The Absolute People Screen assurance is to put in place best-in-class governance to ensure Quality, Capability & Continuity
Code of Conduct
Our guide to earning respect and trust
I pledge to uphold our reputation at all times
Our own reputation is our priceless asset. It leads our clients and business partners to do business with us, our shareholders to invest in us, and the best talent to join us in working for our firm. By following the high standards of business ethics set forth in this code, we each protect and maintain this reputation.
I will uphold these standards in all of my dealings with my colleagues and our stakeholders— including our clients, shareholders and business partners
I commit to the Absolute People Screen code
I understand that no waivers or exceptions to the Absolute People Screen Code will be made under any circumstances for anyone working on Absolute People Screen’s behalf, regardless of job function or role. To maintain the highest standards of integrity, I will dedicate myself to the pursuit of the Absolute People Screen Code.
If I fail to do so, disciplinary action that may include termination of my contract with the firm may be initiated against me.
My moral compass will be my guide
I will, at all times, work towards protecting and enhancing the reputation of the firm. The Absolute People Screen Code and other available guidelines point to the requirements for me to follow in my day-to-day activities. However, I recognise that, not every situation will be covered by them. I will therefore rely on my own good judgment, my own internal moral compass. When faced with a difficult ethical decision, I will ask myself the following questions:
Is my decision consistent with my firm’s values & beliefs?
Am I setting a good example for those I work with?
Would the firm lose its clients if they knew I did this?
How would I feel if my action were to be reported on the front page of a local newspaper?
Would I be comfortable explaining my action to my immediate family and friends?
I commit to my colleagues
Lead by example : I will always exhibit the highest standard of integrity in all dealings with colleagues, clients, business partners and the community at large. I will demonstrate my personal support and commitment to ethics and the highest standards of integrity that the firm stands for. I will exhibit ethical leadership that includes fostering a working environment that encourages people to voice concerns and seek assistance if faced with potentially compromising situations. Regardless of any pressure that I may encounter in any such situation, I shall carefully consider the situation by (i) gathering and analysing all facts, (ii) consider the interests of all persons who may be affected by any decision taken by me, (iii) check all applicable laws as well as the Absolute People Screen Code, (iv) consult any of the firm’s persons who are authorised in this behalf, and (v) do what is right in the said situation, after considering all of the aforesaid factors.
Respect others : I will treat my colleagues and anyone I interact with on behalf of the firm with respect, decency and dignity. I will show compassion and empathy towards my colleagues across all my interactions. I will give respect to get respect. In difficult and trying situations, I will conduct myself with emotional poise, dignity and patience.
Equal opportunity: A mix of people enriches the firm and is essential to creativity and business growth. I will support my firm’s commitment to diversity and equal employment opportunity by ensuring that all decisions pertaining to employment, career growth and treatment of individuals is based on job-related qualifications and without regard to race, ethnicity, caste, gender, disability, religion, sexual orientation, marital status, citizenship, age, political or other opinion or any other legally protected status.
High performance: I will abide-by, champion and contribute to our high-performing culture by always raising the bar of service quality, service experience by adopting best-in-class systems and processes. I will be reliable and dependable in things I say and commit to do. Being result oriented is important and I will make no excuses for my shortcomings, instead work hard to excel at everything I do.
No harassment : I will promote a work environment free from harassment. “Harassment” includes offensive and inappropriate behaviour – physical, non-verbal or verbal, sexual or otherwise, done in person or by other indirect means (including harassing notes or emails) – that interferes with another’s work environment or that has the purpose or effect of creating an offensive, intimidating or hostile work environment. I understand that harassment of any sort towards women, is not only prohibited under the Absolute People Screen Code and the Absolute People Screen Prevention of Sexual Harassment at Workplace Policy but also under the applicable laws in India and I especially undertake to abide by such laws in addition to the Absolute People Screen Code and the Absolute People Screen Prevention of Sexual Harassment at Workplace Policy. I further understand that in the event of any violation of the Absolute People Screen Prevention of Sexual Harassment at Workplace Policy and such laws on my part, I will be duly prosecuted for the same in accordance with the Absolute People Screen Prevention of Sexual Harassment at Workplace Policy and applicable laws and the firm will not be liable for any of my aforesaid actions.
No violence : I will never engage in or tolerate any form of violence. “Violence” includes threats or acts of violence, intimidation of others or attempts to instil fear in others, either through verbal, non- verbal, direct or indirect means.
Safe and healthy workplace : I will meet my commitment to maintain a safe & healthy work place by following the firm’s safety and security procedures, as well as applicable laws and regulations.
No substance abuse : I will conduct business free from the influence of any substance that could impair my work performance. This includes alcohol, illegal drugs, controlled substances and, in certain instances, prescription medication. I will never sell, manufacture or distribute illegal drugs in my workplace. I commit to my clients & business partners
Honesty & ; integrity: I will make only complete, factual and truthful statements about our firms and its products and services. I will never make disparaging remarks about our clients and competitors. This applies to all statements and remarks made by me not only on the firm’s premises and firm-sponsored business and social events but also offsite.
Accepting or giving gifts : I will never solicit, accept or give gifts that may influence business decisions. I will be cautious when giving gifts or entertainment to, or accepting gifts or entertainment from, anyone who does or seeks to do business with our firm. I will never accept or offer gifts that are cash or monetary equivalents, such as gift cards or vouchers; objects that have significant value, or may appear significant to others or indicative of preferential treatment. In addition, I will never accept or offer entertainment that is excessive in value or not related to business. I will never offer gifts, entertainment or any kind of favours to government officials with whom we do business or are seeking to do business. I understand that giving of gifts, entertainment
or any favours of a certain kind and value to any third party, including government officials, is not only prohibited under the Absolute People Screen Code but also under the applicable laws in India and I especially undertake to abide by such laws in addition to the Absolute People Screen Code. I may accept business-related meals, entertainment, token gifts or favours, including those which are customary on festivals, that do not have significant value, do not create a real or apparent sense of obligation and are useful for the purpose of maintaining appropriate business relationships. I understand that this also applies to any gifts and entertainment given to my family members or a charity I support.
Clear & regular communication : I will keep the lines of communication free and clear and provide clients and business partners’ timely information on decisions that will affect their business.
Engaged with partners : I will demonstrate the quality of delivery that is expected at Absolute People Screen before I state my expectations of my business partners. I will actively involve the partners in all discussions about the services that they are helping to produce. I will attempt to leverage partners to make a valuable contribution to the decision-making process when it involves their area of expertise.
Honour commitments : I will exercise sound judgment when making commitments so as not to promise more than I am capable to deliver, and then ensure the necessary follow-through to deliver on promises, agreements, and other undertakings. I understand that I am also expected to ensure delivery of commitments made to Absolute People Screen by third parties.
Superior service experience: I have a personal responsibility to make sure that clients experience the highest levels of service quality and see us as committed to their success as they are. I will make genuine attempts to know my clients and business partners beyond just a transactional work relationship and will invest personal time in building a long-lasting partnership. I commit to myself
No abuse of position: I will make all my decisions free from any conflict of interest. I will not use my position with the firm or information I have acquired during employment in a way that creates a conflict between my personal interests and the interests of the firm or its clients. I understand that these guidelines also apply to members of my “immediate family” which includes spouses, domestic partners, parents, children, siblings, grandparents, grandchildren, in-laws, step-relatives, aunts, uncles and other significant relationships.
Non conflict in outside positions : I will not accept employment from or otherwise provide services (including consultancy) to any service provider, business partner or competitor of the firm without prior approval of the Founding Managing Partner. A conflict of interest may also exist if any member of my immediate family is employed by the firm’s competitors, business partners or service providers. I will promptly disclose any such situations to the Founding Managing Partner as they arise.
Non conflict in employment of relatives: If I need to hire or engage an immediate family member, or his or her firm, to provide goods or services to our firm, I will first disclose the circumstances to the Founding Managing Partner. In addition, if I am involved in the hiring process, I will consult Human Resources before proceeding. In order to avoid conflicts of interest, including the appearance of favouritism, I will not work directly for, work in the same chain of command as, supervise or make employment decisions about a family member.
Non conflict in business opportunities: I will not accept business opportunities, fees, commissions or other advantageous financial arrangements from a customer, service provider, and competitor or business partner of our firm. In addition, I will not purchase for personal use the goods or services of our firm’s service providers on terms other than those available to the general public or established by the firm’s policy.
Non conflict in outside investments: I will not make or hold a significant investment in a private entity that competes with, does business with or is seeking to do business with our firm without the approval of the Managing Partner.
Fair & transparent financial transactions : I will report all financial transactions accurately, completely, fairly, and in a timely and understandable manner. I will ensure that the data I provide for the preparation of financial statements, regulatory reports and publicly-filed documents complies with all applicable accepted accounting principles and our firm’s internal quality control procedures. I will ensure that there are no omissions, misrepresentations, misstatements and/ or false reporting of any entries or information on my part, in any of the firm’s documents and to any of the firm’s authorised persons/ officials or duly appointed third party agencies. I understand that any such omissions, misrepresentations, misstatements and/ or false reporting of any entries or information on my part, in any of the firm’s documents and to any of the firm’s authorised persons/ officials or duly appointed third party agencies, is not only prohibited under the Absolute People Screen Code but also under the applicable laws in India and I especially undertake to abide by such laws in addition to the Absolute People Screen Code. I further understand that in the event of any violation of such laws on my part, I will suffer civil and/ or criminal liability for the same in accordance with such laws and the firm will not be liable for my aforesaid actions, except where and to the extent it is so provided under such laws.
Frugal spending : I will be frugal and prudent and be guided by the best interests of the firm. I understand that irrespective of my designation or role in the firm, I am responsible for reviewing my expenses to ensure they are appropriate and make business sense.
Legitimate reimbursements : I understand that no payment on behalf of the firm is to be approved or made if any part of it is to be used for any purpose other than that described by the supporting documents. All receipts and disbursements must be fully and accurately described in the books and records of the firm and must be supported by appropriate descriptive documentation. I will request reimbursement for business-related expenses in accordance with their appropriateness and as per the norms of the firm.
Protection of all property : I will protect our firm’s property, which includes all tangible and intangible assets. My firm trusts me to respect and care for its property to the best of my ability, at all times. I will not use any such firm property and information for personal gain either for myself as well as for my immediate family and friends. I will play my part to prevent and halt theft, destruction, misuse, misappropriation, unauthorised sale/ mortgage or donation of any or all of the firm’s property, including physical property, confidential information and intellectual property. I will protect these valuable assets and when I leave the firm, I will return all that is in my possession. Falsification, alteration or substitution of records for the purpose of concealing or aiding such acts is also prohibited.
Protection of client collateral : I will often receive collaterals from client in the course of executing a specific campaign or for conducting a perception audit. These could be T-shirts, mugs, pens, ad films, print ads, product designs etc. I understand that it is my responsibility to handle such items with care and ensure that they are accounted for to the client. I also understand that I cannot ask the client the same for my personal use, for distribution to my colleagues or friends and immediate family.
Confidentiality: I will not disclose confidential information or trade secrets (of the firm or its Clients or Service Providers) to anyone outside our firm, including to immediate family or friends, without a business need. If a business need exists, I will first obtain permission to disclose the information from the Founding Managing Partner and ensure that an appropriate confidentiality or non- disclosure agreement is put in place. I shall refrain from providing any such confidential information to the print and/ or electronic media, other publicity media or any other external agency, except upon being duly authorised for the same by the concerned representative officials of the firm. Confidential information includes all non-public information (e.g. customer and supplier lists, marketing, research, sales, strategic and product development plans, unpublished financial or pricing information and intellectual property like ideas, inventions, trade secrets and other results
of intellectual effort), the disclosure of which may be useful to competitors and/ or harmful to the firm. I understand that access to such Confidential information may also be limited to certain employees/ officials of the firm who have a legitimate need to know such information for the purpose of carrying on their employment in the firm and I undertake to limit such access to such employees/ officials of the firm, where I am so authorised to do so by the firm.
Safety of information: I will not discuss confidential information or trade secrets in places where I can be overheard, such as taxis, elevators, cafeterias and break-rooms, or restaurants. Nor will I communicate or transmit confidential information or trade secrets by non-secure methods, such as cell phones, non-secure email and hotel faxes.
No insider trading: I will not engage in insider trading or tipping. Specifically, I understand that I am not allowed to buy, sell and/ or deal directly or indirectly in shares and related stock market derivatives (“Securities”) of companies that are Absolute People Screen’s clients, either for myself or on behalf of any other person. Further, I am fully aware that I am prohibited from communicating, counselling or procuring directly or indirectly information relating directly or indirectly to a firm that is a client of Absolute People Screen, which information, if published is likely to materially affect the price of that firm’s Securities.
Interaction with media : Only persons, officials or employees authorised by the firm to interact and/ or communicate with the print and electronic media, other publicity media and any other external agency, concerning any matter related to the firm, shall engage in such interaction and/ or communication thereto. I shall refrain from any such interaction/ communication with the print or electronic media, other publicity media or any other external agency, unless so authorised by the firm and only upon consultation with the concerned authorised representatives or officials of the firm in relation to the same. I understand that the firm follows this policy to maintain its reputation as well as consistency in relation to all news and information regarding the firm among the media and public at large.
Compliance with governmental laws, rules and regulations : I shall comply with all applicable governmental laws, rules and regulations. I shall undertake to be aware of and comply with all the legal requirements, as amended from time to time, in relation to my duties and position in the firm and prevent any probable levy of penalties on my office or the firm or on any other employees or departments of the firm due to non-compliance on my part or attempt to mitigate any loss resulting from the same to the best of my abilities.
Competition laws: I shall comply with all applicable anti-trust and competition laws which are designed to promote fair and open competition by prohibiting anti-competitive agreements and any abuse of dominance by dominant players in any market in India. I understand that violation of such laws will result in both civil and criminal penalties on my firm and I shall endeavour to the best of my abilities to ensure that there is no failure on my part in compliance of the same. If I have reason to believe that any person working on our firm’s behalf, may have violated/ been violating such laws, I have a duty to my firm to prevent or correct such person’s aforesaid actions, if I am so authorised by the firm in this behalf, or else promptly report my concerns.
Information Technology (“IT”) Laws : I shall endeavour to always access my firm’s computer and information technology systems (including desktops, laptops, mobile communications, external storage media and computing devices), for business use only. I understand that the firm monitors use of these systems. I further understand that the firm also permits reasonable use of these systems for personal purposes and I undertake to be responsible for using these systems (including e-mail and access to the internet), in accordance with applicable IT laws in India and the firm’s IT policies. I further understand that sending any illegal, sexually, racially or otherwise explicit, abusive, offensive or profane materials is strictly prohibited and subject to several criminal liability under the said laws and that in the event of failure on my part to duly comply with such laws, I shall be liable to be prosecuted in accordance with such laws and the firm will not be liable for my aforesaid actions. I commit to my country
No money laundering: I will actively guard against the use of our firm’s products and services for money laundering and the financing of terrorism. I will take reasonable steps to choose business partners that will not use Absolute People Screen’s brand, products or services to engage in illegal activities.
No bribes: I will not offer or accept any improper payments, gratuities or gifts that are given (or may appear to be given) with the intent to obtain or retain business or secure services.
Environment friendly: I will always operate with respect for the environment by working to minimize any environmental hazards, conserve and protect natural resources, and manage our energy usage. I shall ensure to use the firm’s resources as efficiently as possible and undertake best efforts to minimise wastage of the same.
Political activities independent of the firm : While I am free to participate in political activities, I will only participate in such activities on my own time and at my own expense and never use the firm’s name. I will not allow any campaign or candidate to use any firm funds or assets, including facilities, equipment or trademarks. When the firm provides professional service to a political candidate or a party, I will be guided by my professional responsibilities as a service provider and treat the candidate/party as a client. I will report violations to the Absolute People Screen code immediately
If I think I may have violated the Absolute People Screen Code, I will promptly report my concern to the Director. The firm will consider the fact that I have reported my concerns when determining any appropriate disciplinary action.
If I have reason to believe that any counsellor or any other person working on our firm’s behalf, may have violated/ been violating the Absolute People Screen Code, I have a duty to my colleagues and our firm to prevent or correct such person’s aforesaid actions, if I am so authorised by the firm in this behalf, or else promptly report my concerns. Doing so will help our firm to address issues and prevent future misconduct.
I understand that no one who suspects a violation and reports it in good faith will be subject to retaliation for making such a report. “Good faith” means I have provided all the information which was in my possession and which I believe to be true. In addition, I will not face retaliation due to my participation in an investigation of a report.
I understand that reports of violation of the Absolute People Screen Code will be treated confidentially, to the extent allowed by local law. All reports will be investigated promptly and thoroughly by the appropriate parties. I am expected to participate, when asked, in any investigations of violation of the Absolute People Screen Code. If the persons to whom I report a violation are not responsive, then I must contact the Director or the Founding Managing Partner.
Failure to comply with the Absolute People Screen Code will subject me to disciplinary action that may include termination.