COMPANY POLICIES

Energy Policy

We at Manu Yantralaya Pvt. Ltd. are committed to efficient use of various forms of energy to produce and deliver products and services to our customers, minimize cost and enhance competitive position. To accomplish this we will:

  • Monitor closely and control the consumption of various forms of energy through an effective energy management system.
  • Make energy conservation a mass movement with awareness and involvement of all employees.
  • Adopt appropriate energy efficient technology to reduce consumption.
  • Maximize use of cheaper and easily available or alternative forms of energy and implement contingency plans to protect operations from energy supply interruptions.
  • Maintain a clean environment and conserve natural resources.
  • Cooperate with governmental agencies and utility companies on energy programs.

Environmental, Health Safety Policy

MANU is committed to achieve the highest performance in occupational health and safety, and the preservation of the environment in all company’s activities. In the pursuit towards this, MANU shall adopt the following policy based on OHSAS 18001and ISO 14001 guidelines:

1. Individual Responsibility

Every employee is responsible for the safety and health of himself / herself and of others at his/her workplace.

2. Legal Requirements

Comply with relevant environmental, health and safety, regulations, laws and other requirements.

3. Environmental, Health & Safety Awareness

Create awareness on environmental, health and safety issues to prohibit any activity that may damage/ endanger the environment and employees.

4. Training & Support

Provide training, instruction and supervision adequately and promote total involvement of all employees.

5. Management Responsibility & Accountability

Department/ Divisional Heads are responsible to educate and supervise their staff and to be accountable for the overall implementation of this policy in their areas of responsibilities.

6. Audit & Policy Review

Conduct regular inspection and audit and review policy periodically.

7. Continual Improvement

Continually improve Environmental, Health and Safety Management System towards the prevention of pollution and accident-free work environment through effective environmental, health and safety programs.

Quality Objectives

  • Develop methods of identification of defects at an early stage, facilitating their prevention and timely actions.
  • Continuous improvement in process capability levels.
  • Regular training to employees enabling them participate in accomplishment and fulfillment of our goals.
  • Extensive use of 7 QI (Quality Improvement) tools in day to day operations.
  • Develop a system based on team work and participation of individuals at all levels resulting in problem elimination and system improvement at respective functional level.

Anti-bribery Policy

Introduction

The purpose of this policy is to set out the values, principles and responsibilities for all of our employees to ensure that the Company’s business is conducted in a socially responsible and ethical manner. Therefore, all forms of bribery and corruption are unacceptable and will not be tolerated. All directors and employees are required to comply with this policy. Compliance with this policy is a mandatory requirement.

Policy Statement

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as a reward for action which is illegal or a breach of trust. This includes accepting anything of material value to gain a commercial, contractual, regulatory or personal advantage. It is our code to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption.

Scope

Who is covered by the code?

In this code, third party means any individual or organization you come into contact with during the course of your work, and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties. This code applies to all individuals working at all levels, including senior managers, officers, employees (whether permanent or temporary), consultants, contractors, trainees or interns This code covers:

  • Bribes;
  • Gifts and hospitality;
  • Facilitation (foreign officials) payments;
  • Political contributions;
  • Charitable contributions.

Bribes
Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.

Gifts and Hospitality
Employees must not offer or give any gift or hospitality:

  • which could be regarded as illegal or improper, or which violates the recipient’s policies; or
  • to any public employee or government officials or representatives, or politicians or political parties; or
  • which exceeds INR 5000 in value for each individual or event gift, unless approved by Senior Management.

Employees may not personally accept any gift or hospitality from any business partners. Such gifts shall be accepted and distributed fairly to all staff as per Senior Management approval. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

Facilitation payments and kickbacks
Our strict policy is that facilitation payments must not be paid. Facilitation payments are made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage.

Political Contributions
We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage. Employees may personally make political contributions provided they are not used to conceal bribery and are legal and ethical under local laws and practices.

Charitable Contributions
Charitable support and donations are acceptable (and are encouraged!), whether they be in-kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices.

Your responsibilities

You must ensure that you read, understand and comply with this code. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for or with us. All employees are required to avoid any activity that might lead to, or suggest, a breach of this code. You must notify Senior Management as soon as possible if you believe or suspect that a conflict with or breach of this code has occurred, or may occur in the future. Any employee who breaches this code will face disciplinary action, which could result in immediate dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers or organizations if they breach this code.

Record-keeping

We keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. You must disclose to Senior Management all hospitality or gifts accepted or offered. All accounts, invoices and other documents and records relating to dealings with third parties, such as customers, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised directly with Senior Management.

What to do if you are a victim of bribery or corruption

It is important that you tell Senior Management as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this code, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform Senior Management immediately.

Whistle Blower Policy

The Company believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting highest standards of professionalism, honesty, integrity and ethical behaviour. Towards this end, the Company has adopted the Code of Conduct, which lays down the principles and standards that should govern the actions of the Company and its employees. Any actual or potential violation of the Code, howsoever insignificant or perceived as such, would be a matter of serious concern for the Company. The role of the employees in pointing out such violations of the Code cannot be undermined.

Every employee of company shall promptly report to the management, and / or third-party ethics helpline, when she / he becomes aware of any actual or possible violation of the Code or an event of misconduct, act of misdemeanor or act not in the company’s interest. Such reporting shall be made available to suppliers and partners, too.

Any employee can choose to make a protected disclosure under the whistleblower policy of the company, such a protected disclosure shall be forwarded, when there is reasonable evidence to conclude that a violation is possible or has taken place, with a covering letter, which shall bear the identity of the whistleblower. The company shall ensure protection to the whistleblower and any attempts to intimidate him/her would be treated as a violation of the Code.

Definitions

Employee means every employee of the Company including the directors of the Company.

Protected Disclosure means any communication made in good faith that discloses or demonstrates information that may evidence unethical or improper activity.

Whistleblower means an Employee or director making a Protected Disclosure under this Policy.

Scope

This Policy is an extension of the Code of Conduct. The Whistleblower’s role is that of a reporting party with reliable information. They are not required or expected to act as investigators or finders of facts, nor would they determine the appropriate corrective or remedial action that may be warranted in a given case.

Whistleblowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the Director / plant head.

Procedure

All Protected Disclosures should be addressed to the Plant Head or Director of the Company for investigation.

All Protected Disclosures reported under this Policy will be thoroughly investigated by the Director / Plant head or their representative.

The identity of whistle blower and person under investigation will be kept confidential to the extent possible given the legitimate needs of law and the investigation.

Person under investigation will normally be informed of the allegations at the outset of a formal investigation and have opportunities for providing their inputs during the investigation.

The investigation shall be completed normally within 45 days of the receipt of the Protected Disclosure.

Protection

No unfair treatment will be meted out to a Whistleblower by virtue of his/her having reported a Protected Disclosure under this Policy. The Company, as a policy, condemns any kind of discrimination, harassment, victimization or any other unfair employment practice being adopted against Whistleblowers. Complete protection will, therefore, be given to Whistleblowers against any unfair practice like retaliation, threat or intimidation of termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, or the like including any direct or indirect use of authority to obstruct the Whistleblower’s right to continue to perform his/her duties/functions including making further Protected Disclosure. The Company will take steps to minimize difficulties in this process.

Retention of Documents

All Protected Disclosures in writing or documented along with the results of investigation relating thereto shall be retained by the Company for a minimum period of three years.