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Annual Report 2016-17

137

3. Governance related to BR

a. Indicate the frequency with which the Board of Directors, Committee of the Board or CEO to assess the BR

performance of the Company. :ithin 3 months, 3-6 months, Annually, More than 1 year.

– :ithin 3 months

b. Does the Company publish a BR or a Sustainability Report? :hat is the hyperlink for viewing this report? How

frequently it is published?

– The Company publishes its Report on the Activities of Persistent Foundation on a yearly basis and it is

published on the Company website i.e.

'https://www.persistent.com/investors/annual-reports/'

Section E: Principle-wise performance

Principle 1

Policy relating ethics, bribery and corruption

1.

Does the policy relating to ethics, bribery and corruption cover only the company?

All companies under Persistent Group are covered by the policy relating to ethics, bribery and corruption.

2. Does it e[tend to the Group / Joint Ventures / Suppliers / Contractors / NGOs / Others?

Yes, all companies forming part of the Persistent group are covered by the policy. However, the Company has a

separate Code of Conduct for its Vendors / Suppliers / Contractors / NGOs wherein these principles are being

covered for them.

3. How many stakeholder complaints have been received in the past onancial year and what percentage was

satisfactorily resolved by the management? If so, provide details thereof, in about 50 words or so –

During the onancial year 2016-17, the Company has not received any complaint from its shareholder and / or other

stakeholders.

Code of Conduct

Company’s Code of Conduct (also referred to as the ‘Code’) outlines its commitment to ethical standards and compliance

with applicable laws. Company’s Code is based on its values and clarioes the ethics and compliance e[pectations for

everyone who works for the Company. The Code includes sections on operating safely, responsibly and reliably its

people its business partners the Governments and communities the Company works with and its assets and onancial

integrity. The Code takes into account key points from the Company’s internal standards related to anti-bribery and

corruption, anti-money laundering, competition and anti-trust law and trade sanctions. The Company conducts due

diligence on all its vendors and customers in accordance with these policies.

Whom the Code of Conduct applies to

The Code applies to every employee of the Company and its subsidiaries and the endeavor is to e[tend this Code

to all its contractors and business partners. :here feasible, the Company seeks a contractual commitment from its

contractors and business partners to comply and work in line with the Code. :here the Company has the right to do

so, it may consider terminating contracts where a contractor has not complied with the obligations or not renewing a

contract where a contractor has acted in a manner that is not consistent with the Company’s values or the Code. The

Company rigorously follows ethical business decisions, ensuring the actions of all its employees, vendors, business

partners and customers are consistent with the law.

The Company collaborates closely with all stakeholders in order to initiate and foster fair business practices in all

spheres of business to create and sustain an ethical and transparent environment.

Certifying the Code

Each year, the Company engages its employees in Code of Conduct certiocation. It is embedded in the annual performance

contract of all employees to comply with the Code and to create an environment where people can conodently raise

concerns without fear of reprisal. The compliance with this Code by each employee is being monitored by the Company

on a regular basis.