Code of Conduct for Senior Management and Employees

SP Capital Code of Conduct for Senior Management and Employees

The past decade has seen several exciting changes in India's economic thinking. The liberalized business and legal environment, privatization of the public sector, the globalization of the economy and the resulting freedom and challenges have resulted in a dramatic growth in business and business opportunities, and in the way business is conducted. In this environment, it is imperative to maintain the highest standards of corporate conduct and business principles; we should be concerned not just with maximizing profits and shareholder value, but be equally conscious of responsibilities to each of the stakeholders - employees, business associates and partners, financiers, society and the state.

In its pursuit towards this goal, we, at S.P. Capital Financing Limited (SPC), have always laid emphasis on practices that reaffirm the fundamentals of effective governance; practices that maintain a balance between individual aspirations and corporate goals; practices that underline our core values; and, above all, practices that would result in delivering excellent products and services whilst, at the same time, striving to make the world a better place.

SPC recognizes that there are many aspects of corporate governance, each as important as the other. Ensuring an adequate return to shareholders is one of them. Being transparent in the conduct of business affairs and maintaining the trust and confidence of stakeholders is another facet of corporate governance. Corporate governance is also concerned with the empowerment of employees and the ethics, values and morals of a Company and its employees.

Developing capabilities, identifying opportunities and integrating Corporate Social Responsibility with operations is yet another area that adds to value creation…….. the list could go on. It is for us to ensure that all these are carefully woven together to produce a tapestry of myriad hues that symbolizes strong business relationships, shareholder trust, employee loyalty, respect in the community and excellence in all that we do.

This document is a reminder to each of us of the underlying principles governing the conduct of our businesses. These are, in a manner of speaking, a reaffirmation of the same principles upon which the Rassai group of companies built the edifice that we are all so proud of. It must, however, be borne in mind that this can neither be considered a panacea for all situations, nor an answer to every question.

We believe that adherence to this Code will be yet another journey of a thousand miles that has begun with this one step.

Legal and Other Compliances

We shall conduct our businesses as a responsible corporate citizen and shall follow the applicable legal framework of the country in which we operate by the letter of the law and in spirit. SPC expects all its employees to function in line with this principle.

Since our businesses are spread over multiple locations, a common approach shall be adopted in matters that impact us at more than one location.

The exchange of consideration of whatever nature to overcome difficulties in the operation or implementation of legislation is expressly prohibited.

The past decade has seen several exciting changes in India's economic thinking. The liberalized business and legal environment, privatization of the public sector, the globalization of the economy and the resulting freedom and challenges have resulted in a dramatic growth in business and business opportunities, and in the way business is conducted. In this environment, it is imperative to maintain the highest standards of corporate conduct and business principles; we should be concerned not just with maximizing profits and shareholder value, but be equally conscious of responsibilities to each of the stakeholders - employees, business associates and partners, financiers, society and the state.

In its pursuit towards this goal, we, at S.P. Capital Financing Limited, have always laid emphasis on practices that reaffirm the fundamentals of effective governance; practices that maintain a balance between individual aspirations and corporate goals; practices that underline our core values; and, above all, practices that would result in delivering excellent products and services whilst, at the same time, striving to make the world a better place.

SPC recognizes that there are many aspects of corporate governance, each as important as the other. Ensuring an adequate return to shareholders is one of them. Being transparent in the conduct of business affairs and maintaining the trust and confidence of stakeholders is another facet of corporate governance. Corporate governance is also concerned with the empowerment of employees and the ethics, values and morals of a Company and its employees.

Developing capabilities, identifying opportunities and integrating Corporate Social Responsibility with operations is yet another area that adds to value creation..... the list could go on. It is for us to ensure that all these are carefully woven together to produce a tapestry of myriad hues that symbolizes strong business relationships, shareholder trust, employee loyalty, respect in the community and excellence in all that we do.

This document is a reminder to each of us of the underlying principles governing the conduct of our businesses. These are, in a manner of speaking, a reaffirmation of the same principles upon which the Rassai group of companies built the edifice that we are all so proud of. It must, however, be borne in mind that this can neither be considered a panacea for all situations, nor an answer to every question.

We believe that adherence to this Code will be yet another journey of a thousand miles that has begun with this one step.

S.P Capital Corporate Governance Policies

Good corporate governance begins with a Company's own internal practices and policies. While corporate governance issues are common across organizations, each Company requires governance principles that are unique in their approach.

The principles that will guide our actions and the manner of conducting our businesses will be articulated in the sections that follow. These flow from our commitment to be a moving force in the nation's progress without in any way compromising our core values and our unswerving attachment to business ethics. These principles focus on issues that are considered to be significantly important to the governance process as we, in SPC, see it.

The Board of Directors of SPC has set up a corporate governance Cell reporting to the Chairman of the Board, that will oversee the implementation of these Policies and its compliance. It is also the responsibility of the Cell to review the efficacy of these Policies and suggest amendments to make them responsive to the changing times.

For this initiative to be successful, the guiding principles should be clearly understood and put into practice at every level within the Company. This Code should be adhered to in letter and in spirit. The application of these principles would be governed by internally designed procedures that are unambiguous and clearly understood.

Risk Management Policy will be adhered to in case of any decision involving Risk. Whistle Blower policy is in place and employees can directly report of any incident.

Good governance is, ultimately, the sine qua non for continued growth and prosperity.