Code of Conduct
Dhee Vidhya Guru community is committed to the highest standards of integrity, ethics and responsible business practices.
This Code of Conduct (“Code”) reflects our commitment to all our employees, clients, stakeholders affiliates, consultants, contractors and agents, and the obligations expected from all of our employees, clients, stakeholders affiliates, consultants, contractors and agents (collectively, “affiliates”) It is important that we ask all of our Affiliates to adhere to the minimum standards contained in this Code. Therefore, by entering into a business relationship with us, all affiliates are deemed to have accepted the obligations set out in this Code and agree to comply with it in addition to any of their contractual and other obligations.
We expect our Affiliates to maintain records to evidence their compliance with this Code as any breach of this Code may be considered a material breach of contract by the Affiliates. We reserve the right to audit any Affiliates or their sub-contractors to confirm the obligations set out in this Code are in force.
Compliance with laws and regulations
Affiliates must behave lawfully and ethically at all times. Affiliates must respect and comply with all applicable local and international laws, regulations and relevant industry codes when working with us and in the countries in which they operate.
Financial records
Affiliates must conduct business fairly, transparently and with integrity. Affiliates must maintain fair and accurate books and records, follow applicable invoicing and taxation requirements and comply with lawful and appropriate accounting practices.
Confidentiality and Security
Affiliates must keep information relating to ourselves and our clients strictly confidential and secure. Affiliates must never disclose such information to any third party without our prior written permission or without prior written notice to us when disclosure is required by law, regulation or a court order.
All paper and electronic records must be kept secure, and security measures must be in place to prevent unauthorized access to systems containing our information or that of our clients. Affiliates teams may only access documents and information for which such access has been granted and only for the purposes of carrying out their duties.
Affiliates must have security policies and procedures in place to keep information confidential and secure, and all Affiliates employees, workers and sub-contractors must be educated on such policies and made aware of the importance of confidentiality.
Respecting human rights and treating people with respect
Affiliates must demonstrate a commitment to respecting human rights and protecting the dignity of their employees, workers and sub-contractors.
Affiliates must comply with applicable employment and human rights legislation wherever they operate, including relevant child labour laws and minimum employment age limits. They must have zero tolerance of modern slavery and human trafficking and ensure that no form of modern slavery or human trafficking exists within their supply chain. This includes not engaging with any person or organisation suspected of being involved with, or using any form of, forced, bonded or compulsory labour.
Affiliates must also treat their employees and workers fairly and with respect meaning that, amongst other things, they make their employees and workers aware on what basis they are paid, ensure any overtime is voluntary and that any such overtime is remunerated adequately. All Affiliates’ employees and workers should be employed on a voluntary basis and free to terminate their employment or engagement with reasonable notice and in line with applicable laws and regulations.
As respectful employers, Affiliates must value diversity and protect the health, safety and wellbeing of their employees and workers. They must never discriminate, at any stage of employment, against any individual on the basis of age, gender, race, religion, national origin, sexual orientation, disability, or any other classification protected by applicable law. The protection offered by Affiliates must include the prohibition of abuse of any kind, including physical, verbal, sexual or emotional abuse, inhumane or degrading treatment, corporal punishment, threats, intimidation or any other form of harassment or offensive behavior. Such protections should not only apply to the physical workplace but must include protecting individuals from harassment which may occur in the course of business, for example when employees or workers are attending work-related trips, events or functions.
Health andsafety
Affiliates must comply with all relevant local health and safety laws and regulations and generally offer a work environment that is safe, conducive to good health, and helps prevent accidents, injuries and work-related illnesses.
Anti-bribery, corruption and facilitation payments
We prohibit any form of bribery and corruption in all business dealings, in every country around the world, with both government and private sector parties. We have a zero-tolerance approach to bribery in any form, whether directly or through an agent, intermediary or any Affiliates.
Affiliates must comply with all applicable anti-bribery and corruption laws and regulations in all countries in which they operate. They must not offer, give, receive or request a bribe, whether directly or indirectly, and must take reasonable steps to prevent others (who are acting on their behalf) from doing so.
Affiliates must not offer or give an incentive of any kind to any public official which would cause them to improperly fulfill their function or would be viewed as corrupt activity. They must also implement and operate adequate procedures for employees and workers to comply with applicable anti- corruption laws and regulations.
Facilitation payments are small payments often described as ‘commissions’ or ‘fees’ to expedite or ‘facilitate’ a routine government process. Facilitation payments are bribes and must not be made by Affiliates or permitted by them to be made on our behalf.
Gifts and Hospitality
Gifts and hospitality are sometimes a part of the way we do business. However, safeguards must be respected to ensure that gifts and hospitality offered or received are reasonable and do not cause anyone to act improperly.
Affiliates may provide gifts, entertainment and hospitality to our employees if they serve a bona fide business purpose and are of appropriate value, timing and frequency. However, in accepting or providing such gifts and hospitality, Affiliates must comply with Smentor Solutions’ Business Gifts, Entertainment and Hospitality Policy.
Affiliates must not provide any gifts and hospitality if they are unlawful, excessive, and inappropriate or would cause or could be seen to cause a person to improperly provide a business advantage or perform their function or activities improperly or unlawfully. Affiliates should never give or accept gifts in the form of cash, commissions, precious metals (including gold), lottery tickets or betting tokens, pre- paid charge cards, loans, shares in profit, securities or their equivalent fraud.
Tax evasion, fraud and money laundering
Affiliates must adhere to all international laws, regulations and standards in respect tax evasion, fraud and money laundering.
Data protection
The protection of personal data is of fundamental importance to us and data protection compliance is at the core of our business practices. Where we own and control personal data, we do so by adhering to the following data protection principles which provide that personal data must be:
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processed lawfully, fairly and in a transparent manner;
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collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
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adequate, relevant and limited to what is necessary;
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accurate and, where necessary, kept up to date;
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not kept for longer than is necessary;
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kept safe and secure; and
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Transferred in accordance with the law.
Affiliates must also abide by all of these principles in relation to personal data that they provide to DVG and personal data that they control or own. Affiliates must train their staff, subcontractors and agents so that they too understand the importance of protecting personal data.
Affiliates must maintain robust security policies, standards, practices and controls to protect personal data from internal and external threats. They must only use personal data we provide in accordance with our instructions and applicable legislation. Affiliates must not use, collect, disclose or otherwise process personal data we have provided without first seeking our approval. Affiliates must also only collect and process the personal data necessary to fulfill our agreed objectives, which must be relevant and not excessive.
Affiliates must not disclose any personal data we provide to any third-party processor unless that third party has appropriate security measures and a suitable data processing agreement has been put in place or as otherwise permitted by law.
Environment
We are committed to implementing and maintaining environmentally friendly business practices. We expect our Affiliates to support our commitment by:
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regularly assessing their environmental risks and opportunities in relation to their operations and manage those risks accordingly;
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continuously improving their environmental performance;
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taking action to reduce their carbon footprint;
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managing their business operations to protect the environment; and
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Ensuring compliance, as a minimum, with relevant environmental legislation, permits and other environmental requirements relevant to their sector.
Conflicts of Interest
Conflicts of interest may occur when a transaction takes place between two parties who have a pre- existing relationship (for example, as a related party transaction) or when a party acting on our behalf including an employee, contractor or affiliates has interests that could benefit from the knowledge gained or duties performed for us.
Conflicts of interest are not strictly prohibited, but if not appropriately reported in advance of work starting and managed, they may lead to decisions that are not in the best interests of our business.
We recognize the importance of avoiding, mitigating and managing such conflicts of interest. As such, Affiliates may never take advantage of personal relationships, personal investments or corporate opportunities available to them as a result of their connections or relationships with us or our employees, nor engage in activities that conflict with the interests of any company that is part of our network.
Affiliates must make us aware of any actual or potential conflict of interest with any of our companies or employees as soon as they identify them, so that they can be managed appropriately. Once a potential or actual conflict of interest is identified, the Affiliates should work with their main Smentor Solutions contact and, if appropriate, our Ethics & Compliance and/or Legal teams to agree how to best manage such conflict.
Speak up
Affiliates must raise any actual or potential concerns or suspicions of wrongdoing related to their engagement or relationship with us, including any breaches of the Smentor Solutions Code of Conduct and/or our other internal policies, where known. There are several ways to raise such matters, including with the Affiliates’ Smentor Solutions contact, members of the Human Resources, Legal or Ethics & Compliance teams, or by using our external Speak Up hotline, Safe call.
The individual contacting Safe call should state that the concern relates to Smentor Solutions. Safe call can be contacted by calling the number for the related country. Concerned parties can also contact Safe call via email at speakup@smentors.com or help@smentors.com
Affiliates must support a culture and working environment in which every member must feel empowered to speak up and protect those who do so in good faith.
Affiliates should have their own effective reporting system in place for employees and workers to raise their concerns and must not take or tolerate any form of retaliation or poor treatment against those who have spoken up.
SMENTOR SOLUTIONS
www.dhee.guru
Contacting us
If you have any questions about this Code of Conduct, the practices of this site, or your dealings with this site, please contact us at:
Email: help[at]dhee[dot]guru
Phone Number: +91-78384 82682
This document was last updated on 12th December, 2021.