Code of Conduct

Introduction

Each employee is regarded as a brand ambassador and torch bearer of the company. It is the responsibility of each employee to conduct himself in a professional manner at all times.

Objective

The objective of the MFEL Code of Conduct policy is to define and communicate guidelines to all employees on the ethical behaviour and the business conduct that need to be adhered to at MFEL.

Scope

The MFEL code of conduct policy shall be applicable to:

  • All employees who shall be hired on the rolls of MFEL.
  • Contractors, temporary staff, third parties who represent MFEL or act on behalf of the company.
  • Employees of joint ventures where MFEL has management control and employees of new acquisitions.

Standard Conduct

  • At MFEL, we conduct our operations with honesty, integrity and openness, and with respect for the human rights and interests of our employees.
  • The company shall similarly respect the legitimate interests of those with whom it has relationships.

Main Features Of The MFEL Code And Conduct Policy

Obeying The Law

All employees at MFEL are required to comply with the laws and regulations of the countries in which they operate.

Our Relationships With Key Stakeholders

Employees

MFEL shall:

  • Be committed to a working environment that promotes diversity and equal opportunity and where there is mutual trust, respect for human rights and no discrimination.
  • Recruit, employ and promote employees on the sole basis of the qualifications and abilities needed for the work to be per formed.
  • Be committed to safe and healthy working conditions for all employees. The company shall provide employees with a total remuneration package that meets or exceeds the legal minimum standards.
  • Not use any form of forced, compulsory, trafficked or child labour.
  • Be committed to working with employees to develop and enhance each individual ’s skills and capabilities.
  • Respect the dignity of the individual and support the right of employees to freedom of association and collective bargaining.
  • Maintain good communications with employees through company based information and consultation procedures.
  • Ensure transparent, fair and confidential procedures for employees to raise concerns.

Consumers

  • MFEL shall be committed to providing branded products and services to its consumers which consistently offer value in terms of price and quality, and which are safe for their intended use.
  • Products and services shall be accurately and properly labelled, advertised and communicated.

Shareholders

MFEL shall;

  • Conduct its operations in accordance with internationally accepted principles of good corporate governance.
  • Provide timely, regular and reliable information on its activities, structure, financial situation and performance to all shareholders.

Business partners

  • MFEL shall be committed to establishing mutually beneficial relations with its suppliers, customers and business partners. In its business dealings MFEL expects its business partners to adhere to business principles consistent with our own.

Community involvement

  • MFEL strives to be a trusted corporate citizen and as an integral part of the society, the company shall fulfil its responsibilities to the societies and communities in which it operates.

Way We Work At MFEL

Public activities

  • MFEL is encouraged to promote and defend its legitimate business interests.
  • MFEL shall co-operate with governments and other organisations, both directly and through bodies such as trade associations, in the development of proposed legislation and other regulation which may affect legitimate business interests.
  • MFEL neither supports political parties nor contributes to the funds of groups whose activities are calculated to promote party interests.

Business integrity

  • MFEL shall not give or receive, whether directly or indirectly, bribes or other improper advantages for business or financial gain.
  • No employee may offer, give or receive any gift or payment which is, or may be construed as being, a bribe.
  • Any demand for, or offer of, a bribe must be rejected immediately and reported to management.
  • All accounting records and supporting documents shall accurately describe and reflect the nature of the underlying transactions. No undisclosed or unrecorded account, fund or asset shall be established or maintained by the company.

Innovation

  • In its scientific innovation to meet consumer needs MFEL shall respect the concerns of its consumers and of society.
  • The company shall work on the basis of sound science, applying rigorous standards of product safety.

Competition

  • MFEL believes in vigorous yet fair competition and supports the development of appropriate competitive laws. MFEL and its employees shall conduct its operations in accordance with the principles of fair competition and all applicable regulations.

Environment

  • MFEL is committed to making continuous improvements in the management of its environmental impact and to the longer – term goal of developing a sustainable business.
  • MFEL shall work in partnership with others to promote environmental care, increase understanding of environmental issues and disseminate good practices.

Conflict Of Interests

  • All employees at MFEL are expected to avoid personal activities and financial interests which could conflict with their job responsibilities.
  • Employees must not seek gain for themselves or others through misuse of their positions during their employment with MFEL.

Avoiding Conflict Of Interest

  • Employees must not let his/her personal, financial or political activities affect their job performance at MFEL.
  • Any personal, financial or political activities undertaken by the employees which may create an actual or perceived conflict of interest, should be reported to his/her immediate reporting manager immediately.
  • Business opportunities: Employees must not take – or divert to others – any business opportunities that arise in the course of doing his/her job at MFEL that could be of interest to MFEL. He/she must ensure Company is best placed to benefit from any business opportunities that could be of interest to it.
  • Employees must not work for – or provide any services to – competitors, customers or suppliers
  • If you have ‘family members’ who work for, or provide services to, actual or potential competitors, customers or suppliers you must notify your immediate reporting manager and the HR department and agree with them the best way to manage the situation.

Investments

Employees must take care that his/her investments do not affect their ability to take objective decisions when doing their job at MFEL. Employees – must not, without the prior written approval of Company Secretary & Head – Legal hold:

  • ‘Substantial’ interests in Company’s competitor, supplier or customer (‘Substantial’ means 5% of your net worth).
  • Any interest in a supplier if an employee or his/her team member is involved in selecting or assessing the supplier or negotiating with them.
  • Any interest in a customer if an employee or one of his/her team member deal with them.

Note: Investments in publicly traded funds, Mutual funds, ULIP etc. are excluded from the above.

External employment, directorships, consultancy

  • Employees must obtain written approval from his/her immediate reporting manager , HR Head , Head -Legal before taking up a directorship (or equivalent) of another organisation, whether commercial or not-for-profit, in a personal capacity.
  • Such a role must not create an actual or perceived conflict of interest, detract from his/her commitment and contribution to MFEL or take up excessive work time.
  • Before becoming a director of any publicly listed company, an employee must obtain written approval from the Head- Legal and Head-HR.
  • The fiduciary roles e.g. chairman / director’/Executive Committee member of property/housing blocks in which an employee lives are excluded from the above and do not require approval.

Compliance, Monitoring, Reporting

  • Compliance with these principles is an essential element in MFEL’s business success. The MFEL Board of Directors shall be responsible for ensuring these principles are applied throughout MFEL consistently.
  • The CEO is responsible for implementing these principles and shall be supported in this by the Company Secretary & Head – Legal.
  • The day- to-day responsibility of implementing these principles shall be with all senior management team across MFEL locations/geographies. They shall be supported by the HR and legal departments.
  • Assurance of compliance shall be given and monitored each year. Compliance shall be reviewed by the Board and supported by Audit Committee for financial and accounting issues.
  • Any breaches of the Code shall be reported. The MFEL Board shall not criticize management for any loss of business resulting from adherence to these principles and other mandatory policies.
  • Provision has been made for employees to be able to report in confidence and no employee shall suffer because of doing so.

Accurate Records, Reporting & Accounting

  • Employees must:
    • Record all transactions accurately, completely and promptly.
    • Only perform transactions, such as buying, selling or transferring goods/assets, for which he/she is authorised.
    • Ensure transactions he/she approves are legitimate and based on valid documentation.
    • Notify his/her Supervisor of any potential fraud or other misrepresentation of accounting or other information.
    • Retain records in line with the following requirements or longer if required by local laws/regulations:
      • Seven years for accounting records.
      • Ten years for tax records.
      • Six years after contracts end.
      • Seven years for personnel records after employees have left or retired.
  • Retain records that may be relevant to a pending audit, litigation or regulatory investigation, even if they exceed the normal retention period.
  • Co-operate fully, openly and honestly with internal/external auditors and ensure they are aware of all information relevant to their work.
  • Employees responsible for reporting financial and other business information must comply with:
    • All applicable laws, for example, those regarding financial statements, tax and environmental requirements.
    • All applicable external reporting standards and regulations, such as, international and national accounting standards, stock market listing standards and rules, financial regulator rules, health and safety requirements, corporate governance codes and regulatory standards.
  • Finance employees must ensure that:
    • Sales, profits, assets and liabilities are recorded in the correct time period.
    • Assumptions that underpin accounting records are properly documented, especially those relating to provisions, journal entries and contingent liabilities, must complete quarterly and annual Financial Reporting Declarations in line with instructions issued by Management.
  • Employees must not:
    • Do anything to artificially inflate or shift sales or profit between reporting periods.
    • Create, maintain or procure others to produce or maintain undisclosed or unrecorded accounts.
    • Funds or assets.
    • Conceal, alter or falsify company records and documents.

Living The MFEL Code

  • MFEL has earned a reputation for conducting its business with integrity and respect for others. This reputation is an asset, as valuable as our people and brands.
  • MFEL’s Code of Business Principles (the ‘Code’), and the policies that support it (‘Code of Conduct Policies’), set out the standards required from all employees and third parties acting on behalf of the company.
  • MFEL also expects its business partners to adhere to principles consistent with our own.
  • Breaching the Code and Conduct Policies could result in serious consequences including significant fines for Company, imprisonment for individuals and significant damage to MFEL’s reputation.
  • Failure to comply with the Code and Conduct Policies will be taken very seriously and could result in disciplinary action, including dismissal/termination of services and legal action.
  • This Code Policy explains how to ensure the Code and Conduct Policies are understood and followed by all MFEL employees and those acting on behalf. It confirms everyone’s responsibility to speak up and report suspected or actual breaches and outlines how such events shall be managed.
  • The Code and Code Policies may NOT cover every eventuality. Where any employee encounters situations that are not covered, then he/she needs to reflect on the spirit of the Code and Conduct Policies and exercise common sense and good judgement. In case of any doubts, employees shall seek guidance and support from reporting managers and/or local HR/Legal Officer.

Employees must:

  • Ensure they know and understand the Code and Conduct Policies. This means employees shall read the Code and attend the training imparted from time to time.
  • Provide a declaration annexed in the policy every year to refresh themselves and abide by the policy.
  • Get in touch with HR in case of any doubts in interpreting /understanding any aspects of the policy.
  • Report any potential or actual breaches of the Code and Conduct Policy, whether relating to the employee, or his/her colleagues or other people acting on behalf of MFEL and whether accidental or deliberate. This includes instances where he/she believe business partners are not behaving in line with MFEL principles. Concerns must be reported immediately if any breach of the policy is suspected by any party.
  • The Corporate / Unit HR is usually the right person to report potential or actual code breaches. If this is not appropriate, talk to one of the following:
    • The local Legal Officer
    • The Unit Head
    • The Corporate Head HR or Legal Head
  • Employees must read and understand the MFEL Code of Conduct Policies and undertake related mandatory training.
  • All team managers must:
    • Set an example by demonstrating good behaviour and offer guidance and support about the Code and Conduct Policies to your team.
    • Escalate any unresolved questions from his/her team to the Corporate/Unit HR department.
    • Ensure that any of your team who raises concerns, or highlights potential or actual breaches, receives support and respect.
    • Treat any potential breaches with discretion and discuss them with concerned authority as soon as possible.
    • Provide necessary documentary evidence wherever required in case of breach of policy.

Legal Consultation

  • MFEL’s employees must comply with the laws and regulations of the countries in which they work.
  • Breaches can lead to significant financial penalties for the business or imprisonment of concerned employees.
  • Timely legal consultation is therefore essential to ensure that MFEL’s legitimate business interests are protected, competitive advantage is exploited and the law is complied with at all times.
  • The MFEL Code of Conduct Policy sets out how and in what circumstances employees must seek legal advice from the Legal Department.
  • Employees must immediately notify their reporting manager and take legal advice if he/she suspects or discovers any illegal activity /non-compliance of any law, in relation to MFEL’s operations or associated activities involving third parties.
  • Employees must also promptly seek advice from the relevant Legal business partner and give appropriate weight to such advice in the following situations:

    Commercial contracts, leases, licenses and transactions

    • Contracts for goods or services. The only exception is where Legal department has either delegated authority to the business to agree commercial contracts without further legal consultation or has set up a direct route for legal consultation with an external legal provider.
    • Contracts relating to intellectual property, such as, Licenses for Technology, Trademarks, Joint Development or Technical Assistance Contracts, Treasury transactions, for example, raising equity or debt, asset leasing, derivative transactions (such as currency hedging or interest rate swaps) or guarantees of Treasury transactions.
    • Transactions involving mergers, acquisitions, disposals or joint ventures.

    Litigation and regulatory action

    • Civil litigation, such as employment or contractual disputes, whether threatened or actual, by or against company or employee, including commencement of or settlement of such litigation.
    • Criminal prosecutions, whether threatened or actual, by or against Company or employee, or at Company’s instigation.
    • Communication with government or regulatory bodies about investigations, including unexpected investigations, or where Company is seeking regulatory action, such as non-compliant labelling actions through local governmental bodies.

    Competition/anti-trust

    • Compliance issues around competition/anti- trust laws, such as trade terms, exclusive arrangements or pricing.
    • Meetings, contact or other activity, including participation in trade associations, which may involve the exchange of information with a competitor or restrict fair competition.

    Communication

    • Press releases that could impact MFEL’s reputation or create legal liability or contain ‘insider’ or ‘price sensitive’ information.

    Claims, brands, trademarks, marketing materials

    • Product claims and marketing materials, including advertising, promotional materials, packaging and labelling, trade materials, advertorials, point-of sale materials, and web content.
    • Clearance for use of all brand names, marks, logos, slogans, celebrity endorsements and sponsorships.
    • Maintenance, protection and disposal of trademarks, copyrights and domain names used by the business.
    • Competitor challenges to claims, brands, trademarks either by or against Company.

    Employment

    • Issues relating to non-compete obligations, employment disputes and terminations and non- routine employment contract terms.

    Safety

    • Product tampering or counterfeiting.
    • Consumer complaints that may lead to legal disputes.
    • Potential product recalls.
    • Consumer, product, workforce or environmental safety incidents that could have legal implications.

    Legal or governance structures

    • Changes to, or issues around, legal or governance structures, such as changes in capital structure or Board membership, public company filings and arrangements/relationships with third party shareholders.

    Corruption and Bribery

    • Corruption or bribery issues, including related allegations and uncertainty about situations that may have corruption or bribery implications.
    • Employees outside the Legal Department must not appoint, manage or remove externa counsel(s) or pay fees that differ to the fee structures agreed by the Legal Department.
    • Employees must not do anything that the Legal Group has advised is illegal and/ or unlawful . Where an activity is not illegal and/ or unlawful but legal advice highlights significant risks for Company, such as litigation, he/she must escalate this to Legal Department.

Anti Money Laundering Policy

  • Employees must notify his/her Legal business partner if they have any suspicions about money laundering.
  • MFEL employees must look out for warning signs of money laundering, such as:

    Supplier requests to:

    • Pay funds to a bank account in the name of a different third party or outside the country of their operation.
    • Make payments in a form outside the normal terms of business.
    • Split payments to several bank accounts.
    • Overpay

    Customer payments to MFEL:

    • From multiple bank accounts.
    • From bank accounts, overseas when not a foreign customer.
    • Made in cash when normally made by cheque or electronically.
    • Received from other third parties.
    • Made in advance when not part of normal terms of business.
  • Employees responsible for engaging/contracting with new suppliers and/or customers must undertake appropriate checks to assess their identity and legitimacy, before contracts are signed or transactions occur. The outcome of the checks must be considered carefully before deciding whether to engage with the third party. Various factors will determine what checks are appropriate, such as the value of the contract, the nature of the service or goods and the potential for corruption within that third party or the general environment /location.

Checks may include:

  • Verifying that companies are properly registered by obtaining legal registration documents.
  • Under taking a legal review to identify recent or pending court cases against the company or its directors and, where known, the outcomes.
  • Ensuring directors have no relevant convictions and are not barred from holding directorships.
  • Searching for media reports which may indicate impropriety by the company or individuals.

For large contracts, an audit of business partner may be conducted.

Anti – Bribery Policy

  • Employees must not:
    • Give or receive bribes or improper advantages, either directly or indirectly which are or give the impression that they are intended to influence decisions by any third parties about Company or vice versa. This applies in all countries and all situations.
    • Give anything of any value, including nominal cash amounts or gift, which has the potential to be considered or perceived as something intended to cause the recipient to behave improperly. This includes, but is not limited to: money, services (including favours), discounts, use of resources, loans, the promise of future employment or internship, gifts and entertainment.
  • All third parties, whether public or private, are included in this prohibition. For example:
    • Actual or potential customers, distributors, agents.
    • Actual or potential suppliers or consultants.
    • Other actual or potential service providers, such as banks.
    • Government or regulatory officials/employees, either local or regional.
    • Political representatives.
  • Use anyone (whether agents, distributors, consultants, suppliers, intermediaries or anyone else) to give or receive bribes or gain improper advantages on behalf of MFEL by making payments to government officials in their individual capacity for the legitimate services of any government agencies, ministries, municipalities and other state bodies.
  • MFEL must not employ or enter into contracts with agents, distributors, consultants, intermediaries or anyone else to represent Company or its interests externally, without undertaking appropriate checks to assess the third party’s integrity.
  • The outcome of such checks must be considered carefully before deciding whether to appoint the third party. Various factors will determine what checks are appropriate, such as the nature of the potential service and the potential for corruption within the third party or the general environment/location.
  • Checks could include:
    • Verifying that companies are properly registered by obtaining legal registration documents.
    • Undertaking a legal review to identify recent or pending court cases against the company or its Directors.
    • Searching for media reports which may indicate impropriety by the company or individuals.
    • Ensuring directors have not been barred from holding Directorship.

Gifts & Entertainment Policy

Employees must adhere to the following requirements:

Gifts

  • The exchange of gifts must be actively discouraged in relationships with third parties.
  • Any gifts offered to, or received by, MFEL employees or those working on our behalf must be declined or returned wherever possible.
  • Where ‘necessary’ – for example, because national custom requires it or offence might be taken – ‘token’ gifts may be offered or received, if of a nominal value of not more than Rs. 2000.
  • If an employee feels obliged to accept a gift that is more than a token, he/she must agree this with the Corporate/Unit HR.
  • Where acceptance is agreed, the Corporate/Unit HR will decide what to do with the gift, for example, put it in an employee raffle or give it to charity.
  • If acceptance is not agreed, he/she must return the gift.
  • Employees must keep a record of all gifts that they offer or accept that are more than ‘tokens’. This record must be available for inspection by management or Corporate Audit for upto five years.
  • Employees must always act in line with the spirit of this Policy.
  • Employees may accept on behalf of MFEL donations to recognised charities by third parties, if they are not solicited and it is clearly understood that there is no associated business- related obligation.
  • Corporate donations to charities that are part of an approved Company’s programme, such as a disaster relief appeal, can be made by MFEL.

Entertainment

  • Entertainment with a valid business purpose that is in the best interests of MFEL, can be offered or accepted, so long as:
    • It is not intended – and could not be perceived as intending – to influence decisions or create improper advantage.
    • It is in the form of a meal, attendance at, or participation in, a cultural or sporting event organised ‘team-building’ occasion, or similar responsible activity.
    • The usual business contacts for MFEL and the other third parties are physically present.
    • The value of the entertainment is in line with responsible business practice and customs.
    • Guidance on entertainment, including monetary limits/value that has been issued by management time to time must be considered. Any variations from this must be approved by Corporate/Unit HR in advance of the event wherever possible.
    • All entertainment provided by, or on behalf of, MFEL must be recorded and processed in accordance with the travel policy guidelines.

Prohibitions

  • The following prohibitions apply in all situations:
    • Gifts (whether offered or received) must not be in cash or a cash equivalent, such as lottery ticket ,gift certificates, loans, guarantees or any other granting of credit, shares or options.
    • Gifts and entertainment, including payment towards travel or accommodation ,must not be offered to any government or regulatory official or any employee of state-owned/controlled entities without the prior approval of the Legal department.
    • Gifts or entertainment must not be offered to, or accepted by, anyone involved in MFEL tendering or bidding activity.
    • Employees must not attempt to conceal or disguise gifts or entertainment given or received. This includes:
      • Accepting entertainment, including travel to or from events, during vacations. All entertainment accepted while on leave must adhere to this Policy.
      • Gifts/entertainment offered to, or accepted by spouses/partners or close relatives.
      • Use of personal funds to pay for gifts or entertainment.
    • Gifts and entertainment must not be solicited from his/her business contacts. Soliciting charitable donations for personal activities, for example:
      • Running a marathon, from your usual business.
      • Contacts, customers or suppliers, in their personal capacity, that is, using their personal money, is allowed but only if there is no suggestion of a business- related obligation.

Protecting MFEL’S Physical & Financial Assets, Intellectual Property

Physical assets/property

  • Employees must take care to ensure that all MFEL’s physical assets/property they come into contact with while working are not damaged, misused or wasted. (Physical assets/property includes factory and laboratory equipment, MFEL products or components, buildings, computers and company cars).
  • The head of each MFEL Unit/ plant must:
    • Identify potential hazards from activities and services on site.
    • Evaluate the risk of damage to site assets of such hazards and of any potential business interruption or liability that could result.
    • Take steps to reduce risks to an acceptable level , including takin appropriate insurance policies.

Financial assets

  • Employees must Protect MFEL’s financial assets – such as cash, bank accounts and credit cards – guarding against misuse, loss, fraud or theft.
  • Only authorise commitments, expenditure, borrowing or other financial transactions in line with his/her role/band as specified.

Intellectual property

  • Employees must report to the Legal Group any suspected counterfeit products or products/ packaging that strongly resemble MFEL’s own, and may infringe our copyright, trademarks and/or other intellectual property rights.
  • Employees must also report any product /packaging that may infringe MFEL’ patents and/or design rights to the Legal Group.
  • Employees who are researching, developing or preparing to launch new brands, sub brands,designs, inventions, advertising and promotional materials must inform Legal Group for protecting necessary trademarks, Copyright, design or Patent.
  • Employees under taking collaborative work with third parties must ensure a contract is in place, with appropriate clauses to protect MFEL’ intellectual property rights.
  • Employees must not remove MFEL’s physical assets/property from company premises without permission.

Health & Safety Policy

  • All employees at MFEL shall:
    • Comply with SHE manual.
    • Comply with health and safety procedures and instructions relevant to his/her work.
    • Help ensure that those all contractors and visitors at MFEL, are familiar with and follow applicable health and safety procedures and instructions.
    • Only under take work that he/she is trained at, competent, medically fit, sufficiently rested and alert enough to do.
    • Never under take work or related activity, such as driving, when under the influence of alcohol or drugs.
    • Stop any work that becomes unsafe or unhealthy.
    • Make sure he/she knows what to do if an emergency occurs at his/her place of work.
    • Promptly report to local management any actual or near miss accident or injury, illness, unsafe or unhealthy condition, incident, spill or release of material to the environment, so that steps can be taken to correct, prevent or control those conditions immediately.
    • Never assume someone else will report a risk or concern.
  • All Unit Heads at MFEL shall have an overall operational responsibility for health and safety policy implementation at their location. They must:
    • Establish and maintain an appropriate health and safety at work management system for their site, including the appointment of committees, managers, competent experts and a system for gathering employees’ concerns/ input.
    • Identify the health and safety hazards and manage/control risks arising from the site’s routine and planned operations, activities and services.
    • Regularly review and comply with.
      • All applicable local health and safety legislation.
      • Mandatory Safety, Health & Environment (SHE) Standards.
    • Develop site-specific health and safety improvement objectives and monitor performance, including an annual review of the management system’s effectiveness and adequacy.
    • Report mandatory Key Performance Indicators (KPIs) via Safety, Health and Environment (SHE) reporting system as defined in SHE manual.
    • Report all incidents, accidents and near misses in line with the SHE policy.
    • Maintain, communicate and test a site an emergency plan.
    • Ensure all employees, contractors and visitors receive information and training in health and safety relevant to their roles and activities.

Non-discrimation & Equal Opportunities Policy

  • All employees at MFEL shall be treated fairly and equally, without discrimination on the grounds of race, age, role, gender, colour, religion, country of origin, sexual orientation, marital status, dependants, disability, social class or political views. This includes consideration for:
    • Recruitment, redundancy, promotion, reward and benefits, training or retirement which must be based on merit and without discrimination on any of the grounds above.
    • All work must be conducted on the basis of freely agreed and documented terms of employment, clearly understood by and made available to the employee.
    • All employees must respect the dignity and human rights of colleagues and those they come into contact with as part of their jobs.
  • Employees shall be provided with a total remuneration package that meets or exceeds the legal minimum standards and remuneration terms established by legally binding collective agreements must be implemented and adhered to. Other than legally mandated deductions, all other deductions from wages must only be made with the express and written consent of the employee.
  • MFEL shall comply with legal requirements in relation to short term, casual or contractual employees. There shall be a clear and transparent system of employee and management communication that enables employees to consult and have an effective dialogue with management.
  • MFEL shall have transparent, fair and confidential procedures for employees to raise concerns. These must enable employees to discuss any situation where they believe they have been discriminated against or treated unfairly or without respect or dignity, with their reporting manager or an independent manager without fear of victimisation.
  • As part of employees’ obligation to respect the dignity and human rights of those they work with and come into contact with, he/she must not:
    • Engage in any direct behaviour that is offensive, intimidating, malicious or insulting. This includes any form of sexual or other harassment or bullying, whether individual or collective and whether motivated by race, age, role, gender colour, religion, country of origin, sexual orientation, marital status, dependants, disability, social class or political views.
    • Engage in any indirect behaviour which could be construed as sexual or other harassment or bullying, such as making offensive or sexually explicit jokes or insults, displaying, e-mailing, texting, or otherwise distributing, offensive material or material of a sexually explicit nature, misusing personal information, creating a hostile or intimidating environment, isolating or not cooperating with a colleague, or spreading malicious or insulting rumours.
    • MFEL must not use, or permit to be used, forced or compulsory or trafficked labour and child labour.

Safeguarding Information

  • Employees must:
    • Take personal responsibility for the proper use, circulation, retention, protection and disposal of MFEL’s information.
    • Use judgement to determine which MFEL’s information should be shared with and how it should be handled, being mindful at all times of the risks involved.
    • Distribute Company’s information on a need to know basis, ensuring that only appropriate employees and authorised third parties have access.
    • Ensure the proper use of mandated IT security tools and comply with IT security policy.
    • Take care not to disclose MFEL’s information when working in public places, including taking all necessary steps to protect documents and IT devices away from the workplace.
    • Ensure that there is an appropriate confidentiality agreement in place before sharing MFEL’s information with third parties. If in doubt seek the advice of Legal Department.
    • Ensure that all MFEL’s information is returned to the company upon termination of employment.
    • Notify his/her reporting manager if he/she knows or suspects a breach of confidentiality or other misuse of MFEL’s information, whether intended or not.
  • Employees must not:
    • Disclose MFEL’s information externally to third parties without authorisation.
    • Use MFEL’s information for anything other than a legitimate business purposes or as required by law.
  • Personal information relating to employees, consumers and other individuals shall be properly stored and consent must be taken from people in respect to usage of such personal information.
  • Restricted Information:
    • A small sub-set of MFEL’s information is classified as “restricted”, because it is potentially price sensitive (known as “Inside Information”) and/or; – deemed to be highly sensitive for commercial, legal or regulatory reasons to MFEL.
  • Employees having an access to any “Restricted Information” must:
    • Ensure that restricted information is clearly classified as soon as the information is generated or made available. Swift and proper classification is the responsibility of the information owner.
    • Ensure that a list of authorised users, internal and third party, is created and maintained (“restricted list”) and that users are aware of their obligation not to share restricted information with individuals not on the relevant restricted list.
    • Report immediately any suspected or actual misuse of restricted information to the information owner (and Company Secretary in the case of Inside Information).
  • Employees must not:
    • Distribute, share or discuss restricted information with anybody who is not on the relevant restricted list.
    • Add anybody to a restricted list without proper authorisation from the information owner.
    • If in doubt about how to handle any Company’s information, restricted or otherwise, employees must seek advice from their reporting manager and/or Legal Department.

Competitor’s Information & Intellectual Property

  • Competitors’ confidential information:
    • Employees must not seek to obtain competitors’ confidential business information.
    • If he/she acquires competitors’ confidential business information unintentionally, then it must not use it or forward it to anyone.
  • Competitors’ intellectual property:
    • MFEL respects the intellectual property of third parties, including competitors, suppliers and customers. Employees must not knowingly infringe the valid patents, design rights, trademarks, copyrights and other intellectual property rights of any third party.

Personal Data & Privacy

  • Personal data must:
    • Only be obtained from the individual, or from third parties with the individual ’s permission.
    • Be adequate, relevant and used solely for the purpose it is collected for.
    • Be kept up to date and inaccurate data must be corrected.
    • Be kept confidential and secure with paper copies locked away.
  • Personal data must not be:
    • Excessive in relation to the purpose for which it is collected.
    • Retained for longer than necessary to achieve the business objective or meet legal requirements.
    • Shared, internally or externally, unless this is core to the process for which it is collected or as required by law.
    • Moved outside the country of origin, without advice from the Legal Group, as there may be legal restrictions.

Employee’s Responsibility

Innovation

  • Employees involved in innovation activity at MFEL must:
    • Comply with all applicable laws, regulations and industry and be familiar with those that are relevant to their area of work.
    • Ensure that the risks for consumer safety, occupational safety and the environment (safety and impacts) are assessed and managed as defined.
    • Safety is non-negotiable. Ensure that new specifications of raw materials, products and packaging.
    • Comply with relevant standards & SOP in this regard is followed strictly.
    • Ensure that our rights to exploit results are secured.
    • Company’s Intellectual Property Rights must be protected in collaboration with Legal department.

Marketing

  • Employees who are involved in any marketing activities at MFEL must:
    • Comply with all applicable laws and regulations and industry codes. All MFEL promotions must show respect for people who choose not to buy our products.
    • Describe our products and their effects truthfully and accurately, with appropriate factual and nutritional information.
    • Ensure consumers and customers understand how to use our products.
    • Provide clear information on all our products about the presence of specific allergens, by labelling or offering further information on request.
    • Respond sensitively to promotions or advertising from different cultural, social, ethical and religious groups.
    • Reflect generally accepted contemporary standards of good taste and quality, showing awareness of both wider society and a sensitivity to local and cultural variations.
    • Respect private data used for marketing and commercial purposes.
    • Ensure that relationships and financial commitments towards third party agencies are in line with governance rules.
    • Be mindful of the environmental implications of marketing activity, in such areas as new product development, marketing activation plans, packaging and content recycling.
  • Employees involved in marketing activities must not:
    • Associate MFEL brands with – or feature– themes, figures or image likely to be considered offensive, demeaning or disrespectful to any religion, nationality, culture gender, race, minority or people with disability.
    • Advertise in any media that are known for portraying violence, pornography or insulting behaviour.

Product quality

  • Employees involved in the development, procurement, engineering, manufacturing, distribution, marketing and sales of our products must:
    • Implement all Quality Management Standards and follow Quality Manual in spirit.
    • Improve quality performance through systematic application of structured continuous improvement.
    • Protect Company’s brand equity by effectively managing food safety laws, other legal requirements and ensuring regulatory compliance of MFEL products.
    • Reduce quality risks through maintaining and applying a system of Hazard Analysis and Critical Control Points (HACCP).
    • Design quality requirements into products during innovation and development of new products, processes and packaging through application of prescribed standards and tools.
    • Manage business partners, including suppliers and third party manufacturers and logistics providers so that supplied raw materials, packaging components, finished goods and promotional items meet Company’s quality specifications and requirements.
    • Manufacture and distribute Company products to always meet customer, industry and Company requirements.
    • Ensure facilities and equipment are fit for purpose and able to produce, store and transport products to meet quality standards.
    • Maintain processes to locate and trace products quickly and effectively, across the supply chain in the event of a product non-conformance action or recall.
    • Apply MFELs incident management procedure to retrieve non-conforming products from the market place.
    • Apply an effective process to capture and respond appropriately to consumer and customer contacts Including mechanisms for establishing root cause, corrective actions and implementation of preventative steps.
    • Apply an effective process to record and measure quality parameters and data.
    • Ensure they have the required knowledge before taking decisions that impact quality.
  • Employees involved in quality activities must not:
    • Knowingly produce or distribute products, including promotional items, or services that could endanger employees, customers, consumers and/or MFELs brand reputation.
    • Ignore any information regarding potential /actual product quality/safety. These must be discussed with reporting managers immediately.
    • Falsify or hide quality measurements, data and results.
    • Take decisions about quality if they believe they do not have sufficient knowledge or skill.
    • Respond to customers or consumers about the quality/ safety of products unless you are authorised to do so.

Sourcing

  • Employees who contract and/or work with MFEL’s suppliers must:
    Read and understand the fundamental principles (see below).
    • If he/she realises, or suspects, suppliers are not meeting the requirements within the Responsible Sourcing Policy.
    • Sourcing Policy, notify his/her line manager/supervisor and, if appropriate, the relevant Supply Management business partner.
    • Ensure that any shortlist or tendering processes for new suppliers, for which the employee is responsible, consider potential suppliers credentials in the areas covered by the Responsible Sourcing Policy.
    • All Purchasing Agreements/ Contracts (UPAs/UPCs), Master and Local Purchase Agreements (MPAs/LPAs) or Master Services Agreements specify that suppliers must acknowledge adherence to our Responsible Sourcing Policy as a condition of supply.
    • The standard clause states that “Each Supplier and the Supplier’s Parent company acknowledges that it has reviewed Company’s Responsible Sourcing Policy (“RSP”) and agrees that all of their activities shall be conducted in accordance with the RSP. The Buyer may from time to time carry out an audit or other checks on RSP compliance either per formed by it or any third party and each Supplier shall respond promptly to requests from the Buyer for information relating to compliance with the RSP by it.”
    • Employees who contract and/or work with suppliers must not agree to any changes in this clause or its exclusion from any contract without the prior written authorisation of Head – Legal.

Fair Competition

  • All employees at MFEL must:
    • Follow requirements regarding competition law compliance. Not in any event form a Cartel.
    • Consult the Legal Department immediately if you are unsure about the legality of any activity that may involve anti- competitive conduct.
      • Where possible, always consult the Legal Department before you attend a meeting or agree something about which you have concerns.
  • Events involving competitors:
    • Participation in industry or trade associations can be useful and legitimate, but you must take care that any contacts made are not used for anti-competitive purposes. This also applies to less formal meetings or events that involve competitors, such as awards ceremonies, social contacts.
    • Before going to a trade association or industry event, you must have had the relevant compliance training and received your reporting manager’s approval to attend.
    • At such events, you must object immediately if inappropriate topics are raised and leave immediately – and noticeably – if the inappropriate discussion continues.
    • You must report such incidents immediately to your reporting manager and the relevant Legal business partner.
    • Employees must not participate in cartels. You must not discuss or agree any of the following, directly or indirectly, with competitors:
      • The price or terms of sale for products and/or services.
      • The price or terms to be demanded from suppliers.
      • The co-ordination or allocation of bids or quotes.
      • Limitations on production or sales.
      • The division or allocation of geographic markets, customers or product lines .
      • Boycotts or refusals to deal with certain competitors, customers or suppliers.
      • Legitimate joint purchasing arrangements that have received prior written approval from the Legal Group are excluded from the above.

Contact With Government, Regulators & Non-governmental Organisations (Ngos)

When interacting with government, legislators, regulators or NGOs, Company employees (or anyone acting on Company’s behalf) must:

  • Be appropriately trained and authorised by senior level management.
  • Be courteous, open and transparent in declaring your name, company, role, status and, for any enquiry or ‘representation’, the nature of the subject matter.
  • Take all reasonable steps to ensure the truth and accuracy of your information.
  • Keep a record of all contacts and interactions.

Political Activities & Donations

  • Employees must ensure that your:
    • Contributions towards, and support for, political parties are clearly personal and give no impression of being connected to MFEL.
    • Personal political support or contributions do not affect your performance or objectivity at work.
    • At times, MFEL employees are allowed to take part in social or economic advisory groups set up by governments or political parties. Participation in such advisory groups must have the prior approval of the CEO. Approval will only be given for groups whose work relates to areas supporting MFEL’s corporate vision.
    • Such groups must include a cross section of well-known peer companies, national charities, non-political think-tanks, research organisations and representatives of academia, or similar such bodies.
    • The work must be non-political and be publicly communicated as such by the advisory group.
    • MFEL must not, directly or indirectly, support or make contributions to political parties or candidates. Communication, financial contributions, benefits in-kind, gifts, sponsorships and use of Company resources are all prohibited.
    • Involvement in the type of social or economic advisory groups mentioned above must not create a conflict of interest for employees.

Media (Print, Radio, Television, Social) Communication

  • Employees must promptly report emerging issues of potential Media and public sensitivity relating to MFEL to Head – Marketing or to directly to CEO
  • Media response shall only be released by Head of Corporate Communication in consultation with CEO
  • If any Employee requires the release of information to Media, they will consult the Head of Corporate Communication who will assist in drafting an appropriate Media release or statement for approval by the Chief Executive Officer.
  • If you are not part of the Designated Person, you must not communicate with the media, either on or off the record, unless you have received authorisation from one of the Designated persons and have received appropriate training/briefing.
  • You must not communicate proactively with, or respond to enquiries from, the media, without having had authorisation. All enquiries must be directed to the Head – Marketing / CEO.
  • You must not get drawn into conversations, answer any questions or provide any information or opinion.
  • You must not allow any media person to enter the office premises to video / photo shoot or interview, without written permission of Designated Person.