Code of Ethics and Code of Conduct

Contents

  1. Introduction
  2. Open Door Policy
  3. No Retaliation
  4. Comply With Laws
  5. Harassment-Free Work Environment
  6. Be Respectful of Others
  7. Honest and Ethical Conduct and Fair Dealing
  8. Open and Fair Competition
  9. Protecting the Environment
  10. Workplace Safety & Child Labor
  11. Avoid Conflicts of Interest
  12. Insider Trading
  13. Confidential Information
  14. Protect and Properly Use Ample Assets
  15. Gifts and Gratuities
  16. Investigating and Resolving Issues Under the Code
  17. Amendments

Code of Business Conduct

This Code of Business Conduct applies to everyone who works for Ample Technologies at all locations. This includes all our team members, officers and contract team members. The purpose of this Code is to spell out our commitment to doing business not only legally, but also with ethics and integrity and to help you make the right choices as you do your jobs. The reason this is so important is because what we do reflects on who we are as a company and our reputation among our customers, vendors, team members and local communities. This Code also embodies our enduring values.

We are committed to authentic and transparent communications with our customers, our shareholders, and each other. This is critical not only to our business but also to our good reputation. We are also committed to making the right choices about how we do business. This sometimes means saying “no” to courses of action that do not reflect our values. This takes courage.

We recognize that good ethics are good business. We each have a responsibility to uphold the highest standards of business conduct. This is what sets us apart from other companies and inspires us to give our best every day.

If you have any questions or need clarification regarding this Code or how it applies to you in any situation, you should contact your manager or any member of HR department (hr@ample..co.in).

Open Door Policy

We want to hear from you about:

  • Any guidance you might need about a particular legal or ethical dilemma
  • Any concerns you have about questionable accounting or financial reporting matters
  • Any violations or potential violations of this Code or the law.
There are a number of places you can go to discuss any of these matters, including:
    – Your Manager
    – Your HR
    – Any member in the APEX Team
  • Our confidential reporting email address, which are accessed by HR Head and MD. You can choose to identify yourself or remain anonymous using either of these methods. We have found that if you identify yourself when making a report, it helps us conduct a more effective and thorough investigation. 
If you have any questions about this Code of Conduct, just ask!

No Retaliation

Ample has a strict no retaliation policy for any reports made in good faith. This means you will not be disciplined or discriminated against in any way if you report a concern or cooperate in an investigation in good faith. In fact, retaliation is grounds for discipline and possibly termination for anyone who retaliates against a team member who makes a good faith report.

Comply with Laws

We expect every team member, officer and contract team member of Ample to comply with all laws, rules and regulations applicable wherever we do business. We want you to use good judgment and common sense and to ask for advice when you are uncertain about what to do.

Harassment – Free Work Environment

We will not tolerate illegal discrimination or unlawful workplace harassment.

Be Respectful of Others

We are committed to a work environment where team members are treated with respect and fairness. This means that you should act professionally in all job-related activities. You should never verbally or physically mistreat or threaten others. Be respectful in your communications with others, including electronic and online communications such as email, texting, instant messaging, or posts on social networking sites.

Honest and Ethical Conduct and Fair Dealing

It is Ample’s intention to create a business environment that reflects the highest standards of professionalism and ethical behavior. We must all endeavor to deal honestly, ethically and fairly with our suppliers, customers, competitors and other team members. Statements regarding our products and services must not be untrue, misleading, deceptive or fraudulent. You must not take unfair advantage of anyone through manipulation, abuse of confidential information, fraud or any other unfair-dealing practice. This is critical to preserving our good reputation.

Open and Fair Competition

It is illegal for us to collaborate with our competitors to restrain competition or trade by engaging in activities like:

  • Agreeing to establish or maintain prices
  • Dividing up markets, territories or customers
  • Discussing the boycotting of a third party

If a competitor discusses any of these topics, no matter how casually, stop the conversation and report the incident to your Manager or HR Department.

Protecting the Environment

We strive to conduct business in an environmentally responsible manner. To this end, it is our policy to comply with all environmental laws and regulations. We should all continually assess and strive to improve our processes in order to advance our environmental stewardship.

Workplace Safety & Child Labor

Ample is committed to providing a safe, healthy and secure work environment for all team members. We will not tolerate unsafe conditions or conditions that endanger our team members, or other parties. We will not use forced, involuntary or child labor in any of our facilities.

Avoid Conflicts of Interest

We must always act in the best interests of Ample. We must refrain from engaging in any activity that presents a “conflict of interest.” A conflict of interest occurs when your personal or family interest interferes, or appears to interfere, with the interests of Ample. A conflict of interest can arise whenever you take action or have an interest that prevents you from performing your Ample responsibilities honestly, objectively and effectively. For example:

  • We do not become involved in any activity or business on behalf of a Ample competitor, unless Ample specifically asks that we do so.
  • We do not use our position with Ample to influence a transaction with a customer, supplier, vendor or other party in which we or a family member has any personal interest. 
If in doubt, you should ask yourself: Am I doing what’s right for Ample? If you are still not sure, ask your Manager or the HR Department for help. It is better to err on the side of caution by disclosing transactions or relationships that could give rise to a conflict of interest.

Insider Trading

In the course of our jobs, we all come into contact with material information about Ample that is not known to the public, like revenue levels, financial results, the acquisition of a significant new strategic partner, and specific technology achievements. We might also come into contact with material non-public information about other companies, like our suppliers and customers. Until this information is disclosed to the public:

Confidential Information

Confidential information is non-public information related to or held by Ample. This includes many things that are valuable company assets, such as:

  • Strategic, business, marketing, financial and product plans
  • Revenue levels, profits and unpublished financial or pricing 
information
  • Team member, customer and vendor lists
  • Pending acquisitions or transactions with other third parties
  • Trade secrets and other intellectual property. 
It is critical to our continued growth and competitiveness that this information remains confidential and secure. We must not disclose this information to people or companies outside Ample, unless there is a non-disclosure agreement in place or we are required by law to disclose it. We must also maintain the confidentiality of the confidential information of other company, including our suppliers and customers. 
Third parties may ask you for information about Ample. These third parties might include media or securities market professionals (like securities analysts, institutional investors, brokers and dealers). If you receive any inquiries of this nature, you must decline to comment. 
You also must abide by any obligations that you have to your former employers. These obligations may include restrictions on the use and disclosure of their confidential information, restrictions on the solicitation of your former colleagues to come work at Ample, and non-competition obligations.

Protect and Properly Use Ample Assets

  • We should all seek to protect Ample’s assets. These assets include Ample’s equipment, tools, materials, supplies, and technology resources (such as computers and phones). Theft, loss, carelessness and waste have a direct impact on our financial performance. We must use Ample assets for legitimate business purposes and not for any personal benefit or the personal benefit of anyone else. Failure to protect our technology resources can also make our electronic records vulnerable to attack by hackers.
  • We must advance Ample’s legitimate interests when the opportunity to do so arises. You must not take for yourself personal opportunities that you discovered through your position with Ample.

Gifts and Gratuities

  • We value professional objectivity in our business relationships. Our guiding principle is that we do not receive or give any gift if it is intended to influence our or another party’s business decision.
  • We must not accept, or permit any member of our immediate family to accept, any gifts, gratuities or other favors from any customer, supplier or other person doing or seeking to do business with Ample, other than items of insignificant value (less than Rs. 1000 or eatable). Any gifts of more than insignificant value or that are intended to influence our business decisions should be returned immediately. If immediate return is not practical, they should be given to Ample’s admin/HR for appropriate disposition.
  • Procedure for handling the gifting customer: The team member has to politely decline acceptance of the gift. If the gift is of high value, he has to take the help from his reporting manager to handle the situation. In case the nature of the gift is a sponsored or a logoed item from the customer’s organisaiton, the team member has to report it the direct reporting manger, who’ll in turn make a record and also assess the value of the item and convey the decision of acceptance or otherwise to the team member.Once the gift has been accepted, the Manager along with the HR Head determines as to what can be done with the gift/s received.
  • There are special rules about giving anything of value to a government official, which can include government agencies and companies that are owned or controlled by the government (such as public utilities, telecommunications companies or news agencies). Any payment or gift to a government official must be for reasonable and documented business expenses and cannot be for the purpose of securing an improper business advantage. It can be done only with the appropriate approval from the Managing Director of the Company.
  • You must not offer, give, solicit or receive bribes or kickbacks of any kind anywhere in the world.

Investigating and Resolving Issues Under the Code

If the HR department receives information regarding an alleged violation of this Code, it will:

  • Evaluate the information.
  • Determine whether it is necessary to conduct an informal inquiry or a formal investigation and, if so, initiate that inquiry or investigation.
  • Determine whether disciplinary measures must be taken.
  • We are all expected to cooperate fully with any inquiry or investigation by Ample regarding an alleged violation of this Code. Failure to cooperate with any inquiry or investigation may result in disciplinary action, including termination.

Violation of this Code may result in potential legal liability to Ample or cause serious damage to our reputation and so constitutes a serious violation of Ample’s policies. Failure to comply with the standards outlined in this Code may result in disciplinary action including, but not limited to, reprimands, warnings, demotions, reductions in salary or termination. Certain violations of this Code may require Ample to refer the matter to the appropriate governmental or regulatory authorities for investigation or prosecution. Any supervisor who directs or approves of any conduct in violation of this Code also will be subject to disciplinary action, up to and including termination.

Code of Conduct

  1. At all times team members are to give priority to customers (internal as well as external) and work towards creating a motivated customer base.
  2. It is the individual responsibility of team members to respect and protect the confidentiality of information made available to them during their tenure at Company.  Any confidential information such as business processes, customers and clients information, business data, materials, specifications, manuals, business plans, marketing plans, improvement, designs, concepts, training materials, etc., should not be disclosed for public knowledge or persons outside the business scope.
  3. Team members are required to protect and handle safely company’s property, both tangible and intangible. Any damage is to be borne by the concerned team member.
  4. During work hours, team members are to devote their time and attention to the Company’s business entrusted to them with integrity and ethical conduct. Team members shall not engage directly or indirectly in any business or service other than the Company’s business or service except with the Senior Management’s prior approval obtained in writing.
  5. Team members shall carry out their work responsibilities with commitment and diligence. While on the premises of the Company team members are not to indulge in activities of personal interest or for personal entertainment or activities which hinder the interest, the business activities of the Company and the performance of colleagues.
  6. Team members are to ensure adherence to quality, cost and delivery commitments.
  7. Team members are expected to adhere to Attendance and Punctuality as per the guidelines mentioned in the policy. Late coming, Absenteeism, Unauthorized or unexcused absence will be considered as misconduct.
  8. Team members are to comply with all Company Protocols, norms, legal & regulatory requirements. The same applies to policies, processes and procedures.
  9. Team members are expected to, display intellectual honesty, self-discipline, ethical values and not engage in political or religious activities within the office premises.
  10. Team members are not to accept gifts and anything of value from current or prospective customers and/or suppliers of the company.
  11. Team members are expected to treat with respect colleagues, customers and business associates and not to take any action that causes inconvenience to them or harms the Company’s business relations.
  12. Use of mobile phones with fancy ring tones and loud phone discussions are discouraged. When in the office the mobile has to be kept on the silent or vibrate mode, else on a low ringtone.
  13. Ensure that resources like electricity, paper, and water are used optimally as the unproductive and wasteful use of the same has a direct bearing on our environment.
  14. Use of un-parliamentary language or speaking in loud, harsh tones inside the office thereby being disturbance to colleagues is unacceptable under any circumstance.
  15. All team members are required to adhere to all safety, security, environment and housekeeping requirements and prevailing administrative rules, which are subject to modification/change from time to time.
  16. Team members are to participate in training program/seminars and other educative forums as & when nominated. It is expected that all team members take this sincerely, attend all sessions, follow program guidelines/ rules and utilize the new learning besides sharing it with other team members.
  17. During work hours on the Company premises, being under the influence of or being in possession of or use of alcohol, narcotic or like substance/s is strictly prohibited.

Disrespect and non-compliance to the code of conduct may call for disciplinary action as may be deemed appropriate.