Code of Conduct

Octal Credit Capital Limited  (hereinafter referred to as ‘Octal’) expects the highest possible ethical conduct from its Board Members and Principal Executive Officers. This Code of Conduct contains the policy guidelines and procedures adopted by the Board of Directors of the Company for its most senior financial and executive officers relating to legal and ethical standards for conducting Company business. Full compliance with this Code of Conduct by all concerned is mandatory.

The objective of the Code is to promote honest and ethical conduct and disclose in a transparent manner the values in accordance to which the business of the Company will be conducted. The Board is of the view that the standards should apply to them and to Senior Principal Officers of the Company should be higher than those that are applicable to all employees. Accordingly, compliance with this Code is a condition of employment and service for Senior Principal Officers, and is meant to supplement the general Code of Conduct for all employees.

Code of Business Conduct and Corporate Governance

Our code has traditionally embodied such rules regarding individual and peer responsibilities, as well as responsibilities to our employees, customers, shareholders, the public and other stakeholders, and includes:

● Prohibiting conflicts of interest (including protecting corporate opportunities)
● Protecting confidential and proprietary information of the Company, customers' and vendors'
● Treating Econo’s employees, customers, suppliers and competitors fairly
● Protection and proper use of company’s assets
● Compliance with laws, rules and regulations (including insider trading laws)
● Encouraging the reporting of any unlawful or unethical behavior

Business Ethics

It is essential that we all keep an eye out for possible infringements of Econo's business ethics - whether these infringements occur in dealings with the government or the private sector, and whether they occur because of oversight or intention. Econo’s employees who have knowledge of possible violations should notify the same. To assist employees in the day-to-day protection of our business ethics, we've compiled a list of some areas where breaches may occur:

- Improper or excessive payments of any of the following:
● Questionable payments to agents, consultants, or professionals whose backgrounds haven't been adequately investigated or whose association with Econo would be embarrassing if exposed.
●  Payroll-related expenditures, bonuses, awards, and non-cash gifts given to or by Econo employees without proper approval and adequate documentation.
● Payments made in cash or checks drawn to Cash or Bearer or bank accounts/property titles not in Econo's name.
● Transfers to or deposits in the bank account of an individual, rather than in the account of the company with which we are doing business.
● Billings made higher or lower than normal prices for fees, at a customer's request.

● Payments made for any purpose other than that described in supporting documents.
● Payments made to employees of customers or agencies through intermediary persons or organizations, or that seem to deviate from normal business transactions.
● An employment, consulting, or business relationship between Econo employee and another company, especially in the same or related business.
● Frequent trading (buying and selling over short intervals) in Econo’s shares or the
stock of a company with which we do business.

These are examples of possible infringements that Econo employees need to avoid.

Good work environment

The Company’s vision is based on inspiring and unleashing creative potential in human assets of the Company. This is possible in an environment where we all respect the rights of those around us. In this direction, we endeavour:

a) To treat individuals in all aspects of employment solely on the basis of ability irrespective of race, caste, creed, religion, age, disability, gender, sexual orientation or marital status.
b) Not to tolerate racial, sexual or any other kind of harassment.

Conflicts Of Interest

Conflicts of interest can compromise employees' business ethics. Employees are expected to apply sound judgment to avoid conflicts of interest that could negatively affect Econo or its business.

Safety, Health and Environment

The Company’s vision envisages no compromise in its commitment to safety, health and responsible care for the environment. Health and safety of the people in and around is of paramount importance to the Company.

Company Facilities

No director, senior management and employee shall misuse Company facilities except where such facilities have been provided for personal use either by policy or by specific permission. Even in their use for Company purposes, care shall be exercised to ensure that costs are reasonable and there is no wastage.

Special Ethics Obligations for Employees with Financial Reporting Responsibilities

It is of critical importance that Econo's filings with all Regulatory Authorities be accurate and timely. Depending on their position with Econo, employees may be called upon to provide information to assure that the Company's public reports are complete, fair and understandable. Econo expects all of its personnel to take this responsibility very seriously and to provide prompt and accurate answers to inquiries related to the Company's public disclosure requirements.  The Finance Department bears a special responsibility and play a special role. Thus, the Finance Department is bound by the following Financial Officer Code of Ethics, and by accepting the Code of Business Conduct, each agrees that he or she will:

  • Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.
  • Provide information that is accurate, complete, objective, relevant, timely and understandable to ensure full, fair, accurate, timely, and understandable disclosure in reports and documents that Econo files with, or submits to, government agencies and in other public communications.
  • Comply with all Acts, rules and regulations as may be applicable.
  • Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing one's independent judgment to be subordinated.
  • Respect the confidentiality of information acquired in the course of one's work except when authorized or otherwise legally obligated to disclose. Confidential information acquired in the course of one's work will not be used for personal advantage.
  • Share knowledge and maintain skills important and relevant to stakeholder's needs.
  • Proactively promote and be an example of ethical behavior as a responsible partner among peers, in the work environment and the community.
  • Achieve responsible use of and control over all assets and resources employed or entrusted.
  • Promptly report to the Directors of Internal Compliance and/or the Chairman of the Audit Committee any conduct that the individual believes to be a violation of law or business ethics or of any provision of the Code of Conduct, including any transaction or relationship that reasonably could be expected to give rise to such a conflict.

Laws, Regulations And Government Related Activities

Econo is subject to laws and regulations in India. Violation of governing laws and regulations is both unethical and subjects Econo to significant risk in the form of fines, penalties and damaged reputation. It is expected that each employee will comply with all applicable laws, regulations and corporate policies.

Insider Trading

If an employee has material, non-public information relating to Econo or its business, it is our policy that the employee, the employee's family members, or any entities controlled by the employee or his/her family members, may not buy or sell securities of Econo or engage in any other action to take advantage of, or pass on to others, that information. Transactions that may be necessary or justifiable for independent reasons, including emergency expenditures and transactions planned before the employee learned the material information, are not exceptions. Even the appearance of an improper transaction must be avoided to prevent any potential prosecution of Econo or the individual trader.

Political Contributions

No Econo’s assets--including employees' work time, use of premises, equipment, or direct monetary payments--may be contributed to any political candidate, political actions committees, party, or ballot measure without the permission of the Directors. Of course, employees may participate in any political activities of their choice on an individual basis, with their own money and on their own time.

Confidentiality

Information about the company, which is not publicly available, must be handled with discretion and must not be given to others unless they are employees who need to know it in order to do their job or are third parties who the company has authorised to receive it. 

Amendments and waivers to the Code

From time to time, the Board may amend or waive certain provisions of the Code depending on the legal and other requirements or for a bona fide purpose. Every member of the Board and Senior Management, including those recruits (at the time of joining) will be given a copy of the Code and are required to confirm their compliance of the same in writing. A copy of the Code will also be published on the web site of the Company. This code may, from time to time be extended to other senior officers of the company, as the Board may think fit.