FIFSOS is committed to conducting its business based on the highest standards of corporate governance. The Company promotes a culture that is based on the principles of good corporate governance-integrity, equity, fairness, individual accountability and commitment to values.
The Company emphasizes the need for highest level of transparency and accountability in all its transactions in order to individual accountability and commitment to values. protect the interests of all its stakeholders The Board considers itself as a Trustee of its shareholders and acknowledgesits responsibilities towards them for creation and safeguarding their wealth on sustainable basis.
The Senior Management promotes honest and ethical conduct of the business along with complying with the applicableLaws, rules and regulations. They abide by the policies and procedures-Both Legal as well as Social – so as to ensure its commitment to compliance and create and maintain a culture of high ethical standards and maintain a work environment that encourages not only the staff but the stakeholders too to raise their faith in the management of the Company.
The Board of the Company hereby presents the Code of Conduct with an intention to help foster abidance to its above-illustrated philosophy on Code of Conduct provide guidance and mechanisms to help foster abidance to its above-illustrated philosophy on Code of Conduct.
The Way We Do Business
This Code of conduct commits FIFSOS to a set of simple and shared principles. This Code provides guidelines for each Staff Member and Business Associate, whatever their cultural or geographical background. It is not intended to replace local laws and regulations but on the contrary, seeks to encourage their respect. Staff Members and Business Associates use good judgment and common sense in all situations when the requirements of the law or of good business practices appear unclear. Staff Members and Business Associates seek advice and direction from the seniors/ company management in such situations.
III. Applicability
The Code of Conduct shall be applicable to the following category of persons.
The Staff Members and the Business Associates shall act in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct not only on Company’s premises and offsite but also at company sponsored business, social events as well as any places. They shall act and conduct free from fraud and deception. Their conduct shall conform to the best-accepted professional standards of conduct.
The Staff Members and the Business Associates of the Company should avoid any conflict of interest with the Company The Staff Members and the Business Associates of the Company should fully disclose to the Company all financial and commercial transactions that may have a potential conflict with the interest of the Company at large.
3.Transparency in the shadow of Confidentiality
The Staff Members and the Business Associates shall ensure maintainability of transparency in their conduct except insuch circumstances where the needs of business security dictate otherwise. An optimum blend of transparency and confidentiality shall be adopted to give the brightest colors of dignity and pride to the business of the Company.
The Staff Members and Business Associates shall maintain the confidentiality of information coming to them in course of employment or by virtue of being the member of the Board of the Company except in the ordinary course of discharge of their duties. The use of confidential information for his/her own advantage or profits strictly prohibited. No confidential information shall be disclosed even after he/she ceases to hold such office.
Staff Members and the Business Associates of the Company shall not disclose any information either formally or informally, to media or press unless specifically authorised by the Company.
The Staff Members and the Business Associates of the Company must comply with the requirements of all laws, rules and regulations etc. applicable to their respective areas of operations. They are also required to submit various Certificates/Compliance Reports, quarterly/annually, in accordance with various provisions of Listing Agreement with the Stock Exchanges The Code is in addition to and not in derogation with any Act, law, rules and regulations, and all other applicable policies and procedures adopted by the Company that governs the conduct obits Officers.
FIFSOS is committed to respecting human rights in its relationships with Staff Members/ Business Associates. clients, shareholders, suppliers and local communities. FIFSOS’s business is people-driven and our corporate values underpin our relationships with our stakeholders Each employee/ Business Associate is entitled to fair, courteous and respectful treatment by his or her supervisors, subordinates and peers. FIFSOS will not tolerate discrimination or harassment based on sex, colour, marital status, civil partnership, having or not having dependants, nationality, ethnic or national origin, religious belief, political opinion, sexual orientation, disability, age or any other relevant category FIFSOS welcomes and values diversity. Our goal is always to select, retain and develop all Staff Members/ Business Associates, irrespective of the categories mentioned above.
The Staff Members/Business Associates of the Company and treat other Business Associates of the Company and all other persons while discharging his/her duties, with dignity and respect and in the manner so as to maintain a work environment free of any kind of harassment.
Any type of abusive language, harsh language, racial comments, and misbehaviour is not acceptable in any circumstance.
Following activities are not acceptable in the office premise and by the Business Associates and Staff members
-Funding the client/other business associate in any manner.
-Providing wrong or misleading information to the client, other Business Associates and Staff Members
-Running any other activity/business with the Business Associates and Staff Members which has ot been approved by the Company.
The Staff Members and the Business Associates of the Company shall not act in a manner which will tarnish the image/reputation/trade-name/Goodwill of the Company by his/her conduct.
Fraud
FIFSOS is committed to ensuring that any form of fraud is avoided in the company business conduct. Fraud may be defined as “any intentional act or omission designed to deceive others and resulting in the victim suffering a loss and/or the perpetrator achieving a gain.” Fraud can be categorised into three main categories: fraudulent financial reporting, misappropriation of assets, and corruption.
Corruption
While definition may slightly vary depending on local regulations corruption is usually considered as committed where a person offers, promises or gives a financial or other advantage to another person (private or public agent) with the intention of influencing this person in the performance of his or her official functions. The person offering, promising or giving the advantage must also intend to obtain or retain business or an advantage in the conduct of business by doing so”.Comuption notably includes bribery, illegal gratuities and extortion.
Conflicts of interest
While there is no common definition for conflicts of interest, usually “consists of any situation in which a Staff Membe/ Business Associate has or appears to have a direct or indirect interest that may influence the manner in which he or she performs his/her job or carries out his/her responsibilities within a corporation”. Should such a situation occur, communication between employer and Staff Member/Business Associate is of utmost importance, and the parties concerned will to in good faith.
Protecting information
In addition, FIFSOS Staff Members/Business Associates who receive or learn of confidential business information or trade secrets of FIFSOS or others do not, for non-business purposes, disclose that information to third parties or make any other non-business use of such information. Moreover, they take reasonable measures to otherwise safeguard and protect information and trade secrets. In the same way as stated in our Insider Code,FIFSOS Staff Members/ Business Associates who have access to information that is not public and that could affect the FIFSOS share price if made public, do not trade in FIFSOS shares, either directly or through another person, until such time as this information has been made public.
Discussions with our competitors
Discussing with our competitors, while often considered as a way to share best practices, may under certain circumstances expose the company and our Staff Members/ Business Associates to significant compliance risks. We remind that contact with competitors must comply with regulations relating to the principles of competition and exchangeof business information.
Each of us at FIFSOS is responsible for knowing and understanding not only the company policies and guidelines, but also the company values on which they are based. However that is merely the first step. Putting the Code and Values to work implies knowing how to make the “right” decisions whenever we encounter ethical questions and dilemmas. To that end, here is some advice:
A model for ethical decision making
Making the right ethical decision in difficult situations may seem somewhat overwhelming. What is the best way to approach the decision-making process?
To help you, we recommend using Josephson’s Institute model for ethical decision making. Once you become familiar with the framework, it becomes apparent that you have many resources available. You will also realise that you makethese kinds of decisions every day.
As a guide in deciding on a course of action, follow these steps
Clarify
Determine precisely what must be decided.
Formulate and devise the full range of alternatives.
Eliminate patently impractical, illegal and improper alternatives.
Force yourself to develop at least three ethically justifiable options.
Examine each option to determine which ethical principles and values are involved.
Evaluate
If any of the options requires the sacrifice of any ethical principle, evaluate the facts and assumptions carefully Distinguish solid facts from beliefs, desires, theories, suppositions, unsupported conclusions, opinions, andrationalisations.
Consider the credibility of sources, especially when they are self-interested, ideological or biased With regard to each alternative, carefully consider the benefits, burdens and risks to each stakeholder.
Decide
Make a judgement about what is not true and what consequences are most likely to occur.
Evaluate the viable alternatives according to personal conscience.
Prioritise the alternatives so that you can choose which alternatives to advance and which to subordinate.
Determine who will be helped the most and harmed the least.
Consider the worst case scenario.
Consider whether ethically questionable conduct can be avoided by changing goals or methods, or bygetting consent.
Apply three “ethics questions”.
The Human Resources are the most valuable assets to the Company. The Staff Members and the SeniorManagement Personnel must ensure that the true human values are depicted not only in all the dealings and transactions but also in the selection and recruitment procedure and in providing appraisals, remuneration and rewards. The focus of the management shall remain on meritocracy, equity and upholding of Company values.
Any director, officer, employee or business associate of the Company who knows of or suspects of any violation ofapplicable laws, rules or regulations or this Code, he/she must immediately report the same to the Board of Directors or the Company Secretary/Compliance Officer of the Company. The Company recognizes that resolving such problems or concerns will advance the overall interests of the Company that will help to safeguard the Company’s assets, financial integrity and reputation Violations of this Code will result in suitable disciplinary action against the individual concerned It is obligatory on the part of Staff Members and the Business Associates to make a disclosure under the Code affirming their adherence to the Code as per the format given in ‘Annexure A’ of the Code. This disclosure shall be made to the Company Secretary/ Compliance Officer before joining the company business and within 7 days in case the code of conduct is amended. This code of conduct will be available with each Business Associate in his personal ID as well as in FIFSOS website. Company shall contain a duly signed declaration to this effect by the CEO/ManagingDirector of the Company.
FIFSOS has certain terms and conditions for its Staff Members / Business Associates. There are rules and regulations which are applicable to all the members of FIFSOS including the Staff Members/ Business Associates and company management. These rules can be revised/ amended from time to time considering the benefit of the organisation as well as its associates. The details will be displayed on the company notice board for the information of the company associates and staff. These are applicable to each and every individual associated with the company. In case of any confusion and dispute the decision of company director or principal advisor will be final.
VII. Amendment Or Modification To The Code
The Provisions of this code can be amended/modified by the Board of Directors or the Committee of Directors of the Company from time to time and all such amendments/modifications shall take effect from the date stated therein.