2. Principle 1: Ethical dealings with outside parties and conflicts of interests
A. Dealings with suppliers/ customers
 Employees should not make any payments or provide any gifts of value that will
unfairly influence decisions in the Group’s favour
 Any gift, other than of a token value, received by an employee from outside parties
doing business with the Group, should be declared appropriately
 Employees shall not ordinarily use suppliers of goods and services to the Group for
their personal needs, especially when many such suppliers are easily available

3. B. Dealings with the government/ authorities
 All employees are required to strictly adhere to all applicable laws and regulations in
the discharge of their duties
 Do not make or offer, directly or indirectly, any payment or anything of value to any
authority to influence any action or decision unfairly in your or the Group’s favour
C. Business connections
 Employees shall not have any undisclosed
connections, either direct or indirect, with any
firm, person or organisation doing business with
the Group and with significant competitors

4. D. Press and publicity
It is important that press releases, articles and media interactions are coordinated to
ensure that a uniform image of the Group is presented to the outside world
All press releases (except product advertisements or literature) should be cleared in
advance with the Corporate Affairs department
Ensure that the guidelines provided on dealings with the media are strictly adhered to for
ensuring the presentation of a uniform corporate image. Get prior permission whenever
you represent Sanmar outside the organisation

5. Principle 2: Declaration of relationships
Relationships between employees, however distant, need
to be declared as soon as they are discovered or formed.
Ignorance of relationships up to Level 4 is not acceptable
The group will give lower preference to employing
relatives of employees, unless the relative possesses
specific qualifications or skills that make the person
‘uniquely suitable’ for the position

6. Principle 3: Implement policy 100%
There shall be no exceptions when implementing
Group policies
Do not hunt for loop holes in policies
Ensure that policies are followed consistently in
both letter and spirit

7. Principle 4: Clarity of communication
Ensure that the logic of every decision is clear
When preparing communications, ensure that they convey all facts
Ensure that assumptions behind decisions are adequately documented
Actively seek a second view to facilitate more informed decisions
If a paper is sent through you, then you should be able to defend the
decision or recommendation
Information should be available, as and when required, to authorised
users without having to go through the hierarchy

8. Principle 5: Transparent appraisal systems
Performance has to be evaluated with reference to agreed
targets for the year. The performance of employees is also to
be evaluated for cultural conformity with Sanmar Standards
Under-performing employees will be regularly counselled
and provided feedback to improve their performance

9. Principle 6: Fair compensation and reward policies
Compensation and reward policies should be fully
transparent
Employees are paid a cash based remuneration
package which is fully declared for tax and the Group
will not entertain any individual structuring of
compensation. The Group believes that employees are
paid for their value and they are free to determine their
expense priority based on their individual lifestyles
Vigilance must be consciously exercised to determine
that it is the employee’s value to the organisation that
determines his/her compensation and reward. Personal
ties should be scrupulously kept out of such judgments

10. Principle 7: Protection of proprietary information
Confidential information is to be used solely to
pursue the Group’s business interests, and in the
absence of an express authorisation, should not be
disclosed to anyone during, or subsequent to,
employment with the Group
To ensure the retention of proprietary knowledge
within the Group and its use for specific
applications determined by the management,
employees will be required to sign Secrecy
Agreements, wherever it is deemed necessary

11. Principle 8: Commitment to safety and environment
 Employees have to ensure that all applicable
safety and environment laws and regulations are
adequately complied with
The business of the Group has to be conducted
in accordance with recognised industry standards
on safety, health and environment

12. Principle 9: Policy of non-discrimination and work environment
Merit and job-related criteria should be the sole basis for all employment related
decisions without giving any cognisance whatsoever to an individual’s race, origin,
cultural background, gender, age or religion
Always strive to provide a cohesive work environment free of any bias and usher a
spirit of teamwork and co-ordination amongst colleagues
Ensure that every employee is treated fairly and that professional respect is
maintained at all times
Sexual harassment is offensive and will not be accepted by the Group