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Last Updated: [14/03/2024]
I. Objective and Purpose:
To create enduring value for all stakeholders and ensure the highest level of honesty, integrity and ethical behaviour in all its operations, the Company has formulated this Whistle Blower Policy (herein referred to as “Policy”) in addition to the existing Code of Conduct that governs the actions of its employees.
This policy aims to provide an avenue for employees to report suspected or actual occurrence(s) of illegal, unethical or inappropriate events (behaviours or practices), any violations of Company policies, regulatory requirements, incorrect or misrepresentation of any financial statements and reports that affect Company's interest /reputation.
Livspace encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment.
II. Definitions
“Employee” means any person on the rolls including those on deputation, contract, temporary, probationer, apprentice, trainee, part time employees/ workers, full time consultants, holding permanent, honorary, ad hoc, voluntary or short-term positions. For the limited purpose of this policy term “Employee” includes vendors, agents, contractors, suppliers, customers and generally anyone who has business relationships with the Company.
“Whistle Blower” is an employee who raises a concern about any wrongdoing, event or information about an actual, suspected or anticipated Reportable Matter. The Whistle blower is not expected to prove the truth of the allegation; but they need to demonstrate sufficient grounds for concern and good faith.
“Whistle Blower Officer”: For the purpose of this Policy, Whistle Blower Officer will be the Head of Internal Audit, Risk & Compliance.
“Participant” shall have the meaning ascribed to it in paragraph [X] of this Policy.
“Subject” is a person or a group of persons who is the focus of investigative fact finding either by virtue of an allegation made by a Whistle blower or evidence gathered during the course of an investigation which is a result of a Whistle blower reporting an unethical/non-compliant action.
“Integrity Committee” shall have the meaning ascribed to it in paragraph [IV] of this Policy.
“Reportable Matter”/ “Disclosure”: Any communication made in good faith (with a genuine belief in the truth of the matter reported) that discloses information evidencing any unethical or improper action, wrongdoing, misconduct or violations of the Company Policies, any applicable laws, rules and regulations. An illustrative list of general malpractices that can be reported under this policy are as follows:
“Disciplinary actions” shall have the meaning ascribed to it in paragraph [XIII] of this Policy.
III. Exclusions:
1. Complaints related to Human Resources’ issue(s) such as compensation, performance, Prevention of Sexual Harassment (“POSH”), interpersonal relationships or complaints about work culture, etc. will not be covered under this Policy. All such issues to be directed to the respective HR business partners.
2. All customer complaints are to be referred to the respective support team or mail at care@livspace.com.
3. General personnel or administration issues that do not violate the Code of Conduct.
4. Complaints raised on matters which are pending before a court of law or any judiciary body shall not be investigated under this Policy.
IV. Constitution of Integrity and Investigation Committee
The Integrity Committee will comprise of Chief Executive Officer (CEO), Head of Corporate Development, Head of HR, CEO India (for central location) and Chief Business Officer (for all other locations) who can delegate the investigation to relevant stakeholders within or outside the organization.
The investigation committee will comprise members from Risk & Compliance team, HR Business Partner and/ or Legal who shall be responsible to conduct and conclude the investigation into the reported matters.
V. Reporting Channels & Procedures
A Whistle Blower can make a complaint in multiple ways:
1. Written complaint: A written, signed complaint may be personally handed over or posted to the members of the Integrity Committee. The written complaint can also be addressed to Head – Human Resources/ Company Secretary/ Head – Legal/ Head – Risk & Compliance at Livspace India Private Limited, 4th floor, Unit no. 404, RMZ Ecoworld Campus 32, Campus Series 30, Bhoganahalli Village, Bengaluru 560103.
2. Email complaint: A complaint can be sent to the Whistle Blower Officer at ethics@livspace.com or Head – HR or their HR Business Partner.
3. Reporting to the members other than Integrity Committee, whistle blower officer or Head – HR: A written report can also be handed over to the Whistle blower’s immediate or skip level supervisor or Head of the Department (in case there is no personal conflict of interest) or to any other official in the Company whom the Whistle blower can expect to have the responsibility to review the alleged activity. Such official shall forward the copy of the complaint to the Integrity Committee or Whistle blower officer or Head - HR within 5 working days of the original complaint being received.
4. In the event of an oral complaint received by any employee/ personnel from a whistle blower, details of such complaint received shall be informed to the personnel mentioned under above reporting channels within 5 working days. The onus for reporting is on the personnel who received the verbal complaint.
5. Additionally, in case the subject matter of the disclosure in any way involves anyone in the senior management, Integrity Committee member or Whistle blower officer, the Whistle Blower shall have the right to report, in writing, directly to the CEO of Livspace Group.
VI. Responsibilities of a Whistle blower:
VII. Assessment of Whistleblowing reports and Investigation
Conflict of interest management: If any of the Integrity Committee members, Whistle Blower Officer or any member of the investigation committee have a conflict of interest in any disclosure, they shall recuse themselves. The remainder of the members have the right to address the disclosure appropriately.
VIII. Responsibilities of the Integrity Committee
IX. Rights and responsibilities of a Subject
X. Conduct of the participants in an investigation
XI. Confidentiality
Note: If anyone is found not complying with the above, he/she shall be held liable for such disciplinary action as is considered fit by the Company.
XII. Protection of Whistle Blower
XIII. Disciplinary Actions
Where, after proper investigation, any employee is found guilty of misconduct, the investigation committee, in discussion with the Business team, shall have discretion to undertake appropriate disciplinary action. Depending upon the facts and seriousness of each individual case, action against the offender may include:
In case where any customer, vendor or any other business partner is involved in the violation / misconduct, the management shall consider the need to terminate the contract with such customer, vendor or business partner, blacklist the party for future associations, initiate proceedings for recovery of losses, if any and reporting to law enforcement/ initiating legal proceedings.
XIV. Reporting and Retention
The Whistle Blower Officer shall submit a report to the Integrity Committee on a regular basis (quarterly) or at such other frequency as may be deemed fit about all disclosures reported during the period with the results of investigations, if any. In case of any NIL complaints received, such update shall be provided.
All concerns raised in writing and the results of investigation thereof shall be retained by the Company for a minimum period of eight years.
Note: The reports of investigations performed will be provided to the Audit Committee once formed.
XV. Training and awareness
Annual refresher training is to be conducted to educate employees about the Whistle Blower Policy, its importance, and usage of reporting channels which is covered as part of Code of Conduct training. New joiners are mandated to complete the induction training within timelines prescribed by the Company.
This Policy is appropriately communicated to all employees, board of directors and third parties by way of displaying on the intranet (employee self-service portal) as well as the company website.
XVI. Interpretation and Amendment
The Integrity Committee has the right to amend or modify this Policy for non-critical changes and recommend amendment or modifications for critical changes to the Board of Directors for approval.
In the event of any conflict between the provisions of this Policy and any statutory enactments or rules thereunder, the provisions of such enactments shall prevail over this Policy.
XVII. References
Code of Conduct policy available on Employee Self Service portal
Code of Conduct – Business Partners available on the Company website
1. Vision
Our vision is to deliver a beautiful home for everyone with a never-seen-before experience and offer a happier experience to homeowners. At Livspace, we incorporate advanced technology into our modular solutions to create flawless interiors, simplify home design and also to expedite the process of making your dream home a reality.
The Code is designed to provide guidance to all our Business Partners regarding Livspace’s standards of integrity and compliance in our business dealings. This Code is an integral element of the Livspace ethos.
2. Scope
Livspace is committed to conducting its business in an ethical, fair, legally, socially and environmentally responsible manner. We believe that our Business Partners are an integral part of our ecosystem, and we encourage them to conduct their business by upholding the highest ethical standards, act with integrity and be responsible corporate citizens. Business relationships shall be based on trust, transparency, and mutual accountability.
This Code of Conduct (“Code”) applies to each and every Business Partner, irrespective whether consideration is involved in the engagement with the Company. The Code is centered on ensuring that all actions related to Livspace's work are measured against the highest standards of ethical business conduct.
The key areas of focus for this Code are:
(a) Governance and Ethical Business Conducts.
(b) Human & Labour Rights.
(c) Environment Management
For the purpose of this Code, “Business Partner” includes Business Partners/ dealers/ service providers/ vendors/ agents/ franchisee/ consultants /contractors/ sub-contractors/ third parties, acting directly and/or through their representatives, engaged by Livspace, in normal course of business.
(A) Governance and Ethical Business Conduct
(i) Compliance with Laws
Business Partners shall ensure compliance with all applicable local laws and regulations including those related to domestic and international trade, data privacy & personal information protection, and anti-trust/ competition laws/ industrial, labour and environment protection laws, to ensure that their dealings are conducted legally and with integrity.
(ii) Business integrity and ethics
Business Partners are expected to refrain from any form of unethical behaviour including theft, fraud, forgery, bribery, corruption, anti-competitive practises, extortion, or embezzlement. No Business Partners (including their immediate family members) are expected not to offer any bribes, gift or any other kind of direct or indirect benefits to Livspace employees or their appointed agents and vice versa. If a gift (including without limitation, travel or entertainment) is inadvertently sent or received it should be promptly returned by either side, with a note explaining that it's contrary to the Code.
The Business Partner must adhere to all applicable anti-corruption and anti-bribery laws and regulations in the jurisdiction where either the Business Partner or Livspace is based and operates, as well as any relevant laws and regulations from other jurisdictions that may apply to the transactions outlined in the contract(s) with Livspace.
All company-related expenditures involving meals, entertainment, gifts in normal course of business with business partners of amount above INR 5,000 per person or INR 50,000 in total must be pre-approved by the relevant workflow procedures, which include the Chief Financial Officer.
(iii) Anti-Money Laundering and Counter-Terrorist Financing
Money laundering involves concealing the proceeds of illegal activities or making illicit funds appear legitimate. Business Partners are expected to engage with reputable vendors and customers, ensuring all transactions are for legitimate business purposes with lawful funds. They should also be vigilant for 'red flags' in any suspicious payment transactions.
(iv) Avoid Conflict of Interests
Business Partners are expected to avoid participating in any business activity that can create a conflict of interest, actual or perceived. Business Partners are expected to have established measures to prevent any conflict of interest that improperly influences any business judgement. In the event, any conflict of interest arising at the time of prior/post/during engagement, Business Partners are required to promptly disclose such situations to the Company, even if it’s an actual or potential conflict.
If a relative or close associate of a Business Partner is an employee, executive, or director of Livspace and can influence business decisions related to the Business Partner, the Business Partner must disclose this information to legal@livspace.com or ethics@livspace.com. Failure to disclose will be considered a violation of the "Code" and may result in consequences.
(v) Quality
Business Partners are expected to provide goods and services that consistently meet the prescribed standards and are safe for their intended use and perform as intended. Business Partners must meet the specifications agreed upon in the applicable agreement, purchase orders or other contractual relationship with Livspace.
(vi) Privacy and Intellectual Property
Business Partners shall ensure that confidential or proprietary information about Livspace, our customers, employees or other parties, which have been gained through engagement with Livspace, is used only for its intended purpose as decided and agreed upon by Livspace and the Business Partner in a fair, transparent and secure way, ensuring protection of privacy.
Business Partners must protect Livspace’s intellectual property, including confidential and proprietary information of Livspace, its clients, customers, and other Business Partners. This information must be safeguarded from unauthorized use, damage, or disclosure using at least the same measures the Business Partner applies to their own confidential information.
Business Partners are prohibited from misusing or infringing Livspace’s intellectual property, including trademarks, copyrights, trade secrets, software, products, and other proprietary materials. They must not claim any ownership or rights to Livspace’s intellectual property. If using third-party intellectual property in dealings with Livspace, the Business Partner is responsible for ensuring proper authorization and legal rights to use it.
(vii) Financial and accounting practices
All financial and business records are crucial, and Business Partners must ensure their accuracy, integrity, confidentiality and retention, and comply with applicable laws as well as industry guidelines. They must not provide false or inaccurate financial information to Livspace or its clients.
All submissions made to Livspace, for example, invoices, orders, billings, reimbursement must be true and accurate and submitted promptly.
(viii) Anti-tax evasion
Livspace enforces a zero-tolerance policy on tax evasion and expects Business Partners to implement policies, procedures and measures preventing employees and associates from facilitating or committing it.
(ix) Competition laws and business dealings
Business Partners must compete fairly and ethically for all opportunities, ensuring that all statements and communications with Livspace are accurate, complete, and made by authorized representatives.
They must comply with all applicable competition laws and regulations, avoiding any agreements or practices that restrict competition, including cartel formation. Communications with competitors regarding sensitive topics such as prices and terms are prohibited, and any such exchanges may be considered a breach of this Code.
Business Partners should ensure that Livspace is not involved in any disputes and refrain from defaming Livspace, its partners, competitors, or clients. They are expected to adhere to fair business practices and antitrust laws, avoiding collusive bidding, price fixing, and other unfair trade practices.
(x) Data confidentiality, privacy and protection and Information Security
Livspace along with its group companies ensures that it complies with all applicable data protection laws and contractual requirements. Livspace is committed to uphold highest data protection and privacy standards with respect to all Business Partner data and Personally Identifiable Information also referred to as Personal Data.
Business Partners must comply with applicable laws and standards when processing Personal Data, including sensitive personal information. They are also expected to implement and maintain effective security controls to protect the confidentiality, integrity, and availability of all information shared with Livspace. For any concerns, Business Partners should contact privacy@livspace.com.
(xi) Insider trading
Livspace complies with SEBI (Prohibition of Insider Trading) Regulations, 2015. During the course of engagement, if the Business Partner becomes aware of any Unpublished price sensitive information (“UPSI”) relating to the Company, the Business Partners of the Company must not communicate such UPSI nor trade in securities of the Company that are listed or proposed to be listed when in possession of UPSI, in violation of applicable securities laws.
(xii) Cooperation in assessments
Business Partners are expected to fully cooperate with assessments conducted by Livspace, either directly or through a third party. They must provide documentation related solely to transactions between the Business Partner and Livspace. If any non-compliance is identified, corrective action plans will be proposed, with specified timeframes for implementation and progress monitoring.
(xiii) No representation
Business Partners are prohibited from making claims, representations, or warranties on behalf of Livspace to any third party, and do not have the authority to bind Livspace or create obligations unless explicitly authorized in writing.
The Livspace logo is a key symbol of our products and services. Business Partners may not use the Livspace brand, logo, or any related visuals without prior consent. Any media comments or reports regarding their engagement with Livspace must be approved in advance, including the content and details of usage. Business Partners must not make misrepresentations or unauthorized commitments on behalf of Livspace and must respect the privacy of Livspace’s customers and clients.
(B) Human and Labour Rights
(i) Child and Forced Labour
Business Partners shall not employ any labour/workmen less than 18 years of age or use forced labour. Livspace does not engage with Business Partners employing child or bonded labour or those that use any form of mental or physical compulsion as a form of discipline.
(ii) Anti-Discrimination and Fair Wages
Business Partners shall not engage in any discrimination or distinction, exclusion, or preference made on basis of race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, national origin, or marital status in all aspects including hiring, promotions, assignments, wage hikes, training, and termination.
Clear communication with workers regarding compensation, including minimum wages, wage deductions, working hours, overtime, paid maternity leave, and benefits, must be provided in a timely manner. Business Partners should also inform workers about overtime requirements and associated wages.A system for determining, reviewing, and adjusting minimum wage rates in compliance with legal requirements must be implemented and maintained.
(iii) Fair Working Conditions and Humane Treatment
Business Partners must provide its employees with safe and humane working conditions, and maintain compliance with applicable laws, rules and regulations. Business Partners must respect the right of employees to freedom of association and recognition of employees’ right to collective bargaining were allowed by law.
Business Partners must maintain a harassment-free workplace, ensuring employees are not subjected to abuse, coercion, or mistreatment. A written policy and grievance mechanism should be in place to address concerns confidentially and take corrective actions as needed. Business Partners are also expected to promote full, productive, and freely chosen employment, ensuring work availability, productivity, and opportunities for skill development. Regular awareness programs on harassment laws shall also be conducted.
(iv) Health and Safety
Business Partners must provide a safe and healthy workplace for their employees and contractors or sub-contractors. Business Partners must be compliant with local and national laws and regulations on occupational and national authorities. When on our sites, the Business Partners must comply fully with our applicable policies and directives.
(v) Drugs and Alcohol
Our position on substance abuse is simple: it is incompatible with the health and safety of everyone. Business Partners shall ensure that none of its employees/personnel/workmen consume or are under the influence of alcohol or psychotropic substances as defined under applicable laws, while working at our offices or work sites or at sponsored events.
(C) Environment Management
Livspace encourages its Business Partners to commit to protection of environment including but not limited to the followings:
3. Management Systems
Business Partners must implement a management system to ensure compliance with this Code’s principles, applicable laws, and regulations, while identifying and mitigating operational risks and fostering continual improvement.
They should provide training to management and employees to ensure understanding of this Code, relevant laws, and recognized standards. Periodic self-evaluations should be conducted to ensure compliance by the Business Partner, subcontractors, and next-tier partners.
Gaps or deficiencies identified must be addressed promptly, with continuous improvement through setting performance objectives, executing plans, and taking corrective actions based on internal or external assessments and reviews.
4. Non-Compliance
If a Business Partner is found to be non-compliant with the Code, Livspace shall have the right to suspend or terminate any contractual arrangement with the Business Partner without any liability to the Business Partner. In the event of any conflict or ambiguity between any provisions of this Code and the provisions of local laws and regulations, the stricter of the two shall prevail.
The above mentioned right of termination is without prejudice and in addition to any other right and/or remedy that Livspace may have under the applicable laws.
Business Partners should report any concerns about violation of this Code or applicable laws by writing to ethics@livspace.com.
1. PURPOSE
Livspace is committed to conducting its business with the highest moral and ethical standards and in compliance with all applicable laws and regulations regarding bribery and corruption. The Company takes a zero-tolerance approach to bribery and corruption in all its forms, whether direct or indirect, and expects all employees, contractors, suppliers, customers, and business partners to uphold the same standards.
We do not attempt to improperly influence others (directly or indirectly) by paying or accepting bribes or kickbacks in any form. We also do not permit Company funds, assets, or property to be used to benefit any individual, including government officials, our customers, competitors, contractors, suppliers, or any other counterparty unduly or illegally or in ways that violate this Policy.
This Anti-Bribery and Anti-Corruption Policy (“the Policy” or “ABAC”) sets forth the Company’s commitment to prevent, detect, and respond to bribery and corruption. It provides clear guidelines for employees and business partners to follow in order to avoid involvement in any unlawful or unethical conduct that could damage the Company’s reputation and integrity. This policy shall be read in conjunction with the Code of Conduct (for Covered Persons), Business Partner Code of Conduct (for Business Partners), Whistle Blower Policy, Prevention of Corruption Act, 1988, and applicable laws in relevant jurisdictions by virtue of its operations.
2. SCOPE
The scope of the policy covers the Company’s directors, officers, employees (direct/indirect) including its subsidiaries or affiliates. The Policy further applies to anyone who acts for the Company, including, contractors, trainees, suppliers and consultants of Livspace.
3. GOVERNANCE
4. DEFINITIONS
a) Bribery refers to do or attempt to do any of the below:
of value (financial or non-financial) to a government official or any other person, directly or indirectly through a third party, to influence that person in the performance of a duty or to obtain or retain business or any undue business advantage.
Bribe can take many forms, for example any offer, promise, receipt or payment of:
b) Facilitation payments also known as "back-handers" or "grease payments", are unofficial payments made to authorized officials to secure or expedite a routine or necessary action (e.g., the granting of a license or processing an application).
c) Kickbacks is a form of corruption that involves two parties agreeing that a portion of their sales or profits will be kicked back (given back) to the purchasing party in exchange for making the deal.
d) Corruption is dishonest, improper, and usually unlawful conduct intended to secure a benefit undertaken by a person or organization entrusted with authority to attain illicit benefit or abuse power for one's private gain. It encompasses Bribery as well as any other practice that involves the abuse of power for personal gain. Bribery and fraud are considered corrupt practices.
e) Employees Employee" means any person on the rolls of the company or its subsidiaries or associates, including those on deputation, contract, temporary, probationer, apprentice, trainee, part-time employees/ workers, full-time consultants, holding permanent, honorary, ad hoc, voluntary or short-term positions, whether employed for remuneration or not; employed either directly or through an agent; and includes, without limitation, all full-time and part-time employees of the Company, interns; independent contractors; and any other contingent workers.'
f) Gift means any item of considerable value, given to/received from a party that has business dealings with the organization.
g) Third Party/Agents shall mean potential or existing representatives, service providers, intermediaries, suppliers, advisors, agents, design partners, custom brokers, consultants, business partners of the Company or its subsidiaries or associates and includes those employed acting on behalf of, under the supervision of, or jointly with the Company, its subsidiaries or affiliates.
5. GENERAL PRINCIPLES
It is the responsibility of all the employees and third parties to
6. REGULATED/ PROHIBITED ACTIVITIES
a) Bribery and Corruption
Employees are prohibited from offering, promising, transferring or accepting anything of Value, including gifts, entertainment, hospitality, political or charitable donations or sponsorships with the intention of inducing anyone, including Public Officials, to act improperly in obtaining or retaining business or a business or personal advantage.
b) Gifts, Hospitality and Entertainment
Employees are prohibited to offer or receive gifts, meals, entertainment, or travel that may be perceived as an attempt to influence a business decision, or create a conflict of interest. However, this policy does not prohibit giving or accepting gifts in the normal course of business, to or from any person, for any appropriate and/or promotional purposes as described under the Gifts and Entertainment Policy hosted on employee self-service portal.
Further, any benefits received or offered through the immediate family members of the employees or the third parties, where it is intended towards obtaining any undue business advantage, would be considered as benefits received by the concerned employee and hence is prohibited. Immediate family members, for the purpose of this policy shall include, spouse, mother, father, son, daughter, brother, sister or any other person having a personal connection.
c) Political and Charitable contributions
Any charitable contributions made by the Employees and Third Party, on behalf of the Company to current or prospective clients to influence the decision of a government official and/or to obtain an improper advantage for the Company are not permitted. Please contact the Legal department (legal@livspace.com) with any queries regarding charitable contributions.
Further, the employees are also prohibited from taking part in political activities or making political contributions to unlawfully or unethically influence any legislation that may unduly benefit the Company. Employees and third parties may engage in activities that endorse a political or ideological position only in their personal capacities and should not in any way be connected to the Company.
d) Sponsorship
Sponsorships must not be used as bribes, e.g., for the purpose of improper inducements or to influence Public Officials or other individuals.
e) Facilitation payments
Any request for a Facilitation Payment must be refused and any requests must be reported promptly. We neither partake, nor do we allow or authorise third parties acting on our behalf, to make any such payments.
f) Conflict of Interest
A conflict of interest occurs when an Employee or an agent (anyone authorized to act on behalf of the principal) has an undisclosed personal or economic interest in a matter that could influence his professional role. For further guidance in this regard, please refer to the Employee Code of Conduct hosted on employee self-service portal.
g) Economic Sanctions
Economic sanctions ("Sanctions") are financial, trade, and travel-related restrictions targeting individuals, entities, and countries. Sanctions may be imposed by a government or international organization (such as the United States or the United Nations).
It is strictly prohibited for any Employee of the Company, or any Third Parties working on the Company’s behalf, to engage in conduct that violates any applicable sanctions.
If you are in any way unclear as to whether or not a business activity poses any Sanctions issues, or come across any such activity, then please contact our Legal Department (legal@livspace.com).
h) Anti-money laundering
Money laundering is a criminal offence and occurs when someone directly or indirectly gets involved in any process or activity connected with the proceeds of a crime including its concealment, possession, acquisition or use and projecting or claiming it as untainted property.
Personnel covered in this policy must ensure that Livspace does not receive proceeds of criminal activities, as this can amount to money laundering.
Those involved in engaging or contracting with vendors or customers should not assume that third-party screenings have already been completed. Failing to verify or update screenings regularly is considered a violation of this Policy.
Personnel responsible for engaging with third parties, such as suppliers, customers, and distributors, must ensure these entities undergo proper screening to confirm their identity and legitimacy before entering into any agreements or transactions.
7. AGENTS AND THIRD PARTIES
Hiring an Agent
Due diligence is expected to be performed on the Agents before onboarding them. Accordingly, such Agent may be required to provide adequate documentation and other information to complete the due diligence process.
General checks prior to on-boarding
After on-boarding
Employees reviewing or approving invoices for Agents, must verify that all charges are properly documented, recorded, and legitimate. In addition, they must always be aware of potential "red flags" and report immediately. (See section 10 Reporting Bribery and Corruption)
8. EXCLUSIONS
Considering the nature of our business, we understand that employees may receive promotional and sample products for testing before launch of the product. Livspace places trust in the sound judgment of its employees, ensuring that such products are used for legitimate business purposes and not for personal gain or benefit.
9. RECORD RETENTION
Keeping adequate financial records is an important anti-bribery and corruption control. All employees must
10. REPORTING BRIBERY AND CORRUPTION
Employees and third parties must report any concerns regarding the breach of this policy directly to their immediate reporting manager, skip level manager, HR Representative, Legal department or through the whistleblower channel (ethics@livspace.com). Reporting channels are also enshrined in the Company’s Whistleblower Policy disclosed on the website of the Company.
11. CONSEQUENCES OF INDULGING IN BRIBERY AND CORRUPT PRACTICES
Failing to follow applicable laws and this Policy may result in any number of serious consequences, in line with the Code of Conduct and the Whistleblower Policy, including probation, suspension without pay, reduction in salary, termination of employment, and restitution, as well as civil and criminal fines and imprisonment.
12. INTERPRETATION, EXCEPTION AND IMPLEMENTATION
In the event of any conflict between this Policy and any applicable law, the provisions of such Applicable Law shall prevail over this Policy.
Any exception to this policy must be approved by the Head of Human Resources and the Chief Executive Officer.
All personnel (acting on behalf of Livspace) are responsible for adhering to the principles set out in this policy. Any clarification regarding this policy can be addressed to the Head of HR or Head of Legal or Head of Risk and Compliance.