Principle 1: Ethical dealings with outside parties and conflicts of interests

A. Dealings with suppliers/ customers

Employees should not make any payments or provide any gifts of value that will unfairly influence decisions in the Group’s favour

Any gift, other than of a token value, received by an employee from outside parties doing business with the Group, should be declared appropriately

Employees shall not ordinarily use suppliers of goods and services to the Group for their personal needs, especially when many such suppliers are easily available

B. Dealings with the government/ authorities

All employees are required to strictly adhere to all applicable laws and regulations in the discharge of their duties

Do not make or offer, directly or indirectly, any payment or anything of value to any authority to influence any action or decision unfairly in your or the Group’s favour

C. Business connections

Employees shall not have any undisclosed connections, either direct or indirect, with any firm, person or organisation doing business with the Group and with significant competitors

D. Press and publicity

It is important that press releases, articles and media interactions are coordinated to ensure that a uniform image of the Group is presented to the outside world

All press releases (except product advertisements or literature) should be cleared in advance with the Corporate Affairs department

Ensure that the guidelines provided on dealings with the media are strictly adhered to for ensuring the presentation of a uniform corporate image. Get prior permission whenever you represent Sanmar outside the organisation

Relationships between employees, however distant, need to be declared as soon as they are discovered or formed. Ignorance of relationships up to Level 4 is not acceptable

The group will give lower preference to employing relatives of employees, unless the relative possesses specific qualifications or skills that make the person ‘uniquely suitable’ for the position

Principle 2: Declaration of relationships

There shall be no exceptions when implementing Group policies

Do not hunt for loop holes in policies

Ensure that policies are followed consistently in both letter and spirit 

Principle 3: Implement policy 100%

Ensure that the logic of every decision is clear

When preparing communications, ensure that they convey all facts

Ensure that assumptions behind decisions are adequately documented

Actively seek a second view to facilitate more informed decisions

If a paper is sent through you, then you should be able to defend the decision or recommendation

Information should be available, as and when required, to authorised users without having to go through the hierarchy

Principle 4: Clarity of communication

Performance has to be evaluated with reference to agreed targets for the year. The performance of employees is also to be evaluated for cultural conformity with Sanmar Standards

Under-performing employees will be regularly counselled and provided feedback to improve their performance

Principle 5: Transparent appraisal systems

Compensation and reward policies should be fully transparent

Employees are paid a cash based remuneration package which is fully declared for tax and the Group will not entertain any individual structuring of compensation. The Group believes that employees are paid for their value and they are free to determine their expense priority based on their individual lifestyles

Vigilance must be consciously exercised to determine that it is the employee’s value to the organisation that determines his/her compensation and reward. Personal ties should be scrupulously kept out of such judgments

Principle 6: Fair compensation and reward policies

Confidential information is to be used solely to pursue the Group’s business interests, and in the absence of an express authorisation, should not be disclosed to anyone during, or subsequent to, employment with the Group

To ensure the retention of proprietary knowledge within the Group and its use for specific applications determined by the management, employees will be required to sign Secrecy Agreements, wherever it is deemed necessary

Principle 7: Protection of proprietary information

 Employees have to ensure that all applicable safety and environment laws and regulations are adequately complied with

The business of the Group has to be conducted in accordance with recognised industry standards on safety, health and environment

Principle 8: Commitment to safety and environment

Merit and job-related criteria should be the sole basis for all employment related decisions without giving any cognisance whatsoever to an individual’s race, origin, cultural background, gender, age or religion

Always strive to provide a cohesive work environment free of any bias and usher a spirit of teamwork and co-ordination amongst colleagues

Ensure that every employee is treated fairly and that professional respect is maintained at all times

Sexual harassment is offensive and will not be accepted by the Group

Principle 9: Policy of non-discrimination and work environment