This policy has been created to provide a framework and guidance on the company’s approach to achieving and maintaining good business behaviour by means of sound ethical conduct.  This policy serves to ensure that all employees are aware of their individual and collective responsibilities with regard to company ethics and to strongly emphasise our employees, suppliers and customers expectations to being treated fairly and in accordance with good business practices.  

 

All employees are responsible for reading this document in its entirety and for ensuring that they comply with all the policy requirements as stated within this document 

 

1.0 Compliance 

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1. L&W GROUP has adopted this Ethics Policy, and we trust that all employees will use their best judgment to ensure they comply with  its principles. 

2. L&W GROUP cannot police all aspects of employee conduct. However, to ensure the Ethics Policy is upheld we have implemented a compliance program that includes the following:  

   • The Executive Management Team is responsible for overseeing compliance with this Ethics Policy.

   • The Executive Management Team will receive and investigate complaints and reports of non-compliance and may delegate such  investigations to a sub-committee of the Executive Management Team for report back to the full Executive Management Team. 

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2. Key Policies and Principles 

2.1 Honesty and Integrity 

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Consider L&W GROUP’s reputation and credibility in all your business relationships. Be honest and honourable in all dealings with other employees, the public, the business community, customers, suppliers, competitors, and government authorities. 

 

2.2 Entertainment and Gifts 

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1. Never accept a gift, entertainment, or any other benefit from an individual or organization doing business with L&W GROUP. That gift, entertainment or benefit could influence your decisions or, if it were made public, might appear to have influenced your business decision. 

2. Any gift, entertainment, or benefit you provide to a business associate must be modest in scope and value. Never provide a gift, entertainment or benefit that contravenes any applicable law or contract term or that is large enough to influence, or appear to influence, the recipient’s business decisions. Ensure that you record (in L&W GROUP’s accounts) all expenditures on gifts, entertainment, and other benefits. 

 

2.3 Consultant Fees, Commissions and Other Payments  

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Never give or receive any payment that falls outside the normal conduct of business. Ensure that all consulting or agency fees, commissions, retainers or other payments are reasonable in the context of acceptable commercial practice and that they comply with applicable corporate policies. Properly record all payments given or received in the Company’s accounts.  

 

If you engage in giving or accepting kickbacks, bribes, payoffs or other illegal or similar transactions you will be subject to immediate discipline, up to and including dismissal in accordance with L&W GROUP’s policy on employee discipline. 

 

2.4 Conflict of Interest and Other Misconduct 

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1. L&W GROUP expects all employees to act only in the best interests of the Company. Employees should avoid situations or activities where personal interests are, or may appear to be, in competition with or in opposition to L&W GROUP’s interests.  

2. This includes situations that might prevent you from devoting proper time or attention to your duties, or situations that might affect your judgment or ability to act in L&W GROUP’s best interest. Should you be faced with a situation or a transaction that might give rise to such a conflict of interest, you must disclose this information to a member of the Executive Management Team. 

3. It is not possible to give a comprehensive list all potential conflict of interest situations. However, the following are examples of such conflicts: 

   Competing Business Interests:   

1. If you or someone close to you owns or participates in a business that competes with, is served by or provides services to L&W GROUP, it may conflict or interfere with your ability to work for L&W GROUP.  

2. If you are going to participate in any business venture that may compete with L&W GROUP, whether directly or indirectly, you must obtain prior written approval from the Executive Management Team. 

3. You may not engage, on L&W GROUP’s behalf, in any transaction with a business in which you or a family member has an interest unless you have prior written approval from the Executive Management Team. 

4. If you want to serve on the Board of Directors or similar body of any company, you must obtain prior written approval from the Managing Director. 

 

2.5 Activities for Personal Gain 

 

1. Never abuse your position at L&W GROUP by seeking personal gain, e.g. by obtaining personal benefits from those doing or seeking to do business with L&W GROUP. 

2. As an employee, you are entrusted with Company property and resources including vehicles, computer equipment and software, corporate information and tools. Use these resources for Company business, not for personal gain. 

3. Never accept a loan from an individual or organization that does business with L&W GROUP, unless the individual or organization is in the business of making loans 

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2.6 International Business 

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In the course of your employment with L&W GROUP, you may be faced with legal and ethical issues that arise as a result of the Company’s international business activities. In addition to applicable local laws, L&W GROUP must comply with laws relating to international business transactions. 

  

2.7 Corporate Information and Confidentiality 

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1. Every Company employee has access to some type of confidential information. The following are considered confidential: technical information about L&W GROUP tools or equipment; financial data; information about how certain processes work; price lists; methods of conducting operations; business plans and intentions; legal matters; applications for patents and trademarks; and software developments. Commercial and technical information received on a confidential basis from third parties such as suppliers, customers, and partners are also confidential information. 

2. All L&W GROUP employees sign an undertaking of confidentiality to the Company when starting their employment with L&W GROUP. In addition, the Company has a comprehensive policy which details how Company personnel should treat confidential information. 

3. Except as required in the normal course of performing your job, do not reveal confidential information to anyone, either while employed by L&W GROUP or after you leave the Company, unless you have written authorization from the President of L&W GROUP. 

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2.8 Corporate Communications 

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1. All public communications made by or on behalf of L&W GROUP shall be full, fair, accurate, timely and understandable. 

2. The Company’s Executive Management have designated individuals to speak to the public on behalf of the Company pursuant to Company’s Disclosure Policy. Do not speak publicly on behalf of the Company unless you are specifically authorized to do so. 

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2.9 Employment Practices 

 

1. L&W GROUP strives to provide a positive work environment that supports productivity, dignity and self-esteem, and the pursuit of personal goals. 

2. Our employment policies and procedures provide for equal opportunity and fairness in employment decisions. We do not discriminate on the basis of race, colour, ancestry, place of origin, religious belief, physical or mental disability, age, gender, sexual orientation, marital status, family status or source of income, and we take steps to comply with all applicable affirmative action legislation. We also endeavour to ensure that all employees are treated fairly in all aspects of the employment relationship, including performance appraisals, compensation, opportunities for advancement, and disciplinary matters. 

3. Finally, we do our best to ensure that employees are treated with dignity and respect by the Company and by fellow employees. L&W GROUP makes every effort to protect employees from harassment and takes action to address any concerns that arise in this regard. L&W GROUP deals with harassment or other improper conduct with in accordance with the Company’s policies on harassment and on employee discipline. 

4. If you have employment-related questions or issues, you may speak with your immediate supervisor or with a member of the Human Resources team. If you are more comfortable doing so you may also speak with any member of the Legal Department or of the Harassment Committee established under the Harassment and Sexual Harassment Policy. 

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2.10 Health and Safety 

 

1. L&W GROUP’s foremost concern is protection of the health and safety of all employees. 

2. We have adopted policies and procedures that are aimed at ensuring that L&W GROUP meets or exceeds all applicable health and safety laws and regulations as well as prevailing industry standards. We strive to fully implement all safety policies and procedures. 

3. Complete compliance with safety policies and procedures requires the cooperation and commitment of every employee. Be aware of how the company’s health and safety policies apply to you and conduct your duties and responsibilities in compliance with these policies. 

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2.11 Environment 

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1. L&W GROUP is committed to minimizing the effects of our operations on the natural environment. We endeavour to meet all regulatory and industry standards by implementing appropriate measures for the assessment of potential environmental effects, for the prevention of these potential effects and for appropriate response to any incidents that might occur. 

2. As an L&W GROUP employee you are expected to be familiar with the required environmental standards that apply to your work at L&W GROUP, and to comply with these standards always. 

 

2.12 Whistle-Blower Policy 

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1. By way of a “Whistleblower Hotline” L&W GROUP provides procedures for the confidential and anonymous reporting of issues regarding any questionable or fraudulent activities including accounting and auditing actions by employees of the company. The Hotline allows employees to report concerns regarding any alleged fraudulent activities including the Company’s internal accounting controls or auditing matters directly to the Audit Committee of the Company’s Board of Directors. Employees are assured that their calls will remain anonymous and that the system cannot be manipulated in order to determine the identity of the whistleblower. 

2. The Whistle-blower Hotline completely protects the identity of any individual submitting concerns and provides access through all of the primary communication methods: telephone/voicemail, email and web interface. The selection of message types ensures that whistleblowers have access to the messaging platform that is most comfortable and convenient for them. 

Email ID : Integrity@landwindia.com 

 

2.13 Employee Communication 

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1. The Company will provide employees with an opportunity to become familiar with the Ethics Policy and related policies and procedures. We will communicate the contents of the Ethics Policy and provide ongoing opportunity for employees to ask questions and seek additional information. 

2. If you wish to obtain additional materials, or discuss any aspect of the Ethics Policy, speak with any member of the HR Department or of Executive Management 

  

2.14 Reporting 

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1. To implement the Ethics Policy, L&W GROUP needs the full cooperation of all employees. We expect employees to comply with all aspects of this Ethics Policy, and encourage employees to report any violations they observe to any member of the Executive Management Team or a senior member of the Human Resources department. 

2. It is a violation of this Policy to intimidate or retaliate against any person who has reported a violation of this Ethics Policy. 

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2.15 Violations 

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1. The Executive Management Team will investigate all reports or other information received regarding alleged violations of this Ethics Policy, and will report to the Board of Directors on the results of investigations of material violations. 

2. Any person who is found to have violated this Ethics Policy, or any related corporate policy, will be subject to discipline in accordance with L&W GROUP’s policy on employee discipline, which policy provides for appropriate disciplinary measures for employee misconduct, up to and including dismissal. 

 

2.16 Waivers of Compliance 

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Only the Board of Directors has the authority to grant a waiver of compliance with this Policy for directors or executive officers. Such waivers shall be granted only where the Board determines that a waiver is necessary and warranted and is in the best interest of the Corporation. All waivers shall be limited so as to protect the Corporation to the greatest extent possible, and shall be disclosed as required by applicable law. 

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Please fill the below form for acknowledgement