Code Of Conduct

Codes of conduct, as we have seen, have been formulated primarily to

ensure that companies remarry spect fundamental worker rights. Mostly, they
are based on international standards and they aim at improving working
conditions around the world. However, in order to achieve this objective, all
parties involved, i.e. consumers, NGOs, trade unions, workers, companies,
social accountability auditors, governments etc., must effectively play their
respective roles.


We are not a listed entity, but we have a Code of Business Conduct, which
lays down important Corporate Values that help regulate our value system
and business practices. Compliance to the Code of Conduct is mandatory for
all employees. The code clearly defines important Corporate Governance
practices to be followed with respect to the following:

1. Child Labor
2. Forced Labor or Compulsory Labor
3. Health and Safety Conditions
4. Freedom of Association and right to Collective Bargaining
5. Discrimination
6. Disciplinary Practices
7. Working Hours
8. Wages and Benefits
9. Management Responsibility

The Organization and its employees must, at all times, comply with all
applicable laws and regulations. The Organization will not condone the
activities of employees who achieve results through violation of the law or
unethical business dealings. This includes any payments for illegal acts,
indirect contributions, rebates, and bribery. The Organization does not permit
any activity that fails to stand the closest possible public scrutiny.

Moreover the company expects its employees to conduct themselves in a
businesslike manner. Employees must not engage in sexual harassment, or


conduct themselves in a way that could be construed as such, for example,
by using inappropriate language, keeping or posting inappropriate materials in
their work area, or accessing inappropriate materials on their computer.
Below are given list of General Employee Conduct:


Upon joining an employee accepts the mission of the
Company and is subject to the following principles:


Their Creator with certain rights endows all human beings and no
employee of the Company may infringe upon the rights of fellow
















members of


The goal of is use of skills and knowledge
which cannot occur without a safe and comfortable learning
environment. All persons working at and attending
are responsible for the creation and maintenance of such an
environment.


The Garments learning environment must be one in which all persons'
views are listened to and tolerated unless they violate Principles 1 and
2 (mentioned above). Learning in a democratic society must take place
through the free exchange of ideas.


The Garments Employee Code of Conduct has been
formulated with the goal of upholding the stated mission. It is the
responsibility of the Garments to make this Code of Conduct available to all
members of the garments community such that in case of violations and
subsequent convening of the Disciplinary Committee, all measures and
procedures are clear to all parties concerned.


Violations of the Code of Conduct shall invoke disciplinary process as
outlined in this document. Sanctions will be commensurate with the
seriousness of the offense and may include suspension or in extreme cases,
expulsion from the Garments. Repeated offenses justify increasingly severe
sanctions.


The Code of Conduct of Garments is documented as
below (next page) for communication to their employees / Suppliers for their
better understanding and follows up in their premises. This COC aims for
better social and ethical conditions, working environment in the company and
all the applicable benefits are paid to their employees.





Child Labor
The company shall not engage in or support any form of Child Labor in
their premises, at any cost for any reasons what so ever.


Adult labors are only preferred to join the company.


Age verification of everyone is compulsory before recruitment to any
position in the company. Copy shall be collected and maintained in
their records.

Forced Labor/Compulsory Labor

No form of Forced / Compulsory Labor (verbal, physical, psychological)
shall be allowed / practiced in the company.


No original documents (like passport, license, certificate, etc.) collected
during recruitment.


No bonded Labor system practiced by the company.


No long-term loan with excessive interest percentage shall be
practiced.


Health & Safety Condition

Sufficient Lighting and Ventilation shall be provided in all sections
according to their work nature.


First Aid Boxes and its minimum contents shall be provided as per
legal requirements along with trained employees for First Aid.


Fire Extinguishing arrangements shall be made with trained employees
in all areas of work




Potable drinking water shall be provided to all employees

Toilets and Urinals shall be provided for all employees (male / female)
as per legal requirements and shall be maintained well, clean and
odorless, sufficient water shall be available during working hours


Provision and usage of Personal Protective Equipments (PPE) like
mask, gloves, needle guards, eye guards, metal gloves, goggles, ear
plug, ear muff, etc. shall be effectively done.


Freedom Of Association & Rights To Collective Bargaining


Employees are free to joint any trade union of their choice and they
shall not be restricted to join unions or to form a union


Union representatives are not restricted to meet the employees and
discuss


In absence of a union, they shall be allowed to meet the management
directly and do bargaining


Works committee shall be formed to do any discussion or Collective
Bargaining


Discrimination

There shall not be any form of Discrimination in the terms of color,
religion, language, caste, gender, country, etc.


Equal work shall be paid equally (and any difference in benefits are
only based on their efficiency and capability and not a discrimination)


Disciplinary Practices



Employees shall be treated properly during their working in the
premises. Any discrepancies/ mistakes shall be dealt properly as per
procedures of company and legal requirements. Records of any such
cases shall be maintained properly.


Working Hours

Working hours of all employees shall be as per local legal laws and
shall not exceed 8 hours/day and 48 hours/week for regular working


Over Time working shall be limited always and shall not exceed 2
hours/day and 12 hours / week and 50 hours / 3 months

One day weekly off shall be provided to all employees, after every 6
work days



Wages & Benefits


Wages shall be paid as per local legal laws for all employee categories
and records shall be maintained for evidencing them.


Over Time work shall be always paid at a premium rate and records
shall be maintained for evidencing them

Benefits as per law like ESI (Employees State Insurance) and EPF
(Employees Provident Fund) shall be paid to employees



General Employee Conduct




The Organization expects its employees to conduct themselves in a
businesslike manner. Drinking, gambling, fighting, swearing, and similar
unprofessional activities are strictly prohibited while on the job.


Employees must not engage in sexual harassment, or conduct themselves in
a way that could be construed as such, for example, by using inappropriate
language, keeping or posting inappropriate materials in their work area, or
accessing inappropriate materials on their computer.


Conflicts of Interest

The Organization expects that employees will perform their duties
conscientiously, honestly, and in accordance with the best interests of the
Organization. Employees must not use their positions or the knowledge
gained as a result of their positions for private or personal advantage.
Regardless of the circumstances, if employees sense that a course of action
they have pursued, or is presently pursuing, or are contemplating pursuing
may involve them in a conflict of interest with their employer, they should
immediately communicate all the facts to their supervisor.


Outside Activities, Employment, and Directorships

All employees share a serious responsibility for the Organizations good
public relations, especially at the community level. Their readiness to help
with religious, charitable, educational, and civic activities brings credit to the
Organization and is encouraged. Employees must, however, avoid acquiring
any business interest or participating in any other activity outside the
Organization that would, or would appear to:


Create an excessive demand upon their time and attention, thus
depriving the Organization of their best efforts on the job.


Relationships With Clients and Suppliers

Employees should avoid investing in or acquiring a financial interest for their
own accounts in any business organization that has a contractual relationship
with the Organization, or that provides goods or services, or both, to the
Organization if such investment or interest could influence or create the
impression of influencing their decisions in the performance of their duties on
behalf of the Organization.




Gifts, Entertainment, and Favors

Employees must not accept entertainment, gifts, or personal favors that
could, in any way, influence, or appear to influence, business decisions in
favor of any person or organization with whom or with which the Organization
has, or is likely to have, business dealings. Similarly, employees must not
accept any other preferential treatment under these circumstances because
their positions with the Organization might be inclined to, or be perceived to,
place them under obligation.


Kickbacks and Secret Commissions

Regarding the Organizations business activities, employees may not receive
payment or compensation of any kind, except as authorized under the
Organizations business and payroll policies. In particular, the Organization
strictly prohibits the acceptance of kickbacks and secret commissions from
suppliers or others.


Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the
public and others in the Organization, all employees must make every effort
to achieve complete, accurate, and timely communications - responding
promptly and courteously to all proper requests for information and to all
complaints. Their readiness to help with religious, charitable, educational, and
civic activities brings credit to the Organization and is encouraged.


Organization Funds and Other Assets

Employees who have access to Organization funds in any form must follow
the prescribed procedures for recording, handling, and protecting money as
detailed in the Organizations policies and procedures or other explanatory
materials, or both. The Organization imposes strict standards to prevent fraud
and dishonesty. If employees become aware of any evidence of fraud and
dishonesty, they should immediately advise their supervisor or seek
appropriate legal guidance so that the Organization can promptly investigate
further.


When an employees position requires spending Organization funds or
incurring any reimbursable personal expenses, that individual must use good
judgment on the Organizations behalf to ensure that good value is received
for each and every expenditure. Funds and all other assets of the
Organization are purposed for the organization only and not for personal
benefit. This includes the personal use of organizational assets, such as
computers.


Organization Records and Communications

Accurate and reliable records of many kinds are necessary to meet the
Organizations legal and financial obligations and to manage the affairs of the
Organization. The Organizations books and records must reflect in an
accurate and timely manner all business transactions. The employees
responsible for accounting and recordkeeping must fully disclose and record
all assets, liabilities, or both, and must exercise diligence in enforcing these
requirements. Employees must not make or engage in any false record or
communication of any kind, whether internal or external, including but not
limited to:


False expense, attendance, production, financial, or similar reports and
statements

False advertising, deceptive marketing practices, or other misleading
representations


Dealing With Outside People and Organizations

Employees must take care to separate their personal roles from their
Organization positions when communicating on matters not involving
Organization business. Employees must not use organization identification,
stationery, supplies, and equipment for personal or political matters. When
communicating publicly on matters that involve Organization business,
employees must not presume to speak for the Organization on any topic,
unless they are certain that the views they express are those of the
Organization, and it is the Organizations desire that such views be publicly
disseminated. When dealing with anyone outside the Organization, including
public officials, employees must take care not to compromise the integrity or
damage the reputation of either the Organization, or any outside individual,
business, or government body.



Privacy and Confidentiality

When handling financial and personal information about customers or others
with whom the Organization has dealings, observe the following principles:


Collect, use, and retain only the personal information necessary for the
Organizations business. Whenever possible, obtain any relevant
information directly from the person concerned. Use only reputable and
reliable sources to supplement this information.

Retain information only for as long as necessary or as required by law.
Protect the physical security of this information.

Limit internal access to personal information to those with a legitimate
business reason for seeking that information. Use only personal
information for the purposes for which it was originally obtained. Obtain
the consent of the person concerned before externally disclosing any
personal information, unless legal process or contractual obligation
provides otherwise.


Obscene Language

The following Code of Conducts should be maintained by the employees of
regarding obscene language:


Employees are expected not to use objectionable or obscene language
at any time whilst in or on s premises.


Employees are expected to at all times act and behave in a business-
like manner and are courteous to their fellow employees and
colleagues.


Violation of the code may result in punishment for the employees,
which includes suspension and termination from the job.


Employees of are strongly encouraged to
follow the code regarding obscene language.


Inappropriate Conduct

The following Code of Conducts should be maintained by the employees of
regarding inappropriate conduct:


Employees are expected not to conduct themselves in a manner that
has an adverse impact on the work environment, including at
company-sponsored functions.


This inappropriate conduct includes threats, over consumption of
alcohol, violent behavior, the possession of weapons of any type, the
use of recording devices, including web cameras, for other than
management approved purposes.


Violation of the code may result in punishment for the employees,
which includes suspension and termination from the job.




Reciprocal Dealing


The employees of Sayem Fashions LTD. regarding reciprocal dealing should
maintain the following Code of Conducts:

Employees of should not be involved in
reciprocal dealing.


Employees should not tell a prospective supplier that
decision to buy its goods or services is conditioned on
the suppliers agreement to buy goods.


This does not mean that customer cannot be a
Garment supplier or that can never consider its
other relationships with the supplier when it is evaluating the supplier.


It simply means that s decision to buy goods
and services from a supplier must be made independently from that
suppliers decision to buy goods.


Fighting or Engaging in horseplay


The employees of Sayem Fashions LTD. regarding should maintain the
following Code of Conducts fighting or engaging in horseplay:


The employees of should not engage in
fighting with their fellow workers or employees.


Violation of the code may result in punishment for the employees,
which includes suspension and termination from the job.


Employees are expected not to conduct themselves in a manner that
has an adverse impact on the work environment, including at
company-sponsored functions.




Offering, gifts, attitudes & bribe

The employees of must need to follow the following
Codes regarding offering gifts, gratuities or bribes:


expects its employees to compete fairly and
ethically for all business opportunities.


Employees of may provide meals,
refreshments or entertainment to customers or suppliers, provided that
this is done in the ordinary and proper course of business.


All such expenditures must be properly recorded within the books and
records of


Employees of Magnum may also provide small
tokens of appreciation or gifts to prospective and existing customers.


However, beyond this, employees must not offer or give gifts,
commissions, gratuities, or other payments, either openly or secretly,
to prospective or existing customers or suppliers without the prior
written approval of the Administration Department.


No gifts or business entertainment of any kind may be given to any
Government Official without the prior approval of the Administration
Department. For such approval to be given, the gift must be in
compliance with this Code and not in violation of
s policies.


Any employee who offers, pays, solicits or receives any form of bribe,
payoff, unlawful gratuity or kickback, directly or indirectly through third
parties, will be subject to appropriate disciplinary action consistent with
relevant laws and regulations and, if warranted, will be reported to the
appropriate authorities.


A kickback or bribe includes any item intended to improperly obtain
favorable treatment.




Falsifying business or financial records

Employees must not enter into fraudulent activities. Fraudulent activities
encompass an array of irregularities and illegal acts characterized by
intentional deception. Persons outside as well as inside Sayem Fashions LTD
can perpetrate fraud No one has the authority to commit illegal acts related to
Fraudulent activities include acts that are not only a
detriment to , but also a detriment to third parties.
Engaging in any act that involves fraud, theft, embezzlement or
misappropriation of any property, including that of , or
any of its employees, suppliers or customers is strictly prohibited. It is
s responsibility to ensure that incidents of fraud are promptly
investigated, reported and, where appropriate and authorized by applicable
law, prosecuted.


Some examples of fraudulent conduct are:


Falsification of financial records such as valuation of transactions,
amount of income/loss, or failure to disclose financial information


Acceptance or payment of bribes or kickbacks


Diversion of potentially profitable transactions outside



Claims submitted for goods not actually provided to
or a third party;


Intentional concealment or misrepresentation of data, records, events
or information, including but not limited to, expense reimbursement and
achievement against Key Performance Indicators, resulting in reward
and recognition benefits.


Violation of the code may result in punishment for the employees,
which includes suspension and termination from the job.




Financial Interest

Many employees may have relatives who are employed by or invest in
customers or suppliers of These financial interests
should not create a conflict under the Code unless:


The employees have discretionary authority in dealing with any of
these companies as part of their job with The
employees relative deals with on behalf of the
other company.


In either of these situations, the employees must have written approval
from their respective supervisors, and they must renew this approval
annually.


If a competitor of the Company employs the employees relative, the
employee must seek written approval from his respective supervisors,
and renew it annually.


The employee may have friends who are employed by, or have
ownership interests in, customers or suppliers of
If the employee deals with such a customer or supplier, takes
care to ensure that his friendship does not affect, or appear to affect,
his ability to act in the best interest of the Company.


If the employee is uncertain whether his friendship may create an
issue, the employee should consult his immediate supervisor


In addition, personal relationships at work must not influence the
employees ability to act in the best interest of the Company, and must
not affect any employment relationship.


Employment-related decisions should be based on qualifications,
performance, skills and experience.


Misuse of company resources




Generally, the use of the property, information, and resources of
for any purposes other than the business of
is strictly prohibited. Some examples of the application of this
general obligation are set out below.


Approving or making of a payment on behalf of
for something other than the stated purpose.

Intentional alteration of customer or data
for other than legitimate business purposes.

Using personal customer information for any purpose other than the
purpose of managing a customers account and any reasons
allowed under the customers contract.

Using s photocopier or facsimile machines
for personal reasons without authorization from the employees
manager.

Using company vehicles for private purposes without express
authorization from the employees manager.

Claiming expenses from for travel
unrelated to s business or for something
other than the stated purpose.

Appropriating s stationery for personal use.

Protecting the Companys assets, and use those assets in the
manner intended.

The employees should not use Company assets for your personal
benefit or the benefit of anyone other than the Company.






Company money

Company Product

Employees time at work

Company vehicles

Computer system & Software

Telephone

Photocopiers

Ticket to concert and sporting event

Wireless communication Devises

Company Trademarks

Proprietary Information


Media Comments

The employees of Sayem Fashions LTD. regarding media comment should
maintain the following Code of Conducts:


Employees may not make statements or comments to the media or
other external bodies regarding , its business


dealings, and financial status.


Employees are not allowed to comment to the
media or other external bodies regarding s
customers, suppliers, competitors or shareholders unless directed or
authorized by

Such authorization must come from the Board of Directors of
Garment and any violation of the code can cause the employee to be
suspended temporarily or other monetary punishment.


Receiving gifts, gratuities of bribes


The employees of must need to follow the following
Codes regarding receiving gifts, gratuities or bribes:


Employees of are expected at all times to act
in the best interests of and this means
obtaining the best deal for . in any business
transaction. s selection of suppliers must be
based solely on the quality, price and service offered.


Employees must not accept free or discounted goods or services
(beyond a reasonable commercial discount or promotional items) from
persons doing or seeking business with , which
may influence, or appear to influence a business decision unless they
receive the prior written approval of the production department.


If any such goods are received without solicitation, employees must
obtain approval as set out above. If approval is not given, such gifts
must be returned immediately to the person who provided them.


Employees may accept meals or refreshments provided in the ordinary
and proper course of business (for example, at a business lunch), and
on an infrequent basis in connection with business discussions.


Every employee is personally responsible for ensuring that acceptance


of such meals and refreshments is proper and could not reasonably be
construed as an attempt by the offering party to secure favorable
treatment.


Employees must treat all customers, suppliers, contractors, or other
persons with whom they deal in the course of their employment in a
non-discriminatory manner.

Employees should not accept gifts in exchange for doing, or promising
to do, anything for a customer supplier.


Employees should not ask for gifts from a customer or supplier.


Employees should not accept gifts of cash or cash equivalents, such
as gift cards.


Employees should not accept gifts of more than modest value.
Examples of acceptable gifts include a logo pen or t-shirt, or a small
gift basket at holiday time.


Employees should not accept meals or entertainment in exchange for
doing, or promising to do anything for a customer or supplier.


Employees should not ask for meals or entertainment from a customer
or supplier.


If the employees are offered a gift, meal or entertainment that exceeds
the limits noted above, they should politely decline and explain the
Companys rules.






















Financial Interest

Many employees may have relatives who are employed by or invest in
customers or suppliers of These financial interests
should not create a conflict under the Code unless:


The employees have discretionary authority in dealing with any of
these companies as part of their job with


The employees relative deals with on behalf of
the other company.


In either of these situations, the employees must have written approval
from their respective supervisors, and they must renew this approval
annually.

If a competitor of the Company employs the employees relative, the
employee must seek written approval from his respective supervisors,
and renew it annually.


The employee may have friends who are employed by, or have
ownership interests in, customers or suppliers of
If the employee deals with such a customer or supplier, takes
care to ensure that his friendship does not affect, or appear to affect,
his ability to act in the best interest of the Company.


If the employee is uncertain whether his friendship may create an
issue, the employee should consult his immediate supervisor.


In addition, personal relationships at work must not influence the


employees ability to act in the best interest of the Company, and must
not affect any employment relationship.


Employment-related decisions should be based on qualifications,
performance, skills and experience.





Reciprocal Dealing

The employees of Sayem Fashions LTD. regarding reciprocal dealing should
maintain the following Code of Conducts:


Employees of should not be involved in
reciprocal dealing.


Employees should not tell a prospective supplier that
s decision to buy its goods or services is conditioned
on the suppliers agreement to buy goods.


This does not mean that customer cannot be a
Garment supplier or that can never consider its
other relationships with the supplier when it is evaluating the supplier.


It simply means that s decision to buy goods
and services from a supplier must be made independently from that
suppliers decision to buy goods.