Definition

“A set of conventional principles and expectations that

are considered binding on any person who is a
member of a particular group”

Code of Business Conduct & Ethics

Introduction
A code of conduct is a set of rules outlining the
responsibilities of or proper practices for an
individual or organization. Related concepts include
ethical codes and honor codes.
In its 2007 International Good Practice Guidance,
Defining and Developing an Effective Code of
Conduct for Organizations, the International
Federation of Accountants [1] provided the following
working definition:
"Principals, values, standards, or rules of behavior
that guide the decisions, procedures and systems of
an organization in a way that (a) contributes to the
welfare of its key stakeholders, and (b) respects the
rights of all constituents affected by its operations."

Business conduct
In today’s interconnected and interdependent world,
where borders between states are becoming
increasingly transparent, principles in business
conduct are becoming criteria for building a good
reputation in the international business community;
they are the basis on which first impressions are
formed and ongoing relationships maintained.
The Kalyani Group comprises of many leadership
businesses. While ethics is deeply ingrained in our
culture, strong commitments to integrity, fairness,
quality, and excellence have long been the guiding
principles.
The very purpose of Ethics and Business Conduct at
the Kalyani Group is to communicate our values and
standards of ethical business conduct to employees
and to inform them of the company policies and
procedures for doing business. :
Our strong business conduct program helps to keep
our business well within legal requirements and also
provides a working environment in which all
employees can feel comfortable about our business
standards.
This Code of Business Conduct is a statement of our
policies and procedures that cover the way in which
we expect our employees to carry out their work.
The policy of the Company is to promote good
practices, encourage operating in an ethical manner
and ensure that the same standards are upheld
wherever the group operates.

Examples

Code of Conduct
 Global Compliance offers a variety of Code of Conduct
support services to ensure that your Code is sufficient
in terms of breadth, scope, and legality, that it meets
your business objectives, and that it becomes
ingrained in your culture. We possess the legal
expertise and the practical experience necessary to
help your organization establish and reinforce an
effective Code of Conduct that sets the tone for your
desired business culture, outlines organizational
values, and enables a clear understanding of expected
behavior.
 Review and assessment of an existing Code to
determine adequacy and required alignment.
 Modification and updating of an existing Code to
ensure effectiveness and comprehensiveness for all
levels of employees and stakeholders.
 Development of a new Code to define
organizational values, policies, and expected
behavior.
 Production, distribution, and coordinated launch of
Code to provide information to employees, vendors,
agents, the Board, and stakeholders.
 Ongoing awareness and education campaigns
specific to organizational values to drive
understanding and retention and impact behavior.
 Certification of receipt, understanding, and intent to
comply with the Code by all employees and relevant
stakeholders.
 Disclosure of non-compliance with Code to enable
documentation and management review of
exceptions.
Code Review
Our team of nationally known attorneys and
compliance experts reviews your Code of Conduct and
other policies and provides recommendations on:
 Required content given your organization's
industry, states and countries of operation,
employee demographics, function, hierarchy levels,
and legal and regulatory impact.
 Code comparison to best practices and those of
other organizations in your industry.
 Effective formatting and communication of polices
and expectations within your Code.
 Code alignment with your business objectives.

Code Development and Production

Our in-house team of subject matter experts and
writers customizes a Code of Conduct that meets your
specific business objectives, addresses your areas of
risk, and conveys your organizational culture.
 Experienced Writers ensure that the Code is
written at the median reading and comprehension
level and provides clear standards of behavior.
 Commonly used language and relevant content
and scenarios increase the likelihood of
understanding
 Multilingual translation and cultural adaptation
ensures that every employee is universally
presented with your values and expected behaviors
in his/her native language and that the message is
received in the intended manner
 Expert Graphic Designers concept and design an
appealing document that is customized to your
industry and culture and consistent with corporate
brand standards.
 Project Managers coordinate review and printing of
Code in specified quantities and languages.

Code Distribution, Launch, and Certification

 Development of complementary materials helps to
introduce your Code with consistent messaging and
emphasis along with sufficient exposure.
o Manager Responsibility Guides and
Discussion Starters
o Executive Management letters of
introduction
o Posters
o Wallet Cards
o E-mail announcements
 Multiple distribution methods enable worldwide
employees and stakeholders to simultaneously
receive a copy of your Code.
o Hard copy distribution to business locations
or personal residences
o Electronic distribution via a web link
 Validation of receipt, review, and comprehension of
your Code protects your organization and lessens
the chance of business misconduct.
o Web-based or Interactive Voice Response
(IVR)-based certification
o Real-time, online management reports
summarize participatio and testing
o Reminders to employees and stakeholders
that have not completed validation
o Notification to supervisors of employees
who have not complete validation
 Disclosure documentation process enables
employees who are not in compliance with Code
policies to disclose and explain exceptions sothat
they can be reviewed and approved by
management.
o Interactive training on your Code for new
and existing employees and stakeholders
facilitates both introduction and ongoing
 reminder of corporate values and expected
behavior.
o Web-based, video or CD-based, or
instructor-led options enable training of all
employees and stakeholders, regardless of
location or technology access
o Customization for your employee
demographics, industry, and organization
creates relevancy and interest
o "Crack the Code" exercise requires
employees to search for answers to specific
questions within the organization's Code to
increase familiarity
o Quizzes drive retention and validate
comprehension
o Real-time, online reporting displays
participation, completion, and scoring statistics
for program oversight

CODE OF BUSINESS CONDUCT AND

ETHICS
Aztecsoft Limited’s commitment to ethical and lawful
business conduct is a fundamental shared value of its
Board of Directors, Senior Management Personnel and
Employees and critical to the Company'ssuccess. Our
standards for business conduct provide that we will uphold
ethical and legal standards vigorously as we pursue our
financial objectives. The Company, its Directors Senior
Management
Personnel and Employees will not compromise that
honesty and integrity anywhere at any time.
Consistent with these principles, the Company’s Board
has adopted this Code of Business Conduct and
Ethics (“Code”) as a guide to the high ethical and legal
standards expected of its Board Members and
its Senior Management Personnel.
The Members of the Board of Directors and Senior
Management Personnel of Aztecsoft Limited
acknowledge and accept the scope and extent of their
duties as Directors & Senior Management
Personnel. They have a responsibility to carry out their
duties in an honest and businesslike manner and
within the scope of their authority, as set forth in the
general laws of the land where they operate and
in the Memorandum of Association and Articles of
Association of the Company. They are entrusted with
and responsible for the oversight of the assets and
business affairs of the Company in an honest, fair,
diligent and ethical manner and with the duty to make and
enact informed decisions and policies in the
best interests of the Company and all its stakeholders.
The Board of Directors has adopted this Code
and the Directors and Senior Management Personnel are
expected to adhere to the standards of
loyalty, good faith, and the avoidance of conflict of interest
that follow.
In performing their duties the Directors/Senior
Management Personnel will:

 Integrity
Act ethically, diligently, openly, honestly and in good faith
and with the highest standards of
integrity.
 Fiduciary Obligations
Act in the best interests of, and fulfill their fiduciary
obligations to, Aztecsoft Limited and all
its stakeholders.

 Normal business decisions

 Act in good faith, responsibly, with due care,
competence and diligence, without
allowing their independent judgment to be subordinated;
 To act in a manner to enhance and maintain the
reputation of the Company; and
 Discharge their duties, as members of the Board and of
any Board Committees on which
they serve or as Senior Management Personnel in
accordance with their good faith
business judgment and in the best interests of the
Company and all its stakeholders.

 Compliance
 Abide by all applicable laws and regulations;
 Abide by the Company’s Insider Trading Rules; and
 Comply with all applicable laws, rules and regulations in
all areas and geographies
where the Company operates.

 Business conduct
 Become and remain familiar with the Company’s
business and the economic and
competitive environment in which it operates and
understand its principal business
plans, strategies and objectives; operations results and
financial condition and relative
marketplace position;

 Conduct themselves in a professional, courteous and

respectful manner;
 Make available to and share with fellow Directors and
Senior Management Personnel
information as may be appropriate to ensure proper
conduct and sound operation of
the Company; and
 Provide leadership in advancing the Company's vision,
values and guiding principles.

 Board Meetings
 Commit the time necessary to prepare for, attend (in
person or telephonically, as
appropriate) and actively participate in regular and special
meetings of the Board and
of the Board Committees or other meetings on which they
serve/attend;
 Disclose potential conflicts of interest that they may
have regarding any matters that
may come before the Board, and abstain from discussion
and voting on any matter in
which the Director/ Senior Management Personnel has or
may have a conflict of
interest; and
 Inform the Chairman of the Board of changes in their
employment, other board
positions, relationships with other business, charitable,
and governmental entities, and
other events, circumstances or conditions that may
interfere with their ability to
perform their Board or Board Committee duties or impact
the Board's assessment of
whether they meet the independence requirements.

 Confidentiality
 Maintain the confidentiality of all material non-public
information about Aztecsoft
Limited, its business and affairs;
 Respect the confidentiality of information relating to the
affairs of the Company
acquired in the course of their service as Directors, except
when authorized or legally
required to disclose such information.

 Conflict of Interest
 Not enter into, without the prior approval of the
disinterested members of the Board,
any transaction or relationship with the Company in which
they will have a financial or
personal interest (either directly or indirectly, such as
through a family member or
other person or organization with which they are
associated), or any transaction or
situation which otherwise involves a conflict of interest;
and

 Not use confidential information acquired in the course

of their service as Directors or
Senior Management Personnel for their personal
advantage.
All Directors and Senior Management Personnel will
annually on or before March 31 of every year or
such other date as may be determined in this regard sign
a confirmation that they have read and will
comply with this Code.

Waivers and amendments

The Company is continuously reviewing and updating all
its policies and procedures and therefore this
Code is subject to modification. The Company’s Board of
Directors must approve any amendment or
waiver of any provision of this Code in writing.
The Aim, Objectives and Code of Conduct
Aim
An Association for the Promotion and Marketing of
Modular and Portable Buildings.

Objectives
1. To maintain and improve standards of service,
performance and product quality
2. Promote the expansion of the Modular and Portable
Building Industry in ways which benefit both its
customers and the Members
3. To promote just and honourable business practices
ensuring that relations with the public are good and
the clients can have confidence when dealing with
Members
4. To encourage, promote, protect and defend the
legitimate interests of Members
5. To communicate with EC, National and local
governments, public authorities, standardizing
bodies, etc., in respect of legislation and standards
 affecting the industry and also represent members
collectively to those bodies
6. To provide a referral service for potential clients
7. To provide members with information, data and
statistics relating to the industry and also a forum
where opinions can be exchanged
8. To encourage members to further educate and
develop both themselves and their staff

Code of Conduct
1. Members must adhere to the Aims, Objectives and
Rules of the Association
2. At all times members must conduct themselves
personally and corporately in a manner which will
enhance and maintain the reputation of the MPBA
and the Modular and Portable Building Industry
3. All members dealing with clients, suppliers, advisers,
etc. must be legal, just and honourable and comply
with the MPBA Code of Practice
4. Members, with pride, should make it public
knowledge (advertise, etc.) that they are part of the
MPBA and obtain all possible benefit from
membership through ongoing participation
FACT CODE OF BUSINESS CONDUCT AND
ETHICS

This code of Business Conduct Summaries the

Standards of Business Conduct that guide the activities
of all members of the Board of Directors and Officers of
the Company to ensure that the organization is managed
in a manner to protect the interest of all stakeholders.
This code applies to all Directors and Officers of FACT
and in addition to the provisions/rules contained in the
FACT Employees (Conduct, Disciplines & Appeal) Rules
1977, terms and Conditions of the appointment order and
the directives issued by the Government from time to time.

This Code of Conduct is issued/prescribed to deter

wrongdoing and to promote honest and ethical conduct
including the ethical handling of actual or apparent
conflict of interest between personal and professional
relationships.

1. Ethical Conduct

All members of Board of Directors of the

Company/Officers shall deal on behalf of the
company with professionalism, honesty and integrity,
as well as high moral and ethical standards. Such
conduct shall be fair and transparent.
2. Conflict of Interest

No Director/Officer of the Company shall engage in

any business, relationship or activity which might
detrimentally conflict with the interest of the Company
or the policy issued by the Government from time to
time. Directors/Officers should not place themselves
or remain in a position in which their private interest
conflict with the interest of the Company. If there is
any conflict of interest, the interest of the Company
should prevail.

3. Confidentiality concerning Company Affairs

It is the policy of FACT that the business affairs of

the Company are confidential and should not be
discussed with anyone outside the organization
except for information that has already been made
available to the public. No Director/Officer shall
derive any benefit or assist others to derive any
benefit from the access to and possession of
information about the Company which is not in the
public domain and thus constitutes insider
information. No Director/Officer shall use any insider
information for meeting or giving advice on
investment decisions on shares of FACT.

4. Protecting Company Assets

The assets of FACT should not be misused but

employed for the purpose of conducting the
business for which they are duly authorized. The
assets include tangible as well as intangible assets
such as land and building , machinery and
equipments, systems, facilities, proprietary
information, relationship with customers and
suppliers etc.
5. Integrity

Directors/Officers must conduct the business of the

Company fairly with honesty and transparency.
Every one at all time shall ensure the integrity of data
or information furnished to the Company.

6. Excellence

Everyone must constantly strive to achieve the

highest possible standards in the day to day
activities and the quality of goods and services to the
entire satisfaction of all the stakeholders.

7. Unity

Everyone in FACT shall work cohesively with the

colleagues and fair in dealing with the customers,
suppliers and other stakeholders and build a strong
relationship based on tolerance, understanding and
mutual cooperation.

8. Responsibility

Everyone must continue to be responsible to the

Company, and its stakeholders and the environment
in which they work.

9. Accountability
 The Board of Directors are accountable to the
shareholders and other Officers are accountable to
the Board of Directors.

10. Trusteeship

As professional managers, Board of Directors and

other Officers are conscious that FACT has been
given to them in trust by all the stakeholders. They
will redeem the trust reposed in them by continuously
adding value to FACT.

11. Adherence of Government Policy/Guideline

It is the endeavor of the Board and Officers of FACT

to implement various policies and guidelines issued
by the Government from time to time.

12. Innovation

Everyone shall constantly innovate and strive to

better our process, products services and
management practices.

13. Shareholders

FACT shall be committed to shareholder value and

comply with all laws/rules/regulations/directives that
govern and protect the rights and interest of
shareholders.

The Board of Directors shall inform the shareholders

about all relevant aspects of the Company’s
business and disclose such information in
accordance with the respective laws/regulations and
agreements.
14. Corporate Opportunities

All members of the Board/Officers of FACT have a

duty to provide to the Company the benefits of the
opportunities discovered through the use of
Company resources and in the course of
employment. All Directors and Officers are prohibited
from taking for themselves, opportunities that are
discovered by using the properties of the Company
or through the information or positions they occupy.

15. Health and Safety

FACT is committed to maintaining the work

environment safe and secure and healthy for its
employees and others. The Company complies with
all applicable laws and regulations relating to safety
and health in the work place. It is expected that
everyone should promote a positive working
environment for all. Any unsafe or hazardous
conditions or materials, injuries and accidents
connected with the business should be reported. All
kinds of threats or acts of physical violence or
intimidation are prohibited.

16. Compliance with Law

It is the policy of FACT to comply with all applicable

laws including laws on employment, health, safety
and environmental laws. Every Directors and
Officers of FACT is expected to comply with all such
laws, rules and regulations. Transactions directly or
indirectly involving securities of the Company should
not be undertaken without prior clearance from the
 Competent Authorities. All Directors/Officers should
consult legal department of the Company before
taking any legal action for and on behalf of the
Company.

17. No Rights created

This code is a statement of the fundamental

principles and key policies and proceedings that
govern the conduct of business of FACT. It is not
intended to, and does not, in any way, constitute an
employment contract or an assurance of continued
employment or create any right in any Employee,
Directors, Client and other stakeholders of the
Company.

18. Compliance with Code of Conduct

All Members of the Board and Officers of the

Company shall comply with the provisions of this
Code of ethics and any violation will attract
disciplinary action as deemed fit by the Chairman
and Managing Director of the Company. If any
Director or Officer knows or suspects violation of this
code of conduct, he/she must immediately report the
same to the Board of Directors or Chairman and
Managing Director of the Company.

19. Interpretation of Code

Any question or interpretation under this code of

conduct will be decided by the Board of Directors of
the Company and the decision of the Board will be
final and binding to all.
 SUBMITTED BY

[T.Y.B.COM. BANKING &

INSURANCE]

BHOKSE ARATI 04

BHOSLE ANITA 05

CHAVAN SHAKTI 06

NAAZ MALLICK 25

TELWANE PRACHI 53

VEDRE SHITAL 55
ACKNOWLEDGEMENT
 The college faculty, classmates, & the most atmospheres in the
college were all the favorable contribution factor right from the point
when the topic for the report was to be selected till the final copy was
prepared.

It was very enriching experience through out the contribution from

the following individuals in a particular made sure that the project took its
shape in the form in which it appears today. I feel privileged to tack this
opportunity to put on record my gratitude towards them.

Prof. Miss. T.P.GHULE vice principal of our college has always

seen an inspiring & driving force.

Prof. Mr. Madhuri Khot made sure that the resources was mad
available in time & also for immediate advice & guidance through out
making this project.

I am thankful to Mr. Santosh shined associated with

administration part of BANKING &INSURANCE section has been very
helpful in mashie the infrastructure available for data en try.

INDEX
SR.NO. PARTICULARS

1. INTRODUCTION

2. DEFINATION

3. Examples

4. CODE OF BUSINESS CONDUCT AND

ETHICS
5.
The Aim, Objectives and Code of Conduct
6.
FACT CODE OF BUSINESS CONDUCT
7.
AND ETHICS