The Code of Conduct applies to everyone at CCL, regardless of their individual role, position or practice or the terms & conditions of their employment, including Board of Directors, Interns, Trainees, and Third-party Contractors working  in CCL premises {collectively referred to as Employee(s)}.

• The employee has a duty to conduct themselves in accordance with this Code, and therefore to keep themselves informed of its provisions and any amendments.
• The employees of the organization shall be expected to comply with all applicable government and local laws, rules, and regulations.
• Breach of code may result in disciplinary action, up to and including termination of employment.
• CCL safeguards all employees with a means to confidentially, and either anonymously or on a disclosed basis, report an activity that may involve unethical or illegal behavior that is in violation of professional standards or otherwise inconsistent with the CCL Code of Conduct. All reports received will be given careful attention by CCL and can be made directly to the HR Department or emailed at sayit@cclpharma.com.

Our Code of Conduct is organized into nine (9) categories outlining guidelines that should be used by everyone at CCL to steer behavior across all areas:

Protection of Data, Information and Intellectual Capital

• The protection of confidential, sensitive, and proprietary information is of critical importance to CCL, its work force, and its customers.
• It is therefore essential that all employees take steps to safeguard such information. Employees must not use any confidential, sensitive, or proprietary information of CCL in any manner that is unauthorized or detrimental to the best interests of the organization.

Conflict of Interest

All employees and members of the board of directors are expected to use good judgment, to adhere to high ethical standards, and to act in such a manner as to avoid any actual or potential conflict of interest.  A conflict of interest occurs when the personal, professional, or business interests of an employee or board member conflict with the interests of CCL. For the purpose of defining a conflict of interest, own/private interest can also include those of family, friends or associates, clients and partners.

Types of conflicts of interest:

Actual conflict of interest: involves a direct conflict between an employee’s current duties and responsibilities and their existing own/private interests.

Potential conflict of interest: arises when a employee has own/private interests that could interfere with their official duties in the future.

The obligation to disclose a conflict of interest may arise in a range of circumstances and it is important to be mindful of such situations and in turn, the obligation to disclose any conflict of interest. Consideration of whether a conflict of interest exists may be subject to factors such as, but not limited to:

• Undertaking secondary employment
• Financial and economic interests such as debts or assets
• Enmity towards or competition with another individual or group
• Significant family or other relationships with clients, partners, contractors or other employees working in the same group.
• In day-to-day responsibilities at Organization, this may affect employees
• As a member of a tender selection / procurement panel
• As a member of a recruitment/interview panel
• In the determination of new partnership
• General decision making

Similarly, other persons or employees who interact or have dealings with Organization must disclose any conflicts of interest as they arise. In this way, all employees and any person giving advice/consultancy to CCL must disclose pecuniary interests.

Substance Abuse

• CCL is committed to provide its employees a safe and healthy workplace that is free from alcohol and drug usage and effectively deal with any abuse at work place under the influence of alcohol or drug or both.
• This applies, at the workplace, to all employees of Organization and also includes visitors, Consultants, Contractors and others, directly or indirectly working for Organization, inside and outside of normal scheduled working hours.

Gifts

• All CCL employees must ensure that gifts and hospitality must be given and received in a responsible manner in accordance with the approved limits given as per Gifts policy.
• It is of utmost importance for the employees that hospitality and other business courtesies may be appropriate to foster goodwill, but never be used to influence employees or a customer’s business decision or undermine the integrity of our business relationships.

Representation of Organization

• Being an employee of the Organization shall not automatically entail a right to act on behalf of the Organization. It shall also pertain to the right to make statements to the press or to any other persons or body on behalf of the Organization. No employee will communicate on behalf of the Organization to the media, including social media, without a prior written permission from the OpCo Head/ CEO/ Chairman on a specific brief.
• Employees shall not be permitted to use Organization’s letterheads and stationery for personal correspondence or in connection with activities not related to the Organization’s business.

Anti-Bribery

• CCL strictly prohibits any gift, payment or other benefit (such as hospitality, kickbacks, a job offer/work placement or investment opportunities) offered or received, in order to secure an advantage (whether personal or business-related).
• A bribe need not have been paid or received; it is enough that it is asked for or offered.
• Employees must never offer, promise or give any gift, payment or other benefit to any person (directly or indirectly), to induce or reward improper conduct or improperly influence, or intend to improperly influence, any decision by any person to our advantage
• Employees must never ask for or accept, agree to accept or receive any gift, payment or other advantage from any person (directly or indirectly) as a reward or inducement for improper conduct or which influences, or gives the impression that it is improperly intended to improperly influence, decisions of the organization.

Whistle Blower Policy

• All employees share in the responsibility for the prevention and detection of fraud in their areas of work and are required to report suspected frauds coming to their notice. Any employee who suspects fraudulent activity must immediately notify his/her Department Head/Group Head or those responsible for investigations. In situations where the Department Head/Group Head is suspected of involvement in the fraudulent activity, the matter should be notified to the next highest level of supervision, or an employee immediately needs to blow the whistle according to the process and procedure in place.
• The Board of Directors, Senior Management and Heads of Departments are responsible for ensuring that a sound system of internal control is maintained, and business is conducted in accordance with the defined parameters.
• The identity of the whistle-blower will be kept confidential and it will be ensured that no harm occurs to the whistle-blower by virtue of his/her act of blowing the whistle. However, this channel must not be used for personal grudges or intentions.

Diversity, Equity & Inclusion

• CCL and all its OpCos are committed to workforce diversity, creating equity across our systems and fostering/ advancing a culture of inclusion.
• CCL is committed to cultivating an inclusive environment in the workplace with no tolerance to discrimination regardless of religion, race, ethnicity, origin, language, gender, age, sexual orientation, disability, socioeconomic, educational, and professional backgrounds.
• The policy is applicable, but not limited, to our practices and policies on talent acquisition, rewards, learning and development, promotions, transfers, social and recreational programs, employee lifecycle, and ongoing development of a work environment built on the premise of gender, diversity & equity.
• Overall, inclusion at CCL involves leveraging and harnessing the differences in the workforce to create an environment in which people feel they are valued for who they are and have a sense of belonging in the company.

Workplace Harassment and Bullying

• All CCL employees must treat everyone—team members, customers, business partners and other stakeholders—with dignity and respect. CCL promotes a safe and respectful environment without the distractions and disruptions caused by offensive, unprofessional or inappropriate behavior in the workplace.
• CCL prohibits harassment on the basis of sex, race, color, religion, age, national origin, disability or any other factor.
• Harassment is prohibited, both in the workplace and off the premises, including at social activities conducted or sponsored by the Organization.
• Harassment may include, but is not limited to, verbal abuse, ridicule, including slurs, epithets, and stereotyping, offensive jokes and comments; threatening, intimidating, or hostile acts; and displaying or distributing offensive materials, writings, graffiti, or pictures.
• Harassment of or discrimination against, employees in connection with their work by another member will be a direct a violation of this policy. Any member who experiences or observes any harassment or discrimination against a member by anyone should report such harassment to their supervisor or departmental Head/HRBP.
• All aspects of workplace bullying is completely unacceptable. Bullying includes, but is not limited to, any form of sexual, verbal, non-verbal and physical behavior which is abusive, humiliating or intimidating. Such behaviors are unacceptable in any other way, they must be reported to relevant stakeholders.

Sexual Harassment

• Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when submission to such conduct is made either explicitly or implicitly.
• Sexual harassment may include, but is not limited to, intentional physical conduct that is sexual in nature, such as touching, pinching, patting; sexually oriented gestures, noises, remarks, jokes, or comments about a person’s sexuality or sexual experience; repeated unwelcome requests for a romantic relationship; and displaying pictures, posters, calendars, graffiti, objects, promotional materials, reading materials or other materials that are sexually suggestive, sexually demeaning or pornographic. Basing an employment decision or implying that it will be based on an employee’s submission to or rejection of sexual overtures is sexual harassment.

Misconduct involves contravention of the above obligations. Serious misconduct involves serious and/ or repeated contravention of the above obligations.

• If established, misconduct may lead to a reprimand and warning. In case of serious misconduct, if established, will lead to dismissal i.e., dismissal without notice or organization reserves the right to take any legal action as per law of the state.

The following are some specific examples of the types of unsatisfactory behaviors which may constitute misconduct and could lead to a formal warning, a final warning, or dismissal following the due process.

• The list below is not intended to be exhaustive or to imply that there shall be no other cases of dishonesty and/ or misconduct which warrant or may result in disciplinary action, up to and including removal form service, being taken in the matter dismissal. These examples are not listed in any particular order:
• Demonstrating behavior against CCL values
• Defaming CCL and its employees across various platforms and mediums
• Negligence or carelessness in the performance of duty
• Being habitually late or absent without permission
• Leaving the job without permission or conducting personal affairs at work without authorization
• Committing any act or omission that could affect the safety of others
• Disturbing the performance of other employees during the work hours through acts including but not limited to personal telephone calls, solicitations/ gambling, mobile phone etiquettes etc.
• Eating, drinking or smoking in times or places not permitted. Smoking is prohibited in building premises including indoor and outdoor areas, except the designated smoking areas
• Failing to give a superior sufficient time to arrange a replacement when unable to attend work as scheduled
• Failing to meet specific performance targets outlined by CCL
• Failure to show a serious attitude or lack of diligence in carrying out work
• Accessing restricted areas, property or records, or removing CCL/other employee’s property without proper authorization
• Impairment in the performance of duties due to the consumption of alcohol or other drugs or substances
• Absence from duty or place of work without proper reason or authorization
• Failure to comply with management’s instruction
• Using profane, obscene, vile or abusive language while on duty
• Bringing in weapons or using any object as an implement of a weapon
• Committing any act on or off the job that will bring bad repute to CCL
• Unauthorized use of CCL letterhead or logo
• Making unauthorized commitments on behalf of CCL
• Attitude of misbehavior directed across employees, this is applicable across gender, religion, ethnicity etc.
• Failure to declare a reasonably foreseeable conflict of interest
• Willful misuse, mistreatment, or otherwise not taking reasonable care of property
• The employee should comply with lawful requirements to declare membership of, or association with, organizations that could detract from his or her position or proper performance of his or her duties.

• This policy is subject to change at the Organization’s discretion.
• CCL Chairman authority shall maintain the right to approve/decide on any conditions/ circumstances and/ or exceptions outside the conditions stated in this policy in the best interest of the Organization.