Company’s Policies

Whistle Blowing Policy

Human Resource Department provides an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistle blowing.

Conflict of Interest Policy

• In case of an actual or potential conflict of interest on the part of a senior management personnel , he should fully and immediately disclose it and should not participate in the decision-making process.
• In case of an actual or potential conflict of interest on the part of an employee he should fully and immediately disclose it.
• In case of an actual or potential conflict of interest on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process.
• A director who has a continuing material conflict of interest should seriously consider resigning from his position.
• Mechanism to detect, determine and resolve any possible conflict of interest between the company and/or its group and their directors, officers and significant shareholders.
• Company/Group: The basic principle to be observed is that a director should not use his position to profit or gain some benefit or advantage for himself and/or his related interests. He should avoid situations that may compromise his impartiality. If an actual or potential conflict of interest may arise on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process. A director who has a continuing material conflict of interest should seriously consider resigning from his position. A conflict of interest shall be considered material if the director’s personal or business interest is antagonistic to that of the Corporation, or stands to acquire or gain financial advantage at the expense of the Corporation.

Insider Trading Policy

Respect for Trade Secrets/Use of Nonpublic Information

• Board members are reminded not to disclose any confidential, proprietary or trade secret information without specific written approval by an authorized company representative.
• During employment, no employee shall disclose any confidential, proprietary or trade secret information without specific written approval by an authorized company representative.

Related Party Transactions Policy

• Parent Company: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.
• Joint Ventures: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.
• Subsidiaries: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.
• Entities Under Common Control: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.
• Substantial Stockholders: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.
• Officers including spouse/children/siblings/parents: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.
• Directors including spouse/children/siblings/parents: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.
• Interlocking director relationship of Board of Directors: The Corporation reports and discloses all related party transactions in accordance with the PSE and SEC Disclosure Rules.

Policies on Data Related to Health, Safety and Welfare of Employees including Company Sponsored Training

Performance-enhancing mechanisms for employee participation.

• Company’s policy for its employees’ safety, health, and welfareEmployees are urged to report to their immediate superior or to the General Services Department accidents or any condition or practice which is unsafe, whether or not these result in personal injury or no matter how minor they might seem to be.In order to ensure the promotion of employee health and well-being, the company offers health care benefits covered by the health insurance provider of the Company.Employees are involved in deciding, planning and implementing employee activities and programs such as sports and summer outing events, company parties and employee uniform
• Data relating to health, safety and welfare of its employees.
• Generally all regular employees undergo annual medical check-up with their preferred medical clinic/hospital. There have been no reported work-related accidents or health concerns in the Company.
• Company’s training and development programs for its employees.
• New employees are given orientation on the Company’s policies and procedures. Depending on their work assignment and employee development plans, employees undergo or are sent to specialized training courses.
• Company’s reward/compensation policy that accounts for the performance of the company beyond short-term financial measuresIt is the policy of the company to promote advancement among its employees for consistently exceeding expectations over five (5) years, meeting organizational requirements and facilitating the achievement of long-term corporate goals and objectives. Depending on the performance of the Company and also taking into consideration various qualitative performance parameters such as succession planning and corporate governance, the Board also grants performance bonuses.
• Company procedures for handling complaints by employees concerning illegal (including corruption) and unethical behavior
• Concerns may be raised verbally or in writing to the HRD Head, the Company CEO or to the Chairman of the Nomination and Compensation Committee of the Company’s Board of Directors for complaints concerning the CEO should be raised.
• When raising a concern or complaint, the employee should give the background, the nature of the alleged wrongdoing or a description of the event, relevant dates, reasons for the concern, witnesses and the names of the individual involved.
• If the concern is raised verbally, then the person receiving the information should prepare the outline of the matters raised.Employees are assured that Management shall maintain the confidentiality of all the concerns and complaints raised and the anonymity of the person making the complaint to the fullest extent reasonably practicable within the legitimate needs of law.The HRD Head/monitoring officer shall be responsible for deciding whether there are grounds for proceeding further with the case. Potential action may include a clarification of facts, a more formal investigation conducted by the Senior ManCom or Internal Audit Department, or referral to external auditors or legal consultants. Concerns that fall within the scope of specific procedures shall be referred for consideration under those procedures.
  • The monitoring officer (or the HRD Head/CEO/Chairman of NCC as the case maybe) shall inform the reporting employee in writing within seven (7) working days of the following:
    1. What has been done or how monitoring officer plans to deal with the matter;
    2. An estimate of how long it might take to give a final response;
    3. If an initial inquiry has been made;
    4. If further investigation will take place;
    5. Any further information that may be sought form the employee.
    6. The monitoring officer, subject to legal constraints, will provide the employee with information on the outcome of any investigation.

Data Privacy Policy

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SLI Material Related Party Transactions Policy

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