Key Market Sectors
    Automobiles  
    Electrical & Electronics  
       Hydraulics  
    Moulding  
    Medical  
   
   
  Code of Conduct
   
  Applicability
   
  1. These guidelines shall apply to all employees of the company (including Senior Level Employees, employees temporarily transferred to affiliates; non- regular employees and all employees who are working for the “Company”).

2. Further, the definition of employees and officers refer to the Rules on Employment Regulation and Human Resource Management Policy (HRM).

3. When an outsourced company to which an operation is outsourced to, sends its employee to the “Company” as a resident employee, the former shall be requested to ensure that the resident employee comply with these guidelines. In this regard resident employees are included those working for and on behalf of the Company in the area of field investigation and other related field jobs.
   
  Compliance with Law, Ethical Conduct and Respect for Human
   
  1. Conscious of being part of the Company, employees shall comply with all applicable laws of land and regulations, and conduct themselves as members of a law abiding society in ethical and responsible manner while maintaining a high level of corporate and employee ethics.

2. Employees shall familiarize themselves with the cultures, customs and history of every country to which they are brought, into conduct with while performing their duties for the Company and respect them.

3. Employee shall respect human rights and shall not discriminate against persons based on reasons of race, creed, sex, social status, religion, nationality, age, or physical or mental disability.

4. Employee shall discharge his duties with utmost integrity, discipline, honesty, devotion and diligence and do nothing which is unbecoming of an employee or which is likely to tarnish the image of the “Company”. Cases of fraud and dishonesty will attract penalty of dismissal.

5. No employee shall take an active part in politics and stand for election anywhere outside the Company.

6. The employees shall keep constantly and behave in good manner for the sake of up holding good reputation of the company in the society.
   
  Fair trade practices: Procurement Activities
   
  1. Employees shall consistently ensure fairness and justness in selecting suppliers, and avoid any potential “conflict of interest” accordingly, while striving to procure the most superior goods and services.

2. Employees shall not unjustifiably demand a reduction in purchase prices, reject the reduction in purchase prices, reject the reception of any goods, or delay payment of a purchase price in their dealings with subcontractors.
   
  Unfair Trade Practices: Sales Activities
   
  1. Employees shall not engage in any unfair trade practices, such as joint boycotts, dumping, tie-in sales, exclusive transactions with constraints, and abuse of a preferred position.

2. No employee or department other than the one authorized by the Board of Directors will interact with media on matters relating to the Company.

3. An employee shall not enter into any dealings with customers which would land him into pecuniary ( (financial) obligations towards them.
   
  Conflicts of Interest and Distinction between Public and Private
   
  1. Employees shall not participate in any activity which creates or appears to create a conflict of interest between themselves and the company such as working for the Company’s competitors or business partners.

2. Employees shall not use the Company’s property, assets (including telephone; internet, email facility) or information system for any purpose other than for the business affairs of the company.

3. Employees shall not, without the prior consent of the Management, be engaged in any other occupation, profession and business. Provided that an employee may, without such sanction, undertake honorary work of a social or charitable nature or occasional work of a literary, artistic or scientific character, or participate in sports activities as amateur, subject to the condition that his official duties do no thereby suffer.

4. Employees shall not, without the prior consent of the Company, acquire any stock in a privately-held business partner of the Company in which the company invests (or may invest).
   
  Favours and Gifts
   
  1. Employees shall not receive from and render to public officials or persons in a similar position any economic favours, such as money, gifts or other favours in return for the performance of their duties.

2. Employees shall not receive from and render to public officials or persons in a similar position of a foreign country any economic favours, such as money, gifts or other favours for the purpose of securing any improper advantage.

3. Employees shall not pay any agent, advisor or consultant any commission if it is believed that such commission will be used for influencing public officials or persons in a similar position in an unlawful manner.

4. Employees shall not render employees or officers of the Company’s business partners any economic favours, such as money, gifts or other favours, the value of which exceeds the level deemed appropriate according to normal social conventions.
   
  Compliance with Procedures of Various Business Laws and Regulations
   
  1. Employees shall comply with the prescribed procedures for export and import and shall not import prohibited goods and involve in illegal activities which is detrimental to the interest of the Company.

2. For the purpose of securing, peace and security, employees shall comply with not only applicable land laws and regulation but also the company’s self-imposed internal rules concerning international security trade control when exporting goods to any foreign country.

3. Employees shall be aware of the contents of the laws and regulations applicable to the goods or services for which they are responsible and shall comply with the prescribed procedure for obtaining permits and other procedures.
   
  Treatment of information (privacy code)
   
  1. Employees are liable to maintain strict control of any trade secrets, Business plans & policies, customer data base & information, software & hardware configuration and technology used and software used by the company, its reverse engineering etc. information which may effect the goodwill, rights, titles of the company and personal information held by and pertaining to the company and do not divulge such information to any third party or use it for any purpose other than for the business affairs of the company.

2. Employees shall treat any confidential information disclosed by a third party in the same manner as if it were the confidential information of the company.

3. Employees do not infringe intellectual property rights of the company and any third party including but not limited to the unauthorized duplication of computer software, reverse engineering etc even after leaving the company.

4. If any of the employee become acquainted with any important information pertaining to the information in the interest of the company and its business activities unless the management makes it known to public.

5. No employee shall engage himself / herself/ in syndication with others, in any act of unfair competition, unfair trade practices, fraudulent activities while performing their task and assignment and shall be bound to maintain the trade secrets of the company as well as third party related to the company in any manner.

6. Employees are required to maintain secrecy about the customer’s information and sign a declaration of fidelity and secrecy to this effect.
   
  Company Funds and Accounting Reports
   
  1. Employees shall properly manage the Co’s assets and funds and use these only for appropriate business related purposes. Employees shall not establish or maintain off-balance-sheets assets or funds.

2. Employees shall make timely and appropriate accounting reports by consistently ensuring the accuracy thereof and shall not make any false or misleading entries in accounting books and records.
   
  Social Contribution
   
  1. As good corporate citizens, employees should strive to maintain harmony with the local or global communities in which they perform and to improve corporate value on a sustainable basis by building trusting relationships with the various customers/ stakeholders in the company. At the same time, employees shall make positive social contributions towards the realization of thriving and hospitable local or global communities and shall work to create a sustainable society.

2. In addition to economic contributions, employees shall participate on a consolidated basis in activities focused on corporate social responsibility.
   
  Protection of the Environment, Health and Safety
   
  1. Employees shall comply with all laws and regulations concerning environmental protection and actively engage in educational activities related to environmental protection, health and safety of society and the efficient use of resources and energy.

2. Employees shall expand the procedures for evaluating the environmental impact of new business and strive to create a balance between corporate activities and environmental, health and safety protection.

3. Employees shall contribute to the development and spread of environmentally friendly technologies and shall always take into consideration issues of environment, health and safety of society.
   
  Action against anti-social groups
   
  1. If an unreasonable demand is made by an anti-social group, such as a corporate racketeer or an organized crime group, employees shall not resort to an easy monetary settlement.

2. Employees shall not enter into any transaction with any anti-social group or any entity connected therewith.
   
  Quality of Service and Protection of Customer data
   
  1. Employees shall give their highest priority to customer safety and protection of customer data, and trust and shall seek to ensure, in line with related laws and regulations as well as related internal rules, etc., adequacy and safety at all stages, from purchasing of raw material, product development, and production to product distribution and disposal.

2. Employees shall use and accurately state in proper and easy-to-understand documentation expressions in the customer documentations such as application form and legal documentation.

3. In the event that employees learn of any product or service-related trouble or any customer data sharing, they shall immediately provide an accurate report therefore to their superiors and all related departments/divisions. If such trouble causes any damage, then employees shall promptly and appropriately take the necessary action in good faith.

4. Employees shall be willing to listen with sincerity to the opinions of customers, grievances and shall reflect upon them in the carrying out of business affairs in efficient and effective manner in present as well as in future.
5. Employees shall provide customers with accurate information (Including rate) relating to products, services, etc. in order to fulfill customer reassurance and satisfaction.
   
  Protection of Intellectual Property Rights
   
  Employees shall be aware that intellectual property rights serve as a lifeline for business activities and shall make every effort to protect their own rights while paying close attention so that such rights do not infringe upon the rights of others.
   
  Reporting Route, Sanctions and Protection to the Reporter
   
  1. If employees find evidence or indication of any violation of these guidelines, they shall report it to or seek out consultation with respect thereof with their direct superiors or HR dept or at the Board of Directors level if the former first one does not take any further follow up action.

2. If employees wish to anonymously report such alleged violation or seek consultation with respect thereof, they may do so with an appointed external lawyer, or HR Dept or Board of Directors.

3. Employees shall cooperate in any investigation of such alleged violation. If, as a result of an investigation, it becomes clear that there was a violation of these guidelines, then sanctions will be imposed on the violator or his or her superiors and other rules of the company.

4. The company ensures that no retaliatory action will be taken against employees for reporting an alleged violation, and the company will undertake every effort to prevent these employees from suffering any disadvantage at their respective workplaces.
   
  Office Environment; Sexual Harassment and Improper Behavior
   
  1. In order that employees with their individuality and diversity perform their duties for the company to the best of their ability, employees shall respect the character and individuality; employees shall respect the character and individuality of one another and make every effort to ensure that the office is an open and comfortable environment in which to work.

2. Employees shall not engage in any sexual harassment or any other behavior which may appear to be sexual harassment and shall not engage in any sexual behavior that makes others feel uncomfortable.

3. Employees shall not involve in any un-proper behaviors including drug consumptions and activities related to gambling.

4. Employees shall not disturb the sound discipline, environment and good order of the office by conduct which is contrary to public order and good moral standards.
   
  Revisions and Elimination
   
  The HR Dept concerned shall have responsibility for these guidelines, and any revisions to or elimination of any provisions herein shall require a resolution of the board of directors.
   
  Penalties
   
  For violation of any of the rules contained herein or any orders issued by the company or for any other reason considered appropriate, an employee shall be liable for any sanctions / penalties which refers to and follows discipline authority rules.

This version of the CoC supersedes all earlier versions and associated documents and stands effective from 1st January, 2012.