Preamble
GEE’s Code of Conduct was
circulated to the employees last year
and is posted on the Company’s corporate
website. This Code is derived from three
interlinked fundamental principles, viz.
good corporate governance, good corporate
citizenship and exemplary personal conduct.
Philosophy
GEE is a professionally managed organisation
and the core value underlying our corporate
philosophy is "trusteeship".
We believe this organisation has been
handed to us by the various stakeholders
in "trust" and we as professionals
are the "trustees" of these
stakeholders. It is therefore our responsibility
to ensure that the organisation is managed
in a manner that protects and furthers
the interests of our stakeholders. We
recognise society as an important stakeholder
in this enterprise and therefore it is
part of our responsibility to practise
good corporate citizenship.
It is also our belief that in order to
serve the interests of our stakeholders
in perpetuity, we must build GEE into
an institution whose dynamism and vitality
are anchored in its core values.
Corporate Governance
Policy
The Corporate Governance Policy is the
apex level instrument guiding conduct
of the affairs of the Company and clearly
delineates the roles, responsibilities
and authorities of the key entities in
the governance structure of the Company.
This Code forms an integral part of the
Company’s Governance Policy. The
directors, senior management and employees
must adhere to the Corporate Governance
Policy of the Company.
Good Corporate
Citizenship
In the conduct of the Company’s
business, the practice of good corporate
citizenship is a prerequisite and embraces
the following:
Dealing with People in the Organisation
In dealing with each other, directors,
senior management and employees shall
uphold the values which are at the core
of our HR Philosophy - trust, teamwork,
mutuality and collaboration, meritocracy,
objectivity, self respect and human dignity.
Indeed, these values form the basis of
our HR management systems and processes.
GEE will focus on meritocracy, equity
and upholding of Company values in all
people processes including performance
management systems, appraisals, remuneration
and rewards.
A Gender Friendly Workplace
As a good corporate citizen, GEE is committed
to a gender friendly workplace. It seeks
to enhance equal opportunities for men
and women, prevent/stop/redress sexual
harassment at the workplace and institute
good employment practices.
GEE maintains an open door for reportees;
encourages employees to report any harassment
concerns and is responsive to employee
complaints. A committee has been constituted
to enquire into complaints and to recommend
appropriate action, wherever required.
GEE demands, demonstrates and promotes
professional behaviour and respectful
treatment of all employees.
Relationships with Suppliers
and Customers
All directors, senior management and employees
shall ensure that in their dealings with
suppliers and customers, the Company’s
interests are never compromised. Accepting
gifts and presents of more than a nominal
value, gratuity payments and other payments
from suppliers or customers will be viewed
as serious breach of discipline as this
could lead to compromising the Company’s
interests.
Legal Compliance
It is the Company’s policy to comply
fully with all applicable laws and regulations.
Ensuring legal and regulatory compliance
is the responsibility of the Chief Executives
of the Business and the Divisional Management
Committees. The Company cannot accept
practices which are unlawful or may be
damaging to its reputation. Divisional
Management Committees must satisfy themselves
that sound and adequate arrangements exist
to ensure that they comply with the legal
and regulatory requirements impacting
each business and identify and respond
to developments in the regulatory environment
in which they operate. In the event the
implication of any law is not clear, the
Company’s Legal Department shall
be consulted for advice.
Health and Safety
The Company attaches great importance
to a healthy and safe work environment.
GEE is committed to provide good physical
working conditions and encourages high
standards of hygiene and housekeeping.
Particular attention should be paid to
training of employees to increase safety
awareness and adoption of safe working
methods, particularly designed to prevent
serious or fatal accidents.
Environment Policies
The Company believes that commitment to
sustainable development is a key component
of responsible corporate citizenship and
therefore deserves to be accorded the
highest priority. Accordingly, the Company
is committed to Best Practices in environmental
matters arising out of its business activities
and expects each employee to fully demonstrate
this commitment.
In addition to complying with applicable
laws and regulations, employees should
adopt Best Practices in their environmental
policies and procedures.
Personal Conduct
All directors, senior management and employees
have the obligation to conduct themselves
in an honest and ethical manner and act
in the best interest of the Company at
all times. They are expected to demonstrate
exemplary personal conduct through adherence
to the following:
Avoidance of Conflict of Interest
All directors, senior management and employees
must avoid situations in which their personal
interest could conflict with the interest
of the Company. This is an area in which
it is impossible to provide comprehensive
guidance but the guiding principle is
that conflict, if any, or potential conflict
must be disclosed to higher management
for guidance and action as appropriate.
Transparency and Auditability
All directors, senior management and employees
shall ensure that their actions in the
conduct of business are totally transparent
except where the needs of business security
dictate otherwise. Such transparency shall
be brought about through appropriate policies,
systems and processes, including as appropriate,
segregation of duties, tiered approval
mechanism and involvement of more than
one manager in key decisions and maintaining
supporting records. It shall be necessary
to voluntarily ensure that areas of operation
are open to audit and the conduct of activities
is totally auditable.
Protection of Confidential Information
No director, senior management and employee
shall disclose or use any confidential
information gained in the course of employment/
association with the Company for personal
gain or for the advantage of any other
person. No information either formally
or informally shall be provided to the
press, other publicity media or any other
external agency except within approved
policies.
Company Facilities
No director, senior management and employee
shall misuse Company facilities. In the
use of Company facilities, care shall
be exercised to ensure that costs are
reasonable and there is no wastage.
Leading by Example
The organisation’s directors
and senior management set the professional
tone for the Company. Through both their
words and their actions, the organisation’s
leadership conveys what is acceptable
and unacceptable behaviour. GEE’s
directors, senior management and employees
must constantly reinforce through their
actions and behaviour that GEE’s
stated beliefs of responsible corporate
citizenship are rooted in individual conviction
and personal integrity.
Waivers
Any waiver of any provision of this Code
of Conduct for a director, senior management
or employee must be placed for approval
before the Company’s Board of Directors.
Non Adherence
Any instance of non-adherence to the Code
of Conduct / any other observed unethical
behaviour on the part of those covered
under this Code should be brought to the
attention of the immediate reporting authority,
who shall in turn report the same to the
Managing Director.
