NSL Sugars expects employees to adopt ethical practices in their functional areas as well as when they represent the company to the statutory/government authorities.
Our employees shall not offer directly or indirectly anything of value (such as bribes) to any customer or government official to influence a reward or action in favour of the Company. A business courtesy, such as gift, contribution or entertainment should never be offered under such circumstances that might appear to be impropriety.
There are certain obligations that are common to all employees:
NSL Sugars is responsible for properly recording, preserving and reporting financial information to investors, statutory bodies, shareholders and others and to maintain a system of internal accounting controls. We must follow generally accepted accounting principles, standards, laws, regulations and NSL Sugars practices for accounting and financial accounting.
Managers have a vital role to play in ensuring that the code of conduct is followed in letter and spirit within the organization.
Don’t s :
Compliance of the Code of Conduct is a must. Employees who violate the spirit or letter of these policies are subject to disciplinary action up to and including discharge.
Broadly, the violation of the code of conduct may be categorised into the following three types: -
NSL Sugars employees at all levels are prohibited from taking retribution against any one for reporting or supplying information about a policy concern.
As a conscious and vigilant organization, NSL Sugars believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting the highest standards of professionalism, honesty, integrity and ethical behavior. This policy is formulated to create a fearless environment and provide opportunity to employees to access in good faith, to the committee in case they observe instances of unethical and improper practices, actual or suspected fraud, or any other wrongful conduct in the company and to prohibit managerial personnel from taking any adverse personnel action against those employees.
This policy shall be applicable to all employees of NSL Sugars, third party vendors, consultants, customers etc operating out of any location of the company.
Whistle blower: An employee who exposes or makes a disclosure of the unethical and improper practices within an organization in the hope of stopping it. Unethical and improper practices shall mean:
Committee Committee shall mean a committee of NSL Sugars, constituted in accordance with provisions of section 177 (9) of companies Act, 2013.
Protected Disclosure The reporting of any such unethical activity or violation to the committee by a whistle blower as defined above made in good faith would constitute a protected disclosure.
This policy prohibits its employees to take any adverse personal action against its employees for disclosing in good faith any unethical and improper practices or alleged wrongful conduct committed. Any employee against whom any adverse personnel action has been taken due to his disclosure of information under this policy may approach the committee.
An employee who knowingly makes false allegations of unethical and improper practices or alleged wrongful conduct to the committee shall be subject to disciplinary action in accordance with company rules, policies and procedures. Further, this policy may not be used as a defense by an employee against whom an adverse personnel action has been taken independent of any disclosure of information by him and for legitimate reasons or cause under company rules and policies.
Procedure of Investigation :
The committee shall make a detailed written record of the protected disclosure. The record will include:
The committee shall finalize and submit the report to the chairman within 30 days of being nominated/ appointed.
It is the discretion of the committee to inform the whistleblower of the final outcome of the protected disclosure made.
On submission of report, the committee shall discuss the matter with Chairman of the committee.
In accordance with the facts and finding on the report giving by whistle blower a suitable reward decided by the committee will be giving to the concerned whistle blower.
In case the protected disclosure is proved, as per the findings of the committee, Disciplinary Action may be taken up to and including termination and also ensure preventive measures to avoid re-occurrence of the matter. In case the protected Disclosure is not proved, the matter shall be extinguished.
During the investigation period or at any time thereafter, if any employee is found to be A) retaliating against the complaint B) coaching witness or C) tampering with evidence, then it would lead to severe disciplinary action in accordance with company rules, policies and procedures.
In exceptional cases, where the whistle Blower is not satisfied with the outcome of the investigation and the decision, s/he can make a direct appeal to the chairman of the audit committee.
No unfair treatment will be meted out to a whistle Blower by virtue of his / her having reported a protected disclosure under this policy. The company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against whistle blower. Complete protection will, therefore, be given to whistle Blower against any unfair practice like retaliation, threat or intimation of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion etc.
The company will take steps to minimize difficulties, which the whistle Blower may experience as a result of making the protected disclosure. The identity of the whistle Blower shall be kept confidential. Any other Employee assisting in the said investigation or furnishing evidence shall also be protected to the same extent as the Whistle Blower.
The committee shall review the Company’s arrangements for its employees to raise concerns, in confidence, about possible wrongdoing in financial reporting, accounting or other related matters. The committee shall ensure that these arrangements allow independent investigation of such matters and appropriate follow up action. The Whistle blowing mechanism shall provide for adequate safeguards against victimization of persons who use such mechanism and make provision for direct access to the chairperson of the Audit Committee in appropriate or exceptional cases