Code of Conduct for Directors and senior management and all other employees of Leading Leasing Finance And Investment Co. Limited (herein after referred to as “The Company”).
The Company believes that good corporate governance is necessary to achieve long term corporate goals and to enhance shareholders’ values. The philosophy of the Company on corporate governance envisages attainment of high level of transparency in all its operations, making disclosures to the highest possible level without compromising in any way compliance of laws and regulations.
This code of conduct for the Board of Directors, senior management of the Company and all its employees is to reiterate the above commitment and provide guidance in recognizing and dealing with ethical issues and provide a built in mechanism to report unethical practices and in the process sustain a culture of honesty and accountability. Every Director, senior management personnel and other employees are expected to comply with this code of conduct both in letter and spirit.
The aforesaid personnel are expected not only to comply with applicable laws, rules and regulations but their responsibility include creating and maintaining culture of high ethical standards and commitment to compliance and provide a work environment to encourage the stake holders to raise concerns to the attention of the management.
All personnel covered by this Code of Conduct should rely on the discretion, judgment and skills expected from a reasonably prudent person under comparable circumstances.
Following are Enumerated areas wherein the code of conduct be applicable.
- Honest and ethical practices:
The company expects every Director, Senior Management personnel, and all employees to observe the highest standard of honesty, integrity and ethical and law abiding behavior in the course of performance of their duties and in dealing with employees, investors, customers, creditors, auditors, lawyers, government authorities and all other personnel / entities with whom the person has to deal with during the course of discharge of his duties.
- Conflicts of interest or duty:
- A conflict of situation can arise when the subject personnel takes action or has interests that may make it difficult to discharge his/her responsibility objectively and effectively.
- Any significant or substantial interest in any customer/ partner or competitor of the company.
- Any external business activity that distracts the individual’s ability to devote appropriate time and action to discharge his responsibility in the Company.
- The conflict of interest can also be on account of previous employment, long term relationship, direct relationship like relatives or firms/ companies in which the personnel or their relatives are partners, directors etc.
In all the aforesaid situations the personnel is called for to balance the interest of the company or their duties towards the company and their personal or external business interest or their obligations to any external parties.
In all the aforesaid situations every subject personnel are required to make complete disclosure of their interest to the company secretary or such designated officer of the company and as far as the directors are concerned to the Board itself.
Every Director apart from complying with the provisions of the companies Act with respect to disclosure of their directorship and partnership and such other matter, to be placed before the Board and shall not participate in any such discussions when the Board considers the matters in which such director is having a conflict of interest. Similarly every subject personnel must not exploit for their own personal gain the opportunity that are discovered through the use of corporate property, information or possession unless the opportunity is disclosed fully in writing to the company.
- Compliance with law, regulations, policies and procedures:
Every subject personnel must comply both in letter and spirit all applicable laws, rules & regulations and also the company’s policies and procedures and create an environment where in there would be automatic compliances of the statutory laws and regulations from everyone and all.
The Directors, senior management personnel and all other employees shall maintain the confidentiality of information of the company or that of any customer and business associate of the Company except where the disclosure is required to be made as per applicable laws.
- Fair deal:
Every Director, senior management personnel and employees shall deal fairly with customers, competitors and co-employees and shall not take any undue advantage of anyone through manipulation, concealment, abuse of confidentiality, misinterpretation of the facts or any other unfair dealing practices.
It would be the responsibility of every Director and senior management personnel to promote a respectful work place culture free from harassment, bias and discrimination of any kind.
- Protection and proper use of assets:
Every Director and senior management personnel and all employees shall have an inherent responsibility of protecting the assets of the Company and ensure their efficient and effective use. All malpractices, theft, carelessness, wastage of Company’s property and assets shall be discouraged and eliminated.
- Report on deviation from Code of Conduct:
It is expected that the directors, senior management personnel and all other employees to report promptly and in good faith any actual or suspected violation by the officer or employee of the standards, requirements or expectations set out in this code of conduct.
Every employee shall immediately report on the deviation to his / her immediate reporting officer and in the event the complaint is against the said reporting officer himself then to the next higher authority and all such complaints shall be marked confidential to the attention of the company secretary or such other designated personnel or to the Board as the case may be.
It shall be the responsibility of the Director and the senior management personnel to ensure that the reporting person’s position is protected, the reporting person’s identity is disclosed only with his consent unless called for by the law and no disciplinary, other action is tolerated against the reporting personnel for having reported the violation or deviation of the code of conduct.
It shall be the responsibility and duty of the Directors and senior management personnel to take requisite action after thorough investigation of any such deviations/ violations reported to them. Further during the course of investigation in the matter reported the subject personnel shall uphold the principles of natural justice.
- Waivers / Modifications:
As situations continuously change The Company is committed to review and update its policies and procedures to meet the objectives set forth for itself, this code of conduct shall be subject to a modification if required and such amendments/ inclusion or waiver of any provision of this code shall be approved by the company’s Board of Directors or a committee of directors constituted for the purpose.
- Interpretations / Clarifications:
Any question on interpretation under this code of conduct shall be handled by the Board or any person/ committee authorized by the Board of the company.