Code of Conduct
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Applicability
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The code of conduct is applicable to all the directors, management and employees
of the Company
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Preamble
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MAX’s Code of Conduct was adopted by its Board of Directors on 15TH May 2011 and
was circulated to the employees then. The same is posted on the Company’s website.
This Code is derived on the fundamental principles of good corporate governance
and exemplary personal conduct.
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Philosophy
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MAX is a professionally managed organisation and the core value underlying our corporate
philosophy is "trusteeship". We believe this organisation has been handed to us
by the various stakeholders in "trust" and we as professionals are the "trustees"
of these stakeholders. It is therefore our responsibility to ensure that the organisation
is managed in a manner that protects and furthers the interests of our stakeholders.
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Corporate Governance Policy
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It has been a constant endeavour on the part of the Company to achieve excellence
in Corporate Governance by following the principles of transparency, accountability
and integrity in functioning so as to constantly enhance value for all stakeholders
and fulfill the social obligations entrusted upon the corporate sector.
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Good Corporate Citizenship
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In the conduct of the Company’s business, the practice of good corporate citizenship
is a prerequisite and embraces the following:
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Dealing with People in the Organisation
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In dealing with each other, directors, management and employees shall uphold the
values which are at the core of our HR Philosophy - trust, teamwork, mutuality and
collaboration, meritocracy, objectivity, self respect and human dignity. In selection
and recruitment, while meritocracy will be a prime criterion, managers will scrupulously
consider all factors that go towards securing the interests of the Company. MAX
will focus on meritocracy, equity and upholding of Company values in all people
processes including performance management systems, appraisals, remuneration and
rewards.
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A Gender Friendly Workplace
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As a good corporate citizen, MAX is committed to a gender friendly workplace. It
seeks to enhance equal opportunities for men and women, prevent/stop/redress sexual
harassment at the workplace and institute good employment practices. MAX maintains
an open door for reportees; encourages employees to report any harassment concerns
and is responsive to employee complaints about harassment or other unwelcome and
offensive conduct.
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Relationships with Suppliers and Customers
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All directors, management and employees shall ensure that in their dealings with
suppliers and customers, the Company’s interests are never compromised. Accepting
gifts and presents of more than a nominal value, gratuity payments and other payments
from suppliers or customers will be viewed as serious breach of discipline as this
could lead to compromising the Company’s interests.
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Legal Compliance
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It is the Company’s policy to comply fully with all applicable laws and regulations.
Ensuring legal and regulatory compliance is the responsibility of the Management
of the Company. The Company cannot accept practices which are unlawful or may be
damaging to its reputation. In the event the implication of any law is not clear,
the Management shall take legal advice.
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Health and Safety
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The Company attaches great importance to a healthy and safe work environment. MAX
is committed to provide good physical working conditions and encourages high standards
of hygiene and housekeeping. Particular attention should be paid to training of
employees to increase safety awareness and adoption of safe working methods, particularly
designed to prevent serious or fatal accidents.
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Environment Policies
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The Company believes that commitment to sustainable development is a key component
of responsible corporate citizenship and therefore deserves to be accorded the highest
priority. Accordingly, the Company is committed to Best Practices in environmental
matters arising out of its business activities and expects each business to fully
demonstrate this commitment. In addition to complying with applicable laws and regulations,
Businesses must establish procedures for assessing the environmental effects of
their present and future activities. They should adopt Best Practices in their environmental
policies and procedures.
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Personal Conduct
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All directors, management and employees have the obligation to conduct themselves
in an honest and ethical manner and act in the best interest of the Company at all
times. They are expected to demonstrate exemplary personal conduct through adherence
to the following:
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Avoidance of Conflict of Interest
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All directors, management and employees must avoid situations in which their personal
interest could conflict with the interest of the Company. This is an area in which
it is impossible to provide comprehensive guidance but the guiding principle is
that conflict, if any, or potential conflict must be disclosed to higher management
for guidance and action as appropriate.
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Transparency and Auditability
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All directors, management and employees shall ensure that their actions in the conduct
of business are totally transparent except where the needs of business security
dictate otherwise. Such transparency shall be brought about through appropriate
policies, systems and processes, including as appropriate, segregation of duties,
tiered approval mechanism and involvement of more than one manager in key decisions
and maintaining supporting records. It shall be necessary to voluntarily ensure
that areas of operation are open to audit and the conduct of activities is totally
auditable.
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Protection of Confidential Information
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No director, management and employee shall disclose or use any confidential information
gained in the course of employment/ association with the Company for personal gain
or for the advantage of any other person. No information either formally or informally
shall be provided to the press, other publicity media or any other external agency
except within approved policies.
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Company Facilities
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No director, management and employee shall misuse Company facilities. In the use
of Company facilities, care shall be exercised to ensure that costs are reasonable
and there is no wastage.
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Non Adherence
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Any instance of non-adherence to the Code of Conduct / any other observed unethical
behaviour on the part of those covered under this Code should be brought to the
attention of the immediate reporting authority, who shall in turn report the H R
Department.
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For assistance and / or grievance redressal please contact the compliance officer
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Name
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Gitika Arora
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Designation
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Company Secretary & Compliance Officer
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Address
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SD-65, Tower Apartment, Pitampura, 110034
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Telephone
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011-27314646, 27312522
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Fax
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011-27315115
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E-mail Id
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cs@maxheights.com
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Website
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www.maxheights.com
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