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CODE OF BUSINESS CONDUCT &<br />

ETHICAL PRINCIPLES<br />

We believe the best way to build and to maintain trust is to conduct every element<br />

of our business according to the highest standards of integrity. Our ability to do so<br />

rests on the behavior of those who work here, from employees to our Chief Executive<br />

Officer to our Directors. To that end, we select our people based not just on their skills,<br />

accomplishments and potential, but also on their principles and values.<br />

It is impossible to predict the various different unique<br />

circumstances our people will face during their careers. As<br />

such, the policies outlined in this Code should be viewed<br />

as the baseline of expected behavior. While ethical behavior<br />

requires us to comply fully with all laws and regulations,<br />

“compliance” with the law is the minimum standard to which<br />

we hold ourselves.<br />

Our Code of Conduct consists of the following principles<br />

which all Directors and employees are required to apply in<br />

their daily work and observe in the conduct of Company’s<br />

business.<br />

COMPLIANCE WITH LAWS,<br />

RULES AND REGULATIONS<br />

Every Director and employee must comply with all applicable<br />

laws, rules and regulations, including those related to insider<br />

trading, financial reporting, money laundering, fraud, bribery<br />

and corruption.<br />

PERSONAL CONFLICTS<br />

OF INTEREST<br />

Every Director and employee is prohibited from indulging<br />

in actions or relationships that create personal conflicts of<br />

interest unless approved by the Company. It is important that<br />

every Director and employee carefully considers whether<br />

any of their activities or relationships, including business<br />

or volunteer positions outside the Company, could cause<br />

a conflict or the appearance of a conflict with the interests<br />

of the Company. Additionally, personal gain or advantage<br />

must never take precedence over one’s obligations to the<br />

Company. No Director or employee must ever use or attempt<br />

to use their position at the Company to obtain any improper<br />

personal benefit for themselves, their family member(s) or<br />

any other individual or group.<br />

FAIR AND ETHICAL<br />

COMPETITION<br />

Every Director and employee must deal fairly with customers,<br />

suppliers, competitors and each other. No one at the<br />

Company may seek competitive advantage through illegal<br />

or unethical business practices. Taking unfair advantage<br />

of anyone through manipulation, concealment, abuse of<br />

privileged information, misrepresentation of material facts, or<br />

any unfair dealing practice is a violation of this Code.<br />

PROTECTING CONFIDENTIAL<br />

INFORMATION<br />

Every Director and employee must maintain the<br />

confidentiality of the information with which they are<br />

entrusted, including complying with information barrier<br />

procedures applicable to our business. The only exception is<br />

when disclosure is authorized or legally mandated.<br />

06 MUGHAL IRON & STEEL INDUSTRIES LIMITED

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