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ABC Corp India Private Limited

CONFLICT OF INTEREST GUIDELINES


It is the policy of ABC Corp India Private Limited (the Company) to conduct its affairs in strict
compliance with the letter and spirit of the law and to adhere to the highest principles of usiness
ethics! Accordingly" all officers" employees and independent contractors must avoid activities
which are in conflict" or give the appearance of eing in conflict" with these principles and with
the interests of the Company! #he following are potentially compromising situations which must
e avoided! Any e$ceptions must e reported to the C%& and written approval for continuation
must e otained!
'! (evealing confidential information to outsiders or misusing confidential information!
)nauthori*ed divulging of information is a violation of this policy whether or not for personal
gain and whether or not harm to the Company is intended! (#he C&+,I-%+#IALI#.
A/(%%0%+# A+- #1% %0PL&.%% I+2%+#I&+ A33I/+0%+# A/(%%0%+# elaorate
on this principle and are inding agreements!)
4! Accepting or offering sustantial gifts" e$cessive entertainment" favors or payments
which may e deemed to constitute undue influence or otherwise e improper or emarrassing to
the Company!
5! Participating in civic or professional organi*ations that might involve divulging
confidential information of the Company!
6! Initiating or approving personnel actions affecting reward or punishment of employees or
applicants where there is a family relationship or is or appears to e a personal or social
involvement!
7! Initiating or approving any form of personal or social harassment of employees!
8! Investing or holding outside directorship in suppliers" customers" or competing
companies" including financial speculations" where such investment or directorship might
influence in any manner a decision or course of action of the Company!
9! Borrowing from or lending to employees" customers or suppliers!
:! Ac;uiring real estate of interest to the Company!
<! Improperly using or disclosing to the Company any proprietary information or trade
secrets of any former or concurrent employer or other person or entity with whom oligations of
confidentiality e$ist!
'=! )nlawfully discussing prices" costs" customers" sales or mar>ets with competing
companies or their employees!
''! 0a>ing any unlawful agreement with distriutors with respect to prices!
'4! Improperly using or authori*ing the use of any inventions which are the su?ect of patent
claims of any other person or entity!
'5! %ngaging in any conduct which is not in the est interest of the Company!
%ach officer" employee and independent contractor must ta>e every necessary action to ensure
compliance with these guidelines and to ring prolem areas to the attention of higher
management for review!
2iolations of this conflict of interest policy may result in discharge without warning!
Company: Employee:
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