GORADIA SPECIAL STEELS LTD. CODE OF CONDUCT

The values and principles of Goradia Ideology have been deployed through the implementation of the Goradia Code of Conduct ( hereinafter referred to as the 'Code' ). This is intended to serve as a guide to each employee on the values, ethics and business principles expected of him or her in personal and professional conduct. Codehas been made to ensure that diverse cultural and business related issues are addressed universally across the company.

The Code of Conduct is our fingerprint in business; we earn credibility with our customers, business partners, business providers and co-workers "by keeping our commitments, acting with honesty and integrity, and pursuing our goals solely through honorable conduct".

A Goradia Employee would never violate this Code or any Company policy under any circumstances. If you should be coerced into such an act, you are responsible to report the offence to your Manager Administration (rts@goradia.in&hr@goradia.in )

BUSINESS ETHICS

The Company is committed to seeking long term success with no compromise on ethical business standards

The highest standards of integrity, impartiality, equity and objectivity shall be observed in every activity that encompasses the business.

The business of the Company shall be conducted in keeping with the exacting standards that are contained in this Code. The Managementand the employees shall diligently comply with the requirements of this section, and the regulations applicable to the country in which they transact business.

The employees are expected to remain independent in any decision that they may be required to take and should disclose any interest ?personal, professional, academic or business ?which may arise directly or indirectly through their relatives that may conflict with their responsibilities.

The Business decisions shall be taken in a manner that supports full and open competition and secures for the Company the best products and services at the most competitive price.

PROHIBITION OF SEXUAL HARASSMENT

The Company's policy against sexual harassment prohibits sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature, whether or not such conduct is motivated by sexual desire, when:

  • Submission to or rejection of such conduct is an explicit or implicit term or condition of employment,
  • The employee's submission to or rejection of such conduct is used as the basis for employment decisions affecting such individual, or
  • Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, humiliating or offensive working environment

While it is not possible to list all those circumstances that may constitute sexual harassment, the following are some examples of conduct which, if unwelcome, may constitute as sexual harassment.

  • unwelcome sexual advances, whether they involve physical touching or not;
  • sexual epithets, jokes, written or oral references to sexual conduct, gossip regarding one's sex life;
  • comments about an individual's body, sexual activity, deficiencies, or prowess;
  • displaying sexually suggestive objects, pictures, or cartoons, including by downloading such materials from the Internet;
  • unwelcome leering, whistling, brushing against the body, sexual gestures, or suggestive or insulting comments;
  • inquiries into one's sexual experiences.
  • discussion of one's sexual activities.
  • Emailing / SMS chatting / what?s app messaging of vulgar jokes; pornetc.

Prohibition of Other Types of Discriminatory Harassment including Racial & Religious Discrimination.

The Company's policy also prohibits verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, religion, creed, gender, sexual orientation, marital status, gender identity or expression, national origin or ancestry, genetics, age, disability status, protected veteran status (including disabled veteran, recently separated veteran, other protected veteran, or Armed Forces service medal veteran), citizenship status when otherwise legally able to work, or other protected classification, and that:

  • Has the purpose or effect of creating an intimidating, hostile, humiliating or offensive working environment,
  • Has the purpose or effect of unreasonably interfering with an individual's work performance, or
  • Otherwise adversely affects an individual's employment opportunities.

While it is not possible to list all those circumstances that may constitute discriminatory harassment, the following are some examples of conduct which may constitute discriminatory harassment depending upon the totality of the circumstances including the severity of the conduct and its pervasiveness:

  • Epithets, slurs, negative stereotyping, or jokes, or threatening, intimidating or hostile acts that relate to race or other protected classification;
  • Written or graphic material that denigrates or shows hostility toward an individual or group because of race or other protected classification and that is circulated in the workplace, or placed anywhere in the Company's premises such as on an employee's desk, workspace or on Company computer, email or voicemail.

The Company will take an exceptionally stringent action against any employees of the Company, who violates this policy.

NO TO CORRUPTION

The Company does not espouse the payment or receipt of gifts or bribes for business or financial gain. As a corollary, no employee or representative of the Company should do anything that could give an impression that the Company/ officers could be influenced in this manner.

It might be customary, at times, to give or exchange unsolicited gifts during the traditional festive seasons or during certain corporate events. These should be restricted to promotional or advertising material or such terms that are customary or considered to be prudent or of a symbolic nature by the Management, having regard to the nature of the business, the type of markets in which the Company is operating and the event being observed. It would however be unethical and incorrect to gift items where there is an intention to derive any benefit in return.

All officers are directed not to accept any gifts / favor of any kind any kind from any suppliers / vendors / contractor / customers.

Gifts, like sweets / Dry fruits / Diaries / calendars received during festive seasons must be distributed within company itself.

Not to give any bribe to any customers / government officer etc. instead focus on meeting all standard / completing all documentation / following all laid down procedures / business license guidelines.

CIRCUMSTANCES IN VIOLATION OF THE CODE OF CONDUCT

Employee should not interfere with an investigation conducted by the Company, neither should disclose nor discuss an investigation with unauthorized persons.

Failure to comply with any provision of the Code or Company policy is a serious violation, and may result in disciplinary action up to and including termination and in some circumstances criminal charges. These consequences apply not only to the employee who violates the Code, but to those who condone misconduct, fail to report or take reasonable measures to prevent, detect and address misconduct. Violators will also include those who may seek to retaliate against those who, in good faith, report potential misconduct.

Directors and the Human Resources Department can advise us and help make the appropriate decisions concerning conduct in work and in business. If you are uncertain if an action or choice may be a violation of the Code, it is your responsibility to check before making a decision to act.

Should you require any further details on the Code of Conduct of our Company, please feel free to contact HR ?Section on hr@goradia.in.

The business ethos of the CODE is deployed through a specially formulated structure - the Management of Business Ethics (MBE) - which is based on four pillars

LEADERSHIP

The Managing Director is also Goradia?s chief ethics officer. A designated Ethics Counsellor, supported by Departmental Ethics Coordinators, reports directly to the Managing Director and has access to the Board of Directors.

COMMUNICATION AND AWARENESS

Compliance to the Code is a condition of service for all employees and is also a pre-requisite for service for suppliers, contractors and vendors, who must agree to respect it. Employee seminars, compliance training and ethics awareness workshops are conducted at frequent intervals.

EVALUATION OF EFFECTIVENESS

The MBE Programme is evaluated and reviewed and new initiatives as required are introduced under the MBE Annual Business Plan.

COMPLIANCE STRUCTURE

A number of systems and processes based on zero tolerance have been put into place to ensure that governance standards are met. These include Gift Policy, Whistle Blower Policy, Vendors Whistle Blower Policy, and Anti-Harassment Policy.

Although a tough climate in which to do business, employers can take steps to minimize their risks in the areas of discrimination and harassment, while also growing and creating thriving, progressive work environments.

COMPALINT PROCEDURE

Complaints of either sexual or other discriminatory harassment must be brought immediately to the attention of the applicable Human Resources Manager ("HR Manager"). Although reports of sexual or discriminatory harassment Human Resources Policies and Proceduresmay be made verbally, employees are strongly encouraged to make any such reports in writing. Written reports of harassment assist the investigation process.

When a complaint is received, the Human Resources Operations Manager, in conjunction with the Office of the General Counsel, will promptly investigate the allegation as discreetly and confidentially as possible. The investigation will normally include a private interview with the person filing the complaint and with witnesses, as appropriate. The investigation will also normally include an interview of the person alleged to have committed the harassment. When the investigation is complete, the Human Resources Operations Manager or the Office of the General Counsel, will, to the extent appropriate, inform the person filing the complaint and the person alleged to have committed the conduct of the results of the investigation.

If the Company determines that a violation of this policy has occurred, it will take such disciplinary action as it deems appropriate, including but not limited to counseling, warnings, transfers, suspensions, and employment termination.

Moreover, the Company can and will take the disciplinary action it deems appropriate if it determines that conduct which does not meet the definitions in this policy nevertheless is unprofessional, inappropriate or otherwise warrants discipline.

Date : 16.05.2015

PranayGoradia

Managing Director