This comprehensive document serves as the ethical road map for Home First Finance Company India Limited (HFFC) employees and provides the guidelines by which the company conducts its businesses.
The HFFC Code of Conduct is a set of principles that guide and govern the conduct of HFFC and their employees in all matters relating to business. The Code lays down the ethical standards that HFFC employees have to observe in their professional lives, and it defines the value system at the heart of the company.
HFFC is committed to benefit the economic development of the country. No HFFC employee shall undertake any project or activity to the detriment of the wider interests of the community. The company’s management practices and business conduct shall benefit the country, localities and communities in which it operates, to the extent possible and affordable, and shall be in accordance with the laws of the land.
HFFC shall be committed to good corporate citizenship, not only in the compliance of all relevant laws and regulations but also by actively assisting in the improvement of quality of life of the people in the communities in which it operates.
HFFC shall not support any specific political party or candidate for political office. The company’s conduct shall preclude any activity that could be interpreted as mutual dependence / favour with any political body or person, and it shall not offer or give any company funds or property as donations to any political party, candidate or campaign.
Employees of HFFC, in their business conduct, shall comply with all applicable laws and regulations, in letter and spirit. If the ethical and professional standards of applicable laws and regulations are below that of the Code, then the standards of the Code shall prevail.
The management of HFFC shall comply with applicable laws and regulations of all the relevant regulatory and other authorities. As good governance practice they shall safeguard the confidentiality of all information received by them by virtue of their position.
Financial Reporting & Records
HFFC shall prepare and maintain its accounts fairly and accurately and in accordance with the accounting and financial reporting standards which represent the generally accepted guidelines, principles, standards, laws and regulations of the country in which the company conducts its business affairs.
Internal accounting and audit procedures shall reflect, fairly and accurately, all of the company’s business transactions and disposition of assets, and shall have internal controls to provide assurance to the company’s board and shareholders that the transactions are accurate and legitimate. All required information shall be accessible to company auditors and other authorized parties and government agencies. There shall be no wilful omissions of any company transactions from the books and records, no advance-income recognition and no hidden bank account and funds.
Any willful, material misrepresentation of and / or misinformation on the financial accounts and reports shall be regarded as a violation of the Code, apart from inviting appropriate civil or criminal action under the relevant laws.
Equal Opportunities Employer
HFFC shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, religion, color, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin or disability.
Human resource policies shall promote diversity and equality in the workplace, as well as compliance with all local labor laws, while encouraging the adoption of international best practices.
Employees of HFFC shall be treated with dignity and in accordance with the HFFC policy of maintaining a work environment free of all forms of harassment, whether physical, verbal or psychological. Employee policies and practices shall be administered in a manner consistent with applicable laws and other provisions of this Code, respect for the right to privacy and the right to be heard, and that in all matters equal opportunity is provided to those eligible and decisions are based on merit.
Health, Safety & Environment
HFFC shall strive to provide a safe, healthy and clean working environment for its people.
Every employee of the company, shall exhibit culturally appropriate deportment and deal on behalf of the company with professionalism, honesty and integrity, while conforming to high moral and ethical standards. Such conduct shall be fair and transparent and be perceived to be so by third parties.
Every employee of a HFFC shall preserve the human rights of every individual and the community and shall strive to honor commitments.
Every employee shall be responsible for the implementation of and compliance with the Code in his / her environment. Failure to adhere to the Code could attract severe consequences, including termination of employment.
Consistent with applicable laws, an employee of the company shall not, without the requisite, officially written approval of the company, accept employment or a position of responsibility (such as a consultant or a director) with any other company, nor provide freelance services to anyone, with or without remuneration.
Protecting Company Assets
The assets of HFFC shall not be misused; they shall be employed primarily and judiciously for the purpose of conducting the business for which they are duly authorized. These include tangible assets such as equipment and machinery, systems, facilities, materials and resources, as well as intangible assets such as information technology and systems, proprietary information, intellectual property, and relationships with customers and suppliers.
Integrity of Data Furnished
Every employee of the company shall ensure, at all times, the integrity of data or information furnished by him / her to the company. He / she shall be entirely responsible in ensuring that the confidentiality of all data is retained and in no circumstance transferred to any outside person / party in the course of normal operations without express guidelines from or, the approval of the management.
HFFC or its employees shall market the company’s products and services on their own merits and shall not make unfair and misleading statements about competitors’ products and services. Any collection of competitive information shall be made only in the normal course of business and shall be obtained only through legally permitted sources and means.
Third Party Representation
Parties which have business dealings with HFFC, such as consultants, agents, sales representatives, distributors, channel partners, contractors and suppliers, shall not be authorized to represent HFFC without the written permission of the company.
Third parties and their employees are expected to abide by the Code in their interaction with, and on behalf of HFFC. The company is encouraged to sign a non-disclosure agreement with third parties to support confidentiality of information.
Conflict of Interest
An employee of the company shall always act in the interest of the company, and ensure that any business or personal association which he / she may have does not involve a conflict of interest with the operations of the company and his / her role therein.
An employee of the company shall not engage in any business, relationship or activity which might conflict with the interest of the company.
Notwithstanding such or any other instance of conflict of interest that exist due to historical reasons, adequate and full disclosure by interested employees shall be made to the company’s management. It is also incumbent upon every employee to make a full disclosure of any interest which the employee or the employee’s immediate family, including parents, spouse and children, may have in a family business or a company or firm that is a competitor, supplier, customer or distributor of or has other business dealings with his / her company.
Upon a decision being taken in the matter, the employee concerned shall be required to take necessary action, as advised, to resolve / avoid the conflict.
If an employee fails to make the required disclosure and the management of its own accord becomes aware of an instance of conflict of interest that ought to have been disclosed by the employee, the management shall take a serious view of the matter and consider suitable disciplinary action against the employee.
Every employee of the company shall promptly report to the management, when she / he becomes aware of any actual or possible violation of the Code or an event of misconduct, act of misdemeanor or act not in the company’s interest. Such reporting shall be made available to suppliers and partners, too.
Any HFFC employee can choose to make a protected disclosure under the whistle blower policy of the company. Such a protected disclosure shall be forwarded, when there is reasonable evidence to conclude that a violation is possible or has taken place, with a covering letter, which shall bear the identity of the whistle blower.
The company shall ensure protection to the whistle blower and any attempts to intimidate him / her would be treated as a violation of the Code.