Code Of Conduct for Employees
The purpose and our values
The Code of Conduct (hereby referred to as 'Code') sets forth Feeding India's core values, and shared responsibilities into practice. It is built around the recognition that everything we do in connection with our work at Feeding India will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical, as well as aspirational reasons. Our commitment to the highest standards helps us hire great people, build great products, and attract loyal users.
The Code sets out the values and integrity levels of business conduct that Feeding India expects all employees to abide by during the course of their employment at Feeding India and in all business relationships.
The Code cannot address every situation we face at work. Therefore, you are expected to exercise good judgment and seek help for guidance or clarification.
This Code should be read in conjunction with relevant Feeding India policies and procedures and applicable laws.
Your responsibilities
The employees will receive a copy of this Code at the time of joining Feeding India and each year thereafter. You are required to confirm your acceptance to adhere to the principles enumerated in this Code. Additionally, complete all the requisite training in a timely manner. You must remember that under no circumstances does your failure to:
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Read the Code
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Sign an acknowledgement or certify online
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Exempt you from your obligation to comply with the Code
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Read and understand the importance of the Code and follow it consistently
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Complete all required training(s) related to the Code and other Feeding India policies and procedures in a timely manner
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Know that violation of the Code will result in disciplinary action (and may include, but not limited to termination of employment)
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Use good judgment and demonstrate a high degree of personal and professional integrity and honesty at all times, even in situations that are not specifically addressed by this Code
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Follow the Code as a guideline for decision making that is paired with integrity
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Lead by example, by modelling ethical decision making
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Consider conduct in relation to the Code and other Feeding India policies
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Seek advice or clarification whenever unsure of the right thing to do
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Report known or suspected violations to appropriate channels, as soon as you become aware of it.
As a people manager, you should at all times model appropriate conduct.
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Promote a culture of ethics and compliance
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Ensure that your team members are aware of applicable laws, regulations, and Feeding India policies and procedures that govern the respective areas of responsibility/ work and receive adequate guidance and training to perform their jobs the ethical way, as prescribed in the code
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Create an environment of openness and trust where your team members feel secure and comfortable in asking questions and raising concerns, without fear of retaliation
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Discourage your team from achieving business results at the expense of compromising ethical conduct or compliance with the Code or the law
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Escalate any issues or concerns to the appropriate reporting channels in a timely manner.
If you have a concern and/or in doubt regarding any provision of the Code, you should seek clarification, from any of the below reporting channels:
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Your Manager
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Your Skip-level Manager
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Human Resources
This Code cannot possibly address every situation we face at work. Therefore, you are expected to exercise good judgement and seek help for guidance or clarification.
If you wish to raise a concern about actual or suspected violation of the Code, you are required to write to any of the below reporting channels, as you deem appropriate:
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Human Resources, in case of any violation which relates to personal grievances or your employment, such as (i) superior-subordinate relationship, (ii) relationship with peers, (iii) performance evaluations, and alike
• Speakup@feedingindia.org, if you believe you have faced any form of sexual harassment
• compliance@feedingindia.org, if you believe there is a violation of the Code (such as suspected fraud, bribery or corruption) which may be considered as a Reportable Matter
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Reporting Manager or Human Resources, in case the concern does not fall in any of the above
Compliance with Laws and Regulations
Feeding India is committed to full compliance with the laws, rules and regulations of the countries in which it operates. You must conduct business as responsible corporate persons, and must comply with all applicable governmental laws, rules and regulations. You should avoid any activity that could involve or lead to involvement in any unlawful or illegal practice or cause any harm to Feeding India's reputation or image or interest. You must acquire appropriate knowledge of the legal requirements relating to your duties/work/business to recognize potential non-compliances/ dangers. In case of doubt, you must seek help for guidance and clarification from the Compliance/ Legal team.
Free and fair competition
It is in Feeding India's best interest to promote free and open competition.
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You are obligated to deal fairly with merchants, suppliers and other Third parties engaging/dealing with Feeding India. You should not take unfair advantage of anyone through manipulation, concealment, or abuse of privileged information/position, misrepresentation, or any other unfair-dealing practice.
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Feeding India expects you to maintain a commitment to comply with the antitrust legislations and competition laws applicable to the purpose of Feeding India.
As a rule of thumb, you must not:
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Directly deal with, contact or engage with competitors that may create a potential conflict with the provisions of competition law.
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Share or part with Feeding India specific information in an industry forum or enter into agreements with competitors on any matter, unless done after due consultation with the legal department in advance; and
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Enter into agreements that may be constructed as abuse of dominance or restrictive trade practices, such as price fixation, exclusive tie-in arrangements, limiting the supply of goods or services, collusive bid rigging or predatory pricing.
Anti-Bribery and Anti-Corruption
Feeding India strictly prohibits bribery and corruption in any form. You must comply with all applicable laws relating to gifts, bribery, corruption, facilitation payments and other improper payments. However, even in countries where the local law does not prohibit such conduct, it is strictly prohibited by the internal policy of Feeding India for you to make any payment/s to any person or persons, including public officials, customers, merchants or consultants or any other Third party dealing with Feeding India, to obtain or retain business, influence business decisions or secure an unfair advantage. This includes bribes, kickbacks and facilitation payments.
We uphold all laws relevant to countering bribery and corruption applicable to us in the conduct of our business across all the jurisdictions in which we operate including, wherever applicable, the Prevention of Corruption (Amendment) Act, 2018 and its amendment (PCA); and the Foreign Corrupt Practice Act, 1977 (FCPA);
Anti-Money Laundering and Anti-terrorist financing
Money laundering is the process by which funds generated from criminal activity such as drug trafficking are moved through legitimate businesses in order to hide their criminal origin. Terrorist financing refers to funding for terrorist activities and can come from legitimate or criminal sources.
Feeding India only associates with entities and individuals involved in lawful business activities with funds derived from valid sources and not with those who may be involved in criminal activities or are part of any sanction list. Feeding India is committed to complying fully with all anti-money laundering and anti-terrorism laws throughout the world.
You shall not engage in or aid or abet any other person to engage in the following prohibited transactions:
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Any financial transaction that promotes or results from criminal activity
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The receipt, use, diversion or concealment of the proceeds of any criminal activity
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Any act of terrorism, including providing financial support or otherwise sponsoring or facilitating any terrorist, activity or organization
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Any arrangement or dealing with a Third party, which is or has connection with a Politically Exposed Person (PEP) and/or sanctioned individual/entity
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Any arrangement that would result in a violation of this Code or other Feeding India policies.
Some forms of payments and payment related activities that have become associated with money laundering include:
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Payments using monetary instruments that appear to have no identifiable link to the customer or merchant or vendor
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Payments in cash
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Unusually complex deal structures, payment patterns that reflect no real business purpose, or unusually favourable payment terms
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Fund transfers to or from countries unrelated to the transaction or not logical for the customer
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Transactions involving locations identified as secrecy havens or areas of known terrorist activity, narcotics trafficking or money laundering activity
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Payment structures that appear to evade record keeping or reporting requirements (for example, multiple transactions below the reportable threshold amounts)
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Requests to transfer money or return deposits to a third party or unknown or unrecognized account.
Avoiding Conflict of Interest
Feeding India is committed to conducting business in a manner that ensures one's business judgment and decision making is not influenced by undue personal interests. Conflict of Interest (COI) may arise when a Feeding India employee places his or her personal interests above the interests of Feeding India and where such personal interests unduly influence business judgment, decisions, or actions.
Feeding India respects each one`s rights and choices and does not wish to interfere with their personal lives, however, avoidance of conflict is an important part of maintaining integrity and sustainability of our business and builds trust and support with our key stakeholders.
Feeding India employees in client facing roles including but not limited to Sales, Sales Support, Neutrality, Media Content and Client Servicing across all transaction/ business/function at Feeding India are prohibited from writing reviews and/or giving ratings or experiences in Feeding India from either their personal or Feeding India accounts. They are also not permitted to influence others to write biased reviews or give ratings.
A conflict situation could be actual or perceived and may be an event or circumstance when a person does or consciously fails to do an act which allows the person to derive personal gains.
If any of the key principles of COI are applicable to you, then you must disclose such interest to the Human Resource team here. It is pertinent to note that, disclosure must take place as soon as one identifies the conflict and whenever possible, but before engaging in the conduct in question. Business and relationships are dynamic and when circumstances change, existing disclosures may no longer be accurate or complete. When this happens, it is your responsibility to freshly disclose the conflict of interest.
This clause should be read in conjunction with the Conflict-of-Interest policy.
Dealing with Third parties
Feeding India is committed to the highest ethical standards in dealing with Third parties. Dealing with Third parties (including but not limited to, service providers, consultants, merchants, distributors, contractors, vendors, suppliers, or other Third party, whether an individual or an entity, who is employed on a contract basis, or retained to assist Feeding India in any function of the business) should be in a fair and ethical manner.
You must adhere to the following:
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Safeguard the confidentiality of all Third-party intellectual property and data and shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable Feeding India policies or law.
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Understand the business rationale, including its business reputation, and select them on merit basis fairly and transparently.
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Maintain accurate and complete official records with the utmost integrity. All agreements and transactions should be documented. Ensure all Third parties (e.g., merchants) are made aware of the need to comply with the applicable Feeding India policies and guidelines and report any violation thereof.
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Disclose any personal relationship with a potential Third party to your reporting manager and HR POC to ensure they are not involved in the selection process and negotiations.
Feeding India would not be responsible for any misconduct or misbehaviour on your part in an interaction with any Third parties (customers, merchants, vendors). It shall be your responsibility to ensure they do not exhibit any such behaviour.
Protection of confidential information
You should exercise enough safeguards and protect confidentiality of Feeding India's information, which includes everything from business plans, financial projections, strategy, contracts, pricing, contacts, relationships and personal information. Feeding India information should be shared only on a 'need-to-know' basis, that is, to the extent the information is needed to perform their job/work responsibilities.
Payroll information
All compensation matters are privileged and to be kept confidential. You must ensure that information about salaries, appraisals and bonuses are not disclosed to other people within or outside Feeding India.
Unauthorized use of confidential information
You shall not disclose or use any confidential information gained in the course of employment or association with Feeding India for personal gain or for the advantage of any other person. No information either formally or informally, shall be provided to the press, other publicity media, or any other external agency, except by the authorized representative. It is strictly forbidden to trade confidential information or insider's information for individual gain, or to benefit or to put Feeding India's interest in jeopardy.
Use of Feeding India Assets
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You are responsible for protecting and taking necessary steps to prevent the theft or misuse of, or damage to Feeding India's assets and property. The assets include all kinds of physical assets, movable, immovable and tangible property, corporate information and intellectual property, such as inventions, copyrights, patents, trademarks and technology.
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Feeding India's assets and property should be used only for the benefit of Feeding India and in the manner intended. Certain Feeding India policies may allow additional personal use of certain assets, such as a Feeding India provided phone. In using such assets, you are expected to exercise prudent judgment and avoid excessive personal use.
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You are solely liable for any losses incurred by Feeding India in case of damage/loss/theft of these assets.
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Any suspected incident of fraud, misuse or theft should be immediately reported for investigation.
Email, Internet and Information Systems
Feeding India's information technology systems constitute a critical component of our business operation and are provided for authorized business purposes only. Use of these systems must comply with our internal policy and acceptable use standards.
You may engage in reasonable incidental personal use of phone, email and the internet, as long as such usage does not:
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Consume a large amount of time or resources.
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Interfere with your work performance or that of others.
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Involve illegal, sexually explicit, political, discriminatory or otherwise inappropriate material
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Relate to outside business interests.
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Violate our Code or any Feeding India policy.
While it is generally not our practice to monitor Feeding India's employee use of our information systems, Feeding India reserves the right to monitor, record, disclose, audit, and delete without prior notice the nature and content of any Feeding India Employee's activity using Feeding India's email, phone, voicemail, internet, and other systems, to the extent permitted by local law.
Upholding Financial Integrity and Record keeping
Feeding India shall prepare and maintain its accounts fairly in accordance with the generally accepted accounting principles, guidelines, financial accounting standards and applicable regulations from time to time. All business and financial transactions must be authorized and recorded in accordance with the internal approved finance document.
All books of account, financial records, reports and other financial documents of Feeding India must be accurate and preserved in good order and may be disposed of by the Finance Department as per Information storage, archival policy. You are expected to demonstrate integrity, professionalism and due diligence in maintaining accurate records of all financial transactions (e.g., expense reimbursement forms, disclosure forms etc.
Interaction and cooperation with Auditors
Our outside auditors have a duty to review our records in a fair and accurate manner. We must cooperate with them in good faith and in accordance with the law. We must never mislead them in any manner regarding financial records, processes, controls or procedures or other matters which they may enquire about.
Interaction and cooperation with Regulators
We must fully and truthfully cooperate with any examination or request for information from a regulator or law enforcement agency or other investigation consultant/ agency, if any, as appointed by the management. Only authorized representatives from the legal team will be the point of contact for any communication or flow of information to the regulator, law enforcement agency or others, if any.
External Communication and Media
Feeding India does not prohibit Feeding India employees to use social media; however, it is recommended that you use it meticulously and responsibly, in order to avoid damaging the brand`s image and reputation or disclosing any confidential information of Feeding India.
All your communication and expression on social media should be followed by a social media disclaimer, as below, in order to give the impression that you are not speaking or posting on behalf of Feeding India.
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All views, posts and opinions shared are my own;
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All views are obviously just mine; and
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All views are personal.
Feeding India shall carefully review the public disclosures, such as press release(s), financial statements, annual reports, and external website content, before they are released to the external parties (media, stock exchanges, investors, lenders, business partners and others ) and public to ensure they are truthful, accurate, appropriate, and compliant with applicable laws and regulations.
All inquiries or calls from any external parties should be referred to the Corporate Communications team.
Marketing
Marketing is an essential instrument for effective brand building and communicating with all stakeholders. We strive to ensure that our marketing activities are truthful, accurate and are done ethically.
Our marketing activities, displays, and promotions must always be appropriate and sensitive to the culture public in the country in which they are is shown and should avoid political or religious remarks, which may be offensive or defamatory.
In case of doubt regarding the marketing activity, displays, and promotions, that it may be construed as misleading or hurt sentiments, you must seek help for guidance and clarification from the Legal team.
Political activities
Feeding India is an apolitical organization.
Feeding India respects your right to engage in political activities in personal capacity, provided you do not act, or give the impression of acting, as a representative of Feeding India and do it solely in your personal capacity. You are prohibited from directly or indirectly utilizing any Feeding India resources for personal political activities, including but not limited to funds, facilities or any property, or the working time of any FI employees, except as authorized by relevant local Feeding policies or procedures. You must not be a part of or join an extremist's organization.
Feeding India's outlook towards driving social change is governed by two key principles:
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Feeding India is an apolitical organization, and has no political affiliations/ aspirations whatsoever; and
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Feeding India cares for the society, but also strongly believes in the saying, "your opinions don't matter, your actions do".
As a Feeding India, you are prohibited from making, sharing, criticizing or endorsing any politically favoured statement on any of your social profiles. In case you post any such message you should clearly state that views are personal and not of Feeding India.
Feeding India believes that its employees will act with utmost integrity, however, if at times, the Investigation team has reasonable cause to believe that an employee has failed to comply with the requirements of this Code or other Feeding India policies and procedures, they shall inform him/her of the basis for such belief and afford him/her an opportunity to explain the reasons for the same.
FI employee must know:
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We take every concern seriously and our Investigation team (or a delegate for locally managed or other matters) will investigate it thoroughly to determine whether it is qualified for further investigation;
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If yes, the Investigation team shall conduct such investigation in a timely manner and shall submit a written report containing the findings and recommendations in the shortest time possible, not later than 60 days from the date of receipt of the concern;
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The Investigation team will treat all complaints in a confidential and sensitive manner.
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All investigations conducted will be concluded by way of an investigation report.
This clause should be read in conjunction with the Vigil Mechanism & Whistleblower or Sexual harassment policy, as applicable.
Action for Non-observance
If the Investigation team arrives at the conclusion that the allegation has been proved, it shall recommend actions, which may include one or more of the following:
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Written apologies
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Warnings
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Reprimand or censure
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Withholding of promotion
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Withholding of pay increments
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Termination of employment
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Recovery
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Legal action
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And any other action, the investigation team deems fit.
Confidentiality
Upon the request of the complainant, the Investigation team will use its best efforts to protect the confidentiality of the complainant for any good faith report. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Prohibition against retaliation
Feeding India strictly prohibits any reprisal, threats, retribution or retaliation against any employee who has in good faith reported a violation or a suspected violation of law, this Code or other policies or practices of Feeding India, or against any person who is assisting in any investigation or process with respect to such a violation. Any employee who retaliates against someone who has reported a violation in good faith will be disciplined, which can include termination of employment.
Acting in good faith
Any good faith report, concern or complaint is fully protected by this Code, even if the report, question or concern is, after investigation, not substantiated. Anyone filing a complaint concerning a violation/ misconduct or suspected violation/ misconduct must act in good faith and have reasonable grounds for believing that the act reported indicates a violation of the Code or other policies. Any allegations that are proven to be unsubstantiated and found to be malicious in nature, will be treated as a serious disciplinary offense.
No waiver and amendments of any of the provisions of this code shall be valid unless they are specifically approved by the Head of Feeding India.
Contact us
If you have questions about this donor privacy policy or requests about the status and correctness of your donor data, please contact us at contact@feedingindia.org
