The Code of Conduct (the “Code”) provides guidance about business behavior expected of the Akshamaala community as you work and interface with fellow employees, customers, suppliers, business partners and other stakeholders.
The Code is supported by corporate-level policies, which are available on ASPL Corporate Policy Site. This Code and the policies cannot answer every question or address every possible business situation. Therefore, you are expected to use good judgment and seek guidance from HR Department.
The Code is applicable to all officers, directors, and employees of ASPL.
Failure to comply with the Code, including not reporting actual or suspected violations of which you are aware, may result in disciplinary action, including but not limited to termination of employment.
ASPL business success depends on our ability to build trusted relationships—with each other, as well as with our customers, suppliers, governments and communities. This means that we have a responsibility to:
The ASPL Compliance Team is dedicated to giving us the support and advice we need to comply with this Code, corporate-level policies and applicable laws and regulations.
If you have any reason to believe this Code, corporate policies or applicable laws and regulations have been or may be violated, you are expected to immediately report such activity to any of the following resources:
ASPL does not tolerate retaliation against any employee who, acting in good faith, reports suspected misconduct, asks questions or raises concerns.
ASPL commitment to conducting business with integrity requires that we take all credible good-faith reports of suspected misconduct seriously, investigate them fairly and confidentially, and take action where needed.Conduct Business with Honesty and Integrity
Side agreements are strictly prohibited. ASPL policy is to contract with customers and other parties only through formal, written agreements that have been approved by ASPL HR/Legal Department/Consultant and that have been executed by authorized signatories
Side agreements include any commitment, whether verbal or written (including by electronic transmission, e.g., email), that was not part of the original agreement with the counterparty in order to complete a sale or purchase or applicable transaction. Side agreements often substantially change the terms of the original agreement and potentially expose ASPL to a risk of breaching the agreement and impacting the agreement’s accounting treatment. Any modifications to an original agreement must be reflected either in: (i) a new written agreement, or (ii) a written amendment to the original agreement, either of which must be properly approved and executed by an authorized signatory.
You should avoid any activity that conflicts with, or appears to conflict with, the interests of ASPL. A conflict of interest is a situation in which you or a member of your family has professional or personal interests that could affect your objectivity in making decisions as an ASPL employee. Conflicts of interest may arise when you or a member of your family receives improper personal benefits as a result of your position with ASPL.
It is usually a conflict of interest for an ASPL employee to work simultaneously for a competitor, customer or supplier. Employees are not allowed to work for a competitor as a consultant. The best practice is to avoid any direct or indirect business connection with ASPL competitors, customers or suppliers, except on behalf of ASPL.
Conflicts of interest may not always be immediately evident. If you have questions or if you become aware of a conflict of interest or a potential conflict of interest, you should contact the HR Department.
ASPL must comply with various securities laws, regulations and reporting obligations, as well as applicable statutory laws and regulations for local financial and tax reporting.
ASPL is responsible for ensuring that its business records, including paper and electronic records, are created, managed and disposed of properly. An effective, efficient records management program allows ASPL to meet its business needs and to comply with all legal and regulatory obligations. You are responsible for periodically reviewing the records in your possession and assuring you are in compliance with the Records Management Policy and any pending preservation orders.
Obeying the law, both in letter and in spirit, is the foundation of ASPL's ethical standards. We must act in accordance with the applicable laws and regulations where ASPL does business.
ASPL takes a zero-tolerance approach to bribery and corruption and is committed to operate and enforce systems and policies to detect and deter bribery. You may never give or promise to give anything of value directly or indirectly to any third party in connection with any ASPL business to assist ASPL in obtaining an improper business advantage, whether or not any benefit is received.
Normal, occasional and appropriate gifts, entertainment or other hospitality offered to customers, potential customers, suppliers, or other persons connected to ASPL business to foster goodwill and enhance business relationships is generally permissible, after due consultation with HR department. However, the following gifts, entertainment and other hospitality are strictly prohibited, even if you do not submit the expenditures for reimbursement from ASPL:
All business meals and entertainment must be customary, unsolicited, infrequent, in good taste, reasonable in value and provided for legitimate business purposes. Additionally, except as noted below, you may accept occasional, unsolicited gifts of nominal value, such as promotional or commemorative items. You must receive advance approval from your HR Department for any gifts, entertainment or hospitality.
You should never accept:
You may not contribute funds, assets or services for or on behalf of ASPL to any political candidates, political party, charity or similar organizations, unless such contribution is expressly permitted by law and authorized by ASPL.
ASPL will succeed in a fair and competitive marketplace by providing customers with superior products and services at reasonable prices.
ASPL engages with multi district audience. We therefore comply with applicable District and State laws regarding the supply of goods, services, software and technology.
Anyone associated with ASPL who is involved with the supply of goods, services, technology or software is responsible for knowing and following the regulations that apply to their job responsibilities.
ASPL complies with applicable data protection and privacy laws where ASPL does business.Treat Each other with Dignity and Respect
ASPL values the diversity of its workforce. The ASPL approach to diversity is defined by inclusiveness, respect and fostering a culture that allows each individual to contribute to his or her fullest potential. As set forth in the Equal Employment Policy and the Non-Harassment Policy, ASPL does not tolerate any form of harassment, discrimination or retaliation.
A workplace free of violence, weapons and other disruptive behavior keeps all employees safe and able to concentrate fully on business. Violence or other deliberate acts intended to harm another person or their property, including threatening, menacing or intimidating comments and behavior, is prohibited. Violence or threats of violence should be reported immediately to HR Department.
Alcohol, illegal drugs and controlled substances can adversely affect safety, productivity, reliability and judgment. We are prohibited from consuming or being under the influence of alcohol or possessing, distributing or being under the influence of illegal drugs while engaging in ASPL business, with the exception of lawful, moderate and prudent alcohol consumption during legitimate business entertainment.
ASPL assets, including but not limited to equipment, supplies, facilities and systems, should be used for ASPL's benefit. As set forth in the Communications Systems Use and Security Policy and subject to applicable law, ASPL reserves the right to monitor ASPL systems and there should be no expectation of privacy.
Theft and fraud are crimes and will not be tolerated. Fraud is a type of theft by deception that results in your personal gain, profit or advantage or harm or loss to another person or entity. You are expected to report any suspicious activity immediately to HR Department.
The ASPL Information Security Policy serves as the foundation for ASPL's information management policies, standards, and procedures. Employees are personally accountable for ensuring that their ASPL information assets are adequately secured and for complying with ASPL information security policies, standards and procedures.
When it is necessary to share ASPL confidential information with customers, partners or other third parties, you are responsible for ensuring that the proper confidentiality agreements are signed and properly executed in accordance with the Contract Approval and Signature Authority Policy before the information is shared.
You must ensure that business travel is intended to further ASPL business interests, and that travel and entertainment expenditures are reasonable, prudent and in accordance with the Travel and Business Expense Policy.