a Company we will not adopt manufacturing and post manufacturing processes and waste disposal practices that are;

  • In contravention of national or international laws and norms governing such practices and procedures;
  • That will harm the natural environment and surroundings in which we and our social partners and neighbors reside.

In addition to the above, we will;

  • Make every effort to adopt practical and cost effective measures to ensure that we do not harm or damage our environment.
  • Train our employees to follow procedures and waste disposal procedures in handling hazardous waste.
  • Expose our employees and our environment to hazardous processes in accordance with the law and processes and acceptable practices governing such exposure.
  • Constantly upgrade our equipment and use of technology in managing our environment and ensuring it is kept safe and clean.
  • Design, manufacture, transport and sell our products and thereafter dispose of waste /obsolete products and materials in a manner which will not harm the environment or the users of our products.
  • To create manufacturing facilities which will be set in environment friendly and aesthetically designed and landscaped facilities, which will merge with and enhance the beauty of our physical surroundings.

We as a company believe that we are an equal opportunity employer.

We will offer employment to people who are sound of body and mind and qualify as per our Human Resources recruitment policies and selection processes. We will respect the laws of the land pertaining to the employment of disabled persons.

As an equal opportunity employer we believe in offering employment without bias or preferences based on age, caste, sex, race, color, religion or creed within the framework of the constitution of India and the laws of the land governing recruitment and terms and conditions of employment.

However the company will exercise every care to see that we do not make a breach of any national or international law(s) pertaining to making offers of employment to Indian nationals or foreign nationals.

The following would constitute a breach of ethics under this chapter;

  • Rejecting applicants at the stage of short listing applicants / applications or rejecting them during the selection processes based on age, caste, sex, race, color, religion or creed.
  • Providing, referring or recommending employment for relatives and acquaintances without the specific and prior approval of the management.
  • Not divulging names and other details of relatives and acquaintances currently in employment whenever requested for by the management.
  • Attempting to staff a team or a department with a clear bias and preference for employees of a particular sex, caste, creed, ethnic or geographical background.
  • Promising or committing employment on terms or conditions, which are not in compliance with the conditions stated above.

We at Amara Raja are committed to providing our employees with a healthy and safe working environment.

The responsibility of ensuring this healthy and safe working environment rests equally with the employees and those entrusted to mange them and their work environments.

Health and safety other than being a matter of technology and plant layouts and processes is more a result of a positive mindset and attitude. Every industry is fraught with unsafe and unhealthy processes and work practices inherent to the manufacturing processes.

Therefore, it is imperative that we follow some simple rules in making our workplaces healthy and safe;

Some of them are;

  • Thoroughly and carefully understand the processes and the unsafe, dangerous and unhealthy aspects of the manufacturing processes and environment in which you and your teams operate and work.
  • Remember that the safety and health of yourself and those around you depends on your understanding and practice of the safety rules of the company.
  • Attend and attentively participate in safety training programs. Practice what you learn.

The following acts would constitute a breach of ethics under this chapter;

  • Not reporting and / or ignoring dangerous occurrences or technical snags and equipment failure that could lead to an unsafe condition affecting lives and property.
  • Deliberately or callously ignoring or bypassing safety procedures and Standard Operating Procedures.
  • Reporting for duty under the influence of alcohol or drugs and substances that render you incapable of performing your normal duties and thereby compromising on the safety of lives plant and machinery.
  • Not using or preventing others from using safety equipment and gadgets provided by the company.
  • Preferring to ignore or turn a blind eye to acts and practices that could result in an unsafe condition.
  • Creating short cuts in work methods, bypassing safety nets and locks to expedite work and thereby resulting in an unsafe condition.
  • Not attending training sessions, classes and practicals whenever announced.
  • Not briefing or training your team members adequately and clearly about the dangers and unsafe conditions they might encounter in the course of dispensing their duties.
  • Forcing or coercing employees to by pass safety procedures to expedite work to meet production targets and deadlines.
  • Not reporting, recording and highlighting hazardous incidents as required under the rules of the Company and the law of the land.

In every functional area we are expected to maintain records and data. This data, records and information have to be captured and stored in a manner that they can be put to use and / or retrieved for future use. Some of this data has immediate implications on day-to-day transactions. Such records and data may pertain to financial transactions, manufacturing data, quality and R&D data, electricity meter readings, government related and statutory data etc.

It is therefore important that every employee who is entrusted with the responsibility to either capture, record or retrieve data is trained in the processes involved and is competent to understand the importance of maintaining the integrity of the data and records. They must fully appreciate how and why the data and records being maintained by them get dovetailed and integrated with other data.

In the ERP environment introduced in the organization this aspect of record keeping and data entry and retrieval is critical and important.

The following actions will severely affect and compromise on the integrity of data and record keeping in the company and would also constitute a breach of ethics in this chapter.

  • Willful and negligent capturing of data and records in the system, ledgers and registers whether in electronic or manual formats.
  • Altering, defacing, over writing of records and data whether done singly or in combination and connivance with others.
  • Not reporting to the management any information or incidents which involve other employees not maintaining the integrity of company records and data whether it is happening within or outside the department.
  • Manipulating or accessing data and records unauthorizedly and then passing / sharing it with other unauthorized persons.
  • Using data and information for personal gain.
  • Not adhering to protocols, steps and processes that are in force to ensure the proper use, recording and retrieval of data and records and information.

All employees in the Amara Raja Group of Companies are expected to respect, abide and practice the common Laws of the Land in force and as amended from time to time.

Remember Law of the Land is a complicated subject. Take ample care and effort to understand it fully.

It is difficult for the common man to fully understand the full extent and implications of every law of the land. However, ignorance of the law does not absolve you if you make a breach of a law of the land. Neither does a partial understanding or compliance mean that you have understood and abided by the law of the land.

In our businesses we are covered under the provisions of a wide plethora of laws and rules under various Acts and legislations. These are dynamic and keep changing. Every year with the financial budgets declared by the government laws pertaining to Income Tax, Goods and Services Tax, Central Excise and Export / Import duties etc. are impacted or changed. It is our legal obligation to understand these changes as and when they occur and implement them accordingly.

It is a well-known fact that law is also a matter of case law. Different High Courts are known to have taken contrary views in a matter of interpreting the laws of our country. It is therefore imperative that laws and changes in law that may have a financial bearing on the company or impact employee related service rules, terms of employment and benefits should not be left to chance interpretation.

It is therefore important to ensure that we carefully evaluate our contracts and agreements and have the legally cleared by a firm of advocates approved by the company. At times seeking legal advise and counsel from incompetent individuals / firms could lead the company into serious legal problems and implications in the log run. Short cuts and convenient interpretations should be avoided.

Guidelines to be followed in dealing with legal matters;
  • Ensure you have a sound and thorough understanding of the relevant under question.
  • Ensure you have the latest certified copy of the law or amendments as released by the government and their authorized agents.
  • Seek advice and counsel from reputed and competent firms or consultants approved by the Company.
  • Do not deal with touts, agents and quick fix operators who are available to provide such services outside every court or government office.
  • Do not hesitate and always seek a written opinion from legal counsels / advocates. This minimizes chances of you misinterpreting the law especially on complicated and important issues.
The following would constitute a breach of ethics under this chapter;
  • Taking a casual and irresponsible view of an aspect or provision of law.
  • Not ensuring that important contracts involving other external parties and having implications of finance, payments and manpower are cleared by a legal counsel and / or an authorized firm of advocates approved by the company.
  • Ignoring clauses and conditions in our contracts, agreements, purchase orders and dealings etc. that could be detrimental to our interests.
  • Not seeking legal counsel or professional advice in dealing with international trade, purchases and related contracts and agreements.

It is the duty of every Indian to protect the interests of the country.

With the business and trade doors opening wider the businesses we enter into and the relationships we develop nationally and internationally should be carefully evaluated and matters involving national security carefully evaluated. Whenever in doubt seek a legal opinion.

We as a corporate entity we must carefully evaluate that the businesses we are engaged in and the products we manufacture and sell are in no way compromising on the security of our nation.

To illustrate this please appreciate the following examples and situations.
  • It is possible that we may do business with the ministry of defence and in doing so are expected to visit defence installations, factories or are exposed to technical drawings and information. We must under such circumstances ensure that the information we share internally or externally are in no way a threat or compromise to our national security. We must ensure that that we protect the information we are in possession of and safeguard it from misuse by anti national elements or others with vested interests. If we are providing products as sub-contractors or sub-vendors in defence applications or installations we must ensure our interests are protected in our contracts.
  • As common citizens we must be careful about the kind of information we casually exchange about the nation’s defence related issues. Do not discuss such issues and matters with strangers or people you do not know well.
  • Providing information and assistance to persons, institutions, organizations and countries that are engaged in or have anti national interests would constitute a serious breach of national security and a serious breach of ethics under this chapter.
  • When entering into agreements and contracts make sure the contract terms are in no way detrimental to national security or compromise on our integrity and ethics as citizens of our country. As mentioned earlier it desirable to seek a legal opinion whenever in doubt.

Employees of Amara Raja are not expected to indulge in acts that would tantamount to an act of Anti-Trust. It is therefore imperative that employees understand the laws of the land applicable to our businesses and act in accordance with them and in a manner that would not compromise on the interests of the company.

The following acts would constitute a serious breach of ethics on the subject of Anti-Trust Laws;
  • Individuals or a group of individuals acting together with competitors to fix prices of the products we make and sell.
  • Individuals acting together to decide the extent and means of competition in the market.
  • Acting together to boycott trade agreements, products, sales territories and limit the production and sale of products would tantamount to a breach of Anti-Trust Laws.
  • Acting together and using unethical or illegal means to obtain information with the intention of gaining competitive advantage over the competition is a breach of Anti-Trust Laws.
  • Not seeking proper legal advice or ignoring legal advice deliberately in matters pertaining to the method and manner in which we make and sell our products in the open market and thereby violating Anti-Trust laws goes totally against the policies of our company.

Each one of us is entrusted with the responsibility of protecting the property and funds of the company within our control. This responsibility also extends to property and funds not in our direct control.

The following actions would severely compromise on the safe custody and proper use of company property and funds;
  • Using and permitting others to use company property without proper and adequate training and competence, which could result in severe danger and or damage to man, machinery and equipment.
  • Not reporting to the management the misuse of company property or funds.
  • Misusing funds of the company by temporarily lending them to others on short-term basis for personal use. Using funds for purposes other than those they were allotted for.
  • Use of Company stationery, computer stationery for personal use.
  • Using /directing / requisitioning the services of Company drivers and office boys and other personnel for personal errands other personal work / jobs at the work place or after working hours and errands even if volunteered for by them, unless specifically consented for as part of concierge services.
  • Not securing telephone lines by using dynamic locking, not securing lockers and drawers, cash boxes / safes, doors and windows at the end of the days work.
  • Not storing and or securing Company property so as to prevent theft or damage or misuse.
  • Not following Company rules and procedure pertaining to the use and safe custody of Company property and funds.

It is the duty of every employee to do whatever it takes to protect and safe keep the classified information of the company.

In the context of this chapter any information that is related to the financials, pricing and commercial information, Manufacturing Process and R&D related information etc is covered under the definition of “classified information”.

In this competitive age, information is the key to success. Persons with vested interests, vendors and suppliers, and the competition will always be keen to access such classified information. It is a part of corporate life we have to deal with. It is therefore imperative that we are alert at all times, how and when and with whom we share classified information.

The following actions would compromise on the use and security of classified information.

  • Not securing and locking away classified information.
  • Loose and casual sharing of passwords that protect files and data.
  • Not following security protocols. Always consult and seek help from the IT Help Desk to transfer and receive data and information safely.
  • Not sealing envelopes adequately when sending through the post or the courier services.
  • Not reporting the unusual and unrelated interest shown by employees and other outsiders in your area of work.
  • Not reporting unusual internal and external visitors to areas that are meant for restricted personnel only.
  • Sharing process related data, R&D data, Quality Assurance data etc that has not been authorized in advance.
  • Loose talk in public places about classified information and data.

It is imperative that we maintain a clean and professional relationship with our business partners, suppliers and vendors. These relationships should be strongly governed and influenced by our code of ethics and the general policies and rules of the Company.

Considering the complexities of the general law of the land, our internal value systems and the business environment in which we operate and conduct our business it is important to ensure that our relationships with our business associates do not attract scrutiny or investigation which could result in harming the reputation of our Company as well as individuals.

Guidelines for building relationships with suppliers, vendors and business associates:
  • Keep all business terms, deals, contracts, transactions and understandings above board by capturing them in a business document, contract or a memorandum of understating or any other standard legal document or practice.
  • Ensure that all business understandings are adequately protected and covered by appropriate laws of the land governing such transactions. Whenever in doubt seek advice or legal opinions form other competent colleagues / departments or authorized external consultants and advocates appointed by the company for this purpose.
  • Avoid completely verbal or personal assurances on a business deal or contract. It must invariably be recorded in a legal document or in the least by recording the minutes of business meetings. This especially applies t business deals and contracts that result in making or receiving payments.
  • Accepting gifts, gift coupons, personal discounts on products, exchange offers, sample products, product trial offers, money or any other form of gratification, directly or indirectly, during the course of or after entering in to and completing a business deal or contract would tantamount to a breach of this ethics policy.
  • Do not accept favors or arrangements whereby business associates provide services to you, your relatives either at your residence or in any other location or public place or establishment. Unless prior written approval is obtained from the company refrain from utilizing the services of business associates to buy, sell, procure or service and repair personal property like cars, real estate, electrical / electronic gadgets, personal computers. Refrain from using the services of electricians, plumbers, masons, interior decorators or civil contractors and material suppliers for personal use if they are providing similar or such services to the company.
  • Our business associates must be treated with the utmost respect and professionalism.
  • Refrain from bestowing favors, preferential treatment, sharing of confidential data, price sensitive information or giving undue advantage to our business associates in the course of negotiating and finalizing any business transaction. The systems you adopt have to be reflective of and be enshrined in such an approach to our business practices and relationships.
  • Refrain from appointing or utilizing the services of vendors and suppliers who are other employees, associates or relatives of other employees, personal friends and relatives. You must establish the relationships of our business associates with other employees of the company.
  • It is your duty and responsibility to ensure that we are associated with business associates whose credentials are impeccable and whose value systems and business ethics match completely in all respects with those of our company. You must conduct a formal reference check on critical vendors and suppliers and obtain written endorsements and recommendations with regard to their reliability, business practices and values before entering into a formal agreement or contract. These credentials should be periodically monitored and validate to protect the interests of the Company.
  • Refrain from entertaining or entering into a business relationship with vendors and business associates who have or are facing legal prosecution for breach of contract or the general laws of the land. You must obtain such an undertaking from them before entering into any business transaction.
  • Ensure that you are empowered or authorized to enter into a business deal or contracts with our business associates and that the terms of such transactions are completely acceptable to the Company. You must ensure that the interests of the company are protected at all times.

Our business practices and policies are governed and influenced by a variety of factors. Some of these are legal and statutory in nature and some are not within the control of the company and are largely environmental in nature. Our operations are also influenced by the way we use and deploy technology and science. Some aspects of our business are influenced and affected by financial and political events that may be national or international in nature.

It is the duty of every employee to be alert to such occurrences and events that may adversely affect our company and report such risk factors as early as possible. This will enable the company to take timely corrective or preventive action to protect the interests of the company its employees and business associates.

Guidelines to be followed under the ethics policy on Reporting of Risks:
  • Any employee who is privy to or comes in contact with a source of information that in his opinion is a source of risk and could harm the company in any way is duty-bound to report such risks to a responsible officer of the company immediately.
  • Risks the company could face could be a result of political, financial, economy driven, imminent natural disasters or willful / accidental operation and use of technology, operating machinery that could harm other employees or the environment. Knowledge of or apprehension regarding the occurrence of risk arising out of such factors should be reported immediately.
  • Activity and actions arising or likely to arise as a result of poor employee relations or Industrial Relations unrest and thereby exposing the company and its employees to risk must be reported immediately.
  • Unauthorized use and operation of company plant machinery, equipment, facilities, and utilities by untrained and unauthorized personnel is a potential source of risk and any knowledge or information in this regard must be reported immediately.
  • Sharing, forcing or using other employees to do so or the divulging of sensitive technical, product related or business related information, drawings, patents and other classified and confidential information to other employees, competitors or vested interests exposes the company to serious risk.
    Information regarding any employees or persons indulging in such activity should be reported to the senior management of the company or the committee on Code of Ethics immediately.
  • Withholding or forcing other employees and well wishers from divulging and reporting risks or potentially risky matters will constitute a breach of ethics under this ethics policy.

In our country and in many countries abroad, it is an established and accepted business practice to present and receive corporate gifts and mementoes. Our Group also endorses this practice by making and presenting corporate mementoes and gifts to its corporate business partners and associates.

This is done with the intention of thanking our business partners and associates for their patronage and / or association with our business and/or to mark special occasions

However, accepting gifts that are blatantly and obviously expensive is not at all acceptable. Presenting gifts should also be within reasonable limits, discussed and agreed with respective LOF/GROCOM member and not decided individually.

Guidelines for presenting and accepting corporate gifts:
  • Receiving gifts in cash or kind over & above the allowable limit as mentioned below as a result of finalizing or signing of a business contract or deal should not be accepted and any attempt by a business associate or business partner should politely but firmly declined.
  • Gifts should only be received/presented for specific reasons of important visits, to mark and commemorate landmark events in the company or usher in the New Year or some commonly celebrated religious festivals or while at an institution or conference for a public address/speech/interaction.
  • Corporate gifts and mementoes should be preferably having the name of the Institution/ advertisement of the product or services provided by a business partner, vendor or supplier or mention of a special event or introduction of a product or service. However, it is understood that during special occasions or festivals, it could only be the visiting card that might be attached along.
  • Gifts and mementoes either presented or accepted should be of poor resale value or virtually no commercial value and should be reasonably priced. The commercial or intrinsic value of such gifts / mementoes should not exceed INR1500/-. This limit is provided as a maximum and care must be taken not to presume that all the gifts could be of the maximum limit. If there is a need to present a gift beyond this limit, specific approval needs to be obtained from the respective GROCOM member.
  • Corporate gifts should be received in an open and elegant manner. Vendors, suppliers and business associates should be strongly discouraged from presenting such items at the residence or through courier or in person in a private manner.
  • Presenting/Receiving corporate gifts in a suspicious or surreptitious manner that can raise doubt and suspicion in the minds of other employees must be avoided.
  • Generally, accepting or presenting corporate gifts like desk/wall calendars, diaries, pocket planners, folders, inexpensive desk top clocks, pens, a box of sweets, dry fruits etc., are considered as acceptable. It is a good practice if anybody receiving a gift in the form of sweets / fruits etc., distributes the same to people working in their team/ office
  • The gifts as detailed above must be considered as a gift for the role that a person holds in the organization and not at a personal level
  • If a corporate gift is likely to result in a counter obligation, favour or affect the business relationship negatively should be firmly declined without hurting the sentiment of the corporate or individual making such a presentation.
  • Gifts which have been sent across by courier or messenger to residence and/or have been received inadvertently by you or someone in your absence, the same should be immediately informed to your respective Superior and Business HR Head. An official email or letter should be sent with a thanking note and politely mentioning that the same should have been avoided and also spelling out our code of ethics and values. If we realize the gift presented is expensive or has a high commercial value, the same should be informed to respective Superior and Business HR Head and should be returned. While returning the gift, an official email/letter should be sent politely communicating our inability to accept the same and also spelling out our code of ethics and values. The official letter/email to be sent should be vetted with the respective Superior and Business HR Head, to ensure that it is most polite and does not hurt any sentiments and also protects the interest of our Organisation. In cases where it is internally discussed that returning the gift will be inappropriate, in view of any sensitivity, the said gift may be deposited at the Office of Group HR Head providing all the information. Such gifts may be later utilized for any internal rewards or CSR activity.

Every employee of Amara Raja is expected to understand and appreciate his role and responsibility as a corporate communicator.

Each one of us is a spokesperson for the company. Our public and corporate imagery is linked with the quality of our communication.

We all communicate all the time with internal customers as well as external. It is therefore important that we understand and improve our communication constantly and take this responsibility seriously.

We are employees of the company twenty four hours a day and therefore we must be careful about what and how we communicate about the company and handle the communication related to our areas of work.

Some guidelines to handle corporate communication;
  • Communicate only what you are authorized to. If in doubt seek a clarification especially when communicating with external people and institutions.
  • Every functional area has confidential matters, data and information, which needs to be disseminated and shared carefully. Invariably keep the Function Head posted and involved in all such communication.
  • Especially when dealing with the press and other media like TV etc make sure you are authorized to deal with them and have the correct information.
  • Always prepare in advance for meetings with external bodies and individuals especially if you have to divulge or share a lot of sensitive information.
  • To minimize the risk of being misquoted always give information to the extent possible in writing. Keep another colleague present for important and sensitive briefings.
  • Keep your communication clear, unambiguous and accurate. Always seek prior approval and have your communication brief approved in advance.
What acts would constitute a breach of ethics under this policy;
  • Divulging to the public and press or other media sensitive information, which could have a grave or negative influence on the company.
  • Divulging information to external bodies or individual without prior permission and or approval / authorization in writing.
  • Corporate communication also entails internal communication. We must at all times maintain the dignity of the office we hold in the organization. Using unparliamentary and double meaning language that could hurt or intimidate is undesirable and would constitute a breach of ethics.
  • Transferring unauthorized data electronically or otherwise within and outside the company.
  • Sharing information pertaining to your service conditions, compensation and benefits, increments etc with persons other than your Head of Department or the Head of HR.
  • Sharing “sensitive” or divulging information not authorized in writing or approved by your Head Of Department. If in doubt about what to share with whom within and outside the organization seek a clarification instead of mis-communicating.
  • Speaking negatively about the company at public forums or within the company.
  • Signing documents and certificates and undertakings you are not authorized to or providing certificates, which contain false or falsified information.
  • Not ensuring or checking that you are communicating with a bona fide representative of the government and other institutions.

The Company has made and will continue to make investments in IT infrastructure to further electronic commerce mail and other related activities. In the process of migrating to an electronic environment it is important that all employees who use the electronic infrastructure like e-mails, Internet and other computing resources fully understand the use and responsibilities related to this medium of doing business.

The electronic revolution has not only changed the way we work but has also permeated into our homes and our personal lives. Therefore, employees must ensure that this infrastructure provided by the company is used purely for business purposes.

All information on the company’s computer systems including electronic mail is a property of Amara Raja. The company will therefore inspect and disclose information available on the computer systems at any point of time to ensure that such information is being used as expected for the sole purpose of the company’s business.

The following acts would constitute a serious breach of ethics and company’s policy on this subject covered in the chapter.

  • Sending and receiving offensive messages, data, pictures, videos etc which could hurt the sentiments and dignity of other employees in the company as well as the vendors, customers, suppliers of the company and the public in general.
  • Employees who access sites on the Internet which could contain abusive and offensive material related to sex, race and religion and / or other protected categories render themselves open for immediate dismissal.
  • Using the E-Mail and other electronic and communication infrastructure to intimidate, solicit, make suggestive proposals and harass employees of the opposite sex will merit immediate termination from the services of the company.

The Laws of the Land govern employees of our Company.

Therefore, such laws also govern the terms of appointment and service conditions of every employee.

Any employee who is involved in any court proceedings or any similar proceedings is expected to abide by the decisions of that court or forum.

Any employee who is involved in a criminal proceeding initiated against him other than and in connection with his employment with the company is expected to report the details of such criminal proceedings initiated or pending against him in writing within forty-eight hours of such an event occurring. This matter should be reported irrespective of whether he is convicted or not convicted of the criminal charges leveled against him. Any employee who is convicted of a serious criminal act is likely to lose his lien on employment with the company.

The following acts would constitute a breach of this ethics policy;
  • Ignoring Court Notices, intimation to attend enquiries instituted by the company.
  • Not co-operating with the government and statutory authorities in accordance with the laws of the land.
  • Not abiding by or following court orders or other decisions and directions that may arise out of legal and semi-legal proceedings which are in accordance with the laws of land.
  • Any employee who does not intimate the company personally or through an agent the details of an FIR lodged against him by any Police Station within forty-eight hours in writing.
  • Any employee who does not intimate his Head of Department or a Manager of the Company personally or through an agent the details of any criminal proceedings filed or pending against him in any court in the country within forty-eight hours in writing.
There are laws pertaining to International Business.
  • We must exercise extreme caution in exploring business opportunities internationally and when entering into trade and business agreements. We must also carefully evaluate what products we can supply and what information we can supply to our business partners in other countries keeping in mind the rules and laws of the country we choose to do business with.
  • The laws of our country prohibit the manufacture and supply of certain products to some boycotted or restricted countries. Such restrictions could be due to political, trade, commercial and / or other reasons and imposed by the relevant ministries governing international trade. We must ensure that we do not make a breach of such conditions of doing business internationally.
  • It is imperative that we carefully seek proper legal advice and have all contracts, agreements involving supply of products and terms of payment clearly defined. Every care should be exercised to ensure that the interests of the company are protected at all times.
1.0. OBJECTIVE
  • The policy has been laid out to ensure that there is a restriction in the age criteria for the employees working in the premises of any of the companies in the Amara Raja Group (ARG). The age stipulated for working is eighteen years completed and above and this is to ensure that child labour is eradicated.
2.0. APPLICABILITY
  • The minimum age for recruitment of any employee (defined as per clause 3.01 of standing orders i.e., Permanent, Probationers, Badli, Temporary, Casual, Trainee and Apprentice), Contract workers, Interns, Temporary staff, Fixed Term Employees in ARG, should be working after completion of eighteen years and above.
  • SDC students who are on the job training (OJT) and learning are exempted from this policy. These students will be away from dangerous and hazards environment for the sake of safety.
3.0. THE POLICY
  • ARG shall establish, document, maintain, and effectively communicate to all employees and other potential employees regarding this policy.
  • This is to ensure that there is a restriction in the age criteria for the employees working in the Factory premises that is completion of eighteen years and above to eradicate the child labour in the ARG.
  • The policy is to adhere to Child Labour Prohibition Act, and subsequently amended in 2016.
4.0. PROCESS TO BE FOLLOWED FOR ENSURING THE POLICY:
  • Proof of age for all employees will be maintained by Human Resources Department, as a part of personal file.
  • At the time of employment, Human Resources Dept also obtains signed application forms from the employee stating among other things his/her age and date of birth.
  • Age records of the candidate will be verified with SSC Book /Aadhaar.
  • Proper verification of age records to be done Talent Acquisition Cell (TAC) and HR Shared Services. Both TAC and Shared Services/Head are to be responsible of the record verification.
  • The age record should be placed in the personal file of the concerned employee for further verification.
  • Under any circumstances, the deviation of the Policy is not allowed.
5.0. EXPECTED BEHAVIOUR AND CULTURAL IMPACT
  • The Policy aims at child labour free environment at the workplace and to employ only persons who have completed eighteen years of age.
  • The Management is expected to resolve any deviation and advice so that it does not get repeated again.
6.0. GENERAL INFORMATION:
  • In case of any question that arises to the interpretation of the policy any clauses thereof or as to any rights or obligations arising from the policy, the decision of the Group HR Head shall be final and binding.

The Management reserves the right to withdraw, amend, alter or modify the policy at any point of time.

1.0 SPIRIT AND OBJECTIVE OF THE POLICY

Amara Raja is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. It is ARG’s policy to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice, wherever it operates throughout the world, by not engaging in bribery or corruption.

This Anti-bribery and Anti-corruption Policy (this “Policy”) applies to all employees (defined as per Standing Orders under Clause 3.0), including Directors and all stake holders associated with ARG.

2.0 THE POLICY

In this Policy, “stake holders” means any individual or organization, who / which come into contact with ARG or transact with ARG and also includes actual and potential employees, trainees, contract staff, potential clients, suppliers, business contacts, consultants, intermediaries, representatives, subcontractors, agents, advisers, joint ventures and government & public bodies.

A bribe is an inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. It is illegal to directly or indirectly offer a bribe or receive a bribe. It is also an offence as per Prevention of Corruption Act, 1988 to bribe a government/ public official. “Government/ public official” includes officials, whether elected or appointed, who hold a legislative, administrative or judicial position of any kind in a country or territory.

Presents, gifts, mementoes etc., which are permitted under the Corporate Gifts policy will not be deemed as bribe or corrupt practice.

A bribe may be anything of value and not just money i.e., inside information, sexual or other favors, corporate hospitality or entertainment, offering employment to a relative, payment or reimbursement of travel expenses, charitable donation or social contribution, abuse of function and can pass directly or through a third party. Corruption includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery.

3.0 APPLICABILITY OF THE POLICY

It is not acceptable for any employee of ARG (or someone on his / her behalf) to:

  • Accept an offer of a gift of any size from any Third Party which is in negotiation with, or is submitting a proposal with ARG
  • Give, promise to give or offer, any payment, gift, hospitality or advantage with the expectation or hope that a business advantage will be given or received or to reward a business advantage already given.
  • Give, promise to give or offer, any payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure.
  • Accept or solicit any payment, advantage, gift or hospitality from a Third Party that you know or suspect is being offered with the expectation that it will obtain a business advantage for them.
  • Threaten or retaliate against, another employee who has refused to commit a bribery offence or who has raised concerns under this Policy.
  • Engage in any activity that might lead to a breach of this Policy.

Business relationships

ARG expects all stake holders doing business with ARG to approach issues of bribery and corruption in a manner that is consistent with the principles set out in this Policy. ARG requires all Stake holders doing business with ARG to cooperate and ensure compliance with these standards, to continue the business relationship.

In order to maintain the highest standards of integrity, with respect to any dealings with the stake holders doing business with us we must ensure that:

  • Employees and associates shall conduct due diligence enquiries to review the integrity records before entering a commercial relationship with them.
  • Employees and associates shall fully document the engagement process and the final approval of the selection.
  • Employees and associates shall implement a program to provide appropriate information on this Policy to all engaged in business relationship with ARG
4.0 RESPONSIBLE FOR THE POLICY

The Head of Business / CEO / Branch Admin Manager has overall responsibility for ensuring that all employees should comply with the policy.

Managers at all levels are responsible for ensuring that those reporting to them are made aware of and understand this Policy.

The Compliance/ HR team is responsible for this Policy and for monitoring its use and effectiveness (and dealing with any queries on its interpretation). Management at all levels is responsible for ensuring that those reporting to them are made aware of and understand this Policy and adhere to it.

Every person to whom this policy applies is responsible for the success of this Policy and should ensure that he / she should use it to disclose any suspected activity or wrong-doing.

Misconduct in relation to bribery or corruption will be dealt with in relation to disciplinary policy and Certified Standing orders. (Ref: sec: 18.05 and 19.0)

5.0 EXPECTED BEHAVIOURS AND CULTURAL IMPACT

Amara Raja Group is committed to ensure that a culture of openness, honesty and integrity is encouraged and maintained. This will lead to zero tolerance towards fraud, bribery and corruption.

Amara Raja Group employees are committed to take on stand on fraud, corruption and they are positively encouraged to raise any concerns that they may have on these issues. Such concerns will be treated in confidence, properly investigated and fairly dealt with.

6.0 GENERAL INFORMATION:

In case of any question that arises to the interpretation of the policy any clauses thereof or as to any rights or obligations arising from the policy, the decision of the Group HR Head shall be final and binding.

The Management reserves the right to withdraw, amend, alter or modify the policy at any point of time without giving any notice.

1.0 SPIRIT AND OBJECTIVE OF THE POLICY:

The Amara Raja Group strongly believes Safety, health and Environment as one of its highest priority. It is well communicated that no one shall be under the influence of alcohol or drugs at work and that can seriously impair an individual’s judgment and reactions leading to occurrence of accident and injuries.

The aim of this policy is to ensure the safety of all the employees (employees defined as per Standing Orders under Clause 3.0) by having clear rules in place regarding use and possession of alcohol and drugs. This policy is also to help those who have reported having a problem with alcohol or drug dependence

For the purpose of the policy, alcohol dependence is defined as:

  • The habitual drinking of intoxicating alcohol whereby the ability to perform his/her duties is impaired or his/her attendance at work interfered with, or he/she endangers the safety of others.
2.0 PRINCIPLES TO BE FOLLOWED:
  • All employees will be treated consistently and fairly in line with this policy.
  • This policy on alcohol and drugs will be strictly enforced.
  • Those who admit to having a problem with alcohol or drugs shall be advised by their superiors to overcome and guide them to rehabilitate.
  • Employees who are habituated to alcohol or drugs are encouraged to disclose this at the earliest opportunity to ensure guidance for treatment.
  • All matters concerning alcohol and drugs brought to the notice shall be kept as confidential.
  • This policy is designed to comply with relevant legislation such as the Health and safety at Work and the Misuse of Drugs
3.0 APPLICABILITY:
  • This policy is applicable for Amara Raja Group.
  • The Company’s alcohol and drugs policy applies to all the employees and people working in Amara Raja
  • If any contractor workers are found under the influence of alcohol or drugs he would be advised to cease from work through the contractor.
4.0 RULES:
  • The Company’s policy is that during working hours and at all times whilst on work premises Employees must be free from the influence of drugs or alcohol. This will help to ensure the health and safety of the employees and others with whom they come into contact, to maintain the efficient and effective operation of the business, and to ensure customers receive the service they require.
  • The company reserves the right to check any person within the premises of the factory with breathe analyzer when suspiciousness arises.
  • When an employee is identified in the premises under the influence of alcohol intoxication, the company reserves the right to draw blood samples for alcohol intoxication analysis.
  • Misconduct in relation to alcohol and drugs will be dealt with in relation to disciplinary policy and Certified Standing orders. (Ref: sec: 18.12, 18.20 and 19.0)
5.0 GUIDANCE AND ADVICE:
  • The Company will endeavour to ensure that advice and guidance are made available to any employee who feels they have a problem with alcohol or drug misuse. In the first instance, individuals will be encouraged to seek advice from the Company Medical Doctor.
  • Under these circumstances and with the employee's consent, a referral will be made to the Occupational Health Centre, it may occasionally be necessary to request that the employee refrains from work temporarily, or undertakes restricted duties to ensure their own safety and that of others. The Company may also allow additional time off (normally unpaid) for employee to obtain treatment or attend counselling and support groups.
  • Any employee who seeks the assistance of the Company in finding treatment for a drugs or alcohol problem has the Company’s complete assurance of confidentiality.
6.0 EXPECTED BEHAVIOUR AND CULTURAL IMPACT
  • The Policy aims at Alcohol and drug free environment at the workplace and a healthy and safe atmosphere.
  • The Management is expected to resolve the grievances in any and also advice so that it does not get repeated again.
7.0 GENERAL INFORMATION:
  • In case of any question that arises to the interpretation of the policy any clauses thereof or as to any rights or obligations arising from the policy, the decision of the President – Group CI, Quality & HSE and Group HR Head and shall be final and binding.

The Management reserves the right to withdraw, amend, alter or modify the policy at any point of time.

1.0 SPIRIT AND OBJECTIVE OF THE POLICY

This Non-Discrimination and Equal Opportunities Policy ("Policy"), is an internal policy of Amara Raja Group (ARG), to ensure and adhere to non-discrimination and equal opportunities at the workplace.

This policy and procedure are applicable to employees (defined as per clause 3.01 of standing orders i.e., Permanent, Probationers, Badli, Temporary, Casual, Trainee and Apprentice), Contract workers, Interns, Temporary staff, Fixed Term Employees of the company.

2.0 NON-DISCRIMINATION

ARG will not discriminate, and prohibits discrimination at the workplace, on the basis of disability, gender, caste, sex, race, colour, religion, creed or sexual orientation.

ARG will condone any discrimination against any person on its premises

Any person who believes himself or herself to have been subjected to discrimination as mentioned in clause 2.1 should bring it to the notice of the immediate supervisor and the Leader of function (LOF) at the earliest opportunity.

No person will be punished, retaliated against, or limited in employment or other opportunity for filing a complaint, furnishing information for, or participating in an investigation, or any other activity related to the administration of this Policy.

3.0 EQUAL OPPORTUNITY

We as a company believe that we are employer who administers equal opportunity to all.

We will offer employment to people who are sound of body and mind and qualify as per our Human Resources recruitment policies and selection processes.

As an equal opportunity employer we believe in offering employment without bias or preferences based on disability, caste, sex, race, colour, religion or creed within the framework of the laws of the land.

However, the company will exercise every care to see that we do not make a breach of any national or international law(s) pertaining to making offers of employment to Indian nationals or foreign nationals.

The following would constitute a breach of ethics under this chapter;

  • Rejecting applicants at the stage of short listing applicants / applications or rejecting them during the selection processes based on disability, caste, sex, race, colour, religion or creed.
  • Providing, referring or recommending employment for relatives and acquaintances without the specific and prior approval of the management.
  • Not divulging names and other details of relatives and acquaintances currently in employment unless requested for by the management.
  • Attempting to staff a team or a department with a clear bias and preference for employees of a particular disability, caste, sex, race, colour, religion and creed.
  • Promising or committing employment on terms or conditions, which are not in compliance with the conditions stated above.
  • Any deviation to this policy would be seriously dealt with and will be reported to through the department head to the management. Based on the instance management would decide and take necessary action.
4.0 EXPECTED BEHAVIOUR AND CULTURAL IMPACT

The Policy aims at facilitating non-discrimination at the workplace and equal opportunities

The Management is expected to resolve the grievances if any and also advice so that it does not get repeated again.

GENERAL INFORMATION:

In case of any question that arises to the interpretation of the policy any clauses thereof or as to any rights or obligations arising from the policy, the decision of the Group HR Head shall be final and binding.

The Management reserves the right to withdraw, amend, alter or modify the policy at any point of time.

1.0 SPIRIT AND OBJECTIVE OF THE POLICY
  • 1.1 Amara Raja Group is committed to create a healthy and invigorating working environment for all people. This policy is specifically focused to women working in/for any companies in Amara Raja Group, to enable them work without fear of prejudice, gender bias and sexual harassment.
  • 1.2 The objective of this policy is to provide protection against sexual harassment of women at workplace and for the prevention and redressal of complaints of sexual harassment and for matters connected therewith or incidental thereto.
2.0 EFFECTIVE DATE AND SCOPE
  • 2.1 The policy comes into force with immediate effect
  • 2.2 This policy applies to all women whether employed or not, at any of the work place/premises of any of the companies in the Amara Raja Group
3.0 DEFINITIONS & MEANINGS
  • 3.1 Sexual Harassment: includes any one or more of the following unwelcome acts or behavior (whether directly or indirectly) namely:-
    • a) physical contact and advances; or
    • b) a demand or request for sexual favours; or
    • c) making sexually colored remarks ; or
    • d) showing pornography; or
    • e) any other unwelcome physical, verbal, non-verbal conduct of sexual nature;
    • The following circumstances, among other circumstances, if it occurs or is present in relation to or connected with any act or behaviour of sexual harassment may amount to sexual harassment:-

    • f) implied or explicit promise of preferential treatment in her employment; or
    • g) implied or explicit threat of detrimental treatment in her employment; or
    • h) implied or explicit threat about her present or future employment status; or
    • i) interferes with her work or creating an intimidating or offensive or hostile work environment for her; or
    • j) humiliating treatment likely to affect her health or safety.
  • 3.2 Aggrieved woman: “Aggrieved woman” means any woman working for Amara Raja Group on the rolls of the Company or not, including those on deputation, ARTS, Contract, Part time or working as Consultants.
  • 3.3 Chairperson: “Chairperson” means who is heading the Internal Complaints Committee.
  • 3.4 Complaint: “Complaint” means a written statement disclosing identity of Complainant and Alleged with narration of the incident on sexual harassment duly signed by the Complainant.
  • 3.5 Local Support Representative (LSR): A representative from each location who will help in smooth execution of PPSH, extend necessary support to female aggrieved employee and to ensure that the complaints will be genuine.
4.0 CONSTITUTION OF INTERNAL COMPLAINTS COMMITTEE (ICC)
  • 4.1 An Internal Complaints Committee has been constituted by the Management to consider and redress complaints of Sexual Harassment which is shown in Annexure - I. The Committee constitutes five members:
    • a) Mrs. Sulochana V, Asst. General Manager-CI (M05), ARBL-COM as Chairperson;
    • b) Mrs. Amulya. S, Manager - ERP-Transformation (M6A), ARBL-COM
    • c) Mrs. Satya Sobha, Manager-QA (M6A), AREL;
    • d) Mr. Andrew Jayakumar, Head – Shared Services (HR &A) (M04), ARBL-COM;
    • e) Dr. S A Thasleem Sulthana (External Member), Abhaya Kshethram, Renigunta.
  • 4.2 A Local Support Representative (LSR) is available at each location and the details of the LSRs are available with respective Business HR team, Shared Services and on “AR Engage”.
5.0 PROCESS OF COMPLAINT HANDLING:
  • 5.1 Any aggrieved woman who feels and is being sexually harassed directly or indirectly may send a complaint as per Annexure – II in a sealed cover narrating the alleged incident in writing with her signature within 10 days of occurrence of incident to the Chairperson / any member of the ICC as prescribed in Annexure - I.
  • 5.2 Within fifteen days, the Committee members shall hold a meeting with the Complainant and shall hear the Complainant and record her allegations. The Complainant can also submit any corroborative material with a documentary proof, oral or written material, etc., to substantiate her complaint.
  • 5.3 Thereafter, within ten days of discussion with the complainant, the committee shall hold a dialogue with the alleged for further clarification on the complaint.
  • 5.4 Subsequently, the Complainant and the Alleged are called upon for the process of conciliation to settle the issue at mutual consensus.
  • 5.5 In the case of disagreement in the Conciliation process, an “Enquiry” shall be conducted and concluded by the Committee in the laid-down process.
  • 5.6 It is left to the discretion of the ICC to cross-examine the Complainant and the Alleged.
  • 5.7 If the Complainant or the person, against whom complaint is made, desires any witness/es to be called, they shall communicate in writing to the Committee the names of witness/es whom they propose to call.
  • 5.8 The Committee shall call upon all witnesses mentioned by both the parties.
  • 5.9 The Committee shall provide every reasonable opportunity to the Complainant and Alleged, for putting forward and defending their respective case.
  • 5.10 The ICC shall hold discussions with concerned parties and share their findings and recommendations to the Management (Group Chairman / Vice Chairman and President – Group HR) within 40 days from the closing of discussion with the alleged. (Within Seventy five days from the date of receipt of complaint).
  • 5.11 The recommendations of the committee shall be treated as an enquiry report on the basis of which an erring employee will be awarded an appropriate punishment within 90 days from the date of receipt of Complaint and in line with Certified/Model Standing Orders / Service Rules of the Company.
  • 5.12 The probable punishment will be Censure, Warning, Fine, Suspension, Dismissal or any other punishment proposed basing on the severity of the incident.
6.0 GENERAL CONDITIONS:
  • 6.1 The Complainant and the alleged shall work for Amara Raja only.
  • 6.2 In the event, the complaint does not fall under the purview of Sexual Harassment or the complaint does not mean an offence of Sexual Harassment, the same would be dropped after recording the reasons thereof.
  • 6.3 In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management.
  • 6.4 The Committee shall keep complete and accurate documentation of the complaint, its investigation and the decision thereof. The incident would be documented in both the complainant’s and the alleged’s files with the full report of the Complaints Committee.
7.0 EXPECTED BEHAVIORS AND CULTURAL IMPACT:
  • 7.1 The Policy aims at facilitating speedy and transparent resolution of grievances pertaining to Sexual Harassment of Women at workplace.
  • 7.2 The respective members of Internal Complaints Committee are expected to resolve the grievances in an amicable settlement preferably in conciliation manner.
8.0 GENERAL INFORMATION:
  • 8.1 In case of any question arises to the interpretation of the scheme or any clauses thereof or as to any rights or obligations arising from the policy, the decision of the President- Group HR shall be final and binding.
  • 8.2 The Management reserves the right to withdraw, amend, alter or modify the policy at any point of time.
ANNEXURE – I

(As per policy clause 4.1)

Internal Complaints Committee Members and their Addresses

Mrs. Sulochana V,
Asst General Manager-CI
Amara Raja Batteries Limited,
Karakambadi – 517 520, Tirupati,
Chittoor Dist A.P.
Ph: 0877 – 2265000 Extn:7407
Email: vsc@amararaja.co.in
Mrs. Amulya. S,
Manager - ERP-Transformation
Amara Raja Batteries Limited,
Terminal A
1-18/1/AMR/NR, Nanakramguda
Gachibowli, Hyderabad - 500032
Ph: 040 – 23139000 Extn:9022
Mrs. Satya Sobha,
Manager - QA
Amara Raja Electronics Limited,
Diguvamagham (Village & Post)
Thavanampalli (Mandal)
Chittoor District, AP – 517 129
Ph: 08573 – 283636 Extn: 4280
Mr. Andrew Jayakumar,
Head – Shared Services (HR &A)
Amara Raja Batteries Limited,
Karakambadi – 517 520, Tirupati,
Chittoor Dist A.P.
Ph: 0877 – 2265000 Extn:7272
Dr S A Thasleem Sultana,
Founder – Abhaya Kshethram
Near Railway Gate
Renigunta – 517 520
Chittoor Dist.

ANNEXURE II

(As per policy clause 5.1)

  COMPLAINT LETTER

Location Support Representative (LSR) under policy on Prevention of Sexual Harassment (PPSH) reconstituted on 14-Feb-2017