vasant chemicals pvt. ltd., 1-11/152, 4 floor, vasant

VASANT CHEMICALS PVT. LTD.

Version: 01 of 18 Effective from: 10.01.2021

Vasant Chemicals Pvt. Ltd.,

1-11/152, 4th Floor, Vasant Towers,

Behind Shopper’s Stop,

Begumpet, Hyderabad - 16,

Telangana,

INDIA



Table of CONTENTS 1.0 MESSAGE FROM CHAIRMAN ............................................................................................................................. 4

2.0 MISSION, VISION & CORE VALUES .................................................................................................................. 5

3.0 PURPOSE ............................................................................................................................................................ 6

4.0 SCOPE ................................................................................................................................................................ 6

5.0 POLICY STATEMENT: ........................................................................................................................................ 6

5.1 FAIR DEALING WITH OUR CUSTOMERS: ...................................................................................................... 7

5.2 EMPLOYEES (RESPONSIBILITIES TO EACH OTHER) .................................................................................... 7

5.2.1 HONESTY & INTEGRITY ........................................................................................................................ 7

5.2.2 ANTI-HARASSMENT STATEMENT .......................................................................................................... 7

5.2.3 EQUAL EMPLOYMENT OPPORTUNITY .................................................................................................. 8

5.2.4 ENVIRONMENT, HEALTH AND SAFETY ................................................................................................. 8

5.2.5 CHILD LABOR ........................................................................................................................................ 8

5.2.6 WORK ENVIRONMENT ........................................................................................................................... 8

5.2.7 FORCED LABOUR & BONDED LABOUR: ................................................................................................ 9

5.2.8 FAIR COMPENSATION:........................................................................................................................... 9

5.2.9 EMPLOYEE PRIVACY: ............................................................................................................................ 9

5.2.10 NON-DISCLOSURE / CONFIDENTIALITY: ............................................................................................. 10

5.3 RESPONSIBILITIES TO STATUTORY BODIES & REGULATORY AGENCIES: ................................................ 10

5.3.1 COMPLIANCE WITH LAWS, RULES AND REGULATIONS ..................................................................... 10

5.3.2 ANTI-CORRUPTION LAWS ................................................................................................................... 10

5.4 SUPPLIERS TO VASANT CHEMICALS .......................................................................................................... 11

5.5 RESPONSIBILITIES TO ALL STAKEHOLDERS: ............................................................................................. 11

5.5.1 PROTECTION OF VASANT CHEMICALS ASSETS: ................................................................................ 11

5.5.2 CONFIDENTIAL INFORMATION ........................................................................................................... 11

6.0 BUSINESS CONDUCT AND ACCOUNTING DISCLOSURE PRACTICES ................................................................ 12

7.0 CONFLICTS OF INTEREST ................................................................................................................................ 12

7.1 OUTSIDE ACTIVITIES ................................................................................................................................... 13

7.2 STOCK OWNERSHIP .................................................................................................................................... 13

7.3 OTHER OUTSIDE INVESTMENTS .................................................................................................................. 13

7.4 ASSISTING A COMPETITOR ......................................................................................................................... 14

7.5 GIFTS AND ENTERTAINMENT ..................................................................................................................... 14



7.6 CHARITABLE DONATIONS .......................................................................................................................... 14

7.7 POLITICAL CONTRIBUTIONS AND ACTIVITIES........................................................................................... 15

7.7.1 CORPORATE CAMPAIGN CONTRIBUTIONS ......................................................................................... 15

7.7.2 OTHER POLITICAL CONTRIBUTIONS .................................................................................................. 15

7.7.3 LOBBYING ACTIVITIES ........................................................................................................................ 15

7.8 BREACHES OR POTENTIAL BREACHES OF THESE GUIDELINES ................................................................. 15

8.0 OPEN DOOR POLICY ........................................................................................................................................ 15

9.0 DRUGS AND ALCOHOL..................................................................................................................................... 16

10.0 USE OF INFORMATION SYSTEMS .................................................................................................................... 16

10.1DATA SECURITY & CONFIDENTIALITY: ..................................................................................................... 16

10.2E-MAIL / TELEPHONES ............................................................................................................................... 17

10.3INTERNET USE: ........................................................................................................................................... 17

11.0 COMPANY ASSISTANCE / EXCEPTIONS ........................................................................................................... 17

12.0 REPORTING VIOLATIONS ............................................................................................................................... 17

13.0 CONSEQUENCES OF VIOLATION OF POLICY ................................................................................................... 18

14.0 OTHER CONSIDERATIONS ............................................................................................................................... 18



1.0 MESSAGE FROM CHAIRMAN

Dear Colleagues,

We, at Vasant always believe that there 4 pillars to its business i.e. Customers, Suppliers, employees

and statutory/regulatory agencies. As a responsible corporate citizen, Vasant always protect and

safeguard the interest of all Stakeholders. There is no wonder if I say that Vasant is built with well-

defined and very well described Rules, regulations, policies, procedures, guidelines, system, SOPs,

manuals, process instructions, work instructions by having a strong base in the form of Ethics, Values

and Culture. To make every stakeholder to understand this fact, and to follow in Vasant’s way by each

and every stakeholder, we have prepared this booklet “Code of Business Conduct & Ethics”.

This Code is nothing but a general statement of what Vasant exhibits and expects from its employees in

the conduct of day to day work. It does not mean or constitute an employment contract or assurance of

continued employment, and does not create any legal rights for any prime or secondary stakeholders

including employees. Though the Board Directors have power to add or amend and waive the Code,

normally the Board does not intend to grant waivers of any kind to this Code.

I expect that you all should familiarize yourself with these guidelines and adhere to them in every walk

of your personal and professional life. I also advise Human Resources department to provide awareness

and make this as a part of Induction.

On behalf of the Board of Directors, I wish you all a very happy & healthy life. Let us work together

with more Respect, Trust and pride.

GKB CHOWDARY

Chairman



2.0 MISSION, VISION & CORE VALUES

Mission

Contributing to the well-being of society by providing quality products and services globally.

Vision

Vasant Group is a global multi-dimensional organization, enjoying a leadership position in its operations,

while living up to the demanding expectations of customers; by providing innovative solutions, adopting

environment friendly state-of-art technology; fulfilling hopes & aspirations of its employees & shareholders,

in addition to discharging its social obligations to the fullest.

Core Values

Customer success

Integrity

Excellence

Accountability

Innovation and Learning

Environment and Safety

Profits for a purpose

Team spirit.



3.0 PURPOSE

All employees must conduct themselves and the business of Vasant Chemicals in a legal and more

ethical manner. This Code of Business Conduct and Ethics ("Code") sets out basic principles for all

employees to follow in fulfilling their responsibility to conduct themselves accordingly.

4.0 SCOPE

The Code applies to all the employees and members of the board of directors of Vasant Chemicals Pvt.

Ltd. direct or indirect wholly-owned subsidiaries (such individuals, "Employees"). We use "Vasant

Chemicals" to refer to Vasant Chemicals Pvt. Ltd. In addition, unless the context otherwise requires,

please note that when used in this Code: (i) the terms "we," "our," "us" and similar terms refer to Vasant

Chemicals, (ii) the terms "you" and "your" refer to employees, and (iii) the term "including" (and any

form of it) will not be limiting or exclusive.

In addition to the Code, Vasant Chemicals has adopted numerous policies addressing specific aspects of

our business. When appropriate, we refer to those separate policies in this Code, and the terms and

conditions of those policies should be considered incorporated as part of this Code. If there is a conflict

between the Code and a specific policy, you must comply with the specific policy.

Neither the Code nor any of our other policies are, and should not be interpreted as, a contract for

employment.

5.0 POLICY STATEMENT:

A reputation for integrity is one of the most valuable assets a company can possess. Vasant Chemicals

reputation has been built over many years and is dependent on the integrity and sense of responsibility

demonstrated by our Employees. The Code sets forth our commitment that all employees exemplify a

high standard of ethical and legal conduct in all Vasant Chemicals business practices.

While compliance with applicable law is the foundation for the Code, you are expected to avoid unethical

business dealings, whether actual or perceived, even when those business dealings may not violate

applicable law. In many respects, the Code sets forth a higher standard than applicable legal

requirements.

The Code covers a wide range of topics, but it cannot be expected to cover every issue that may arise. As

a result, the Code sets forth certain fundamental principles to guide you.



The standards set forth in the Code evidence responsibilities by reflecting “Business conduct” to a

variety of stakeholders, including:

a) Customers

b) Employees (each other)

c) Statutory bodies / Regulatory Agencies

d) Suppliers

e) Share holders

5.1 FAIR DEALING WITH OUR CUSTOMERS:

We treat our customers with honesty, fairness and respect. Every employee will deal honestly and

ethically with customers, vendors, contractors, competitors, employees and others while engaged in

business on behalf of Vasant Chemicals. No employee will take unfair advantage of anyone through

manipulation, concealment, abuse of privileged or confidential information, misrepresentation of

material facts, or any other unfair dealing practice.

5.2 EMPLOYEES (RESPONSIBILITIES TO EACH OTHER)

5.2.1 HONESTY & INTEGRITY

Vasant always expects a high degree of honesty and integrity from its employees. Employees must

understand the company’s value system, Code of Conduct, Business ethics, etc. No employee shall give

or receive bribes, gifts. Every employee’s employment is subject to anti-corruption and ethical

practices.

5.2.2 ANTI-HARASSMENT STATEMENT

We strive to maintain an environment that is free from any threat, physical / verbal abuse, intimidation and

hostility. It is illegal under state & national law and prohibited by Vasant Chemicals for an employee to

harass another employee based on any legally protected characteristic such as color, religion, gender,

sexual orientation, gender identity, age, national origin, military status, veteran status, or disability. We

have developed a separate policy (please refer “Guidelines for safety of women employees at work

place” for additional information) that stresses strong opposition to harassment of women employees.

That separate policy establishes complaint procedures and disciplinary penalties that may be imposed

for violation of the policy by any Vasant Chemicals employee.



5.2.3 EQUAL EMPLOYMENT OPPORTUNITY

In order to provide equal employment and advancement opportunities to all Employees, employment decisions

at Vasant will be based on merit, qualifications, abilities, capabilities and potential. Equal opportunity

employment practices extend to all aspects of employment, including recruitment and hiring,

compensation, benefits, transfer, termination, and participation in Vasant Chemicals-sponsored

trainings, social and recreational programs because of color, religion, gender, sexual orientation, gender

identity, age, national origin, military or veteran status, disability, pregnancy or any legally protected

characteristics.

5.2.4 ENVIRONMENT, HEALTH AND SAFETY

We conduct our operations with the highest regard for the safety and health of employees and the

protection of the environment and general public. Our commitment to protecting the environment and

providing a safe and healthy workplace for our Employees and other business associates is one of our

core values. No job is so important, and no task is so urgent for taking necessary steps to be taken to

assure the health & safety of our Employees and business associates. Please refer to the "Environmental

Management System’s policy, Occupational Health & Safety Management System’s policy" for

additional information.

Vasant Chemicals prohibits the possession of firearms, guns, explosives and any other weapons of any

kind, as well as ammunition while on Vasant Chemicals premises unless such prohibition is otherwise

precluded by the laws of a particular jurisdiction, and then only to the extent expressly precluded.

Further, Vasant Chemicals will not tolerate any acts or threats of violence against our Employees or

business associates while engaged in business on behalf of or with Vasant Chemicals, whether on or off

Vasant Chemicals premises.

5.2.5 CHILD LABOR

We do not engage children or any person who has not completed his/her 18years of age.

5.2.6 WORK ENVIRONMENT

We seek to provide a work environment that will attract and retain highly talented people, through

fostering growth and innovation, in order to help all employees to achieve their full potential. Vasant

will provide freedom to its employees in choosing employment, and also to become members in

Associations, professional bodies and also in various internal committees.



5.2.7 FORCED LABOUR & BONDED LABOUR:

Vasant at their work places or in any of their activities will not engage any Forced Labour or Bonded

Labour or such related practices; thereby maintains cordial relations with People at work. The

initiatives taken by the Company against such abuses are indicated hereunder:

The Company will not engage any Forced Labour and see that no employee is made to work as

Forced Labour in the Company.

The Company will not engage any Bonded Labour and see that no employee is made to work as

Bonded Labour in the Company

No person is made to work against his/her will

Ensure that employees work voluntarily and not because they have been threatened or intimidated

in any way

Not unreasonably and/or unnecessarily restrict employee movements

5.2.8 FAIR COMPENSATION:

Vasant operates in a highly competitive environment characterized by rapid change arising from

technological advance, and has to satisfy increasingly demanding requirements of our customers.

Innovation and speed of response to market conditions are critical success factor for us and we are

heavily depended on the accumulated expertise of a workforce consisting primarily of knowledge

workers.

With the immense competition of attracting and retaining talented human resources, an attractive

compensation package is key factor to motivate and retain our valuable employees, so our pay structures

are based on market standards for the respective job categories. In order to attract quality employees, as

well as keep competent workers who are already associated with the company we provide additional

incentives like Production Incentive, Performance Incentive, Welfare payment/ Loyalty Payment,

Retention Payments per laid down regulations.

5.2.9 EMPLOYEE PRIVACY:

We respect the privacy and dignity of our fellow employees and safeguard the confidentiality of

employee records. We monitor Company-owned technology used for e-mail, internet and other

communications in accordance with local laws.



5.2.10 NON-DISCLOSURE / CONFIDENTIALITY:

The protection of confidential business information and trade secrets is vital to the interests and success

of Vasant. Such confidential information includes, but is not limited to, the following:

Intellectual Property Management

Product, process, methods, systems, designs, drawings, technical know-how, etc

Pending projects and proposals

Marketing Information / Business development activities

Financial information

Personnel records

Compensation data

Conversations between any persons associated with the company

Employees who improperly use or disclose trade secrets or confidential business information will be

subject to disciplinary action including termination of employment and legal action, even if they do

not actually benefit from the disclosed information.

5.3 RESPONSIBILITIES TO STATUTORY BODIES & REGULATORY AGENCIES:

5.3.1 COMPLIANCE WITH LAWS, RULES AND REGULATIONS

All Vasant Chemicals business should be conducted in full compliance with applicable law. Employees

are expected to understand and comply with all laws affecting their work.

5.3.2 ANTI-CORRUPTION LAWS

Wherever we do business, we will comply with all applicable anti-corruption laws. The Indian Penal

Code, 1860 and Prevention of Corruption Act, 1988’s makes it a criminal offense to bribe or offer to

bribe a foreign governmental or political official to obtain or retain business.

The Indian Penal Code, 1860 and Prevention of Corruption Act, 1988 also requires that Vasant

Chemicals maintain and keep records and accounts that fairly and accurately present our activities and

transactions. Please refer to the "Anti-Corruption Policy" for additional information.



5.4 SUPPLIERS TO VASANT CHEMICALS

Generally, employees may not work for or represent a Vasant Chemicals supplier or vendor, or be a

member of a supplier's or vendor's board of directors while working for Vasant Chemicals. In addition,

employees may not accept money or benefits of any kind for any advice or services provided to a supplier

or vendor in connection with its business with Vasant Chemicals.

5.5 RESPONSIBILITIES TO ALL STAKEHOLDERS:

5.5.1 PROTECTION OF VASANT CHEMICALS ASSETS:

You are expected to protect Vasant Chemicals assets against theft, loss, or misuse. Vasant Chemicals

assets include tangible items like buildings and equipment as well as intangible items like business plans

and potential prospects.

Further, to the extent you operate a vehicle on Vasant Chemicals business, whether the vehicle is owned,

leased or rented by Vasant Chemicals or is your personal vehicle, you are expected to do so in a safe

manner. Vasant Chemicals is required by law to retain certain types of records, usually for a specific

period of time, and employees are required to assist Vasant Chemicals in fulfilling these records

retention requirements, as well as maintaining accurate records.

Employees will promptly and fully communicate to Vasant Chemicals in writing any invention, idea,

discovery, developed, or reduced to practice in the course of their employment, either alone or as a co-

inventor or discoverer.

5.5.2 CONFIDENTIAL INFORMATION

As an employee, you may have access to non-public information concerning Vasant Chemicals, other

employees and third-party business relationships. You may not communicate that information to any

person, including other employees, unless that person has a need to know that information for a

legitimate business purpose.

Information that is considered confidential and therefore the property of Vasant Chemicals includes

information regarding business activities, business plans and financial performance, technical data and

other proprietary information, as well as documents, files, maps, reports, manuals, computer programs

and e-mail. You may not release or remove these items from Vasant Chemicals property without proper

approval, and you may not use such information for your personal gain or in a manner not in Vasant

Chemicals’s best interests. Additionally, in the event of termination from employment for any reason,

a terminated individual may be required to immediately deliver to Vasant Chemicals all copies of the

above described information.



Employees with access to wage, salary and confidential benefit information must not disclose to anyone

(including other Vasant Chemicals employees) who does not have a legitimate business purpose for

obtaining such information. Additionally, employees are strictly prohibited from gaining access to

Vasant Chemicals information, if they do not have a legitimate business purpose or do not have

legitimate access to such information for the performance of their particular job. Employees may be

asked to sign a Confidentiality Agreement.

6.0 BUSINESS CONDUCT AND ACCOUNTING DISCLOSURE PRACTICES

Vasant Chemicals Pvt. Ltd. is committed to do our business ethically and legally. The information

presenting related to our financial aspects, internally and externally, in a complete, fair, accurate and

timely manner that will not mislead or misinform its stake holders.

It is organization’s policy to keep books, records and accounts that completely and fairly reflect our

financial condition and to comply with applicable accounting principles, laws, rules and regulations.

Employees are responsible for familiarizing themselves with Vasant Chemicals's authority limitations

and policies on the execution of contracts and should limit their actions to those within the specific

authority granted to them by Vasant Chemicals. Employees who have accounting and auditing

responsibilities are responsible for understanding and complying with all Accounting Rules, ethical

standards and internal procedures.

Full and complete disclosure of important information to the public about Vasant Chemicals, both

financial and non-financial, is a complex process involving numerous departments to ensure that truthful,

accurate and reliable information is shared. We have designed accounting and disclosure processes to

record, process and report in a timely manner all material information as required by applicable laws.

Head – Finance & Accounts is responsible for overseeing these processes. All Employees are expected

to comply with these processes and carefully consider and respond in a timely manner to any inquiries

from.

7.0 CONFLICTS OF INTEREST

It is imperative that employees maintain unbiased judgment when acting on behalf of Vasant Chemicals.

As an employee, you may find yourself in a situation in which your personal interest and that of Vasant

Chemicals are inconsistent. Such a situation, whether actual or apparent, is commonly referred to as a

conflict of interest.



Employees are prohibited from holding a position of Substantial Financial Interest (as defined below)

in an entity when that interest (a) conflicts with, or appears to conflict with, the proper performance of

the Covered Person's duties or responsibilities to Vasant Chemicals or (b) might affect the employee’s

independent judgment in transactions between Vasant Chemicals and the entity. Employees are required

to disclose any position (i.e. director, officer, employee, consultant) or Substantial Financial Interest that

they, or their Associate (as defined below), have in any entity that has business relations or dealings with,

or is a competitor of, Vasant Chemicals.

Conflicts of interest may not always be clear-cut. If you have any questions or concerns about a potential

or perceived conflict of interest, you must promptly notify and consult with our Senior management or

Director.

The following summarizes some of the more common conflicts of interest that may arise.

7.1 OUTSIDE ACTIVITIES

It is Vasant Chemicals's general policy that employees should not participate, directly or indirectly, in

outside business or personal activities that conflict with, or appear to conflict with, the proper

performance of Vasant Chemicals duties and responsibilities or might affect independence or judgment

in transactions between Vasant Chemicals and such an entity. This includes participation in any business

activity that would benefit from a relationship with Vasant Chemicals. Employees are encouraged to

work with civic, social and charitable organizations as long as participation does not present a potential

conflict of interest.

7.2 STOCK OWNERSHIP

Nominal ownership of securities of a publicly traded entity will not be considered a conflict of interest

and need not be disclosed. However, without proper approval, employees should not hold a Substantial

Financial Interest, either direct or indirect, in the securities of any company that conflicts with, or appears

to conflict with, the proper performance of Vasant Chemicals duties or responsibilities or might affect

independence or judgment in transactions between Vasant Chemicals and such an entity. Lower levels

of ownership could also be considered substantial, depending on the particular circumstances.

7.3 OTHER OUTSIDE INVESTMENTS

Outside investments by employees are not to include ownership, either directly or indirectly associated

with any current or proposed Vasant Chemicals operations or activities. In addition, employees may not

take advantage of personal investment or other business opportunities made available to them because

of their position with, or information from, Vasant Chemicals.



7.4 ASSISTING A COMPETITOR

An obvious conflict of interest is providing assistance to an entity or other business enterprise that

competes with our current or proposed activities. Without Vasant Chemicals's consent, employees may

not work for such an organization as an employee, consultant or member of its board of directors.

REPORTING OF BUSINESS TIME AND EXPENSES

Vasant Chemicals requires honest and accurate recording and reporting of information. Only the true

and accurate number of hours worked should be reported.

All expense reports must be submitted promptly and accurately. Managers are responsible for the careful

review of all expense reports submitted for their approval. Please refer to the guidelines set forth in the

"Business Travel and Expense Reporting policy" in making travel arrangements and incurring and

reporting related business expenses.

7.5 GIFTS AND ENTERTAINMENT

Gifts and entertainment must only be offered and accepted for conventional social and business purposes

at a level appropriate to the status and seniority of those involved. Review once when considering gifts

and entertainment (whether giving or receiving them) whether they could be intended, or even be

reasonably interpreted, as a reward or encouragement for a favor or for preferential treatment – if they

could be, then they are not permitted under these guidelines. Gifts and entertainment must never be

offered or accepted to obtain or retain business or for reward or inducement. All proposed offers of gifts

and hospitality made to government officials and corporate entities or a person or entity for the benefit

of such an official must be approved in advance in writing by the Chairman or Director.

7.6 CHARITABLE DONATIONS

Vasant is very keen by having social accountability to support charities, education trusts etc., but must

not do so at the request of customers and/or business partners. The donations whether made in cash or

by way of contribution to charitable events, publications or fundraising initiatives must be approved in

advance. Vasant does not allow gifts or donations to political parties. Payments to Officials Facilitation

payments are not permitted by these Guidelines. Facilitation payments are small payments made to

secure or expedite the performance of a routine action by a government official or agency (e.g. issuing

licenses or permits, processing goods through customs) to which the payer has a legal or other

entitlement. There are circumstances where Vasant must by law pay for the services of public officials



e.g. customs clearances or visits from the environmental regulators. We expect such officials to fulfill

their legal and regulatory duty and that any fee paid has a legal basis. Before any such payment is made,

a written document setting out the legal basis for the payment must be obtained from the official together

with a receipt. Additional payments or gifts must not be made to such officials. Vasant always gives its

full support to anyone refusing to pay a bribe whatever the inconvenience, loss of business or extra costs

involved for Vasant.

7.7 POLITICAL CONTRIBUTIONS AND ACTIVITIES

When we make political contributions in India, the following guidelines must be followed;

7.7.1 CORPORATE CAMPAIGN CONTRIBUTIONS

Vasant Chemicals will contribute Vasant Chemicals funds or assets (including property, services, or use

of facilities) in accordance with applicable law and as authorized by our Chairman or Director.

7.7.2 OTHER POLITICAL CONTRIBUTIONS

Applicable laws may limit our ability to make certain other types of political contributions. Vasant

Chemicals will contribute funds for political purposes as authorized by the Chairman or Director.

7.7.3 LOBBYING ACTIVITIES

Without prior approval of our Chairman or Director, no employee may officially represent Vasant

Chemicals in making contacts on our behalf with any central, state or local government official or

member or employee of a legislative body or government agency for the purpose of influencing policy,

legislation, agency rules or regulations or any other official action.

7.8 BREACHES OR POTENTIAL BREACHES OF THESE GUIDELINES

All employees are encouraged to raise concerns about any actual or suspected cases of bribery and

corruption at the earliest possible stage. Where anyone (supplier / customer / employee / public) believes

the Guidelines are not being complied with or they are being asked to carry out any act not in compliance

with these guidelines, these concerns must be raised immediately to “[email protected]”.

The employee’s concerns must be brought directly to the attention of the Chairman / Director. Anybody

can also report a suspected violation of these guidelines through Vasant’s suggestion scheme.

8.0 OPEN DOOR POLICY

A clear and open channel, for employee suggestions and problems, is a fundamental principle of Vasant

management philosophy. Therefore, each employee is encouraged talk with his/her supervisors about



any suggestion, problem or complaint that might arise concerning his/her work, working conditions,

treatment, Safety, Health and Environment, if any. If for any reason a satisfactory response is not

obtained from the supervisor or if for some reason the employee prefers not discuss the matter with

his/her supervisor, he/she encouraged to approach the Site HR Incharge. If for any reason a satisfactory

response is not obtained from the Site HR Incharge or if for some reason the employee prefers not

discuss the matter with Site HR Incharge, he/she encouraged to approach the Site In-charge The decision

of the Site Incharge is final. The receiver of complaint will look into the subject matter with fair mind,

and, if required, they will keep confidentially the name of the complainant and safeguard the interest of

the concerned employee. Simultaneously, the Management has designed and developed a process of

handling of grievances.

9.0 DRUGS AND ALCOHOL

Vasant is committed to providing its employees a safe working environment. Nothing interferes with

this mission more than employees reporting to work under the influence of alcohol or drugs unfit for

employment. Employees who are guilty of alcohol or drug abuse at work are a hazard to themselves and

other employees. In addition to possible violations of criminal laws, such conduct increases accidents

and serious injuries, reduces productivity, damages Company property and hurts morale. Therefore,

Employees are prohibited from performing Vasant Chemicals-related tasks while under the influence of

drugs or alcohol.

10.0 USE OF INFORMATION SYSTEMS

Employees generally have access to our information systems, such as computers, systems network and

Internet equipment, software and data, telephones, voice mail and xerox machines. Our information

systems should be primarily used for conducting Vasant Chemicals business.

10.1 DATA SECURITY & CONFIDENTIALITY:

Employees should have no expectation of privacy as to any communications and files (including

personal data and correspondence) that use Vasant Chemicals's information systems and should

recognize that such communications and files are considered business records that may be subject to

disclosure by the organization. Except as necessary in the normal course of business, employees should

not transmit e-mail concerning non-public information or potential liability. In addition, employees

should recognize that many materials available through the Internet and elsewhere are copyrighted. As

such, prior to using Vasant Chemicals assets to copy or download copyrighted materials, employees are

required to obtain the publisher's permission.



10.2 E-MAIL / TELEPHONES

The purpose of e- mail is to extend company business communications. Employees should not leave

messages containing sensitive or confidential information on e- mail systems.

All e-mails are treated as company’s property, regardless of content. E-mail should be treated as other

verbal or written business communications. Appropriate language and standards of decency must be

used. Offensive, demeaning, defamatory, or disruptive messages are prohibited. System users are

responsible for the content of all text, audio, and video sent using the internet or e-mail.

Company telephones, computers, and other communication devices are supplied for business purposes,

and while employees are allowed to use these devices periodically for personal use, this privilege is not

to be abused.

10.3 INTERNET USE:

Internet access is granted to employees, vendors, contractors, and customers based on business need.

Company may choose to limit internet access at their discretion. Acceptable use of the internet for

performing job functions might include:

to know the updates on statutory & regulatory requirements;

to see the potential vendors through the web sites for new vendor identification;

reference technical information; and

literature survey for research.

11.0 COMPANY ASSISTANCE / EXCEPTIONS

You should address any questions you may have about the Code to your supervisor or manager, who will relay

them to our Senior Management Team and Director. If you do not feel comfortable raising your questions with

your supervisor or manager, you may raise your questions directly with our Senior Management Team or Director.

12.0 REPORTING VIOLATIONS

Employees are obligated to help enforce the Code. If you become aware of a potential violation of the Code, you

must report that fact by:

contacting our Senior Management Team or Director; or utilizing Vasant Chemicals's contact number

(+91-40-27760905); or making report Offline / online to [email protected]



Vasant Chemicals will not allow any retaliation against you for reporting a potential violation of the

Code in good faith. Reports of a violation will be investigated promptly and the matter will be treated,

to the extent possible, as confidential.

13.0 CONSEQUENCES OF VIOLATION OF POLICY

Violating the Code is a serious offense that may subject you to disciplinary action, up to and including

termination of employment. In addition, violations of the law may subject Vasant Chemicals or you to

fines, penalties or other legal remedies, including imprisonment.

14.0 OTHER CONSIDERATIONS

Vasant Chemicals reserves the right to amend, supplement, or rescind the Code or any policy, in whole

or in part, at any time and to adopt different policies and procedures. This Code will be reviewed

periodically by the Code Owner.

--- End of the document ---

vasant chemicals pvt. ltd., 1-11/152, 4 floor, vasant

Documents