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20. Our employees shall use all company assets, Insider trading
tangible and intangible, including computer 22. Our employees must not indulge in any form
and communication equipment, for the of insider trading nor assist others, including
purpose for which they are provided and in immediate family, friends or business
order to conduct our business. Such assets associates, to derive any benefit from
shall not be misused. We shall establish access to and possession of price sensitive
processes to minimise the risk of fraud, and information that is not in the public domain.
misappropriation or misuse of our assets.
Such information would include information
21. We shall comply with all applicable about our company, our group companies,
anti-money laundering, anti-fraud and our clients and our suppliers.
anti-corruption laws and we shall establish
processes to check for and prevent any
breaches of such laws.

Q & A

our company has recently announced the launch of a new business initiative. In connection
with this, your friend who is a journalist with a leading business newspaper has asked you
to provide some information that he could cover in his forthcoming article. He has promised
not to quote you, or reveal your identity. Should you be giving him this information?

No. You should not be sharing information of this nature with the media, even if it is assured that the
source would remain anonymous. Only authorised personnel in the company are permitted to speak
to the media and provide information of this nature.
our company has a “Use of Social media” policy that lays down the “dos and don’ts” for use of
social media even if you may access such media on your own time. Why is there such a policy?
External communication is a serious matter. It must be carefully managed because information put
out with reference to our company or its businesses needs to be clear, truthful and not violate any
undertakings we have given to other parties. In each business there are managers nominated to authorise
and make different types of statements to the outside world. These managers should be consulted about
any request for information you may receive or information you think we should give out.
In using social media, in particular blogs or social networking sites, you should exercise great caution
while talking about our company or the business we do. It may feel like you are chatting with
friends or expressing a personal opinion but even while doing so you cannot share any confidential
information of our company.

RemembeR…
We must respect the property rights of others by never misusing their assets, intellectual property
or trade secrets, including the copying or downloading of unauthorised software, trademarks,
copyrighted material or logos. We should never make unauthorised copies of computer software
programs or use unlicensed personal software on company computers.
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