Integral Advisory Services (hereinafter called “Integral”) is committed to conducting its business in accordance with all applicable laws, rules and regulations and the highest ethical standards, and this commitment is embodied in this Code of Professional Conduct.
As bribery and corruption are key concerns for firms doing business in India, this Code clearly defines and spells out acceptable and appropriate standards of behavior for all Integral employees/retainers/advisers etc.
The purpose of this Code of Professional Conduct is to reiterate Integral’s commitment to full compliance by employees/retainers/advisors etc with legislation against bribery and corruption:
• Indian Laws –
o Prevention of Corruption Act
o Prevention of Money Laundering Act,
o Central Vigilance Commission Act
o Lok Ayukta Acts of State Govts etc.
• The Anti-Bribery Act of England & Wales;
• The U.S. Foreign Corrupt Practices Act (“FCPA”);
• Any other local anti-bribery or anti-corruption laws that may be applicable.
In the interest of remaining compliant with the law, the Code shall be reviewed at regular intervals to ensure it remains applicable to the challenges of a dynamic business environment.
For the purposes of this Policy, Associated Persons means anyone who is engaged or paid to represent Integral and includes representatives, intermediaries, introducers, consultants, retainers and advisers or anyone else who acts on behalf of the organization.
This Code is applicable to every employee/retainer/adviser etc of Integral, who must comply with all applicable laws, rules, and other corporate policies.
Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain.
Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage.
Bribery and corruption can take many forms, including the provision or acceptance of:
• Cash payments;
• Political contributions;
• Charitable contributions;
• Gifts, travel, hospitality, and reimbursement of expenses.
Integral personnel and agents are strictly prohibited from offering, paying, promising, or authorizing any payment or other thing of value to any person directly or indirectly through or to a third party for the purpose of (i.e., in exchange for) causing the person to act or fail to act in violation of a legal duty causing the person to abuse or misuse their position or securing an improper advantage, contract or concession for Integral or any other party.
IMPROPER PAYMENT ACTIVITY
To promote compliance with anti-corruption laws in India and other applicable jurisdictions, no IPR personnel shall undertake any improper payment activity in respect of any Indian of foreign official, or a person doing business in the private sector.
Integral personnel must ensure that there is a reasonable relationship between the substance of a transaction and how it is described in the Company’s books and records.
CODE OF PROFESSIONAL CONDUCT
Any inducements offered but not accepted, or promised and never delivered, can come under the ambit of corrupt practices.
Therefore, it is important to categorize certain norms of behavior to ensure that at all times the firm’s employees safeguard public trust in IPR and its reputation.
A. CONDUCT TOWARDS THE PUBLIC
- 1. Shall at all times be familiar with and observe all relevant national, state, local and international law in force, shall have due regard for the public interest and shall not seek to improperly influence the decision-making processes of government, public or international institutions.
- 2. Shall take reasonable steps to ensure that all information supplied, and representations made, by them to third parties is factually accurate and honest.
- 3. Will actively disclose, at the earliest possible opportunity, the identity of clients on whose behalf they are making representations on matters of public policy or decision-making, current or proposed legislation.
- 4. Shall ensure that any financial relationships involved in their professional dealings are legal and ethical. IPR employees, Retainers, Advisors or Consultants will neither offer or give, nor cause a client/employer to offer or give, any inducement or reward, direct or indirect, to any public official or person acting on their account.
- 5. Shall act at all times in a professional, ethical and reasonable manner and shall not bring unreasonable or undue pressure or influence to bear in their activities as public relation and public affairs practitioners. All public officials should, at all times, be treated with courtesy and respect.
B. CONFLICTS OF INTEREST
- 1. An employee’s primary employment obligation is to Integral. Integral’s employees shall avoid entering into any situation in which their personal or financial interests may conflict with those of the organisation. Business decisions and actions must be based on the best interests of the organisation and must not be motivated by personal considerations or relationships.
- 2. Where he/she is a member of a local authority or is appointed by the government to any state or semi-state body, or is engaged by such organisations on a consultancy basis, shall not offer public relation and public affairs consultancy services to third parties in respect of the business or related activities of that authority, body or organisation as well as to related, linked or subsidiary organisations.
- 3. Shall not offer public relation and public affairs consultancy services for financial reward or other inducements and simultaneously be employed in the Public Service or engaged as a full time advisor to government.
- 4. Shall take all necessary steps to ensure that they are properly informed of their clients’ or employers’ relevant concerns and interests and shall at all times properly and honestly represent these interests.
- 5. Shall properly inform clients about any potential conflicts of interest, or of any competing interests arising from their professional practice or other business, family or social associations.
- 6. If it should emerge that an actual conflict of interest exists and it cannot be resolved, the Associated Person must cease to act for that client. Such person may represent such competing interests only:
A. where he/she has obtained the explicit and informed consent of all the parties involved, and;
B. where such person is enabled to act for each of the parties with an equal professionalism and duty of care.
C. ETHICAL PRACTICES
- 1. Have a positive duty in all their professional dealings to maintain full and proper client confidentiality.
- 2. Where he/she forms the opinion that the objectives or activities of his or her client may be unethical, illegal or contrary to good professional practice, including this code of conduct, are required to so advise the client. In circumstances where this advice is not acted upon in the appropriate manner, the member shall forthwith cease to act on behalf of the client in such matters.
- 3. Shall not make improper claims regarding their access to, or influence over, any institution of the national, state or local government, public official or member of the media.
- 4. Shall not knowingly guarantee the achievement of results nor undertake assignments which are beyond the Associated Person’s capabilities.
D. GIFTING & ENTERTAINMENT
- 1. Integral discourages the accepting or giving of gifts if they unduly influence business decision making or cause others to perceive an undue influence.
A. Never personally pay for a gift in order to avoid complying with entity’s code of conduct
B. Never offer/take gifts from any entity involved in a bid or tender with entity.
- 2. Integral never takes any charitable, political or other contribution on behalf of itself, or its employees under any circumstances.
- 3. Bona fide hospitality and promotional, or other business expenditure seeking to improve the image of a commercial organisation, are permissible with approvals from reporting authority and accounted for by expense reports.
- 4. Integral personnel maintains record of any payments received from or made to Integral with adequate supporting documentation; in relation to provision of services by Integral.
DISCIPLINE OR COMPLIANCE
We expect all employees, to adhere to these standards. Any employee who violates the terms of this Policy will be subject to disciplinary action. Any third party agent who violates the terms of this Policy, who knows of and fails to report to Integral management potential violations of this Policy, or who misleads investigators making inquiries into potential violations of this Policy, may have their contracts re-evaluated or terminated.