1. INTRODUCTION
1.1 The Code applies to all employees, officers, and directors of Mwiven infra tech private limited (MWIVEN). It also applies in certain respects to business partners, such as suppliers, consultants, representatives, and agents. We are all expected to conduct ourselves according to the Code. When conduct is found to violate the Code, we hold ourselves accountable and disciplinary action is likely to occur—up to and including after employment termination.
1.2 This Code of Conduct is intended as a guide on the standards that are expected. It is not intended to be exhaustive, but rather to give an indication of the areas that may fall within the scope of the Code of Conduct.
2. STANDARDS
2.1 Everyone associated with the MWIVEN are expected to give the highest possible standard of service and where it is part of your duties, to provide appropriate advice with impartiality.
2.2 There can be NO impropriety or breach of procedure
2.3 Everyone associated with MWIVEN are expected, through agreed procedures and without fear of recrimination, to bring to the attention of the appropriate level of management any deficiency in the provision of service. A Confidential Reporting Policy is available for use in appropriate circumstances.
2.4 The MWIVEN has standing orders and financial regulations, which describe important rules and standards. all employees are required to work in accordance with them.
2.5 The Code is intended to help to maintain and improve standards and protect everyone associated with MWIVEN from misunderstanding or criticism. However, a failure to comply with the code would be investigated and will lead to disciplinary action.
3. PERSONAL INTERESTS
3.1 Proactively identify situations that could put the company’s interests and our own into possible conflict;
3.2 Disclose actual or potential conflicts consistent with company policy and applicable laws and regulations;
3.3 Remove ourselves from the decision-making process when a conflict may exist;
3.4 Don’t allow the desire to help friends and family to influence our decisions at work;
3.5 Are not influenced by the prospect of financial gain for ourselves or our family members;
3.6 Win business and build relationships based on trust and mutual value—never through inappropriate gifts or hospitality;
3.7 Show loyalty to MWIVEN by not keeping for ourselves opportunities gained through the use of company position or resources;
3.8 Give our best effort at work every day, not allowing outside jobs or other activities to hinder our contributions to our business.
3.9 There cannot be any financial interests / Non-financial interests that could conflict with the MWIVEN’s interests.
4. CORRUPTION
4.1 Win on the merits of our products, services, and business terms;
4.2 Never offer or accept bribes, kickbacks, or anything of value that could improperly influence—or appear to influence—a business decision;
4.3 Take special care not to promise or provide anything of value to public officials or anyone else to gain a business advantage;
4.4 Apply company policies and our values when it comes to giving and receiving business gifts and entertainment and seek guidance from corporate security department if unsure about the correct course of action;
4.5 Record all transactions completely, accurately, and truthfully;
4.6 Follow the letter and spirit of anti-corruption laws everywhere we do business;
4.7 Choose business partners carefully and hold them to our high ethical standards;
4.8 Never use a third party to do anything improper on our behalf, including making improper payments, because we cannot do it ourselves.
4.9 Immediately report any corruption or bribery concerns to Board of Directors.
4.10 It is a serious criminal offence and will jeopardize national security
(a) the receiving or giving of any gift, loan, fee, reward or advantage, or
(b) by either taking inappropriate action or failing to take action when there is a clear need to do so, or
(c) by showing favour, or disfavour, to any person or organisation.
4.11 Should not take advantage of your position with MWIVEN. This could mean:
(a) By acquiring goods or services at a preferential rate which would not normally be available to other employees.
(b) By acquiring goods or services at a reduced rate because a contractor or those bidding for contracts in your area of work, or another person or body seeking influence with MWIVEN treats you, your relatives or friends more favourably than others.
(c) By accepting gifts or hospitality from a contractor or those bidding for contracts with MWIVEN or any other person or body seeking influence with MWIVEN.
5. PREVENTING INSIDER TRADING
5.1 Never use inside information to trade shares or any other publicly traded company—unless and until such information has been made public;
5.2 Do not share inside information with anyone outside the company, including family members, relatives, or friends;
5.3 Share inside information with colleagues only on a need-to-know basis;
5.4 Take care to protect inside information from accidental disclosure (e.g., by securing confidential documents and by not discussing sensitive company information in public places);
5.5 Avoid “tipping”—passing along material, non-public information about any company to anyone who may be tempted to make investments or trades based on the information provided.
6. HOSPITALITY
6.1 You should only accept offers of hospitality where there is a genuine need to impart information or representing MWIVEN. Offers to attend purely social or sporting functions should be accepted where the MWIVEN wishes to be represented. Offers of hospitality should be authorised by the Board and recorded in the relevant Register of Interests.
6.2 When hospitality has to be declined, those making the offer should be courteously but firmly informed of the procedures and standards operating within the MWIVEN. Hospitality that is rejected must be recorded in the relevant Register of Interests.
6.3 When receiving authorised hospitality, you should be particularly sensitive as to its timing in relation to decisions which may be taking affecting those providing the hospitality.
6.4 Acceptance of hospitality through attendance at relevant conferences and courses is acceptable where it is clear the hospitality is corporate rather than personal, offered to MWIVEN rather than the individual employee on a personal basis. In such cases, you should obtain the consent, in advance, from the Board and it should be recorded in the Register of Interests.
6.5 Where visits to inspect equipment etc. are required, you should ensure that the MWIVEN meets the cost of such visits to avoid jeopardizing the integrity of subsequent purchasing decisions.
6.6 Where you have to offer hospitality to visitors to MWIVEN premises, meals should normally be taken in the dining area (or other appropriate venue).
6.7 Only in special circumstances should meals be provided away from MWIVEN premises and the reason for this should be stated on the reclaim voucher. Prior authorisation from the board will be necessary.
7. GIFTS
7.1 As a general rule you should not accept significant personal gifts from clients, contractors and outside suppliers. Gifts, such as wines or spirits, which are given to individuals must not be accepted. However, the MWIVEN allows employees to keep insignificant items of token value such as pens, diaries etc.
7.2 Nobody associated with MWIVEN may not accept personal payments from clients, contractors or outside suppliers.
8. SPONSORSHIP – GIVING AND RECEIVING
8.1 Where an outside organisation wishes to sponsor or is seeking to sponsor a local activity, whether by invitation, tender, negotiation or voluntarily, the basic conventions concerning acceptance of gifts or hospitality apply. Particular care must be taken when dealing with contractors or potential contractors.
8.2 Where MWIVEN wishes to sponsor an event or service and you are involved in some way in consideration of the application, neither you nor your partner, spouse or relative must benefit from such sponsorship without there being full disclosure to the manager for inclusion in the Register of Interests. Similarly, where the MWIVEN through sponsorship, grant aid, financial or other means, gives support in the community, employees should ensure that impartial advice is given and that there is no conflict of interest involved.
8.3 An employee is not normally expected to register that they undertake voluntary work in an organisation that is in receipt of a grant from MWIVEN. However, if in the course of their employment they were involved in the processing of the application or advising officers or members on the application they would need to register the potential conflict of interest.
9. CREATING, MAINTAINING, AND DISCLOSING ACCURATE BOOKS AND RECORDS
9.1 There is a statutory responsibility that requires certain types of information to be made available to auditors, government departments, and the public. The MWIVEN itself decides to be open about other types of information. You must be aware of the information you may be open about, and act accordingly.
9.2 Record all assets, liabilities, revenues, expenses, and business transactions completely, accurately, in the proper period, and in a timely manner;
9.3 Prepare books and records to conform to generally accepted accounting principles, our policies, and our internal controls system;
9.4 Never set up secret or unrecorded cash funds or other assets or liabilities;
9.5 Use appropriate and accurate wording when creating records;
9.6 Correct any errors promptly, notifying those affected;
9.7 Do not conceal or destroy documents or records that are subject to investigation or may be needed in legal proceedings;
9.8 Comply with Legal Hold notices;
9.9 Maintain and eliminate company records in compliance with our records retention and management policies;
9.10 Accurately record any gifts or hospitality given or received, and any sponsorships, consistent with company policies; and
9.11 Speak up when we have questions or concerns about accurate financial reporting, accounting, or financial integrity.
9.12 You should not use any information obtained in the course of your employment for personal gain or benefit, nor should you pass it on to others who might use it in such a way.
9.13 You should be aware that the MWIVEN’s standing orders limit communication with the news media. Only Board of Directors and the Head of Press and Public Relations may give information to the Press about any aspect of the business, unless specific items have been delegated to other Officers.
9.14 Making unauthorised or improper use of confidential information is a serious offence, which the MWIVEN may regard as gross misconduct.
9.15 If you are privy to confidential information on tenders or costs for either internal or external contractors, you should not disclose that information to any unauthorised party or organisation, including any other potential bidder whether internal or external.
10. EQUALITY ISSUES
10.1 All employees contribute to ensuring that policies relating to equalities issues as agreed by the MWIVEN in addition to the requirements of the law are complied with. All members of the local community, customers and other employees have a right to be treated with fairness and equity.
11. INTELLECTUAL PROPERTY AND COMMERCIAL RIGHTS
11.1 Access and use the company’s IP and confidential information only as required to perform our duties;
11.2 Share confidential information only with those who are authorized and have a business need to know it;
11.3 Follow all policies and procedures and take reasonable steps to prevent unauthorized use or disclosure of IP;
11.4 Promptly disclose to the company any inventions we create in the course of our work so they may be evaluated in time for patenting;
11.5 Ensure agreements governing intellectual property protection and license rights are in place before collaborating with third parties;
11.6 Do not discuss confidential matters when there is a risk of being overheard;
11.7 Take care outside the workplace to ensure that documents and electronic devices are secured and not visible to others;
11.8 Never use confidential information for personal gain or to benefit anyone outside the company;
11.9 Remember that the obligation to protect the company’s confidential information continues after leaving the company; and
11.10 Promptly report concerns involving suspected data/IP loss or theft to Corporate Security Department.
11.11 Follow all policies and procedures that protect intellectual property and other confidential business information;
11.12 Report suspected theft or misuse of proprietary data or intellectual property;
11.13 Do not acquire, use, or disclose the proprietary information of our customers, business partners, competitors, or other third parties without authorization;
11.14 Do not bring to the company or use IP or proprietary information gained through prior employment;
11.15 Avoid copying the work of others—including, for example, images, publications, videos, or other content found on the internet—unless we have a license to do so;
11.16 Respect others’ patent rights, trade secrets, and proprietary information;
11.17 Follow applicable intellectual property license agreements and other contractual terms related to the use or disclosure of others’ proprietary information;
11.18 Recognize third-party copyrights, logos, trademarks, trade names, and designs in our marketing and other publications;
11.19 Investigate and report suspected counterfeit products (which raise concerns about product performance and safety as well as IP), trademark misuse, or IP concerns.
12. SAFEGUARDING COMPANY ASSETS
12.1 Use company assets with care and only for business purposes;
12.2 Prevent loss, waste, destruction, theft, and abuse of company resources;
12.3 Limit personal use of company communications equipment and systems and never access inappropriate or restricted content;
12.4 Report circumstances where we suspect company assets are at risk and co-operate with all audits and investigations;
12.5 Ensure that business transactions are authorized by management and subjected to internal review and approval processes;
12.6 Design and follow internal controls that help ensure accurate financial reporting and full compliance with laws and regulations;
12.7 Prevent financial assets from being used for money laundering or terrorist financing by remaining alert to warning signs and following international regulations;
12.8 Think before we click on links or attachments in emails from external sources;
12.9 Never bypass security controls;
12.10 Ensure that our workstations, servers, networked factory equipment, and all other devices connected to our networks are patched as quickly as possible;
12.11 Obtain formal approvals to ensure our monitoring services have the information they need to protect the device;
12.12 Change all default passwords, especially on operational technology such as factory equipment; and
12.13 Report any suspicious activity.
12.14 Follow internal controls and procedure for international travel with company laptops and other electronic assets.
12.15 Requests for payments to be made to personal or offshore accounts rather than usual company accounts;
12.16 Requests for payments to be made at odd times or in unusual amounts; and
12.17 Requests for numerous payments that are all below Rs. 10,000
13. WORKING WITH OUR BUSINESS PARTNERS
13.1 Seek to do business with partners who best meet our needs and share our values;
13.2 Evaluate partners on clear performance measures, such as quality, price, service, reliability, and availability;
13.3 Conduct risk-based due diligence to ensure potential partners are qualified and reputable before onboarding;
13.4 Monitor business partner performance on an ongoing basis;
13.5 Expect our partners to uphold our values and comply with anti-bribery conventions and all other applicable laws;
13.6 Treat all current and potential partners fairly and with integrity, regardless of the transaction value or length of the relationship;
13.7 Avoid any conflicts of interest (or the appearance of them) by avoiding the selection of a partner based on friendships, family relationships, or financial interest;
13.8 Do not accept inappropriate gifts, entertainment, or any kind of favouritism, which might compromise selection of the best partners for MWIVEN;
13.9 Formalize relationships in writing to provide transparency and accountability; and
13.10 Seek opportunities for small, disadvantaged, minority-owned, woman-owned, veteran-owned, and historically under-used businesses.
14. APPOINTMENTS AND OTHER EMPLOYMENT MATTERS
14.1 Employees / officers involved in appointments should ensure that these are made on the basis of merit and in accordance with the Recruitment and Selection Procedures. It would be unlawful for an appointment to be made on the basis of anything other than the ability of the candidate to undertake the duties of the post.
14.2 In order to avoid any possible accusation of bias, you should not be involved in an appointment where you are related to an applicant, or you have a personal relationship outside work with him or her.
14.3 Similarly, you should not be involved in decisions relating to discipline, promotion or pay adjustments for any employee who is a relative, partner or a personal friend.
15. ENGAGING IN THE POLITICAL PROCESS
15.1 Avoid contacting government officials on any legislative, regulatory, policy, or electoral matter without express authorization;
15.2 Comply with all legal limitations on corporate contributions to parties, political committees, and individual candidates;
15.3 Obtain advance approval from the Board of Directors to make political contributions on the company’s behalf or use corporate funds (where permitted by law);
15.4 Cannot run for any elected office, to avoid potential conflicts of interest;
15.5 Understand and follow the rules on political lobbying, including public disclosure and reporting requirements;
15.6 Never apply improper influence on a government agency, representative, or legislator to produce an outcome favorable to the company;
15.7 Make it clear when engaging in politics as private citizens that our views and actions are our own, not those of MWIVEN.
15.8 Use our personal information and assets (not MWIVEN’s resources), including laptops and mobile phones, when engaging in political activities.
16. USING SOCIAL MEDIA RESPONSIBLY
16.1 Exercise good judgment and personal responsibility in our online activities;
16.2 Are open and honest about our identities as employees of MWIVEN, and make it clear when we are expressing personal opinions, not the company’s views;
16.3 Never post classified, export-controlled, or other confidential or proprietary information online;
16.4 Permit only authorized employees to post approved information on behalf of the company;
16.5 Do not disclose non-public information about our company, customers, or business partners without appropriate authority and approval;
16.6 Never post content that is false, malicious, obscene, or otherwise offensive or illegal;
16.7 Ensure that time and effort spent on social media does not interfere with job responsibilities and is conducted on personal time.
17. OUTSIDE COMMITMENTS
17.1 You should be clear about your contractual obligations and should not take outside employment that conflicts with the MWIVEN ’s interests.
17.2 The MWIVEN is entitled to ownership of intellectual property or the copyright of material created by you in the course of your duties as an employee / officer of MWIVEN.