Airtel Coc

8/18/2019 Airtel Coc

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CODE OFCONDUCT


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EXPECTATION

From Leadership

Q1)I reported an incident regarding a code o cond!ct "reach "# m#

co$$eag!e to m# manager some time "ac%& '!t it seems that nothing

has "een done& (hat sho!$d I do no*

A1) It may not always be apparent when action has been taken, but since

you are not sure, you may speak again with the manager and if you are still

not satised that anything has been done, you can bring this back to the

Ombudsperson oce. But please rst check with your manager before youescalate it any further. It is also important to remember that not all

complaints are resolved publicly and sometime no action is taken because

the allegation are not substantiated or proven.

Q+)I ha,e came to %no thro!gh m# co$$eag!es that there is an

Om"!ds in,estigation going in o!r department regarding some CoC

,io$ation& -an# peop$e ha,e "een inter,ieed tho!gh no one has

approached me #et& Fran%$#. I am not too %een on getting in,o$,ed

in this mess tho!gh I do %no some acts a"o!t this iss!e& (hat

sho!$d I do*

A+) As a responsible employee, it is epected that you will cooperate with

the investigation process and also volunteer any relevant information that

you may know. !eeping silent is not an option and if you are concerned

about your visibility in the investigation, you can reach out to the

Ombudsperson in condence and seek protection of your identity.


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App$ica"i$it#

Q1) I ha,e a concern that I ant to raise& (hi$e going thro!gh the

code o cond!ct. I rea$i/e that this iss!e has not "een co,ered in the

c!rrent CoC rameor%& (hat sho!$d I do*

A1) "he Bharti #ode of #onduct is indicative and it is not possible to cover

each and every situation. $owever, the guiding principles mentioned in the#o# can certainly help you take the right decision. As employees, we are all

epected to act ethically even in the absence of a stated company policy. If

you need more help, talk to your $uman %esources, reporting manager or

the Ombudsperson oce.

Q+) Is the 'harti Code o Cond!ct app$ica"$e across di0erent

"!siness and co!ntries& Does o!r CoC app$# or$dide*

A+) &es, "he #o# is uniformly applicable across all Bharti Business regardlessof the location. 'i(erences may eist on certain issues due to local

customers, cultures, or laws, $owever, employees must be guided by the

#o# or the local re)uirements * whichever sets the highest standard of

behaviour with respect to that issue.


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AT TE (O23 PLACE

Cond!ct and "eha,ior

Q1) -# manager is a rising star and ,er# good at his or%& e is,er# s!pporti,e o his 4!niors. reards them and has "!i$t a ,er#$o#a$ o$$oing& oe,er. he has a ha"it o ad4!sting sa$es n!m"ers5 re,en!es ,er# inno,ati,e$# s!ch that the act!a$ or% is done "#his 4!niors at his direction& I respect him "!t am !ncomorta"$e ithma%ing ad4!stments in the s#stem to sho "etter than act!a$res!$ts& I am orried a"o!t comp$aining a"o!t him since he is ,er#senior and e$$ regarded "# the $eadership& I am a$so orried that i I manip!$ate the n!m"ers. I ma# get a$$ the "$ame i ca!ght since hisdirections are ,er"a$

A1) Ad+usting sales number has nancial implications for the company. Anymanipulations will be a misrepresentation of facts and impact the accuracyof the numbers and is denitely not allowed. &ou should immediately reachout to your $% anager or skip level anager and eplain your problem.

Q+) -# manager !ses ,er# a"!si,e and co$$o6!ia$ $ang!age to sco$d

me in ront o the entire team i something goes rong and

h!mi$iates me a$$ the time& I am threatened ith termination d!e to

poor perormance i I protest at his "eha,io!r and the !se o harsh

$ang!age to "erate me&

A+) &our manager is engaging in an unprofessional conduct that isintimidating and o(ensive and a breach of the code. -lease raise the matterwith your $% head or skip level manager.

Q7) A co$$eag!e comes to or% at times !nder the in8!ence o a$coho$& e has shared ith me in con9dence a"o!t his persona$iss!es and is 6!ite stressed& e is a good riend and I %no that he


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needs his 4o" and is the so$e earner in his ami$#& I ha,e tried toco!nse$ and he$p him "!t it does not he$p& (hat sho!$d I do*

A7) Being under the inuence of alcohol or drugs in workplace poses a

safety ha/ard and besides lowering the dignity of the oce also causes low

productivity. &our colleague may make mistakes at work that can provecostly for the company since his ught process becomes somewhat impaired if

he is inebriated. &ou should discuss the same with your manager. &our

colleague may be in need of help and support to deal with his issues.

arassment ree and congenia$ or%p$ace

Q1) D!ring a team o!t"o!nd program. some senior team mem"ersgot dr!n% and made $ed gest!res& -!ch to the em"arrassment o a$$. some 4!nior omen co$$eag!es ere coerced to drin% and danceon stage& The ne:t morning. the gro!p as inorma$$# to$d to ignorethe entire incident since it as minor and no one as h!rt&

A1) 'runken and unruly behaviour during outbound programs andcompelling +unior lady colleagues to participate is a breach of the code. Itcannot be dismissed as a minor incident and such incidents in a public placehave anadverse impact on the reputation of the company. It needs to bereported to the Ombudsperson0s oce in condence&

Q+) O,er a #ear ago. I accepted m# "oss;s re6!est to "e a riend onFace "oo% since man# o m# o


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Q7) -# co$$eag!e does not spea% indi e$$ and this is his 9rst or% stint in North India& is manager ridic!$es his accent. $ang!age.dress and ma%es !n o his home ton and mannerisms& At times.other team mem"ers a$so 4oin in the "!$$#ing tho!gh there are a eho either %eep 6!iet or protest mi$d$#& These incidents are not

reported to an#one "!t disc!ssed in the oince "oth the concerned persons are not compan#emp$o#ees and the a$$eged incident too% p$ace o!tside the o


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ina!g!ra$ disco!nt or m# co$$eag!es& Is there an#thing rong in m#

actions*

A1) &es, there is a conict of interest in promoting your family0s business inthe oce since you will be a direct beneciary to this source of income. By

using your designation and authority to solicit admissions, you are likely toput undue inuence and colleagues may feel obliged to admit their childrenin your spouse0s school. &ou are also not allowed to solicit personal businessduring oce hours in the premises.

Q+) 'esides m# 4o" ith 'harti. I a$so he$p m# mother in anins!rance agenc# that is in her name& I do not so$icit "!siness romco$$eag!es and on$# or% or the ins!rance agenc# o!tside o o


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A1) &es, such a relationship is in breach of the company policy onrelationships at the work place since there is a possibility of conict of interest, given the reporting relationship. 8ither or both of you may have tolook for a new assignment within the company or outside. &ou should discussthis with your $% head and decide the net course of action.

Q+) I ha,e heard thro!gh the ohe as reerred "# the CFO. and

hence her re$ationship as neither disc$osed nor %non& -# s%ip

manager discreet$# inormed me a"o!t it and to$d me that the

trainee i$$ "e reporting to me& Is there a pro"$em in this reerence

p$acement*

A7) "he training in itself is not prohibited but the senior leader ought to havedisclosed his relationship to the trainee, and not used the indirect referenceof #6O for getting her placed. :econdly, the trainee cannot be placed underin the same department as her father since this would constitute a conict of interest.

Q=) There is an !rgent printing 4o" that needs to "e de$i,ered ithin,er# sti0 time$ines& Not ha,ing eno!gh time to sco!t aro!nd or agood ,endor or ta%e an# comparati,e 6!otes. I aard theassignment to m# sister@in@$a ho ons a printing agenc#& Is thisan iss!e*

A=) &ou have given the assignment to your relative without disclosing the

relationship, further you have not followed the process for awarding such a


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contract. It is a breach of the #o# and your urgency for bypassing the

process is not an ecuse.

its and entertainmentQ1) A e$$@%non man!act!rer o mo"i$e phones has presented meith + o the $atest mode$s costing IN2 =B to !se& (hen Ihesitated to accept it. he stated that he has gi,en the sets as parto an e,a$!ation program rom indi,id!a$s and he o!$d ,a$!e m#eed"ac% and that o m# spo!se& I am a senior mem"er o themar%eting team and ha,e the a!thorit# to in8!ence an# decision onentering into partnership arrangements or the phones& (hatsho!$d I do*

A1) ;iven your position of authority and inuence, this present appearsmore like a favour in kind 2though masked as an evaluation program3 therebyepecting positive decisions from you in future. &ou should decline any suchgift and notify your manager.

Q+) A ,endor o0ered to passes or a high$# acc$aimed concert

since he as !na"$e to attend& The passes cost IN2 each and I

am ,er# interested in m!sic and o!$d $o,e to attend the concert

tho!gh I o!$d not ha,e paid s!ch s!ms to "!# tic%ets& >ho!$d I

accept the o0er since the tic%ets o!$d go aste i I did not accept&

A+) "here could be many such similar sounding o(ers that may come yourway in work life. "he key point is that these passes are a gift. If they eceedthe permissible monetary value dened in ;ift -olicy, it would be appropriateto decline the o(er, more so since you have stated that you would not havepaid to buy the highly priced tickets

Q7) Its Dia$i and one o m# s!pp$iers has sent me a sma$$ git "o:&Uns!specting. I !nrap the git to 9nd an e:pensi,e si$,er artic$e& Irea$i/e that this s!pp$ier is "idding or a ne tender that I am$oo%ing ater& (hat do I do*

A7) :ince, it is likely that the gift is being given to inuence your businessdecision, the gift should be returned to the supplier.

Q=) 'eing in a "!siness de,e$opment ro$e. I meet a $ot o ind!str#proessiona$s and go,ernment o


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A=) O(ering gifts is a sensitive matter. It is important to be compliant with

our company gift policy as well as run a check on the recipient organi/ation0s

business guidelines to prevent any concerns about improper gifts9 undue

inuence.

DEALIN (IT OTE2>

o,ernment agencies

Q1) The go,ernment reg!$ator has so!ght data rom o!r o


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Q1) I ha,e recent$# 4oined in a mar%eting ro$e o a "!siness di,isionand the compan# is in he process o se$ecting an agenc# orhand$ing the or% or the department& I as the creati,e head o anagenc# that as a competitor to the agenc# that is hand$ing o!racco!nt and I am inc$ined to aard the or% to m# ormer emp$o#er

since I %no that the 6!a$it# o the or% i$$ "e good and de9nite$#"etter than the agenc# that is c!rrent$# in charge o o!r acco!nt&(hat sho!$d I do*

A1) :ince there is a possibility that your personal preferences may inuence

your +udgment while awarding the agency contract, it would be prudent not

to participate in the decision on award of contract.

Q+) I am responsi"$e or netor% ro$$ o!ts in m# region and a diese$s!pp$# ,endor has o0ered his premises in a good $oca$it# on rent at

"e$o the mar%et rates& e sa#s that he on$# ants the premises to"e maintained e$$ and a good tenant. hence the o0er at $oerrates& I need a ho!se or m# ami$# and this one !$9$s a$$ there6!irements inc$!ding m# ho!sing "!dget& >ho!$d I accept theo0er*

A+) :ince the house if being o(ered at below the market rates, there is a

possibility that the same is done to obtain an undue benet, hence you

should not accept the o(er, though it is promising.

-edia and comm!nications

Q1) -# riend or%s or a "!siness dai$#. and has "een chec%ingith me a"o!t the compan#;s reaction to certain ne$# introd!cedgo,ernment po$icies Can I comment*

A1) Only the company spokesperson is allowed to interact with the media.

&ou should clarify that you are not the authori/ed spokesperson of the

organi/ation to comment on such matters in the public domain. &ou can

however o(er to introduce your friend to the #orporate #ommunications

team for appropriate inputs.

Q+) I ha,e "een in,ited to participate as an e:pert on a e$$ %nonTG program& Can I accept the same and participate in the pane$disc!ssion


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A+) :ince you have been invited as an epert, you may participate but after

informing the corporate communications and your direct manager. 'uring

the program, take care to state that the views are personal and make no

comments or views about the company or provide any condentialinformation about the company.

LA( AND 2EULATIONCompetition and comp$iance ith $a

Q1) I represent the compan# at an ind!str# or!m and its mem"ersha,e agreed to share inormation on mar%et share. certain mattersre$ated to pricing. inrastr!ct!re sharing and costs& Can I pro,ides!ch inormation since a$$ the mem"ers ha,e agreed to share theinormation* O!r ind!str# is high$# competiti,e and hence thechances o orming a carte$ or ind!$ge in anti@competiti,e practices

is not high&

A1) :haring information with competitors on market share, costs and pricing

is tricky and is best avoided even in situations that seem innocuous at rst.

&ou snthould consult with the legal department before agreeing to share any

information and further also ensure that you are not comprising the

company0s interest by sharing information that may be used against your

company. It is advisable to refrain from such sharing and collaboration with

competition.

Insider Trading

Q1) -# "rother spends a $ot o time dea$ing ith the share mar%etand recent$# to$d me that he is p$anning to se$$ a$$ his shareho$dingin the compan# since the shares ha,e not mo,ed !p m!ch in the $ast


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? months& I am aare that a ma4or anno!ncement is a"o!t tohappen hich i$$ signi9cant$# raise the 'harti share price& Can Igi,e him some gent$e hints to deer his decision to se$$ the shares*(e $i,e in a 4oint ami$# and m# "rother does not ha,e a permanent 4o"&

A) &ou cannot share any inside information which yet not available publicly.ince he has no ami$# set !p here. hecontin!ed ith the g!est ho!se arrangement in a persona$ capacit#&The g!est ho!se oner recent$# con9ded in me that the 2 eadhas since not paid his sta# and ood "i$$s& It seems the oner has%ept 6!iet "eca!se he has "een promised more "!siness and asa$so concerned a"o!t $osing his "!siness ith the compan# i he

comp$ained or e,en as%ed or pa#ment&& >ho!$d I remain si$ent sinceI ha,e not done an#thing rong and am not s!re hether the g!estho!se oner is te$$ing the tr!th&

A) &es. "he $% $ead is misusing his position and authority for seekingpersonal benet 2free guest house stay3 in lieu of favour to the vendor infuture. In this case, availing services without payment would be considered


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as a #O# violation. "he vendor0s action of not seeking his pending dues fromthe $% $ead is a way of supplicating him for future rewards.

Q+) It is m# 4o" to o"tain consents and appro,a$s rom ,ario!sgo,ernment agencies. a$$ o hich are essentia$ or the "!siness to

!nction& De$a# means e:pense. cost and $oss to the compan# sincesome o the permits ta%e a ,er# $ong time& (e ha,e thereoreengaged a cons!$tant to get some o these appro,a$s since he is a$oca$ person and %nos the processes and a!thorities& Thecons!$tant;s "i$$s indicate a ee o IN2 B. or o"taining the$icense and additiona$$# ser,ice charge o IN2 =. andmisce$$aneo!s charges o IN2 1.& (hi$e appro,ing the "i$$s.there is no c$arit# "rea% !p o misce$$aneo!s e:penses& >ho!$d Iorr# a"o!t this misce$$aneo!s e:pense head*

A) &es. 8penses in ecess of the permit fee and beyond reasonable

overheads could be implying undue facilitation payment, which is a violationof the #O#. Any such act of giving or receiving undue benet in cash or kindwill be deemed as bribery or corruption for the organi/ation even though aconsultant is involved.

Q7) (e need certain appro,a$s rom the $oca$ m!nicipa$it# or righto a# to $a# !ndergro!nd ca"$es& The o


15/20

Q1) I ha,e got a "ig order on the $ast da# o the 9nancia$ #ear "!tthe paperor% remains to "e done and e do not ha,e a orma$p!rchase order& -# manager te$$s me to register this transactionithin the c!rrent 9nancia$ #ear e,en tho!gh it has not "eenorma$ised& (hat do I do*

A1) Any booking of a revenue or epense should be basis the laid downprocess and its date of commencement or closure be recorded in the correcttime period. In case, the necessary documentation is pending, it is incorrectto show the order as received, and such a violation could be deemed as afraud. -lease seek clarity from the 6inancial #ontroller for any suchinstances.

Q+) D!ring an a!dit scr!tin#. the a!ditors ha,e as%ed me or certaindoc!ments pertaining to a partic!$ar transaction& -# manager hashoe,er instr!cted me to dec$are those doc!ments to "e

!na,ai$a"$e& (hat do I do*

A+) Incorrect, misleading or withholding information is a grave #O# violationwith serious conse)uences. >hile insubordination to your reporting manageris incorrect, you have to stand by the company policies over individual +udgement calls. If you are faced with such a situation, do reach out to theOmbuds Oce in condence&

Q7) I ha,e recent$# 4oined the operations team& -# immediate tas% is to do "ac% dated entries in a $edger hich reconci$es the ph#sica$assets at ,ario!s "!siness sites month on month& Loo%ing at the

"ac% $og. it seems that this process had not "een o$$oed or man#months. and is no "eing 6!ic%$# done in ,ie o the orthcominga!dit& I am to$d to or% discreet$# on this e:ercise& D!ring the a!ditscr!tin#. an a!ditor a$%s !pto m# des% and as%s me to hando,erthe $edger that I am or%ing on c!rrent$#& (hat do I do*

A7) &ou cannot refuse to handover documents or withhold any information

from the auditor. >hile you are epected to comply by your manager0s

instructions, cooperation with auditor or any investigating agency is

absolutely important. "herefore, if such a conict arises, talk to your skip

manager or the Ombuds oce.

Protecting compan# assets and propert#

Compan# Assets


16/20

Q1) I am in !rgent need o some cash to pa# m# credit card "i$$s intime so that I do not inc!r high interest charges& The amo!nt isaro!nd IN2 B. and I ha,e an o


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entreprene!ria$ ro$e in a start !p that c$osed don or ant o !nding& It is no 7 months since I 4oined this compan# and I en4o#m# or% "!t ee$ g!i$t# a$$ the time or hiding m# past. especia$$#ater signing the code o cond!ct& (hat sho!$d I do* I ant to %eepm# 4o" and am ear!$ o "eing terminated i I re,ea$ the tr!th no&

A1) It was wrong on your part to make an incorrect statement on your #?about your past eperience and if found out, you are liable to be terminated.If you did not participate in the fraud perpetrated by your previous employer,it is advisable for you to approach your manager and eplain the correctsituation. :ince you volunteered the information on your own, there is achance that the company may not terminate your services though it wouldbe within its rights to do so.

Q+) I recent$# o!nd o!t that m# spo!se or%s or a compan# thatma# "e co!ntereiting o!r prod!cts tho!gh I am not s!re& I ha,e a

do!"$e di$emma since I ma# "e rong and either a#. m# spo!sei$$ "e ad,erse$# a0ected& (hat do I do*

A+) If you have a genuine concern about fraud9counterfeiting, you should

report the same, you will not be penalised even it is established that there is

no fraud. :ince your spouse works for the other company, you should

re)uest that your complaint be treated in condence and your identity not be

revealed to the other company while investigations are on. 6ailure to report a

suspected breach is a #o# violation and hence you must report your

suspicion.

Inte$$ect!a$ Propert# and con9dentia$ inormation

Q1) I am part o the '!siness >trateg# team and ha,e "een or%ingon the "$!e print o "!siness transormation or the ne:t B #ears& Ariend o mine ho or%s or a "!siness maga/ine has as%ed me torite an artic$e on simi$ar $ines& Can I !se m# "!siness strateg#inp!ts or creating this artic$e*

A) 1o, using your organi/ation0s classied information for any use outsidethe company is wrong. &our work on the company strategy is condentialand comes under 4intellectual property5 of the company. Any use9 referencesto the same without prior management approvals will amount to a breach of the #O#.


18/20

Q+) -# e:@co$$eag!e ca$$ed me !p to re6!est that I emai$ her some

doc!ments regarding a compan# po$ic# rameor% that she needs to

set !p in her ne or%p$ace& Can I share these detai$s*

A+) &ou should not provide this information since it is the property of your

organi/ation and condential in nature. &ou e7colleague is also violating herobligation to protect condentiality of her former employment. &ou can

report this matter to your manager for suitable action.

Q7) I ha,e "een ca$$ed or a 4o" inter,ie "# a ri,a$ compan#& Thedesignation and compensation $oo%s ,er# attracti,e and I am %eento ma%e this career mo,e& oe,er. d!ring m# !nctiona$ inter,ie.I am "eing contin!o!s$# as%ed ,er# speci9c detai$s o m# c!rrentpro9$e inc$!ding some ,er# con9dentia$ inormation& I ee$ hesitantto ta$% and ear that m# hesitation to anser i$$ %i$$ m# 4o"

prospects& (hat do I do*

A7) 8very person carries with himself9 herself certain skill sets and functional

competencies that were developed on the +ob. $owever, the data and

information he9 she worked on belongs to the organi/ation and not the

individual. "herefore, divulging any such condential and classied company

information is a breach of the company policies and the #O#. It is unethical

for the hiring company to prod a candidate for information in such a manner.

But it is worse for you since you are a serving employee who is violating the

company norms. And there is no guarantee that you will get the +ob even

after divulging all this information.


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CO--UNIT 2E>PON>I'ILIT

>aet#. hea$th and en,ironment J>E)

Q1) D!e to a $ast min!te "!siness re6!irement. I am re6!ired totra,e$ to De$hi and the tra,e$ des% gi,es me a 8ight that is

sched!$ed to reach Chennai at 11pm in the night& 'eing a $ad#emp$o#ee. I am !ncomorta"$e and see% ear$ier 8ight options "!t amto$d "# that the high cost o tic%ets or the ear$ier 8ights is an iss!e&(hat do I do*

A13 >hile optimi/ing travel costs is important, employee safety is a priority. "he #O# and Bharti0s policies are committed to providing each person a safeand secure work environment, and it is the responsibility of each manager toensure this, particularly for lady employees. -lease raise this concern withyour manager to resolve this matter.

Q+) I ha,e noticed on to occasions that the ca" dri,er ho comesto pic% !s !p or the $ate shit. is accompanied "# an !n%nonperson& I ee$ a $itt$e !nsae or am I o,er reacting*

A+) It is important to raise this observation with the 6acilities team rightaway. 1ever ignore any such observations which can have a potential impacton your or anyone else0s safety and well7being.

Q7) I oten hear a ne team mem"er o mine "oosting a"o!t his

ami$# co$$ection o pisto$s and g!ns& It pro,ides or an interesting

disc!ssion topic and I get a sense that he does this to impress his

co$$eag!es& One da#. I act!a$$# notice him earing a pisto$ ho$ster

!nderneath his 4ac%et& (hen I te$$ him that it;s rong to carr# a

pisto$ to or%. he 4o%es aa# m# misgi,ings& (hat sho!$d I do*


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A7) It0s no laughing matter and should not be treated as such. Bringing any

sort of re arms or ammunition into work place is a security violation. -lease

report this to your manager or the security $ead right away.

Corporate >ocia$ 2esponsi"i$it# JC>2)

Q1) The $oca$ go,ernment programs on po,ert# a$$e,iation need!nding& As the Chie E:ec!ti,e. I am %een to contri"!te a signi9cant"!siness amo!nt to this ca!se& Can I do so*

A) 1o, this is not allowed. Any funding for community initiatives should be inline with the #ompany0s charter on #orporate %esponsibility as approved bythe Board.

Q+) -# ne manager is passionate a"o!t he$ping !nderpri,i$egedchi$dren and is engaged ith man# $oca$ NOs& >he oten ta%es !sand other co$$eag!es ith her hen she goes ,isiting these NOs.and a$so see%s donations rom !s rom time to time& >ince these,isits happen d!ring or%ing ho!rs. she !ses the o

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Airtel Coc