Ethics & Compliance Policy

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Ethics & Compliance Policy

The Tata Emerindo Group

 

MANAGING DIRECTOR’S MESSAGE

To Employees:

Our reputation and integrity are critical and imperative factors to the Tata Emerindo Group's ability to conduct business. Maintaining a high standard of business ethics enables us to attract and retain the people we need to ensure our success as a regional leader in offering Marine / Civil Engineering & Construction & Services and supplies and to maintain the respect and confidence of our customers regardless of country and/or location, we will comply with all applicable laws and regulations and operate our businesses with the highest ethical standards.

I am personally dedicated to developing a culture in which people are committed to integrity. Of all our shared values, none is more important. Integrity is the key ingredi­ent in building and maintaining trusting business relationships and must be earned both internally and externally.

Every interaction we have, every decision we make, and every goal we pursue must be undertaken with a dedication to ethical business compliance.

Tata Emerindo Group reputation is upheld and enhanced – or diminished – by the actions taken by each employee, manager and or Director of our Company. In this regard, I pledge my personal commitment to our Ethics & Compliance Policy.

Each of you must do your part to ensure that the Tata Emerindo Group name has a strong rep­utation for integrity and responsible business practices.

 

POLICY DESCRIPTION:

Our Ethics & Compliance Policy (ECP) is a overview of how we do business with a commitment to integrity. By following this Code, you will ensure that your business activities and decisions support Tata Emerindo Group values and principal directives. Each of us should endeavor to deal with our fellow employees, and with the Company's cus­tomers, suppliers and competitors honestly, openly, and impartially, adhering to the philosophy that business should be won or lost based solely on the merit of the prod­ucts and services being provided. We should not take advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-business practice. As a Company employee, you are required to adhere to this philosophy, and to always conduct yourself and your business dealings honestly and in accordance with the highest level of ethical stan­dards.

The Ethics & Compliance Policy (ECP) applies to directors and all full-time, part-time, and temporary employees. In addition, we expect our suppliers, vendors, contractors, agents, representatives, consultants and joint venture partners to behave in the same ethical manner.

 

CONFLICT OF INTEREST

The Company requires you to make reasoned and impartial decisions in the workplace. Conflicts of interest can affect your decision-making and may adversely affect the Company. For practical purposes, the Company cannot and does not distinguish between an actual conflict of interest and the appearance of one. Conflicts of Interest can arise through outside employment interests, financial participation in an outside business, customer and supplier relations and through gifts and entertainment.

You have a conflict of interest when your actions or your private interest interferes in any way – or even appears to interfere – with the interests of the Company. A conflict situation can arise when you take action or have an interest that makes it difficult to perform your work objectively and effectively. Conflicts can arise not only when you personally benefit or gain, but also when other persons (including family members) or organizations with which you have ties stand to gain. 

In general, if a potential conflict of interest exists, you must excuse your self from making any decisions about the issue at hand, disclose the relevant facts in writing, and explain the possible conflict to your immediate supervisor.

Avoid all interests that conflict or appear to conflict with those of the Company. 

Some common examples are:

Outside Employment and Interests.

Direct or Indirect Financial or Other Participation in Business.

Gifts and Entertainment. Opportunities..

ENTERTAINMENT, GIFTS AND PAYMENTS

 

The Company offers products and services on the basis of quality, price and reliability. In turn we expect our customers to obtain our products and services on the same basis. Giving and receiving gifts and entertainment can potentially affect the independence of our judgment and that of our customers. As a Company employee, you must avoid even the perception that giving or receiving gifts, favors, hospitality, entertainment or other gratuities is connected in any way with favorable treatment.

You must not give or receive gifts of any value under circumstances that are unlawful or might otherwise appear to be an attempt to improperly influence a decision which affects the Company.

You may offer or receive gifts and entertainment commonly accepted as business courtesies, provided they are of nominal value and will not inspire favoritism or a sense of obligation. Meals and entertainment must be reasonable, must be for a business purpose, and must not be so frequent that they suggest a pattern.

 

PROTECTION OF PROPRIETARY INFORMATION

Company proprietary information is information or knowledge which is not generally available to the public about the Company’s operations and that we have determined must not be disclosed to others, except as required by law or under circumstances permitted by Company policy. As an employee, you must protect the Company’s proprietary information, and must not seek to obtain or disclose the proprietary information of others.

Disclosure of proprietary information could put the Company at a competitive disadvantage or could hurt or embarrass employees and customers.

Should you be offered or discover another company’s proprietary information, or become aware of the existence of misappropriated information, you should immediately contact your company compliance officer.

 

PROTECTION OF PHYSICAL AND INTELLECTUAL ASSETS

The company’s assets both physical and intellectual – are highly valuable and are intended for use only to advance business purposes and goals. These assets must be secured and protected in order to preserve their value.

Each of us is entrusted with Company assets in order to do our jobs. We are personally responsible for safeguarding these assets, including equipment, buildings, tools, funds, accounts, supplies, computer programs, information technology, documents, know-how, data, patents, trademarks, copyrights, and any other resources or property of the Company. We are also personally responsible for using these assets and resources appropriately.

The Company does allow the personal use of the Company’s communication and information systems provided that the use does not represent a conflict of interest, does not include pornographic or defamatory material, is not excessive and does not interfere with work priorities. As employees we should have no expectation of privacy when using these Company services.

We expect others to show the same respect for Tata Emerindo Group physical and intellectual assets.

 

INTEGRITY OF RECORDS AND ACCOUNTING PROCEDURES

We create documents and records in the normal course of business to assist in our decision-making process and to document our compliance with laws, regulations and Company policies and procedures. All entries in the Company’s books, records and accounts must be complete, accurate and fairly reflect our business transactions conforming to applicable accounting standards.

False or misleading entries are unlawful and will not be tolerated. No one may establish undisclosed or unrecorded funds or assets for any purpose. Except for normal and customary petty cash funds, which are strictly controlled, cash transactions are not allowed.

It is essential that you adhere to both the spirit and the letter of the law in these matters. If you observe any shortcomings in our record keeping or accounting procedures, you should advise your supervisor, or your company compliance officer.

 

ANTITRUST

Generally speaking, the antitrust and competition laws of the United States and other countries forbid agreements or activities that restrain trade or limit competition, and prohibit attempts to monopolize. The Company is committed to vigorous but fair competition in compliance with the law.

Antitrust violations include, but are not limited to, a variety of agreements with competitors, such as mutual understandings to control prices, to boycott certain suppliers or customers, or to allocate products, territories or markets. Violations may also involve non-competitive practices between the Company and its customers.

Price Fixing. Agreements or understandings between competitors to raise, lower, maintain, stabilize, or otherwise fix prices. Competitors may not agree on the prices they will charge for their products. No employee shall ever discuss our, or a competitor’s pricing practices or components of pricing with a competitor. If the competitor is a customer and the discussion is in conjunction with a specific sales transaction in the normal course of business, then you may discuss the price being offered; however, you need to check with your Legal representative prior to such a discussion. You may not provide the basis on which prices are established. This prohibition includes such items as man-hours for a job, rates for man-hours, wages, or benefits for employees. Bid Rigging. Agreements or understandings between competitors to “Rig” bids or proposals, such as by

(1) agreeing upon prices or other terms and conditions.

(2) agreeing to rotate or alternate submission of bids.

(3) agreeing that one competitor will bid for certain contracts or customers while other competitors will bid for different contracts or customers. Market Division. Agreements or understandings by which competitors divide the market in which they compete, such as by allo¬cating customers, territories, or products among themselves.

 

FOREIGN CORRUPT PRACTICES ACT

The Foreign Corrupt Practices Act (FCPA) of the United States and the laws of many other countries prohibit payments or offers to make payments of any kind, including the giving or offering of anything of value to foreign (Non-U.S.) govern¬ment officials, including officials of public international organizations, office seekers, political parties, or party officials to influence business in any way. The FCPA also applies to the activities of joint ventures and consortiums between the Company and foreign governments or their agencies.

NOTE: the FCPA does not prohibit “Facilitating” or “Expediting” payments (normally payments of modest amounts of money intended to speed or initiate the performance of routine and expected government services to which the Company is Legally entitled).

 

POLITICAL CONTRIBUTIONS

We encourage you to participate in the political process, always keeping in mind that the law as well as Company policy requires that your political activity be an entirely personal matter. The Company may not force your involvement in the political process; you may not use the Company for political purposes.

You may not use Company funds or the Company name for any political purpose, direct or indirect, except as permitted by law. You may not cite your position in the Company or use Company facilities for political purposes. If you give money to political candidates or parties, you should not expect repayment or special consideration from the Company.

The Company will not provide loans, advances or gifts of services, or anything of value in support of political candidates or parties, except as permitted by law.

 

PROCUREMENT ACTIVITY

Suppliers play a critical role in the Company’s core businesses and contribute to its goal of providing high quality, efficient and competitive solutions for our customers. 

We must offer all equipment, supplies and services on the basis of merit, treating all customers and or sub-contractors fairly and without discrimination.

As a Company employee, you must employ the highest ethical standards in choosing sources, in negotiations, in determining awards and in administering all purchasing activities. You must be especially careful to avoid conflicts of interest between the Company and the person or firm to be employed.

All records must be accurately created and maintained to document the procurement process and to substantiate procurement decisions.

All steps in the bid request, evaluation and award/order process are to be executed on a confidential basis. Do not divulge procurement information to anyone outside the Company or to persons inside the Company who do not have a “Need to know.”

It is essential that each employee involved in the procurement process avoid any appearance of favoritism in the award of contracts for goods and services. Any relationship between you and a supplier or contractor must in no way compromise your ability to transact business on a professional, impartial and competitive basis or influence business decisions made by the Company.

Purchasing decisions must be based on merit alone.

 

EQUAL EMPLOYMENT OPPORTUNITY

Tata Emerindo Group offers equal employment opportunity (EEO) to qualified individuals, regardless of race, religion, national origin, age, sex, disability – or any other factor protected by law and /or Company policy.

The Company is committed to maintaining a diverse workforce where employees are hired, retained, compensated, disciplined and promoted based on their contribution to the Company and their performance. All employees should work in a professional atmosphere that promotes productivity, and encourages creativity and innovation. The Company is committed to ensuring that all individuals in the work environment are treated with respect and dignity.

 

ALCOHOL AND SUBSTANCE ABUSE

Our goal is a workplace free from substance abuse of any kind. You are expected to be fit for duty and capable of performing your assigned responsibilities in a safe and productive manner. Use of alcohol or use of controlled substances in the workplace is inconsistent with this goal.

 

HARASSMENT AND DISCRIMINATION

Harassment in the workplace is behavior that is unwelcome and offensive to specific individuals or groups, or that unreasonably disrupts their work. The company will not tolerate actions, comments, inappropriate physical contact, sexual advances, or any other conduct that is intimidating or otherwise offensive or hostile.

Harassment can occur under many different conditions. The most common form of harassment is sexual harassment, which in general occurs when.

(1) a request for a date, a sexual favor, or other verbal or physical conduct of a sexual nature that is unwelcome, is made a condition of employment or used as the basis for employment decisions.

(2) an intimidating, offensive, or hostile work environment is created by unwelcome sexual advances, insulting jokes, or other offensive verbal or physical behavior of a sexual nature.

Harassment may include verbal or physical conduct that denigrates or shows hostility toward an individual and can reasonably be perceived as threatening, offensive and/or insulting.

The Company is committed to ensuring a work environment in which all employees are treated fairly. The law requires non-discriminatory and equal treatment of individuals in employment decisions, and the Company is committed to provide such a workplace.

 

HEALTH, SAFETY & ENVIRONMENTAL

The Company is committed to preventing all Health, Safety, and Environmental (HS&E) incidents and has adopted the following principles:

• All occupational and environmental incidents can be prevented. 

• All operations must be performed safely and with minimal environmental impact. 

• All personnel have the right and responsibility to stop any work they feel may be unsafe. 

• Working safely and following Company HS&E policies and procedures are conditions of employment.

The Company directs and expects all employees, contractors, customers, and vendors to perform their duties in accordance with these principles as well as Company polices and procedures.

The Company considers the protection of human health, safety, and the environment for all its employees, contractors, customers, and the community to be of primary importance.

 

INTEGRITY IN BUSINESS RELATIONSHIPS

The Company enters into various business relationships with third parties to further our business objectives. We may establish joint venture corporations, partnerships, project-specific consortium relationships, etc., which may be partially owned by and/or jointly managed with other companies. In addition, the Company retains and utilizes third party professionals, including sales representatives, agents and consultants in the connection with the pursuit of new business opportunities and the execution of our business.

The Company will only engage third party professionals, such as sales representatives, agents and consultants, who are reputable, qualified and agree to comply with the business practices reflected in our Ethics and Compliance Policy.

 

QUALITY OF PRODUCTS & SERVICES

The Company empowers and expects all employees to work in accordance with established policies and procedures in order to meet contractually agreed customer requirements. If at any time employees are not sure what these requirements are, they are expected to ask their Manager or Supervisor for clarification before continuing the work. The Company determines compliance with contractual requirements through inspections which have to be performed and presented in an ethical manner. The company considers that meeting customer contractual requirements is of primary importance together with a focus on continual improvement. We expect that requirements are identified before work starts and that they are communicated to all concerned. The achievement of a quality product, safely, on time, in budget with no ethical violations is our prime focus.

 

TAKING ACTION

The Tata Emerindo Group is responsible for implementing the ethics and compliance program, creating and maintaining policies, updating and distributing this document, and making other resources available to employees. All conversations, calls, and reports made in good faith will be taken seriously. Our Company will investigate all reported concerns – promptly and as confidentially as possible – and resolve those concerns appropriately. If, after investigation, we find that the Ethics & Compliance Policy has been violated, we will take appropriate action, including disciplinary action, and make such changes necessary to prevent recurrences. Our actions may include notifying the appropriate governmental agency. As an employee of this Company you must first take responsibility for your own ethical behavior. You have the responsibility to read, understand, and comply with this Ethics & Compliance Policy.

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Tata Emerindo Group

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