Sharekhan has an established set of codes of professional ethics to help guide its staff in performing their functions according to sound and consistent ethical principles. These are the policies and procedures that govern the behaviour of all Sherus. These have already been communicated to you. Today, we have consolidated the key points of each of these policies for your easy reference. It always helps to have the golden rules of professional ethics handy.

A ready reckoner of Sharekhan’s policies on professional ethics

Group Code of Conduct and Addendums to the Anti-Bribery and Corruption Policy

1. You are expected to adhere to the BNP Paribas Group’s Code of Conduct all the time.
2. The Group Code of Conduct sits at the heart of every action. It guides all decisions at all levels of the organisation. As such, all internal policies and procedures within the Group will be reviewed and made consistent with the Code, if deemed necessary.
3. The Code of Conduct comprises three parts. The first section, on Mission and Values, is intended to guide and inspire all behaviours. The second section covers the Rules of Conduct to be shared and implemented. The third section, called the Code of Conduct in Practice, provides helpful guidelines on how to apply the Rules of Conduct.
4. The Group and its employees must have zero tolerance for corruption and influence peddling, and will pro-actively fight them and such corrupt practices including bribery and influence peddling are entirely prohibited and must be promptly reported.
5. Employees have an obligation not to take any part in corrupt practices, they are bound by their professional duty to do everything within their power to help prevent bribery and influence peddling, and to put a stop to it if they become aware of it. Taking part in corrupt practices constitutes a professional misconduct. Any employee who acts in a manner contrary to this Code of Conduct faces disciplinary action.

Gifts and Invitation Policy

1. The “Reasonable Amount” is Rs.3,000/- (three thousand rupees only) per individual per calendar year for gifts and invitation given/received.
2. Gift or invitation, in any form, to government officials, regulatory authorities, public bodies of any jurisdictions etc. is prohibited unless specifically approved by the business/function head and the Head of Compliance.
3. No Gift or Invitation exceeding Rs.3,000 can be given/received unless approved by the function head and the Compliance Officer.
4. Offering/receiving cash or cash equivalent gifts to/from clients respectively is strictly prohibited.
5. Festive gifts (eg hampers) received from clients are generally allowed, provided that the gifts are not, in the reasonable sense, considered to be of excessive value. The staff are encouraged to share such gifts with their team members. Any gift in excess of the reasonable amount has to be approved by the business head and the Head of Compliance.
6. Register with the Compliance department any gift or entertainment which is below or beyond the identified “Reasonable Amount” Rs.3,000/-. (Gifts & Invitations Register)
7. It is strictly prohibited to solicit any gift or invitation in the broadest sense from any client, supplier or tied agent.
8. Gifts given to a family member or close relation of staff, regardless of their monetary value even if these are of Reasonable Amount (except invitations to leisure activities). It is forbidden for the staff to entertain clients at the staff’s residence or any place of residence.
9. G&I employee approval form (G&I Approval Form).

Outside Business Interest Policy

1. If you hold or wish to hold a corporate office on a private basis, ie if you are engaged or wish to do any activity other than your employment in Sharekhan, you are required to declare and obtain an approval from the Compliance Officer as per the process mentioned in the procedure.
2. In commercial companies (commercial companies are those that keep full accounts, draw up annual financial statements, have a workforce of more than 5 persons, have a turnover in excess of approx Rs.2 crore or have a total balance sheet of approximately Rs.8 crore) or EIGs, it is required to declare this information and to collect a definite approval of Sharekhan according to the process resumed in Appendix 2 and the notification is made to the Head of Compliance.
3. As a general rule, you are exempt from the declaration procedure if you hold a corporate office on a private basis and it involves an entity other than those referred to Point 2-1 in the procedure. However, a declaration must be made if it relates to: (a) A legal entity in which the Group / Sharekhan also has an interest (in terms of capital or as an agent); (b) a legal entity that has a commercial relationship with a BNP Paribas Group entity within which the employee who is a corporate officer performs his/her professional activity; and (c) a legal entity that is listed on a stock exchange in any market.
   With regard to these exceptions, the corporate office must be declared and authorisation must be obtained in accordance with the procedure described in Appendix 2.
4. Employees have to submit Appendix 1 duly filled to the Compliance department, which would approve or reject the same based on the evaluations of parameters provided in the procedure. For example, the following do not need to be declared: offices in family-owned property, investment companies constituted under civil law, forestry units, agricultural land grouping and in associations that do not meet the criteria set in Point No 2.

Whistleblowing Policy (updated version)

1. This policy encourages all employees to report any proven or suspected breaches or concerns. It defines the scope of whistleblowing and provides the contact details.
2. If you observe any suspected bribery, corruption or related unethical issues, please do not hesitate to escalate the matter through our whistleblowing channel.
3. The staff shall not be penalised or subject to any discriminatory measure, directly or indirectly, in terms of recruitment, remuneration, promotion, training, assignment or re-assignment for making reports in good faith.
4. Know who has whistleblowing rights: Any natural person, permanent employee or temporary staff and any external staff is authorised to use the group’s whistleblowing framework for reporting.
5. Find details of the Whistleblowing procedure here Sharekhan-L3-Whistleblowing Instruction
6. Check the process for reporting a concern.

Conflict of Interest Policy

1. All staff (and their close relations) must refrain from purchasing or selling goods or services of any kind on the basis of confidential information obtained from a client or the company, another employee or an external party.
2. All staff (and their close relations) must refrain from taking a personal interest of any kind in a transaction carried out by Sharekhan, whether with a client or for its own account, or by a client unless they have prior written authorisation from the head of their operating unit and from the Compliance department.
3. The staff must not enter into business relations with counterparties who have not been approved by Sharekhan. Entering into business relationships with an intermediary on the basis of a personal relationship may expose the staff to conflicts of interest or situations involving corrupt practices.

Procedure for Professional Knowledge

1. This purpose of this procedure is to create awareness about the importance of client service quality and provide the staff with sufficient training in client relation management.
2. It is important:
   1. To ensure that the staff have the appropriate qualifications and expertise.
   2. To check that they have the relevant basic knowledge to perform their duties as quickly as possible, ie within the timeframe defined by the business line managers concerned or the local regulations, if any. In any event, it would appear reasonable to require that all the staff gain the necessary knowledge within six months of taking up their posts, as a general rule.
3. The mode of acquisition of the necessary knowledge (eg existing training programme through e-learning, external or internal seminars etc, reference books, professional practice) and specify the organisation selected to integrate the newly recruited employees as well as to update their knowledge periodically.

Global Anti-Corruption Policy

1. To maintain the highest level of ethical standards BNP Paribas adopts a complete zero-tolerance policy on bribery, corruption and related unethical issues. As such, we would like to draw your attention to the group’s Global Anti-bribery and Corruption, Gifts and Invitations, and Whistleblowing policies.
2. SAPIN II and updated Global Anti-Corruption Policy:The French law for fighting against corruption, namely “Sapin II”, was published in late 2016. The law has an extraterritorial reach which obliges large corporates, like BNP Paribas and their representatives, to put in place a framework for preventing and detecting corruption. French Anti-Corruption Agency is empowered to penalise individuals and the bank if non-compliance is detected.

All the policy documents are available on Sharekonnect, the HR intranet. (http://sharekonnect.sharekhan.com/)

All employees are requested to comply with all the policies at all times.

If you have any queries write to us at eit@sharekhan.com or call us on 022 6226 3315/3314.

Professional ethics follow kar, Sharekhan kar

Team Compliance