Kundan Group has consistently adhered to the values and ideals articulated by the Founders of the Organisation. This Code of Conduct helps ensure compliance with standards of our business practices and legal requirements. It articulates the Kundan group Values ’s values and ideals that guide and govern the conduct of our group companies as well as our employees, vendors, service providers, consultants etc. in all matters relating to business. This Code is a bedrock on which we base our individual, as well as leadership commitments to core values.

This Code of Conduct outlines our commitment to each of our stakeholders, including the communities in which we operate, and is our guiding light when we are sometimes faced with business dilemmas that leave us at ethical crossroads. The Code is also dynamic in that it has been periodically refreshed in order to remain contemporary and contextual to the changes in law and regulations. However, it remains unaltered at its core.

Our stellar reputation and success as a business entity has been defined by the powerful commitment and adherence to the core values and principles expressed in this Code, by all our employees, officers and our top management. We expect every person and Organisation, interacting with us in any manner whatsoever, will continue to not only comply with the laws and regulations that govern our business interests around the world, but will continue to set new standards of ethical conduct that will generate deep respect and inspire emulation by others.

Every employee and officer (‘employees”) of Kundan Group must follow this Code at all times when representing or working for Kundan Group or on behalf of the Kundan Group. Even where specific reference is made to Kundan Group , the same principles and guidance applies whether employees are working any location of Kundan group. All persons, including service providers, vendors, consultant dealing with Kundan Group, will be required to act consistently with this Code when acting on our behalf or in our name.

A. OUR CORE VALUES

Kundan group has always been values-driven. The seven core values that underpin the way we expect all stakeholders to conduct themselves are:

Core Work Values:

• Decision Making ability –

Every employee at all levels should have ability to take decisions or have ability to create Alternate solutions Mechanism for Decision Making

• Multi Task Responsibility –

Ability to Multi Task in Ones function and across cross functions synergy

• Speed –

Speed is an essence to be ahead of all Business variables both micro and macro.

• Transparency-

• Transparency in all dealings within and outside the organization.

Core Personal Values

• Multi Task Responsibility –

• Humble ness –

Be non-defensive; Treat everyone with respect and recognize others’ contributions.

• Self-Discipline

Self-Discipline is being discipline initiate by one self in terms of all activities on 360degrees of Work

• Sincerity & Honesty

Sincere and honest in all policies, processes, procedures and all activities of work

B. DEFINITIONS

1. Term “we”, “us”, “our”, “our Company” “Company” means Kundan Group and its Companies with Kundan affiliation as the context may require.
   
   
2. The term “our Kundan Group companies” in this Code typically means companies with Kundan affiliation intends for this Code to apply to, and / or to whom this Code has been issued.
   
   
3. Term “our stakeholders” means, our financial stakeholders, our employees and those who work with us.
   
   
4. The term “Partner” means and include our vendors, service providers, suppliers, consultant, external agencies, advisors etc.

SCOPE AND PURPOSE OF THIS CODE

1. This code sets out how Kundan Group behave with:
   
   • our employees, and those who work with us;
   
   • our customers;
   
   • the communities and the environment in which we operate;
   
   • our partners, including suppliers and service providers, distributors, sales representatives, contractors, channel partners, consultants, intermediaries and agents;
   
   • our joint-venture partners or other business associates;
   
   • our financial stakeholders;
   
   • the governments of the countries in which we operate; and
   
   • our Kundan affiliated companies.
   
   
2. This Code sets out our expectations of all those who work with us in any manner whatsoever. We also expect those who deal with us to be aware that this Code underpins everything we do, and in order to work with us, they need to act in a manner consistent with this code.
   
   

C. OUR CORE PRINCIPLES

1. We are committed to operating our businesses conforming to the highest moral and ethical standards. We do not tolerate bribery or corruption in any form. This commitment underpins everything that we do.
   
   
2. We are committed to good corporate citizenship. We treat social development activities which benefit the communities in which we operate as an integral part of our business plan.
   
   
3. We seek to contribute to the economic development of the communities of the countries and regions we operate in, while respecting their culture, norms and heritage. We seek to avoid any project or activity that is detrimental to the wider interests of the communities in which we operate.
   
   
4. We shall not compromise safety in the pursuit of commercial advantage. We shall strive to provide a safe, healthy and clean working environment for our employees and all those who work with us.
   
   
5. While representing Kundan Group or any of its affiliated companies, we shall act with professionalism, honesty and integrity, and conform to the highest moral and ethical standards.
   
   
6. In the countries we operate in, we shall exhibit culturally appropriate behaviour. Our conduct shall be fair and transparent and be perceived as fair and transparent by third parties.
   
   
7. We shall respect the human rights and dignity of all our stakeholders.
   
   
8. We shall strive to balance the interests of our stakeholders, treating each of them fairly and avoiding unfair discrimination of any kind.
   
   
9. The statements that we make to our stakeholders shall be truthful and made in good faith.
   
   
10. We shall not engage in any restrictive or unfair trade practices.
    
    
11. We shall provide avenues for our stakeholders to raise concerns or queries in good faith, or report instances of actual or perceived violations of our Code.
    
    
12. We shall strive to create an environment free from fear of retribution to deal with concerns that are raised or cases reported in good faith. No one shall be punished or made to suffer for raising concerns or making disclosures in good faith or in the public interest.
    
    
13. We expect the leaders of various businesses of Kundan affiliated companies to demonstrate their commitment to the ethical standards set out in this Code through their own behaviour and by establishing appropriate processes within their companies.
    
    
14. We shall comply with the laws of the countries in which we operate and any other laws which apply to us. With regard to those provisions of the Code that are explicitly dealt with under an applicable law or employment terms, the law and those terms shall take precedence. In the event that the standards prescribed under any applicable law are lower than that of the Code, we shall conduct ourselves as per the provisions of the Code.
    
    

D. OUR EMPLOYEES

Equal opportunity employer

1. We provide equal opportunities to all our employees and to all eligible applicants for employment in our Company. We do not unfairly discriminate on any ground, including race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin, disability or any other category protected by applicable law.
   
   
2. When recruiting, developing and promoting our employees, our decisions will be based solely on performance, merit, competence and potential.
   
   
3. We shall have fair, transparent and clear employee policies which promote diversity and equality, in accordance with applicable law and other provisions of this Code. These policies shall provide for clear terms of employment, training, development and performance management.
   
   

Dignity and respect

4. Our leaders shall be responsible for creating a conducive work environment built on tolerance, understanding, mutual cooperation and respect for individual privacy.


5. Everyone in our work environment must be treated with dignity and respect. We do not tolerate any form of harassment, whether sexual, physical, verbal or psychological.


6. We have clear and fair disciplinary procedures, which necessarily include an employee’s right to be heard.


7. We respect our employees’ right to privacy. We have no concern with their conduct outside our work environment, unless such conduct impairs their work performance, creates conflicts of interest or adversely affects our reputation or business interests.

Human rights

8. We do not employ children at our workplaces.


9. We do not use forced labour in any form. We do not confiscate personal documents of our employees or force them to make any payment to us or to anyone else in order to secure employment with us, or to work with us.

Bribery and corruption

10. Our employees and those representing us, including agents and intermediaries, shall not, directly or indirectly, offer or receive any illegal or improper payments or comparable benefits that are intended or perceived to obtain undue favours for the conduct of our business.


11. We also do not hire third parties to do things we are not allowed to do ourselves, like paying bribes. Third parties acting on our behalf must therefore never give or receive bribes. The term ’third parties’ can include consultants, subcontractors, franchisees, sales agents, resellers, customs brokers, accounting or law firms, companies that provide assistance with obtaining visas, permits or inspection certificates and joint venture partners. Regardless of the type of third party, it is critical that all third parties who conduct business or provide services for or on behalf of Kundan Group are selected and engaged in compliance with the required Third Party Due Diligence Procedures.


12. Any attempt to bribe must immediately be reported to Concern Head of Department and / or Plant Head and / or Compliance Officer or Legal Counsel of Kundan affiliated companies.

Gifts and hospitality

13. “Gift” include any item, benefit, gesture (of value or not) to employees and/or their families. An employee is prohibited from accepting a gift from a Third Party, if:

a. Gifts which may give an appearance of a past, present or future conflict of interest

b. it includes cash or transfer of money regardless of value; or

c. Any Gifts received need to be handed over to the authorised personnel of the company



In case the gifts received can be distributed then it should be distributed among office colleagues. It is advisable that a month before festivities begin, Administration are expected to send a note via email to all their vendors, external partners on “No Gift Policy” to refrain any gifting from their side.

Social Media

14. No employee shall, except with the previous sanction of the Company, make use of any social media platform such as Facebook, WhatsApp, twitter, any other messaging platform etc., for disclosing any confidential/proprietary data or information relating to the internal workings of Kundan Group or Kundan affiliated companies.
    No employee (including an ex-employee) shall do or cause to be done anything that is derogatory or defamatory to Kundan Group or Kundan affiliated companies. or any of the employees or business partners of Kundan Group or Kundan affiliated companies. by means of social media.

Working outside employment with us

15. Taking employment, accepting a position of responsibility or running a business outside employment with our Company, in Employee’s own time, with or without remuneration, could interfere with your ability to work effectively at our Company or create conflicts of interest. Any such activity must not be with any customer, supplier, distributor or competitor of our Company. Our employees must notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of this Code and in accordance with applicable Company policies and law.

Integrity of information and assets

16. Our employees shall not make any wilful omissions or material misrepresentation that would compromise the integrity of our records, internal or external communications and reports, including the financial statements.


17. Our employees shall seek proper authorisation prior to disclosing Company or business-related information, and such disclosures shall be made in accordance with our Company’s media and communication policy. This includes disclosures through any forum or media, including through social media.


18. Our employees shall ensure the integrity of personal data or information provided by them to our Company. We shall safeguard the privacy of all such data or information given to us in accordance with applicable Company policies or law.


19. Our employees shall respect and protect all confidential information and intellectual property of our Company.


20. Our employees shall safeguard the confidentiality of all third party intellectual property and data. Our employees shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable Company policies or law.


21. Our employees shall promptly report the loss, theft or destruction of any confidential information or intellectual property and data of our Company or that of any third party.


22. Our employees shall use all Company assets, tangible and intangible, including computer and communication equipment, for the purpose for which they are provided and in order to conduct our business. Such assets shall not be misused. We shall establish processes to minimise the risk of fraud, and misappropriation or misuse of our assets.


23. We shall comply with all applicable anti-money laundering, anti-fraud and anti-corruption laws and we shall establish processes to check for and prevent any breaches of such laws. Insider trading


24. Our employees must not indulge in any form of insider trading nor assist others, including immediate family, friends or business associates, to derive any benefit from access to and possession of price sensitive information that is not in the public domain. Such information would include information about our Company, our __ companies, our clients and our suppliers.



Prohibited drugs and substances

25. Use of prohibited drugs and substances creates genuine safety and other risks at our workplaces. We do not tolerate prohibited drugs and substances from being possessed, consumed or distributed at our workplaces, or in the course of Company duties.



Conflicts of interest

26. Our employees shall always act in the interest of our Company and ensure that any business or personal association including close personal relationships which they may have, does not create a conflict of interest with their roles and duties in our Company or the operations of our Company. Further, our employees shall not engage in any business, relationship or activity, which might conflict with the interest of our Company or our Kundan Group or Kundan affiliated companies.


27. Should any actual or potential conflicts of interest arise, the concerned person must immediately report such conflicts and seek approvals as required by applicable law and Company policy. The competent authority shall revert to the employee within a reasonable time as defined in our Company’s policy, so as to enable the concerned employee to take necessary action as advised to resolve or avoid the conflict in an expeditious manner.


28. Notwithstanding such or any other instance of conflict of interest that exists due to historical reasons, adequate and full disclosure by interested employees shall be made to our Company’s management. At the time of appointment in our Company, our employees shall make full disclosure to the competent authority, of any interest leading to an actual or potential conflict that such persons or their immediate family (including parents, siblings, spouse, partner, children) or persons with whom they enjoy close personal relationships, may have in a family business or a Company or firm that is a competitor, supplier, customer or distributor of, or has other business dealings with, our Company.


29. If there is a failure to make the required disclosure and Company becomes aware of an instance of conflict of interest that ought to have been disclosed by an employee, Company shall take a serious view of the matter and consider suitable disciplinary action as per the terms of employment. In all such matters, we shall follow clear and fair disciplinary procedures, respecting the employee’s right to be heard.

E. OUR CUSTOMERS

Products and services

1. We are committed to supplying products and services of world-class quality that meet all applicable standards.
   
   
2. The products and services we offer shall comply with applicable laws, including any law of the country or in countries we operate.
   
   
3. We shall market our products and services on their own merits and not make unfair or misleading statements about the products and services of our competitors.
   
   

Export controls and trade sanctions

4. We shall comply with all relevant export controls or trade sanctions in the course of our business.

Fair Competition

5. We support the development and operation of competitive open markets and the liberalisation of trade and investment in each country and market in which we operate.



6. We shall not enter into any activity constituting anti-competitive behaviour such as abuse of market dominance, collusion, participation in cartels or inappropriate exchange of information with competitors.



7. We collect competitive information only in the normal course of business and obtain the same through legally permitted sources and means.

Dealings with customers

8. Our dealings with our customers shall be professional, fair and transparent.



9. We respect our customers’ right to privacy in relation to their personal data. We shall safeguard our customers’ personal data, in accordance with applicable law.

F. OUR COMMUNITIES AND THE ENVIRONMENT

Communities

1. We are committed to good corporate citizenship and shall actively assist in the improvement of the quality of life of the people in the communities in which we operate.
   
   
2. We engage with the community and other stakeholders to minimise any adverse impact that our business operations may have on the local community and the environment.
   
   
3. We encourage our workforce to volunteer on projects that benefit the communities in which we operate, provided the principles of this Code, where applicable, and in particular the ‘Conflicts of Interest’ clause are followed.
   
   

The environment

4. The production and sale of our products and services, we strive for environmental sustainability and comply with all applicable laws and regulations.


5. We seek to prevent the wasteful use of natural resources and are committed to improving the environment, particularly with regard to the emission of greenhouse gases, consumption of water and energy, and the management of waste and hazardous materials. We shall endeavour to offset the effect of climate change in our activities.

G. OUR PARTNERS

1. We shall select our suppliers, vendors, service providers etc. (Referred as “Partners”) fairly and transparently.
   
   
2. We seek to work with Partners who can demonstrate that they share similar values. We expect them to adopt ethical standards comparable to our own.
   
   
3. Our Partners shall represent our Company only with duly authorised written permission from our Company. Our Partners are expected to abide by this Code in their interactions with, and on behalf of us, including respecting the confidentiality of information shared with them.
   
   
4. Our Partners shall ensure that any gifts or hospitality received from, or given to, our Partners comply with our Company’s gifts and hospitality policy.


5. Our Partners are expected not to practice or tolerate any form of corruption, extortion or embezzlement. They will not offer or accept bribes or other unlawful incentives in their business. They are expected not to offer to Kundan Group or Kundan affiliated companies. employees/representative’s gifts or any other kind of personal benefit resulting from their relationships.


6. They shall not, directly or through intermediaries, take any recourse to any unethical behaviour (implicit or explicit), or offer or promise any personal or improper advantage in order to obtain or retain a business or other advantage from a third party, whether public or private, including with any employee of Kundan Group or Kundan affiliated companies.


7. They shall not enter a financial or any other relationship with any employee/representatives of Kundan Group or Kundan affiliated companies. (directly or indirectly) that creates any actual or potential conflict of interest for Company.


8. Our partners shall behave in a professional manner and in line with the Company Code of Conduct.

H. GOVERNMENTS

Political non-alignment

1. We shall act in accordance with the constitution and governance systems of the countries in which we operate. We do not seek to influence the outcome of public elections, nor to undermine or alter any system of government. We do not support any specific political party or candidate for political office. Our conduct must preclude any activity that could be interpreted as mutual dependence/favour with any political body or person, and we do not offer or give any Company funds or property or other resources as donations to any specific political party, candidate or campaign.
   
   Any financial contributions considered by our Board of Directors in order to strengthen democratic forces through a clean electoral process shall be extended only through the Progressive Electoral Trust in India, or by a similar transparent, duly-authorised, non- discriminatory and non-discretionary vehicle outside India.
   
   

K. RAISING CONCERNS

1. We encourage our employees, customers, suppliers and other stakeholders to raise concerns or make disclosures when they become aware of any actual or potential violation of our Code, policies or law. We also encourage reporting of any event (actual or potential) of misconduct that is not reflective of our values and principles.
   
   Avenues available for raising concerns or queries or reporting cases could include:
   
   • the Human Resources department of our Company
   
   • any other reporting channel set out in our Company’s ‘Whistleblower’ policy.
   
   We do not tolerate any form of retaliation against anyone reporting legitimate concerns. Anyone involved in targeting such a person will be subject to disciplinary action.
   
   If you suspect that you or someone you know has been subjected to retaliation for raising a concern or for reporting a case, we encourage you to promptly contact the Human Resources department or write to us at Kundan Group or Kundan affiliated companies.
   
   

L. ACCOUNTABILITY

1. This Code is more than a set of prescriptive guidelines issued solely for the purpose of formal compliance. It represents our collective commitment to our value system and to our core principles.
   
   Every person employed by us, directly or indirectly, should expect to be held accountable for his/her behaviour and must adhere to this Code. Should such behaviour violate this Code, they may be subject to action according to their employment terms and relevant Company policies. Violations of our Code, our policies, directives or the law can have serious consequences, including disciplinary action up to and including termination of employment, as well as possible civil or criminal penalties both for the Company and for individuals.
   
   When followed in letter and in spirit, this Code is ‘lived’ by our employees as well as those who work with us. It represents our shared responsibility to all our stakeholders, and our mutual commitment to each other.