Code of Conduct and Business Ethics

At Havelock One Interiors, we have an unwavering commitment to “Doing what is right” irrespective of how demanding or challenging the situation is. We must act with sincerity and integrity in everything we do, in every decision we make, and in every decision, we see others make. This will enable us in achieving the highest professional standards in conducting our business. In our business activities and relationships, we should demonstrate integrity, trust and professional leadership.

Below 15 principles constitute our Code of Conduct and Business Ethics and guide our day-to-day behaviour at work.

Principle 1: We provide equal opportunity and value diversity

Havelock One is an equal opportunity employer and values diversity. Our hiring practices and subsequent dealings with our employees (work opportunities, promotion, training and development, etc.) are purely on the basis of competency, performance and regulatory requirements, and they are free from any discrimination on the basis of race, colour, creed, religion, gender, nationality or ethnicity, age, sexual orientation or disability. The same principle applies for any dealings with our Business Associates.

Principle 2: We do not tolerate harassment or abusive behaviour

Havelock One does not tolerate any instances of harassment or abusive behaviour towards its employees or Business Associates.

Harassment includes any behaviour or conduct which is intimidating, insulting or offensive. It may or may not interfere with a co-worker’s or Business Associate’s ability to do his or her job effectively. Harassment and abusive behaviour include bullying, humiliation, inappropriate language or gestures, offensive remarks about religion/nationality/ethnicity, violence, making sexist jokes or misogynist humour, etc. It can be verbal, physical, sexual and/or psychological.

Principle 3: We adhere to local labour laws and respect international labour rights conventions

Havelock One is committed to adhere to local labour laws and to respect international labour rights conventions wherever we operate. Our human resource policies and practices are developed accordingly, and we prohibit child labour, forced labour or bonded labour of any kind. We respect the free will of our workers and do not restrict their freedom of movement.

We also encourage our employees, sub-contractors and third parties associated with us to adhere to the same labour rights as we do and encourage them to report non-compliances.

Principle 4: We care for the health and safety of our employees

Havelock One endeavours to provide safe working conditions to all our employees. We believe that it is their fundamental right.

We regularly assess the health and safety-related risks associated with our operations. We take appropriate measures to prevent accidents, injuries, and occupational health hazards. In doing so, we are fully committed to complying with the applicable laws and regulations related to health and safety.

Carrying or possession of any weapon at work is also strictly prohibited (exception: security personnel).

Principle 5: We conduct ourselves in a responsible and professional manner

Havelock One recognises its responsibilities towards shareholders, employees, Business Associates, bankers, regulators, and the society at large and conducts its business operations in a legitimate and professional manner.

We also recognise that, while we may have our individual preferences and choices, our success depends on how consistently we work as a team. We firmly believe that, functioning within our operating philosophy, adhering to our corporate policies and operating procedures, maintaining cohesive work environment and enabling others to deliver, help us achieve this objective.

As a rule, all our employees are prohibited from consumption, possession or distribution of alcohol, narcotics, or any other intoxicating substance while at work (in our office buildings, factories, project sites, client locations, etc.). Attending the work under the influence of such intoxicating substances is also prohibited. These rules apply to the Company organised gatherings, team meetings, outings or such similar occasions. Consumption of liquor is also prohibited in the Company organised events. Further, employees are advised to refrain from consuming liquor during the business hours when representing Havelock One in corporate events.

Principle 6: We operate in adherence with applicable laws and regulations

Havelock One conducts its business operations in strict compliance with laws and regulations applicable in the geographies it operates.

Given that we operate in multiple countries, laws and regulations that govern our business operations may differ. We are required to understand them and strictly comply with the applicable requirements. Wherever they differ, as a rule of thumb, unless required otherwise, our endeavour is to adhere to the most stringent regulatory requirements.

We are prompt and transparent in our interactions with regulatory authorities and government agencies.

Principle 7: We use media responsibly and wisely

Havelock One communicates responsibly – whether it is in print media, on online web portals or social media. Only authorised officers of the Company are permitted to advertise, interact with media and post or tweet on behalf of the Company.

We recognise the right of our employees to use social media for self-expression as well as networking. We expect our employees to conduct themselves in a responsible and matured manner in their online activities. All the principles of our Code, which govern our offline conduct, also apply to our online comments, postings, or other activities.

Our employees are permitted to share or retweet information or any other official communication that is released by our corporate accounts to the public at large; however, they are restricted from posting any information, images, or updates about the Company or its employees, brands, clients, projects, financial results, etc. on the internet and social media without prior approval from our Head of Marketing.

Further, in case you encounter any questions or queries from media, please refer them to our Head of Marketing.

Principle 8: We maintain the confidentiality of business data and employees’ personal details

Havelock One understands sensitivity associated with data and information belonging to the Company, employees, or our Business Associates. Our obligation to maintain the confidentiality of data and information received or accessed (either officially or inadvertently), created, or processed by us is implicit as this data and information belong either to the Company or its employees or its Business Associates. Also, in some cases, due to the non-disclosure agreements signed with our clients, we are contractually obliged to maintain strict confidentiality of their data and information.

Confidential data and information include employee files, strategy documents, organisation charts, business plans, budgets, statements of accounts, contracts, costing and pricing details, contracts with service providers, drawings, diagrams, changes in business operations, changes to management, client lists, vendor lists, marketing plans, etc. It should be noted that this list is for illustration purpose only and it is by no means an exhaustive list.

You should treat all data and information as confidential and only share with others on a need-to-know basis for legitimate official use. You are required to access, store, and transmit such data and information in a secured manner. Your obligation to maintain the confidentiality of business data and employee’s personal details continues even after you leave the Company.

Principle 9: We always act in the interest of the Company and avoid conflicts of interest

Havelock One expects its employees to act with the highest level of integrity. Every decision we make while working with Havelock One should be objective and in the interest of the Company.

Conflict of interest is a situation where an employee’s personal interests or benefits influence or may influence his/her business decisions. Such situations may arise when personal relationships, business ventures, vocations or investments are involved. Employees must recognise such situations of actual or potential conflicts of interest and make appropriate disclosures as follows:

– Employees (excluding direct reports of Executive Management): to HR Director
– Direct reports of Executive Management: to Executive Management
– Executive Management: to the Board

Employees should always apply the yardstick of “substance over form” while assessing whether a particular situation falls within the ambit of conflict of interest. Some situations may not actually fall within the ambit of conflict of interest but may appear so to others. Hence, it is advisable to make appropriate disclosure.

Principle 10: We do not use the Company’s assets or money for personal use or benefit

Havelock One prohibits the use of the Company’s assets or money for personal use or benefit. For this purpose, the Company’s assets include its tangible assets (e.g. office building, laptops, mobile phones, cars, etc.) and intangible assets (e.g. brand, trademarks, copyrights, drawings, software, etc.) and its eco-system.

As a general rule, all business data created by our employees while in service with Havelock One belongs to the Company and it cannot be used for personal gain. Similarly, assets provided by the Company to its employees should be used for business purpose only.

We expect our employees to exercise the same level of prudence and financial propriety as they would exercise for their own assets or money. Occasional minor and incidental use of electronic communication devices provided by the Company for personal purpose is permitted when there is no incremental cost or minimal incremental cost to the Company.

In any case, use of the Company’s assets or money for any illegal, unlawful, immoral, unethical, or political purpose is strictly prohibited.

Principle 11: We maintain accurate and adequate records of our business transactions

Havelock One maintains accurate and adequate records of its business transactions – financial as well as non-financial. We are committed to making full, fair, accurate, timely and clear disclosures in our financial statements and other legal documents submitted to our stakeholders, regulatory authorities, and bankers.

In order to facilitate the accurate and timely recording of business transactions, the Company has defined appropriate workflows, procedures and approval requirements (these are revised or updated on a regular basis). Furthermore, the Company has also implemented Information Technology (IT) Systems to initiate, authorise, process and record business transactions. Employees should adhere to these requirements carefully.

All records and supporting documents/vouchers should be retained in accordance with applicable record-keeping laws or internal guidelines. For digital records, employees are required to adhere to IT policies/guidelines related to maintaining and protecting data stored on their IT systems.

Principle 12: We build our business relationships on integrity and transparency

Havelock One believes that integrity and transparency are key ingredients for building successful business relationships. Our behaviour, when driven by integrity and transparency, helps us create an environment of trust and mutual respect. It is very important that we adhere to this principle in our day-to-day activities. This requires us to follow certain basic rules while operating within our eco-system:

When dealing with our clients or prospective clients:	When dealing with suppliers (includes other service providers):
– Treat our current and prospective customers fairly and deliver on our commitments. – Ensure that our advertisements are not misleading or deceptive. – Adhere to contractual terms and conditions. – Understand clients’ codes of conduct and comply with them.	– Engage with suppliers who uphold and adhere to the principles outlined in our Vendor Code of Conduct. – Select suppliers objectively – basis criteria of price, quality, service parameters and market reputation. – Do not exploit or mistreat our suppliers.

 

Principle 13: We do not indulge in corrupt or unethical business practices

Havelock One does not give or receive, whether directly or indirectly, any bribes, kickbacks, commissions, or other improper advantages or financial or non-financial benefits (collectively referred as “bribes” or “bribery”) for achieving its business objectives. No employee, directly or otherwise, should demand, receive, or offer bribes. Any demand for or offer of a bribe must be immediately rejected and reported to the Head of Internal Audit & Risk.

We strictly comply with the applicable anti-corruption and anti-bribery laws and expect our Business Associates to do so.

Bribes may be disguised as gifts (cash or non-cash) and entertainment. Therefore, employees are required to demonstrate sound judgement and caution in offering or accepting any gifts or entertainment. They are required to go through our policies in this regard and abide by them.

Principle 14: We condemn acts of fraud and corporate espionage

Havelock One conducts its business ethically and expects the same from its employees and Business Associates. We condemn any acts of fraud or corporate espionage, and such acts by our employees or Business Associates would lead to the immediate termination of our relationship. We also reserve our right to initiate legal proceedings in such cases.

When we employ any staff previously employed with our competitors or Business Associates, we understand and respect their obligations relating to protecting confidential data or information of their former employers or clients. We do not expect them to pass on those details to us.

Principle 15: We are committed to promoting environmentally responsible and sustainable practices

Havelock One is mindful of the impact of its business activities on the environment and we continuously strive to reduce it. We believe that promoting environmentally responsible and sustainable practices is one of the critical success factors for our long-term business aspirations. Our modern production facilities with state-of-the-art machinery (which optimizes energy consumption) and dust extraction systems are testimony of this.

We strictly adhere to local laws and regulations related to environment protection.