We are honest and open in our relationships with business partners and third parties, and we expect our business partners and their suppliers to behave in the same way. We honor our commitments and respect the agreements we have entered into. In our business dealings we expect our partners to adhere to business principles consistent with our own.

Corruption includes a wide variety of activities. It is not only about money but also includes other forms of favors, such as nepotism and favoring friendship. We have zero tolerance towards corruption and bribery in any form, whether direct or indirect. We will not offer, promise or give anything of value or an undue advantage to a public official or to any third party to influence such person to act or refrain from acting for the purpose of improperly obtaining a benefit of any kind. This applies regardless of whether the advantage is offered directly or through an intermediary. Consulting and agency arrangements must be in writing, reasonable in amount, and reflect work actually performed.

Business gifts and corporate hospitality can play a positive role in building relationship between parties, provided that they are given in compliances with applicable laws and locally accepted good business practice and cannot reasonably be construed as a bribe so as to secure unfair preferential treatment.

1. The distinction between a gift and a bride is different. A gift is something you can talk about Openly a bride is assumed to involve favors in returns whereas a gift is not. Unsolicited gifts may be given or taken provided that
2. The gifts are small, occasional, customary and usual e.g. advertising and promotional materials.
3. The Gifts are moderate in terms of frequency and quantity.
4. Acceptance of the gift does not violate any applicable law and
5. Gifts should never be given in cash or cash equivalents.

Reasonable business-related entertainment and other corporate hospitality is acceptable when customary. Reasonable hospitality expenses (meals, lodging and entertainment) incurred on behalf of public officials or business associates are generally acceptable if directly related to the promotion, demonstration or explanation of our products or services. In no event can the purpose of any gift, hospitality or other expenditure be to cause the recipient to improperly perform his or her duties. The same principles shall apply if a supplier, service provider or entity seeking to do business with us offers business-related entertainment or other corporate hospitality to a SUNLAC employee. When entertaining our customers, a SUNLAC representative must always be present.

We comply with all applicable competition laws. Our Competition Compliance Policy prohibit discussions, communication, agreements and understandings with a competitor concerning prices, pricing policy, discounts, promotions, terms and conditions of sale, purchases, territorial markets, production costs, distribution, etc. This issue is addressed more in detail in our Competition Compliance Policy .

We only collect and process personal data (i.e. information relating to an identified or identifiable person) of customers, employees and third parties in compliance with applicable laws and regulations and secure that such information is maintained securely.

We follow all laws that apply to prevent money laundering as well as law related to export / import control and anti-terrorism.

Guidelines for Personal Conduct

1. Our contacts with business partners and officials

   SUNLAC uses the persuasion of product and service quality, price and competence. We treat all our business contacts with fairness. The company does not tolerate any influence on, or distortion of, competition through bribery, fraud, industrial espionage, theft or extortion. There shall be no participation in cartel agreements.

2. The contacts of business partners and officials with us

   No attempts by business partners or officials to influence SUNLAC personnel in a dishonest way, will be tolerated. Any attempts to influence personnel shall be reported to a superior.

3. Conduct toward fellow employees

   Employees are expected to show honesty, fairness and respect to one another.SUNLAC does not accept any form of abuse, discrimination or other behavior that co-workers or business partners can interpret as intimidating or derogatory.

1. Respect for human and labor rights

   We support and respect the protection of human rights as defined in the constitution of India on Human Rights and basic labor rights as defined by the government from time to time. No employee is allowed to take any action that violates these human and labor rights principles, either directly or indirectly.

2. Non-Discrimination

   We are committed to an inclusive work culture. We appreciate and recognize that all people are unique and should be respected for their individual abilities and views. We shall only use merit, qualifications and other professional criteria as basis for employee-related decisions, such as recruitment, training, compensation and promotion. In making such decisions, no relevance shall be given to the employee’s gender, age, religion, sexual orientation, political orientation, national or ethnical background, or other similar characteristics. We do not accept any form of discrimination, bullying or harassment, direct or indirect, physical or verbal. This applies particularly sexual harassment by any parties, including superiors, fellow employees, customers or suppliers.

3. Forced and child labor

   We do not accept any form of forced or compulsory labor, or the use of child labor.

The SUNLAC Paints Ltd is expected to make independent decisions on various business issues from time to time,

However, the standards addressed in this Code of Conduct represent the core of SUNLAC’s culture and commitment. Uniform compliance is essential, and every employee is responsible for upholding these principles. All employees are expected to report any suspected or observed violation of the law, of this Code of Conduct or of company policies. Each Employee is also expected to report if he or she is instructed to act or refrain from acting in a way that would lead to a breach. Normally concerns and complaints should be discussed with your superior. If you deem this not to be appropriate, you may address any of your other superiors, HR personnel, the internal controller or another person deemed suitable within the company. The person who receives the report shall forward it to a person that is authorized to take appropriate action to correct the situation.

Failure to comply with or instructing or forcing another employee, supplier or business partner to breach this Policy require immediate corrective measures and, depending on the gravity of the breach and/or lack of corrective action, result in appropriate disciplinary action, up to and including possible dismissal, termination of contract and payment of damages. Certain violations of a criminal nature can also lead to criminal sanctions.

Employees may also report possible violations anonymously by sending an e-mail to hr@sunlacpaints.com or ethics@sunlacpaints.com administered by the board of directors, using an outside e-mail account that does not reveal their name (there are many free services such as Gmail, Yahoo, Outlook, etc.).

Confidentiality will be maintained to the fullest extent possible. Retaliation against any employee who in good faith reports a concern to the company about illegal or unethical conduct will not be tolerated and be subject to disciplinary action. Employees who have questions about a specific situation should ask for advice from his or her superior or by using any of the aforementioned contacts. It is important to speak up and bring concerns into the open so that problems can be resolved quickly before serious harm can occur. It is also a breach of this Code of Conduct to fail to report a violation or suspected violation that employees know about or to refuse to cooperate with the investigation of a suspected violation.