Code of Conduct Policy
Establishing standards of integrity, professionalism, and ethical business conduct across all operations
1. Policy Statement
AIRVINCIBLE ("Company") is committed to conducting its business with the highest standards of integrity, professionalism, accountability, transparency and ethical conduct. Every employee represents the Company's values while interacting with customers, clients, vendors, business partners, regulatory authorities and fellow employees. Accordingly, every individual associated with the Company is expected to conduct themselves in a manner that upholds the Company's reputation, protects client confidence and promotes a respectful, secure and legally compliant workplace.
This Code of Conduct ("Code") establishes the minimum standards of professional behaviour expected from every employee during the course of employment. The Code serves as the foundation for ethical decision-making, operational discipline and workplace accountability across all departments of the Company.
The Company adopts a Zero Tolerance approach towards unethical conduct, fraud, dishonesty, discrimination, harassment, abuse of authority, confidentiality breaches, data misuse, customer exploitation, misrepresentation and any conduct that adversely affects the Company's business, employees, clients or reputation.
Every employee is expected to read, understand and comply with this Code together with all other Company policies, employment contracts and applicable laws. Compliance with this Code is a condition of employment, and violation of its provisions may result in disciplinary action, including termination of employment and legal proceedings wherever warranted.
2. Objectives
The objectives of this Policy are to:
- (a) establish uniform standards of professional conduct;
- (b) promote honesty, integrity and accountability in the workplace;
- (c) ensure ethical business practices;
- (d) maintain a respectful and inclusive work environment;
- (e) safeguard client confidence and business reputation;
- (f) establish behavioural expectations for employees;
- (g) ensure compliance with applicable laws and Company policies;
- (h) promote responsible handling of Company and client information;
- (i) strengthen operational discipline and workplace professionalism;
- (j) prevent fraud, corruption and unethical conduct;
- (k) encourage responsible decision-making;
- (l) establish customer service excellence;
- (m) protect Company assets and confidential information;
- (n) promote transparency in business operations; and
- (o) create a culture of mutual respect, responsibility and continuous improvement.
3. Scope and Applicability
This Policy applies to every person associated with AIRVINCIBLE, including:
- Permanent Employees;
- Probationary Employees;
- Fixed-Term Employees;
- Contractual Employees;
- Temporary Employees;
- Interns;
- Apprentices;
- Trainees;
- Consultants;
- Advisors;
- Directors;
- Agency Personnel;
- Third-Party Workforce;
- Remote Employees;
- Hybrid Employees; and
- Any other individual authorised to perform work on behalf of the Company.
This Policy shall apply throughout the employment lifecycle, including:
- recruitment;
- onboarding;
- probation;
- confirmation;
- transfers;
- promotions;
- business travel;
- work-from-home arrangements;
- client assignments;
- resignation;
- notice period; and
- post-employment obligations relating to confidentiality, intellectual property and non-disclosure.
The Policy applies while employees are:
- working at Company premises;
- working remotely;
- attending client locations;
- participating in official events;
- travelling for official purposes;
- communicating through Company systems; or
- representing the Company in any capacity.
4. Core Values
Every employee shall conduct themselves in accordance with the following core values:
- Integrity;
- Honesty;
- Professionalism;
- Respect;
- Accountability;
- Transparency;
- Fairness;
- Confidentiality;
- Customer Commitment;
- Compliance;
- Teamwork;
- Responsibility;
- Excellence; and
- Continuous Learning.
Every business decision and workplace interaction shall reflect these values.
5. Professional Conduct
Employees shall maintain the highest standards of professional conduct while performing their duties.
Every employee shall:
- (a) perform assigned responsibilities diligently;
- (b) comply with lawful instructions issued by authorised supervisors;
- (c) maintain honesty and integrity in every official activity;
- (d) avoid behaviour that may damage the Company's reputation;
- (e) maintain professionalism during all workplace interactions;
- (f) perform duties with due care, skill and responsibility;
- (g) act in the best interests of the Company while discharging official responsibilities;
- (h) maintain respectful communication;
- (i) comply with all Company policies and procedures;
- (j) refrain from abusive, threatening or offensive conduct;
- (k) maintain appropriate workplace etiquette;
- (l) avoid conduct bringing disrepute to the Company; and
- (m) immediately report any violation of this Code.
Employees shall not misuse their designation, authority, access privileges or official position for personal benefit or for causing unlawful advantage to any person.
6. Respectful Workplace Standards
The Company is committed to maintaining a workplace founded upon dignity, equality, mutual respect and professionalism.
Accordingly, every employee shall:
- (a) treat colleagues, customers and visitors with courtesy;
- (b) respect diversity and individual differences;
- (c) avoid abusive language;
- (d) refrain from discriminatory behaviour;
- (e) avoid bullying or intimidation;
- (f) refrain from workplace harassment;
- (g) cooperate with colleagues;
- (h) maintain professional boundaries;
- (i) resolve disagreements respectfully;
- (j) contribute towards a positive work culture; and
- (k) comply with the Company's POSH Policy, Zero Tolerance Policy and Employee Grievance Redressal Policy.
Any behaviour creating a hostile, intimidating, humiliating or offensive work environment shall constitute misconduct.
7. Ethical Business Conduct
Employees shall conduct Company business honestly, fairly and ethically.
Employees shall not:
- (a) engage in bribery;
- (b) offer or accept unlawful gratification;
- (c) manipulate Company records;
- (d) falsify documents;
- (e) conceal material facts;
- (f) misrepresent information;
- (g) misuse Company funds;
- (h) abuse official authority;
- (i) engage in dishonest business practices;
- (j) knowingly violate applicable laws;
- (k) facilitate fraudulent activities; or
- (l) assist another person in committing unethical conduct.
Every employee owes a fiduciary duty to protect the Company's legitimate business interests.
8. Customer Service Standards
Every employee interacting with customers shall provide courteous, professional, accurate and lawful service.
Employees shall:
- (a) communicate respectfully;
- (b) actively listen to customer concerns;
- (c) provide accurate information;
- (d) follow approved Company scripts, where applicable;
- (e) maintain patience and professionalism;
- (f) avoid arguments with customers;
- (g) escalate complex matters appropriately;
- (h) maintain customer confidentiality;
- (i) avoid making false commitments;
- (j) avoid misleading statements;
- (k) ensure proper documentation of customer interactions;
- (l) comply with quality standards; and
- (m) maintain complete honesty while representing the Company.
Customer satisfaction shall never justify violation of law, Company policy or ethical standards.
9. Inbound Calling Standards
Employees engaged in inbound customer support shall:
- (a) answer calls promptly and courteously;
- (b) identify themselves in accordance with approved scripts;
- (c) verify customer identity before disclosing confidential information;
- (d) understand customer requirements before responding;
- (e) communicate clearly and professionally;
- (f) avoid unnecessary call transfers;
- (g) accurately record customer interactions in the CRM system;
- (h) provide only authorised information;
- (i) maintain call quality standards;
- (j) follow approved escalation procedures;
- (k) avoid placing customers on unnecessary hold;
- (l) ensure proper call closure; and
- (m) comply with all client-specific operational guidelines.
Employees shall not intentionally disconnect calls, delay customer assistance or manipulate call outcomes.
10. Outbound Calling Standards
Employees engaged in outbound calling shall:
- (a) identify themselves and the Company truthfully;
- (b) clearly state the purpose of the call;
- (c) comply with approved calling scripts;
- (d) maintain courteous communication;
- (e) respect customer preferences;
- (f) avoid misleading sales practices;
- (g) refrain from making false representations;
- (h) accurately record call outcomes;
- (i) comply with applicable calling regulations;
- (j) immediately discontinue communication where legally required;
- (k) avoid coercive or aggressive selling practices;
- (l) escalate customer complaints promptly; and
- (m) maintain complete professionalism throughout every interaction.
Employees shall not impersonate any individual, organisation or government authority during customer interactions.
11. Communication Standards
Employees shall communicate honestly, respectfully and professionally through every mode of communication, including:
- verbal communication;
- emails;
- official messaging platforms;
- video conferences;
- CRM notes;
- reports;
- presentations;
- written correspondence;
- client communications; and
- social or digital workplace platforms.
Employees shall not:
- (a) use abusive language;
- (b) make defamatory statements;
- (c) circulate rumours;
- (d) intentionally provide misleading information;
- (e) use offensive expressions;
- (f) disclose confidential information without authority;
- (g) make discriminatory remarks;
- (h) engage in workplace gossip affecting professional relationships; or
- (i) communicate in a manner likely to damage the Company's reputation or client relationships.
12. General Employee Obligations
Every employee shall:
- comply with all applicable laws and Company policies;
- maintain professional conduct;
- safeguard Company property;
- protect confidential information;
- cooperate during investigations;
- report unethical conduct;
- respect workplace diversity;
- maintain accurate business records;
- perform duties honestly and responsibly; and
- uphold the Company's values at all times.
Failure to comply with this Code may result in disciplinary action in accordance with the Company's Disciplinary Policy and other applicable policies.
Information Security, Confidentiality, Conflict of Interest, Social Media Conduct, Attendance & Punctuality, Anti-Fraud Requirements & Employee Protection Mechanism
13. Information Security
The Company recognizes that information is one of its most valuable assets. Every employee is responsible for protecting Company information, client information, customer data and all electronic resources from unauthorized access, disclosure, misuse, alteration, destruction or loss.
Employees shall comply with the provisions of the Information Technology Act, 2000, as amended, applicable rules, client contractual obligations, Company Information Security Policy and all cybersecurity directives issued by the Company from time to time.
Every employee shall:
- (a) protect Company systems against unauthorized access;
- (b) use only Company-approved software, applications and communication platforms;
- (c) maintain secure passwords and authentication credentials;
- (d) immediately report suspected cybersecurity incidents;
- (e) comply with access control requirements;
- (f) safeguard Company devices;
- (g) protect digital records from unauthorized copying or transmission;
- (h) follow secure login and logout procedures;
- (i) comply with client-specific information security requirements; and
- (j) cooperate during information security audits and investigations.
Employees shall not:
- (a) install unauthorized software;
- (b) disable security controls;
- (c) bypass security protocols;
- (d) share passwords;
- (e) disclose login credentials;
- (f) access information without authorization;
- (g) copy Company or client data without approval;
- (h) connect unauthorized storage devices;
- (i) use Company systems for illegal activities; or
- (j) deliberately compromise information security.
Violation of information security requirements shall constitute serious misconduct and may attract disciplinary, civil and criminal action.
14. Confidentiality Obligations
Every employee owes a continuing duty of confidentiality towards the Company, its clients, customers, vendors and business partners.
Confidential Information includes, without limitation:
- (a) customer information;
- (b) client databases;
- (c) business strategies;
- (d) pricing information;
- (e) contracts;
- (f) financial information;
- (g) employee records;
- (h) payroll information;
- (i) passwords;
- (j) source codes;
- (k) software systems;
- (l) CRM records;
- (m) call recordings;
- (n) operational manuals;
- (o) policies;
- (p) intellectual property;
- (q) marketing strategies;
- (r) trade secrets;
- (s) legal documents; and
- (t) any information designated as confidential.
Employees shall:
- access confidential information only for legitimate business purposes;
- disclose confidential information only to authorized persons;
- maintain confidentiality even after separation from employment;
- securely store Company records;
- immediately report any confidentiality breach; and
- comply with all confidentiality agreements executed with the Company.
Employees shall not:
- (a) disclose confidential information to unauthorized persons;
- (b) discuss client information in public places;
- (c) forward confidential emails to personal accounts;
- (d) retain Company documents after cessation of employment without authorization;
- (e) copy confidential data for personal use;
- (f) disclose customer details to third parties; or
- (g) misuse confidential information for personal or commercial benefit.
15. Conflict of Interest
Employees shall avoid every situation in which their personal interests conflict, or appear to conflict, with the legitimate interests of the Company.
A Conflict of Interest may arise where an employee:
- (a) has a financial interest in a competitor, vendor or client;
- (b) engages in outside employment affecting Company duties;
- (c) awards business to relatives or associated entities without disclosure;
- (d) uses Company resources for personal business;
- (e) accepts personal benefits influencing official decisions;
- (f) participates in decision-making where personal relationships exist;
- (g) competes directly with the Company;
- (h) exploits business opportunities belonging to the Company; or
- (i) engages in any activity likely to impair impartiality.
Exceptional Circumstances
Where an employee believes that a potential conflict cannot reasonably be avoided, the employee shall immediately disclose the same in writing to the Human Resources Department and the Compliance or Legal Department.
The Company may, after evaluating the facts, permit continuation of the activity subject to written disclosure, mitigation measures, recusal from decision-making or any other safeguards considered appropriate.
Failure to disclose an actual or potential conflict of interest may constitute misconduct.
16. Social Media and Public Communication
Employees shall use social media responsibly and in a manner that protects the Company's reputation, client relationships and confidential information.
This Policy applies to all forms of digital communication, including:
- Facebook;
- Instagram;
- X (formerly Twitter);
- LinkedIn;
- YouTube;
- WhatsApp;
- Telegram;
- Snapchat;
- Blogs;
- Discussion Forums;
- Online Communities; and
- Any other social networking or digital platform.
Employees shall not:
- (a) publish confidential Company information;
- (b) disclose client information;
- (c) publish customer data;
- (d) circulate internal documents;
- (e) post defamatory, false or misleading statements concerning the Company, its employees, clients or business partners;
- (f) create or circulate rumours;
- (g) upload photographs or videos taken within restricted workplace areas without authorization;
- (h) make unauthorized public statements on behalf of the Company;
- (i) misuse Company logos, trademarks or branding;
- (j) engage in online harassment, bullying or abusive conduct connected with the workplace;
- (k) share screenshots of internal systems, emails, customer records or meetings;
- (l) circulate irrelevant, offensive or objectionable content using Company communication platforms; or
- (m) engage in any online activity that may reasonably damage the Company's reputation or business interests.
Nothing contained in this Policy shall restrict any rights available to employees under applicable law.
17. Attendance, Punctuality and Work Discipline
Employees shall maintain regular attendance and report for duty punctually in accordance with their assigned work schedules.
Employees shall:
- (a) report to work on time;
- (b) comply with assigned shift timings;
- (c) accurately record attendance through approved systems;
- (d) obtain prior approval for leave wherever practicable;
- (e) promptly notify their Reporting Manager in case of unavoidable absence;
- (f) comply with roster schedules;
- (g) remain available during assigned working hours; and
- (h) complete assigned duties before leaving the workplace.
Employees shall not:
- (a) engage in habitual late reporting;
- (b) leave the workplace without authorization;
- (c) manipulate attendance records;
- (d) permit attendance marking by another person;
- (e) misuse work-from-home arrangements;
- (f) remain unavailable during assigned duty hours without justification; or
- (g) repeatedly violate attendance requirements.
Repeated attendance-related violations may attract disciplinary action.
18. Company Property and Assets
Employees shall exercise reasonable care while using Company property and assets.
Company assets include:
- computers;
- laptops;
- mobile devices;
- headsets;
- access cards;
- servers;
- software;
- furniture;
- documents;
- identity cards;
- communication systems;
- storage devices;
- client equipment; and
- every other asset provided by the Company.
Employees shall not:
- (a) misuse Company property;
- (b) remove assets without authorization;
- (c) intentionally damage Company property;
- (d) use Company assets for unlawful activities;
- (e) install unauthorized hardware or software; or
- (f) retain Company property after cessation of employment.
19. Anti-Fraud Requirements
The Company adopts a strict Zero Tolerance approach towards fraud, dishonesty and financial misconduct.
Employees shall not:
- (a) falsify attendance records;
- (b) manipulate customer information;
- (c) forge signatures;
- (d) alter official records;
- (e) create fictitious transactions;
- (f) manipulate incentive calculations;
- (g) submit false reimbursement claims;
- (h) misuse Company funds;
- (i) facilitate fraudulent customer activities;
- (j) conceal financial irregularities;
- (k) knowingly assist fraud; or
- (l) derive wrongful gain through misuse of official position.
Every employee shall immediately report any suspected fraud to Human Resources, Compliance, Legal Department or any designated reporting authority.
20. Gifts, Hospitality and Improper Benefits
Employees shall not solicit, accept or offer gifts, hospitality, favours or benefits that may improperly influence business decisions or create an actual or perceived conflict of interest.
Nominal customary gifts of insignificant value exchanged during recognised festivals or business occasions may be accepted only where they do not compromise integrity and are otherwise permissible under Company guidelines.
Any gift, hospitality or benefit that may influence, or appear to influence, official decision-making shall be disclosed to the Company and may require prior approval or refusal.
Bribery, kickbacks, secret commissions or any unlawful gratification are strictly prohibited.
21. BPO Operational Compliance
Employees engaged in inbound and outbound calling operations shall additionally comply with operational requirements including:
- (a) adherence to approved call scripts;
- (b) accurate customer verification procedures;
- (c) proper CRM documentation;
- (d) lawful call recording practices;
- (e) compliance with quality assurance standards;
- (f) timely escalation of unresolved customer concerns;
- (g) prohibition on unauthorized call transfers;
- (h) prohibition on intentionally disconnecting customer calls;
- (i) prohibition on call avoidance or manipulation of call metrics;
- (j) accurate disposition of calls;
- (k) compliance with client Service Level Agreements (SLAs);
- (l) proper use of AI-assisted tools only where authorised by the Company;
- (m) maintenance of customer privacy during every interaction; and
- (n) compliance with all client-specific operational guidelines.
Any manipulation of operational metrics, falsification of call records or deliberate non-compliance with client instructions shall constitute misconduct.
22. Employee Protection Mechanism
The Company encourages employees to report suspected violations of this Code in good faith.
No employee shall be subjected to retaliation merely because such employee:
- (a) reports misconduct;
- (b) reports fraud;
- (c) reports unethical behaviour;
- (d) reports client data misuse;
- (e) participates in an investigation;
- (f) provides evidence;
- (g) refuses to participate in unlawful conduct; or
- (h) cooperates with Compliance, Human Resources or Legal Department.
The Company shall take reasonable measures to protect reporting employees from intimidation, discrimination, victimization or adverse employment consequences arising solely from bona fide reporting.
Knowingly making false, malicious or fabricated allegations shall not be protected under this clause and may attract disciplinary action.
Reporting Violations, Investigation Procedure, Disciplinary Framework, Responsibilities, Compliance, Policy Administration & Employee Acknowledgement
23. Reporting of Violations
Every employee has an ethical and professional obligation to promptly report any actual, suspected or attempted violation of this Code, Company policies or applicable laws.
Reports may be made to:
- (a) Immediate Reporting Manager;
- (b) Human Resources Department;
- (c) Compliance Department;
- (d) Legal Department;
- (e) Senior Management; or
- (f) any other reporting mechanism notified by the Company from time to time.
Employees are encouraged to make reports in good faith and with reasonable belief that the information provided is true.
The Company shall endeavour to treat every report seriously and take appropriate action wherever warranted.
Failure to report serious misconduct despite knowledge thereof may itself constitute misconduct.
24. Investigation Procedure
Upon receipt of a complaint or report concerning an alleged violation of this Code, the Company may initiate an internal investigation.
Depending upon the nature of the allegation, the investigation may be conducted by:
- Human Resources Department;
- Compliance Department;
- Legal Department;
- Information Security Team;
- Internal Audit Team;
- Special Investigation Committee; or
- any authority nominated by the Management.
The investigation process may include:
- (a) preliminary assessment;
- (b) collection of documentary evidence;
- (c) examination of electronic records;
- (d) review of CCTV footage, where available;
- (e) review of emails, CRM logs, call recordings and system logs;
- (f) interviews of concerned persons;
- (g) examination of witnesses;
- (h) obtaining written explanations;
- (i) forensic review of digital evidence, where required; and
- (j) preparation of an investigation report.
Every investigation shall be conducted impartially, confidentially and in accordance with the principles of natural justice.
Employees shall fully cooperate during investigations.
Obstruction of an investigation, destruction of evidence, influencing witnesses or providing false information shall constitute serious misconduct.
25. Disciplinary Framework
Violation of this Code may result in disciplinary action proportionate to the seriousness of the misconduct.
While determining disciplinary action, the Company may consider:
- (a) nature of misconduct;
- (b) severity of the violation;
- (c) financial impact;
- (d) operational impact;
- (e) client impact;
- (f) reputational impact;
- (g) previous disciplinary history;
- (h) intention of the employee;
- (i) frequency of violations;
- (j) cooperation during investigation; and
- (k) any mitigating or aggravating circumstances.
The Company may impose one or more of the following actions:
- (a) verbal counselling;
- (b) written warning;
- (c) advisory memorandum;
- (d) mandatory retraining;
- (e) performance improvement measures;
- (f) withholding of incentives or variable pay, where permissible;
- (g) suspension pending inquiry or disciplinary proceedings;
- (h) transfer to another role or department;
- (i) withdrawal of specific responsibilities or system access;
- (j) recovery of financial losses to the extent permissible under law and contract;
- (k) termination of employment;
- (l) termination of contractual engagement;
- (m) blacklisting of vendors, consultants or contractors, where applicable;
- (n) reporting the matter to clients, regulatory authorities or law enforcement agencies where legally required; and
- (o) initiation of civil or criminal proceedings, wherever appropriate.
Nothing in this Policy shall prevent the Company from taking immediate action where necessary to protect its employees, customers, clients, assets or business interests.
26. Corrective and Preventive Actions
In addition to disciplinary measures, the Company may implement corrective and preventive actions to address the root cause of violations and reduce the likelihood of recurrence.
Such actions may include:
- (a) revision of internal procedures;
- (b) enhancement of operational controls;
- (c) strengthening of information security measures;
- (d) additional employee training;
- (e) process audits;
- (f) supervision or mentoring;
- (g) policy amendments;
- (h) enhancement of technological safeguards;
- (i) client communication, where required; and
- (j) any other corrective measure considered appropriate by the Management.
27. Responsibilities of Employees
Every employee shall:
- (a) comply with this Code and all Company policies;
- (b) perform duties honestly and diligently;
- (c) protect Company property and confidential information;
- (d) maintain professional conduct;
- (e) avoid conflicts of interest;
- (f) promptly report unethical conduct;
- (g) cooperate during investigations;
- (h) comply with applicable laws and client requirements;
- (i) maintain accurate business records; and
- (j) uphold the Company's reputation at all times.
28. Responsibilities of Managers and Supervisors
Managers and Supervisors shall:
- (a) lead by example;
- (b) promote ethical conduct within their teams;
- (c) ensure compliance with Company policies;
- (d) address employee concerns promptly;
- (e) encourage reporting of misconduct;
- (f) prevent retaliation against reporting employees;
- (g) cooperate during investigations;
- (h) ensure timely escalation of serious violations;
- (i) maintain confidentiality of sensitive matters; and
- (j) foster a respectful and legally compliant workplace.
Failure by a Manager or Supervisor to take reasonable action after becoming aware of serious misconduct may itself constitute a violation of this Code.
29. Responsibilities of Human Resources, Compliance and Legal Department
The Human Resources Department shall:
- (a) administer this Policy;
- (b) conduct awareness programmes;
- (c) maintain disciplinary records;
- (d) coordinate investigations, where applicable;
- (e) recommend disciplinary action; and
- (f) monitor policy implementation.
The Compliance Department shall:
- (a) monitor adherence to regulatory and internal compliance requirements;
- (b) conduct compliance reviews and audits;
- (c) investigate compliance-related concerns;
- (d) recommend preventive measures; and
- (e) support implementation of corrective actions.
The Legal Department shall:
- (a) advise on legal implications of misconduct;
- (b) assist in investigations involving statutory or contractual issues;
- (c) coordinate with external legal authorities where necessary;
- (d) recommend legal action where warranted; and
- (e) safeguard the Company's legal interests.
30. Record Keeping
The Company shall maintain appropriate records relating to:
- (a) complaints received;
- (b) investigation reports;
- (c) disciplinary proceedings;
- (d) employee acknowledgements;
- (e) policy training records;
- (f) compliance audits;
- (g) corrective actions;
- (h) warning letters;
- (i) termination records; and
- (j) any other records required under applicable law or Company policy.
Such records shall be maintained securely and shall be accessible only to authorised personnel.
31. Compliance with Applicable Laws
Every employee shall comply with all applicable laws, regulations, contractual obligations and governmental directions relevant to their duties, including but not limited to:
- labour and employment laws;
- the Information Technology Act, 2000, as amended;
- data protection and privacy obligations, where applicable;
- intellectual property laws;
- anti-corruption and anti-bribery laws;
- consumer protection laws;
- contractual obligations with clients; and
- any other law applicable to the Company's operations.
Where any provision of this Code is more stringent than the minimum legal requirement, employees shall comply with the higher standard to the extent permitted by law.
32. Relationship with Other Company Policies
This Code shall be read together with, and shall complement, the Company's:
- Zero Tolerance Policy;
- Employee Grievance Redressal Policy;
- Prevention of Sexual Harassment (POSH) Policy;
- Information Security Policy;
- Data Privacy Policy;
- Confidentiality & Non-Disclosure Policy;
- Attendance & Leave Policy;
- Disciplinary Policy;
- Anti-Fraud Policy;
- Equal Opportunity Policy; and
- any other policy, procedure or guideline issued by the Company from time to time.
Where a particular act constitutes a violation under multiple policies, the Company may initiate action under one or more applicable policies simultaneously, subject to the principles of fairness and applicable law.
33. Policy Review and Amendment
This Policy shall be reviewed periodically and may be amended, modified or replaced by the Company to reflect changes in applicable laws, judicial decisions, client requirements, technological developments or business needs.
Any amendment shall become effective from the date notified by the Company unless otherwise specified.
34. Saving Clause
Nothing contained in this Code shall:
- (a) restrict the Company's right to initiate disciplinary, civil, criminal or regulatory proceedings where warranted;
- (b) affect the statutory rights or obligations of employees or the Company under applicable law;
- (c) limit any contractual rights available to the Company;
- (d) prevent employees from approaching competent statutory authorities where such right exists under law; or
- (e) prejudice any action required to ensure workplace safety, operational continuity, regulatory compliance or protection of Company assets, confidential information and business interests.
In the event of any inconsistency between this Code and any applicable law, the provisions of the applicable law shall prevail to the extent of such inconsistency, while the remaining provisions of this Code shall continue to remain valid and enforceable.
35. Employee Acknowledgement
Every employee shall be deemed to have read, understood and accepted this Code upon its communication, publication on the Company's intranet or internal portal, inclusion in the Employee Handbook, issuance through electronic means or execution of an acknowledgement form.
Employees shall comply with this Code throughout the course of their employment and, where applicable, continue to honour obligations relating to confidentiality, intellectual property, non-disclosure and protection of Company interests even after cessation of employment.
Failure to comply with this Code may result in disciplinary action, including termination of employment, recovery of losses where legally permissible, and initiation of civil or criminal proceedings, depending upon the nature and seriousness of the violation.