The Code of Business Conduct and Ethics (COBCE) provides the ethical guidelines and expectations for conducting business on behalf of Wipro Enterprises (P) Limited, its subsidiaries and associate companies (“Entities”). These entities are commonly referred to as “Wipro” or “the Company.” The COBCE applies to all employees and members of the Board of Directors of the Company. It also applies to individuals who serve the Company on contract, subcontract, retainer, consultant or any other such basis. Show
The COBCE further applies and covers the extended Wipro family comprising of Suppliers, service providers, external professionals, agents, channel partners (dealers, distributors and others) who serve as an extension of the Company. The extended Wipro family is also expected to adhere to the Company COBCE in equal measure while working for and on behalf of Wipro. How to use the Code of Business Conduct The COBCE is designed to help employees and the extended family members of the Company to understand, recognize and deal with ethical issues which they may face from time to time while working for or on behalf of Company. Wipro’s policy is to comply with all applicable laws and regulations, to be committed to conducting business in an ethical manner and to act with integrity in dealing with our customers, suppliers, partners, competitors, employees and other stakeholders. The COBCE is a guide to help whenever you have questions about ethics or if you are faced with an ethical dilemma. COBCE may not address all the situations which you may encounter and sometimes you may need expert views to understand and interpret the specific aspects dealt with under COBCE. In these situations, consult the Wipro policies (forming part of the Book of Policies) referenced throughout the COBCE. The Book of Policies is available on Wipro’s intranet portals i.e. MyWipro. They provide more detailed information on seeking help. You can also discuss the matter with your manager, Human Resources (HR) or other designated persons mentioned in the COBCE. Employee responsibilities Wipro is made up of thousands of individuals, each with unique perspectives and aspirations. Though we are all different, we all share a common understanding of ethical conduct and more so the importance of “Unyielding Integrity.” Without having unchallengeable reputation for integrity, we would fail with customers and in our own eyes. We must strive to maintain the highest ethical standards. In particular:
Remember: No reason, including the desire to meet business goals, should ever be an excuse for violating laws, regulations and the policies governing COBCE. Q I understand that some leaders at Wipro have a separate code. Is that true, and do they also have to abide by the COBCE? A All Wiproites are governed by the principles and values embodied in the “Spirit of Wipro.” There is no separate code for leaders and they must also abide by the COBCE. Wipro’s Principal Executive Officer and Senior Financial Officers have an additional Code of Ethics to support requirements of complete and accurate financial records and reporting. Q In my country, our local laws differ from some of the standards in the COBCE. What should I do? A Wipro does business in several countries worldwide and we are committed to following the laws and regulations everywhere we operate. Sometimes these laws may vary or conflict with the COBCE. Where they do, the laws of the land will prevail. However, in some situations, COBCE may take a more conservative stand to avoid conflicts with certain other country laws. If you believe local laws conflict with the COBCE or related policies, discuss the issue with your manager or contact the HR manager or Ombudsperson or Legal & Compliance Department for clarification. Q Why are we expected to cooperate with investigations and inquiries? I would rather not get involved. A When the Company conducts an investigation it is because there is the possibility of a breach of our policies or legal requirements. The investigation is necessary to protect individuals, Wipro, and, in some cases, the public. If employees do not cooperate it may be impossible to get all the facts and take the right actions. Also, the investigation will help the Company to initiate course corrections which would help in avoiding repeat violations. Withholding information or knowingly giving false or misleading information or sharing information about an investigation is a serious violation of your duties as an employee and could result in disciplinary action. Notwithstanding the above, choice is always with the employee or any other member of the extended family not to actively participate in investigation and inquiries if one desires to do so. Cooperating with surveys, investigations and inquiries The Company will promptly investigate all credible reports of misconduct. Also, using both internal and external resources, Wipro conducts surveys and audits to assess risks and enhance compliance. All employees are required to cooperate fully and truthfully with designated audit and investigations professionals. Never mislead any investigator and never alter or destroy documents or records in response to an investigation.
Ethical leadership If you are in a leadership position at Wipro, you are also expected to meet the following additional responsibilities:
Q My business unit sets various goals that we are asked to achieve. Sometimes I find that I can achieve some of the goals only if I violate the COBCE. Is this acceptable? A No. While successful businesses set high goals and employees strive to achieve them, you should never violate the COBCE or Wipro’s policies in a quest to achieve your goals. Q I’m a manager and I’m not clear what my obligations are if someone comes to me with an accusation—and what if it involves a senior leader? A No matter who the allegation involves, you must report it without exception. Wipro provides several avenues for reporting concerns. If for any reason you are uncomfortable making a report to a particular person, you may talk to the Ombudsperson. Q I’m a manager. If I observe misconduct in an area not under my supervision, am I still required to report the issue? A Though you are chiefly responsible for personnel under your supervision, all Wiproites are required to report any misconduct they become aware of, and as a leader you are especially obliged to take action. The best approach is to first talk with your manager who oversees the area where the problem is occurring, but if this doesn’t work, or isn’t feasible, you should use other resources listed in the COBCE. Making the right choice Making the right decision is not always easy. There will be times when you will be under pressure or unsure of what to do. Always remember when you have a tough choice to make, you are not alone. Your fellow Wiproites are available to help and you have other resources to turn to including the COBCE. When faced with a tough ethical decision it may help to pause and ask these questions. If you give a negative answer to even one question, consider a different action or seek help
Asking questions and raising concerns In today’s complex business environment, it is inevitable that questions and ethics and compliance concerns will arise. The sooner Wipro leadership knows about possible problems, the sooner they can be addressed. Each one of us is responsible to promptly raise issues or concerns about misconduct. If you become aware of conduct that you believe violates Wipro’s policies, regulations, or the law, talk to your manager. If this seems inappropriate, or if you don’t believe the person to whom you’ve reported your concern has taken appropriate action, you have several additional options:
In addition, if you have a question about a Wipro policy, you can send your query to: [email protected]. You also have the option to use Wipro’s Hotline. To access the Hotline, please visit www.wiproombuds.com. Calls to the Hotline may be made anonymously; however, Wiproites are encouraged to provide their name. Anonymous calls will be considered for further action at the sole discretion of Wipro and anonymous callers may need to provide additional information before an effective investigation can take place. You also have an option to raise your concerns directly to the Chairman of the Audit Committee: [email protected]. No form of retaliatory action will be taken against that employee raising a concern even if the same does not turn out to be true. But in raising the concern the employee is advised to exercise due care to ensure good faith. Q Our manager typically does nothing when concerns about potential misconduct are brought to her attention and I believe she has made things difficult for co-workers who have raised issues. Now I have a problem. A co-worker is doing something that I believe to be ethically wrong. What should I do? A Take action and speak up. You are required to report misconduct. Though raising it with your manager is often the best way to efficiently address a concern, if you do not believe that it is appropriate or do not feel comfortable doing so, you should talk to your manager’s manager, or any of the resources listed in the COBCE. Q. You have actual knowledge that your supervisor has been sexually harassing some employees. You will: A. Raise your concern with your Line 2 Manager, HR and / or the Ombudsperson. As an employee of Wipro, we are duty bound to escalate concerns about Policy violations. Preventing retaliation Managers must listen openly to concerns about misconduct, respond appropriately, and never retaliate against those who raise issues in good faith. Lack of content/expert knowledge could cause anxiety on an employee’s part to believe it to be wrong—that’s fine. It is a violation of our policy and contrary to our values to engage in retaliatory acts against any employee who reports wrongdoing of any type, or any employee who testifies, assists or participates in a proceeding, investigation or hearing relating to allegations of misconduct. Wipro takes claims of retaliation seriously. All such claims will be thoroughly investigated and if substantiated, retaliators will be disciplined up to and including termination. If you believe you have been retaliated against, you should report such action to the Ombudsperson or use any of the reporting methods described in the COBCE. Accountability and discipline Violating relevant laws, regulations, or the COBCE, or expecting or encouraging others to do so, exposes the Company to liability and puts the Company’s reputation at risk. If an ethics or compliance problem does occur, you have an obligation to contact one of the resources listed in the COBCE so that an effective solution can be developed. Wipro will take appropriate disciplinary action including up to termination against any employee, agent, contractor or consultant, whose actions are found to violate these policies or any other policies of Wipro. The Compliance process at Wipro has the oversight of the Board of Directors, Audit Committee and Corporate Compliance Committees comprising of Board Members. Acting in the best interest of our customers, business partners and the publicThe “Spirit of Wipro” enshrines the following principles: –
Wiproites, know that winning and success are only possible if we consistently act in the best interests of our clients, business partners and the public as a responsible corporate citizen with unyielding integrity. Customer relations Our standard Customers purchase our services and products because they trust them. They trust the quality of our services and products, they trust their value, and they trust that we will stand behind what we sell and deliver. We must preserve that trust. Wipro has a fundamental responsibility to ensure that customers have faith in the quality of our services and products. It is the primary responsibility of every employee to make sure that our services and products are consistently of the highest quality. Our responsibilities
Marketing and advertising Advertising is an essential instrument for effective brand building and communicating with customers. We strive to ensure that all advertisements of Wipro’s services and products are done ethically. All product claims and benefits must have been technically substantiated through research and requisite studies. Our advertising must never misrepresent, deceive or be likely to mislead customers. Marketing and advertising of Wipro services and products must be truthful and accurate. False or unsubstantiated claims about competitors’ offerings must never be made. Our advertising, packaging, displays and promotions must always be appropriate and sensitive to the culture of customers and the public in the country in which the advertising is shown, and we will avoid political or religious remarks in advertisements that may be offensive. Protecting customer information Our standard During the course of our business operations, we often have access to personal and business confidential information related to customers and others. While protecting this information may now be a legal requirement, for us at Wipro, data privacy has always been a matter of trust and respect for others. We respect the confidential information of our customers and others. Protecting their privacy and confidentiality is very important to us. Our responsibilities
If you notice a breach of this policy or receive a customer inquiry or complaint about Wipro’s handling of personal information, forward the inquiry or complaint to Security Incident Reporting (SIR) through the Company’s intranet system.
Supplier selection Our standard Wipro’s suppliers make significant contributions to our success. To create an environment where our suppliers have an incentive to work with Wipro, they must be confident that they will be treated lawfully and in an ethical manner. Our policy is to select suppliers and make purchases based on need, quality, service, price and other terms and conditions. We select suppliers through a competitive bid process where all supplier relationships are reduced to writing in appropriate manner. We believe in doing business with suppliers and business partners who embrace and demonstrate high standards of ethical business behaviour and who share our commitment to environmentally sustainable practices and human rights. Wipro will not establish a business relationship with any supplier if its business practices violate local laws and does not comply with our Supplier Code of Conduct. Our responsibilities
Government contracting Wipro’s policy is to comply fully with all laws and regulations that apply to government contracting and transactions. It is also necessary to strictly adhere to all terms and conditions of any contract with central, local, state, federal, foreign or other applicable governments. Wipro’s Legal & Compliance Department must review and approve all contracts with any government entity to confirm this. Further information: Supplier Code of Conduct Conflicts of interest Our standard A conflict of interest occurs whenever you have a competing interest that may interfere with your ability to make an objective decision in the best interests of Wipro. Personal involvement including financial interests or dealings with competitors, clients, managers, subordinate employees or peers of Wipro that has the potential to affect the employee’s ability to exercise judgment in the best interests of Wipro creates an actual or potential conflict of interest. Each of us is expected to use good judgment and avoid situations that can lead to even the appearance of a conflict. Conflicts of interest can undermine the trust others place in us and damage our reputation. It is impossible to describe every potential scenario of conflict, which is why Wipro relies on each of us to uphold the high standard of “Unyielding Integrity” and to seek advice when needed. If you believe a conflict or potential conflict exists, discuss it with your manager, the Legal & Compliance Department or HR. Some examples of conflicts of interest are:
Family member and close personal relationships As a rule, employees must avoid conducting any Wipro business with a relative (which includes a “significant other”) or a business in which a relative is associated in a key role. If such a related-party transaction is unavoidable, the employee must fully disclose the nature of the related-party transaction to his/her HR manager. Members of an employee’s immediate family and those in a close personal relationship may be considered for employment based on their qualifications and they may be hired if such employment would not create manager-subordinate relationship. If a close personal relationship exists or develops between two employees, both employees involved must bring this to the attention of their manager and HR manager. Attempts will be made to find a suitable resolution in the form of job segregation. Personal investments and corporate opportunities Employees may not own, either directly or indirectly, a substantial interest in any business that does or seeks to do business with, or is in competition with Wipro, without written approval of the CFO and General Counsel of Wipro Enterprises (P) Limited. Employees are also prohibited from making personal business or investment opportunities that are discovered during their work at Wipro. Q. You notice frequent financial transactions such as hand loans, joint trades in stock market etc. among your supervisor and team members. You will: A. Report to your Level II supervisor considering it to be a case of conflict of interest and Financial transactions with colleagues brings conflict of interest and adversely impact the professional relationship Outside employment While it is not the intent of Wipro to unduly restrict the activities of employees on their own time, employees may not work for or receive payments for services from any business whether it competes with Wipro’s business or not. A conflict of interest will also arise if an employee opts for outside work, including self-employment or commercial pursuit of hobbies and interests since it will interfere with the employee’s ability to fulfil his or her responsibilities to Wipro. Q Your relative is keen on starting a family business unrelated to Wipro’s business and wants to make you an active partner in the same. What should I do? A Decline to become a partner since active participation in business together with employment would be a case of conflict of interest and Dual engagement while in Wipro’s employment is not permissible. Q. A start-up company into manufacture of personal care products approaches you for technical support and advice in setting up manufacturing operations. The company’s CEO, your friend, says the work you do for him will not affect your work at Wipro. The CEO needs your support only on weekends and holidays. You will: A. Decline the offer as this will result into conflict of interest and will breach Wipro’s COBCE and dual engagement while in Wipro’s employment is not permissible Volunteer or charitable work On a case-by-case basis, employees may be permitted to work for non-profit/not-for-profit organizations, clubs and charitable institutions provided prior disclosure is made to the HR manager. The employee must ensure that the services they provide do not affect Wipro’s interest or reputation. The employee must not accept remuneration for any service rendered except reimbursement of reasonable and customary expenses. Our responsibilities Avoid conflict of interest situations whenever possible.
Gifts, entertainment & business courtesies Our standard In many industries and countries, gifts and entertainment are used to strengthen business relationships. For Wiproites, one principle is always clear: we do not accept or provide gifts, favours, or entertainment if the intent is to influence a business decision. No employee shall give, offer and promise to offer, or authorize the offer, directly or indirectly, of anything of value (such as money, securities, goods or services) to government officials, customers, potential customers, foreign officials including officials of any public international organizations or any other entity which could be regarded as influencing any business decision or obtaining improper advantage. Employees shall neither use business courtesies to attempt to improperly influence the decisions of our customers or other third parties nor provide such courtesies in violation of the law or customer’s internal policies. Gifts, entertainment and business courtesies are only to be offered or accepted if all of the following conditions are met:
Accepting occasional gifts and entertainment may be appropriate when developing business relationships. However, they should never be lavish or in excess of the generally accepted business practices of the country or industry. When accepting gifts, the value shall not exceed our Acceptable Limit, i.e.: US$ 100 or equivalent currency for employees in the United States and Europe, and US$ 50 or equivalent currency for employees in the rest of the world, per financial year. Employees and agents acting on Wipro’s behalf must never offer a gift of any kind to anyone doing business with Wipro or seeking to do business with Wipro that is not within the Acceptable Limit. Standard corporate gifts with the Wipro logo can be offered as an acceptable business practice to private customers provided the conditions mentioned above are met. However, for gifts other than standard corporate gifts, employees are encouraged to refer to the internal Books of Policies for limits and approval matrix. No other manner of gifting is permissible except as specifically set out above. In particular the following are strictly prohibited:
Charitable contributions or donations are permitted only to registered charitable organizations as per internal guidelines and processes. The following types of business courtesies are not permitted: Offering business courtesy
Accepting business courtesy
Our responsibilities
Gifts, entertainment or business courtesies to government officials No gift, entertainment or business courtesy can be offered to or accepted from government officials or foreign officials including officials of public international organizations or government customers (including public sector undertakings and government-run enterprises) either directly or indirectly. Government customers means and include customers operating through state-owned and state-controlled entities in areas such as aerospace and defence manufacturing, banking and finance, healthcare and life sciences, energy and utilities, telecommunications, transportation, etc. including the following:
However, reasonable conveyance or other facilities to government officials is allowed if it is in connection with the performance of their official duties for Wipro, such as their visits to our manufacturing facilities for inspection/audit like the visit of pollution control officials. Q When I was traveling, I received a gift from a supplier that I believe exceeds our Acceptable Limit. What should I do? A If you have received any gift which exceeds the Acceptable Limit, you are required to disclose the receipt of the gift in the Gifts Disclosure Tracker and hand over the gift to the Facilities Management Group of your location. A determination will then be made as to how the gift should be used. Further information: SOP on Gift entertainment & business courtesies Communicating with the public Our standard We are committed to transparency in our disclosures and public communications. Wipro needs a clear, consistent voice when providing information to the public and the media. For this reason, it is important that only authorized persons speak on behalf of the Company. Never give the impression that you are the official spokesperson of the Company in any communication that may become public if you are not authorized to do so. Our responsibilities
Further information: Social Media Guidance and Networking Social media and networking Our standard Social media sites are popular platforms for communication and interaction. Wipro supports the rights of its employees to express themselves freely through social networks, blogs, wikis, chat rooms, comment forums, and other online locales. However, employees must remember to be cautious when such activity involves information about Wipro or may adversely affect the image of Wipro, its customers and business partners. All Wipro employees are expected to conduct themselves professionally in their online activities and to respect and protect the reputation of Wipro, its customers, and business partners. All rules which apply to offline conduct also apply to online comments, postings and other communications. Employees must also bear in mind that unwarranted postings on social media may also result into breach of confidentiality obligations by an employee. Wipro reserves the right to review and monitor the online activities of its employees when they are relevant to the Company, as well as any online communications made using Company resources (computers, phones, tablets, data cards, etc.). If Wipro perceives that such online activity is in violation of Company policies, appropriate investigation and action will be taken. Social networking Be especially careful when writing communications that might be published. This includes postings to the internet. If you participate in online forums, blogs, newsgroups, chat rooms, or bulletin boards, never give the impression that you are speaking on behalf of Wipro unless you are authorized to do so. And before you hit the “Send” button, think carefully and review. These types of communications live forever. Our responsibilities
Further information: Social Media Guidance and Networking Protecting our information and assetsOne of the major concerns in the present information technology era is protection of confidential and personal information that is collected and disseminated. For Wipro, protection of confidential information rests on our pledge to act with sensitivity and to demonstrate respect for the individual. It is simple: when we take action to safeguard confidential information and Company assets that have been entrusted to us, we are delivering on our commitments and living up to the assurances we have made to others. Confidential information Our standard One of our most valuable assets is information pertaining to Wipro or the information of third parties who deals with Wipro. The unauthorized release of confidential information can cause irreparable damage to Wipro in many ways such as to lose a critical competitive advantage, embarrass the Company, damage our relationships with customers and others etc. For these reasons, confidential information must be accessed, stored, and transmitted in a manner consistent with Wipro’s policies and procedures. Each of us must be vigilant to safeguard Wipro’s confidential information as well as third parties’ confidential information that is entrusted to us. We must keep it secure, limit access to those who have a need to know in order to do their job and avoid discussion of confidential information in public areas. The obligation on an employee to preserve Wipro’s confidential information is perpetual and survives the end of employment with Wipro. “Confidential information” includes but is not limited to the following:
Our responsibilities
Q I am unable to complete the submission of Technical and commercial bid document in office. Can I forward the bid related documents through email to my personal email account so that I can continue and complete that work from home? A No. You cannot forward any Wipro or customer information to your personal email account. Doing so will be considered as serious breach of confidentiality. Q I would like to have a backup of all information that I create for Wipro and our customers. I feel the safest and most secure way to preserve them is by using a secure cloud-hosting service. Can I do so? A No. You cannot use any public cloud-hosting service such as Dropbox, SkyDrive, iCloud, Amazon Cloud Drive for back-up or storage of information belonging to Wipro or its customers. You must contact the Information Security team for an appropriate solution. Intellectual property Our standard We have an obligation to identify and protect the intellectual property, trade secrets and other confidential information owned by Wipro, our customers, and business partners. Doing so is critical to our success. Intellectual property or IP refers to business methods, trademarks, service marks, trade names, copyrightable subject matter and trade secrets whether belonging to Wipro or to third parties dealing with Wipro. We must all be aware of and comply with Wipro procedures necessary to safeguard these assets, including complying with any agreement relating to IP and confidentiality agreements signed upon the commencement of or during employment. In addition to protecting Wipro’s own intellectual property rights, Wipro respects the valid intellectual property rights of others. Our responsibilities All employees are responsible for complying with the requirements of software copyright licenses.
Q You developed a patent / design at Wipro but this was not used for any purpose. While leaving Wipro, a colleague advises you to copy and take the intellectual property with you and use it for commercial purposes. You will: A Not take it as the intellectual property rights over the patent / design belongs to Wipro, this is Wipro’s property and cannot be used or carried away for personal purposes Competitive/business intelligence Our standard Information about competitors is a valuable asset in the highly competitive markets in which Wipro operates. When collecting competitive intelligence, Wipro employees and others who are working on our behalf, must always live up to Wipro’s standard of “Unyielding Integrity.” We must never engage in fraud, misrepresentation or deception to obtain information. Nor should we use invasive technology to “spy” on others. Care should be taken when accepting information from third parties. You should know and trust their sources and be sure that the knowledge they provide is not protected by trade-secret laws, or non-disclosure or confidentiality agreements. While Wipro employs former employees of competitors, we recognize and respect the obligations of those employees not to use or disclose the confidential information of their former employers and they must join Wipro by abiding to the principles of “empty pocket declaration”. Our responsibilities
Red flags: Obtaining competitive intelligence
Q One of my team members who recently joined Wipro from a competitor has with him a customer list and price list of the competitor. He says he Plans to use it to Wipro’s advantage. Should I just ignore this? A No. If an employee retains competitor information, this can result in legal action by the competitor. You must promptly report this to the Legal & Compliance Department for appropriate action, which could include collecting lists and destroying them or returning them to the competitor. Q Your colleague has recently joined Wipro from a competitor company. You find that he has brought with him on a pen drive, confidential material of previous company that he says is created by him in his previous employment. He wants to use it at Wipro for company’s benefit. You will. A Report this to your manager or Ombudsperson and this violates Wipro’s policy of confidentiality and hence incorrect Protecting personal information and the privacy of employees Our standard In recent years, individuals, companies and governments have grown increasingly concerned about the privacy and security of personal information. In many countries and cultures around the world, people have deeply held beliefs on the topic and as a result, laws protecting the privacy of personal information and how it may be collected, shared and used are becoming more common. We have a responsibility to protect the confidential and personal information of our fellow Wiproites and others. Our responsibilities
Business records and internal controls our standard Investors, government officials and others need to be able to rely on the accuracy and completeness of our business records. Accurate information is also essential within the Company so that we can make good decisions. Inaccurate records can adversely impact Wipro in many ways, including weakening of our internal controls over financial reporting. Wipro is committed to making full, fair, accurate, timely and understandable disclosure on all material aspects of our business including periodic financial reports that are filed with or submitted to regulatory authorities. Employees with a role in the preparation of our public, financial and regulatory disclosures have a special responsibility in this area, but all of us contribute to the process of recording business results and maintaining documents. Each of us is responsible for helping to ensure the information we record is accurate, complete and maintained consistently with our system of internal controls:
Our responsibilities
Document management and legal holds Each of us is responsible for information and records under our control. We must be familiar with the recordkeeping procedures that apply to our jobs and we are accountable for the accuracy and truthfulness of the records we produce. It is also our responsibility to keep our records organized so that they can be located and retrieved when needed. Documents should never be destroyed in response to or in anticipation of an investigation or audit. Contact the Legal & Compliance Department if there is any doubt about the appropriateness of document destruction. A “legal hold” suspends all document destruction procedures in order to preserve appropriate records under certain circumstances, such as litigation or government investigations. The Legal & Compliance Department determines and identifies what types of Wipro records or documents are required to be placed under a legal hold. Every Wipro employee, agent and contractor must comply with this requirement. The Legal & Compliance Department will notify employees if a legal hold is placed on records for which they are responsible. If employees have any questions about this, they shall contact the Legal & Compliance Department. Safeguarding company assets Our standard To best serve our customers we all have a responsibility to use Wipro’s assets and resources wisely and with care. All employees are responsible for using good judgment to safeguard the tangible and intangible assets of Wipro, and to ensure that our assets are not misused, damaged, lost, stolen or wasted. Company assets include Wipro’s physical facilities, property and equipment, electronic communication devices, intellectual property, confidential information, files and documents, as well as inventory, computer networks, and supplies. Our responsibilities
Our Policy on Password Use The ethical guidance on password sharing under the disciplinary handbook as well as under the COBCE put together prohibits any one or all of the following practices:-
Consequences in the event of violation of policy on Password Use [A] Malafide or Intentional violation After due process of enquiry, if it is established that the violation of the policy happened with the purpose of committing a fraud or any other prohibited act, or if the same employee has had a prior violation, then the concerned employee will face severe penal consequences including but not limited to the termination of employment. [B] Unintentional violation After due process of enquiry, if it is established that the violation of the policy was committed due to negligence or for work related convenience, and it is a first violation for the employee, then the concerned employee will face consequences in the form of suitable warning together with having to provide an undertaking about not repeating the offence in future. Personal use of Wipro’s electronic communication devices may be permitted within the following guidelines: We deliver our work in various roles through devices and assets that Wipro provides. Business Conduct through actions, approach are interlinked to the assets that are provided by the company. Business Conduct is applicable even when we are delivering official work through personal devices (Like Mobile, Tablets). The following are critical to keep in mind as part of the ethical business conduct:-
Additional Guidelines on use of Wipro’s electronic devices
Red flags: Misuse of Wipro assets
Q You find that your team members are regularly sharing the passwords of their laptops, SAP and other secure processes. You will: A Alert your colleagues about our Password Policy and report to Ombudsperson, sharing of passwords is strictly prohibited Following the letter and the spirit of laws and regulationsCompliance with laws, regulations and contractual obligations is the bedrock on which organizations are built. Compliance with the highest order of governance and ethics has been a hallmark of Wipro and will continue to be non-negotiable. We pride ourselves in upholding the “Spirit of Wipro” and we consistently demonstrate our values in our actions. All our actions should pass the Triple Test: Is it legal? Is it ethical? Does it maintain and build our reputation? Anti-trust and fair competition our standard We believe in free and open competition and we never engage in improper practices that may limit competition through illegal and unfair means. We do not enter into agreements with competitors to engage in any anticompetitive behaviour, including setting prices or dividing up customers, suppliers or markets. As Wipro’s business interests are spread across the world, Wipro may be subject to competition laws of various jurisdictions. Most countries have well-developed bodies of law designed to encourage and protect free and fair competition. Wipro is committed to adhering to these laws both in letter and spirit. These laws often regulate Wipro’s relationships with our distributors, resellers, dealers and customers. Our responsibilities
Warning signs: Anti-trust
Q I received sensitive pricing information from one of our competitors. What should I do? A Do not use the information for any purpose. Contact the Legal & Compliance Department without delay and handover the information. Q You and your competitor have bid for a LED lighting order of the State Government and know that the current order that you are competing for will be shared equally with both of you. Your competitor calls you for a meeting to decide on the pricing cartelization to maximize the price on supplies. What should I do? A Refuse the offer of your competitor since it is an unfair trade practice and violates the spirit of competitive bidding and it is incorrect to violate anti competition law for business gains. Anti-corruption Our standard Wipro conducts its business free from the influence of corruption and bribery. Employees and business partners are expected to be aware of and follow all anti-corruption and anti-bribery laws everywhere we do business (including the Prevention of Corruption Act in India, US Foreign Corrupt Practices Act or “FCPA” and the UK Bribery Act). Employees must be careful to avoid even the appearance of offering or accepting an improper payment, bribe or kickback. It is important that intermediaries and third parties who are operating on our behalf shall adhere to the anti-corruption and anti-bribery laws of the country where they operate as well be fully compliant with Wipro set standards. We must exercise due diligence to ensure that their reputation, background and abilities are appropriate and meet our ethical standards. Intermediaries are expected to act in accordance with the requirements set out in this Code. We must never do anything through a third party that we are not allowed to do by ourselves (“Proxy Bribing”). Our responsibilities
Red flags: Anti-corruption
Q Your team member wants to offer gifts in the form of sweets / dry fruit packs / moon-cakes to government officials for a festival or New Year. What should I do? A Advise him not to proceed as this is not permissible under Wipro’s policy and offering gifts violates the anti-bribery policy of Wipro as well the prevailing Anti Bribery laws. Q You wish to engage a lead finder to secure a government contract. You are aware of the fact that the lead finder was involved in a bribery case. What Should I Do? A. Initiate a thorough due diligence about the acquittal of the lead finder from the previous case of bribery scandal before you decide to engage, engaging with such lead finder has potential of breach of anti-bribery laws. Political involvement Our standard Wipro respects the rights of employees to voluntarily participate in the political process which any person as citizen of the country is entitled to. Employees must always make it clear that their views and actions are their own and not those of the Company and employees must never use Wipro resources to support their personal choice of political parties, causes or candidates. Q I’m thinking about running for local political office. Do I need to get approval from the Company? A So long as you are in the employment of Wipro, holding public office will be considered as a case of conflict of interest and hence not permitted. Our responsibilities
Q My brother is contesting for political office and I believe he is an eligible candidate. Can I campaign for him at office among colleagues? A No, you cannot. You must keep this off limits from work at Wipro. Global Trade Our standard Many laws govern the conduct of trade across borders, including laws that are designed to ensure that transactions are not being used for money laundering, others that prohibit companies from illegal trade boycotts, as well as laws regulating exports. We are committed to complying with all such laws that are applicable in the countries in which we operate. Each of us is responsible for knowing the laws that apply to our jobs and seeking expert advice if in doubt about the legality of an action. Our responsibilities
Global trade restrictions and controls Every country place restrictions and controls on how trade must be conducted within and across its borders. Specific regulations and rules apply to customs, imports and exports, technology transfers, as well as how companies should respond to trade boycotts enforced by one set of countries against another. These global trade restrictions apply when we ship products across national borders, but in some cases they also apply when we send data and technological information to colleagues or third parties via email or over the internet. Since laws concerning international trade are complex and are often subject to change, it is important that employees who travel internationally, or who provide services or information across national borders, remain up to date on relevant requirements. If you have any questions, consult with the Legal & Compliance Department. Performance through teamwork and respectAs a global company, we employ individuals and we work with business partners who represent a rich variety of backgrounds, skills and cultures. Combining this wealth of resources creates the diverse and collaborative teams that consistently drive our achievements. To attract and retain talented and dynamic individuals from around the world, it is vital to have a supportive work environment, based on mutual respect. Wipro always encourages and promotes favourable employment conditions and positive relationships between employees and managers, and we encourage open communication and employee development. Living our values helps our Company succeed, and it also creates the setting for each of us to thrive and to reach our full potential. Following are some of the key areas where we must be guided by in our commitment to the “Spirit of Wipro.” Human rights Our standard Wipro prohibits any act of human trafficking, slavery, servitude, and forced or compulsory labour throughout the organization, its business and its supply chain. We support fundamental human rights for all people. We will live up to and champion a commitment to human rights among our employees, business partners and suppliers, and comply with the applicable laws in every country in which we operate. Child labour Wipro will not use, nor do we support others who use child labour. Wipro also recognizes that this evil cannot be eradicated by simply setting up rules or inspections. Towards this end, Wipro is committed to work in a proactive manner to eradicate child labour by actively contributing to the improvement of children’s social situation. Wipro supports the use of legitimate workplace apprenticeships, internships and other similar programmes that comply with all laws and regulations applicable to such programmes. Wipro encourages its suppliers to also work towards a no child-labour policy and we encourage the employment of the parents of such children to secure the existence of the family and the education of the children. Q. You find that one of the workers in the factory canteen is a 13 years old child. What should you do? A. You should raise concern with HR department and factory manager since employment of child labor is strictly prohibited under law, it is our responsibility to ensure compliance to applicable laws not only for Wipro but also for third parties who deal with Wipro Freedom of association Wipro respects the right of employees to exercise their lawful right of free association and we recognize the rights of our employees to choose or not choose to be represented by trade unions. It is Wipro’s expectation that our suppliers would also do the same. Abolition of forced labour Wipro prohibits forced or compulsory labour including prison or bonded labour. We will not tolerate physical punishment or abuse and we are committed to ensuring that employees enter into employment and stay on in Wipro out of their own free will. We also insist that our suppliers prohibit forced labour or other compulsory labour in all of their operations. Our responsibilities
Diversity and non-discrimination Our Standard Wipro’s greatest asset is our employees. We believe that every employee deserves the opportunity to work and grow in a congenial environment where everyone can work without any inhibition, and free of discrimination and harassment. We are committed to attracting, retaining and developing the highest quality and most dedicated work force possible in today’s market. We understand that when diversity is embraced, we benefit from the creativity, varied perspectives and increased innovation. Wipro hires and promotes people based on their qualifications, performance and abilities, and is determined to provide a work environment free of any form of discrimination. Our responsibilities
Q One of my co-workers sends emails containing jokes and derogatory comments about certain nationalities. They make me uncomfortable but no one else has spoken up about them. What should I do? A You should notify your immediate manager or your HR manager. Sending such jokes violates our values as well as our policies pertaining to the use of email and our standards on diversity, harassment and discrimination. By doing nothing you are condoning discrimination and tolerating beliefs that can seriously erode the team environment that we have all worked to create. Wipro offers equality of opportunity to all employees and does not engage in or support discrimination in hiring, compensation, access to training, promotion, termination or retirement based on ethnic and national origin, race, caste, religion, disability, age, gender or sexual or political orientation. Wipro does not impose any fees or charges from employees we hire. Q. Your male colleague has a team that consists of only male members. On a recruiting visit to a local college, he elaborates to the team why he does not want to have female members on his team. You will: A. Report the conversation to your supervisor, VP, HR, and / or the Ombuds person since it is a clear cut case of sexual discrimination in hiring which is against Wipro’s policy of fair and equal employment opportunities and Ombuds process requires us to be vigilant and raise concerns to make the Ethics Policy effective and to support the Wipro’s endeavor towards fair and equal employment opportunities to all Harassment-free workplace Our standard Wipro is committed to maintaining a workplace where each employee’s personal dignity is respected and protected from offensive or threatening behaviour including violence. At Wipro, we believe that everyone has the right to work in an environment that is free from intimidation, harassment and abuse. We understand that harassment and abuse undermine the integrity of employment relationships and can cause serious harm to productivity, efficiency and a harmonious workplace. For these reasons, Wipro does not tolerate verbal or physical conduct by any employee that harasses another, disrupts another’s work performance, or creates an intimidating, offensive, abusive or hostile work environment. This includes such behaviour directed towards third parties during the course of conducting Wipro business. At Wipro we do not tolerate:
If you become aware of conduct relating to sexual harassment, you have the option to raise your concern with the Prevention of Sexual Harassment Committee. Q. You noticed that your colleague has been receiving obscene emails from another colleague but has never complained. You will: A. Advise your colleague that he / she should inform the Function Head / HR / Ombuds person, Ombuds process requires us to be vigilant and raise concerns to make the Ethics Policy effective What constitutes harassment? Harassment can be verbal, physical or visual behaviour where the purpose or effect is to create an offensive, hostile or intimidating environment. The following are signs that an action may be harassment:
Our responsibilities
Q While on a business trip, a male colleague of mine repeatedly asked me out for a drink and made comments about my appearance that made me uncomfortable. I asked him to stop, but he wouldn’t. We weren’t in the office and it was “after hours” so I wasn’t sure what I should do. Is it harassment? A Yes. This type of conduct is not tolerated, not only during working hours but in all work-related situations including business trips. Tell your colleague such actions are inappropriate and must be stopped, and if they continue you need to report the problem. Q I just learned that a good friend of mine has been accused of sexual harassment and that an investigation is being launched. I can’t believe it’s true and I think it’s only fair that I give my friend an advance warning or a “heads up” so he can defend himself. Don’t I have a responsibility as a friend to tell him? A Under no circumstances should you give him a “heads up.” Your friend will be given the opportunity to respond to these allegations and every effort will be made to conduct a fair and impartial investigation. An allegation of sexual harassment is a very serious matter with implications not only for the individuals involved but also for the Company. Alerting your friend could jeopardize the investigation and expose the Company to additional risk and possible costs. Further information: Policy on POSH and Me-Too Policy Safe and healthy work environment Our standard Wipro promotes employee well-being as a strategic value and fundamental component of its success, and we define well-being as more than what is traditionally thought of as occupational health and safety. Wipro takes appropriate measures to prevent workplace injuries and ill health and to provide employees with a safe and healthy working environment by considering evolving industry practices and societal standards of care. Wipro is proactive and actively assesses and manages the health and safety impact, and possible risks associated with our existing activities as well as when planning for new activities, production of services and products. We are committed to providing a safe and healthy workplace for colleagues and visitors to our facilities. Our responsibilities
Q I’ve noticed some practices that we do in my area that don’t seem safe. Whom can I speak to? A Discuss your concerns with your manager or the Emergency Response Team (ERT) member in your office. There may be very good reasons for the practices. Raising a concern about safety does not cause trouble, it is being responsible. Q Are subcontractors expected to follow the same health, safety and security policies and procedures as employees? A Absolutely. Managers are responsible for ensuring that subcontractors and vendors at work on Company premises understand and comply with all applicable laws and regulations governing the particular facility, as well as with additional requirements the Company may impose.
Sustainability and corporate Citizenship Wipro recognizes that corporations are socio-economic citizens and that their objectives have to be congruent with society’s goals. We therefore understand that it is our responsibility as a global citizen to assess the socio-ecological impact of its business activities, and to mitigate and improve this impact, while simultaneously remaining committed to inclusive economic development. Our environmental stewardship and leadership in Corporate Citizenship are an integral part of our “Spirit of Wipro.” To accomplish this, we will expect our employees to comply with the following: What is corporate misconduct?Chapter 2: Corporate Misconduct & Corporate Governance The term corporate misconduct or misgovernance refers to frauds committed by corporate entities to wilfully erode shareholder value. The corporate misconduct extends beyond malpractice in accounting, reporting, operations and therefore results in misconduct.
What is corporate ethics and code of conduct?A code of ethics and professional conduct outlines the ethical principles that govern decisions and behavior at a company or organization. They give general outlines of how employees should behave, as well as specific guidance for handling issues like harassment, safety, and conflicts of interest.
Which is an example of poor corporate conduct?Lying to employees
The fastest way to lose the trust of your employees is to lie to them, yet employers do it all the time. One of out every five employees report that their manager or supervisor has lied to them within the past year.
What are the types of corporate ethics?Corporate ethics codes often include subjects like social responsibility, insider trading, discrimination, corporate governance and bribery.. Personal responsibility. ... . Corporate responsibility. ... . Loyalty. ... . Respect. ... . Trustworthiness. ... . Fairness. ... . Social and environmental responsibility.. |
Some corporate cannot be tied to one individual or even a group and misconduct
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