let’s come together, walk together

KIRLOSKAR BROTHERS LIMITED

A Kirloskar Group Company
Established 1888
Third Edition
January 2019
Printed in India
All rights reserved with Kirloskar Brothers Limited
 Laxmanrao Kashinath Kirloskar
(1869-1956)
Founder, Kirloskar Brothers Limited

Treat your work as your duty. He who works earns the

world’s respect. So immerse yourself completely in work if
you want to succeed in the world.
 MISSION

We shall be known globally as a reliable, innovative and cost effective

solution provider in hydraulic machines & systems.

VISION

Kirloskar Brothers Limited will be one of the most admired engineering

companies in the world.

VALUES

• Developing and working with mutual trust

• Building and nurturing teamwork
• Fairness in dealing with stakeholders
• Quality in everything
• Commitment towards environment
 Every Team KBL member is a valuable part of this
global organisation. We are the leaders in the
industry that we operate, because of our ability
to adapt to changes instantaneously, but never at
the cost of our ethics.
This document will guide you at each step in
your career with KBL. Read it in its entirety, use
it wisely, refer it regularly and most important -
‘Question when Confused’. Remember, we are
personally accountable for our own actions, and
this document will prevent you from taking wrong
decisions during your work tenure with KBL.
Our reputation and success depends largely on
our personal commitment to uphold the values,
virtues and ethics prescribed in this document
Foreword while doing business for KBL. We shall not
tolerate retaliation against any employee who
in good faith reports misconduct or co-operates
Dear All, with a compliance investigation.
I am filled with a sense of both pride and Let us grow KBL ethically, morally and well within
pleasure while presenting to you the third edition the Laws of Business, as prescribed in any
of Kirloskar Brothers Limited’s (KBL’s) Code of country within which we operate.
Ethics.
At the onset, let me express myself clearly. Warm Regards,
This is one of the important documents for our
company’s image, a company which has a rich
heritage to bank upon and an equal responsibility
to create a future, for generations to come.
It is more of a guide on ‘Ethical Behaviour’ and Sanjay C. Kirloskar
less of a teacher. At the same time, do not miss Chairman & Managing Director
the undercurrent of strict adherence in following Kirloskar Brothers Limited
it. Each of us at KBL are morally and physically
bound to adhere to the norms and ethical
behaviour patterns prescribed in this document.
 Index

Mission, Vision, Values II f. Social Media 39

Foreword by CMD III (Web Logs, Social Networks,
An Understanding 11 LinkedIn, etc.)
Applicability 13 g. Acquiring Information about 40
Summary of Values 14 Competitors or Other Third Parties
Compliance 16 h. Use of Company Resources 41
a. Business Practices 17 i. Manufacturing 43
b. Dealing with Government 20 j. Project Management 46
Machinery k. Customer Service and 49
c. Intellectual Property 22 Operations Management
d. Brand and Logo 23 Relationship 50
Business Conduct 25 a. KBL and its Employees 51
a. Financial Integrity 26 b. KBL and its Customers 54
b. Business Courtesies, 31 c. KBL and its Subsidiaries 55
Gifts, etc. d. KBL and its Suppliers 56
c. Conflict of Interest 34 e. KBL and its Dealers 58
d. Charitable Donations 36 f. KBL and Society 59
e. Protecting 37 Enforcement 60
Confidential Information
10 Code of Ethics
 An Understanding

Kirloskar Brothers Limited welcomes you to its Let us understand the code
world of Ethical Business Standards. We will
KBL has prepared this code, to help you as you
refer to Kirloskar Brothers Limited and all its
go about your daily work. This is a standard set
subsidiaries as ‘KBL’ throughout this document.
of values and ethics, common for all. KBL is
This code is not a contract and no contract is well aware of differences in customs of other
implied, but it will guide you while addressing countries, since we are a multi country outfit.
legal and ethical issues that come up during your Rules, regulations, customs and practices may
journey of business dealings for KBL. Let this be differ but ethical standards remain the same.
clear that if any part of this code conflicts with All of us at KBL should be committed to uphold
applicable law, the law shall always prevail. the Code of Ethics and should be responsible
In case, a part of this code is deemed invalid, and accountable for the same, for it is on these
it will not affect the validity and enforceability Ethical Standards that the success and reputation
of its other sections. KBL has sole discretion to of a business like KBL depends.
interpret the code. The KBL Code of Ethics starts with a summary
KBL does recognise and respect regional and of core business values. These values are the
local differences in employment, privacy and foundation of KBL and shall be responsible for
other applicable laws. We will comply with its success, growth and widespread reputation
regional and local requirements concerning the in the years to come. They shall enhance our
matters discussed in the code, as appropriate. ability to serve customers to help us be more
competitive and promote our pride in being a part
of Team KBL.

Code of Ethics 11
 The KBL Code of Ethics specifically addresses • Relationship:
four areas: It is our responsibility to interact fairly and
• Compliance: respectfully with each other, our customers, our
It is our responsibility to abide by the laws, rules, partners, our suppliers and the community at
regulations and KBL policies that apply to our large in which we operate
business practices • Enforcement:
• Business Conduct: It is our commitment to conduct investigations
It is our obligation to conduct internal and external in an ethical, transparent and legal manner and
to promote consistent disciplinary action for
business, fairly and ethically
violations of our policies or business conduct/
Code of Ethics

12 Code of Ethics
 Applicability

This Code applies to all personnel employed by Waiver of this code or a part of it, by any employee
or engaged to provide services to the Company. must be approved by the Ethics Committee. Such
They include the Company’s directors, officers, waivers if any, along with the reasons shall be
temporary employees, workers (including disclosed to the Company Shareholders through
agency workers) and independent contractors Annual Reports.
(hereinafter referred to as “employees”).

Code of Ethics 13
 Summary of Values

Conduct Discipline
We Strive... We Strive...
• To conduct business with honesty and integrity • To conduct business with uncompromising
• To follow the letter and spirit of the prevalent integrity and professionalism
law • To ensure a safe, clean and injury-free work
• To treat each other fairly place
• To act in the best interest of the company and • To make and keep commitments
to avoid conflict of interest • To properly plan, fund and staff projects
• To protect the company’s reputation and • To pay attention to detail
assets

Great Place to Work

Customer Orientation We Strive...
We Strive... • To be open and direct
• To listen and respond to our customers, • To promote a challenging work environment
suppliers and stakeholders that develops our diverse workforce
• To communicate our mutual intentions and • To work as a team with mutual respect and
expectations clearly trust for each other
• To deliver innovative and competitive products • To win and enjoy victory
and services
• To recognise and reward the accomplishments
• To make it easy to work with us
• To perform fairly and firmly
• To excel at customer satisfaction
• To be an asset to the human community
worldwide

14 Code of Ethics
Quality Risk Taking
We Strive... We Strive...
• To achieve the highest standards of excellence • To foster innovation and creative thinking
• To do things in the right manner • To embrace the changes and challenge the
• To continuously learn, develop and improve status quo
• To take pride in our work • To listen to all ideas and view points
• To encourage and reward informed risk taking

Result Orientation
We Strive...
• To set challenging and competitive goals
• To focus on quality output
• To assume and accept responsibility
• To confront and solve problems constructively
• To execute flawlessly

Code of Ethics 15
 Compliance
Business Practices
Dealing with Government Machinery
Intellectual Property
Brand and Logo

16 Code of Ethics
 Business Practices

Compliance with the ‘Law’ Q: In case you are at a meeting or public place and
you overhear an informal group of competitors
It is our policy to operate within applicable
discussing a future product or its pricing etc. Will
laws and to comply with those laws, rules and
you join the conversation to gain some extra-
regulations, which affect our business and to
ordinary competitive intelligence?
co-operate fully with relevant authorities and
regulatory bodies wherever necessary. A: No. KBL believes in fair and honest competition.
You must avoid any discussion on the same and
Compliance with applicable competition laws
must stay away from such situations. In case of
shall also be ensured. These are laws which
such a situation, report the incidence immediately
prohibit agreements or actions that infuse unfair
to the Legal Department.
competition or reduce competition without
benefitting consumers.
Examples restricting competition are : Unfair methods of competing for business are
totally prohibited. Some examples of the same:
• Fixing or controlling prices
• Making false and or misleading representations
• Structuring bids (bid rigging)
about company’s products
• Boycotting specified suppliers or customers
• Downgrading a competitor or its products
• Dividing or allocating markets or customers
• Making false claims of our products without
• Limiting the production or sale of products or substantial facts to back them
product lines
• Using another company’s trademarks in a way
that confuses a customer about its source
• Every employee is expected to work within the
Company policy and without violating the law,
whether accidentally or deliberately If criminal
violence has occurred, the company shall take

Code of Ethics 17
 appropriate measures to stop and correct the insider or outsider, directly or indirectly, by way of
criminal conduct and also to stop it from re- making any recommendation for the Purchase /
occurring. Sale of Company Securities or take any advantage
of their position for their direct or indirect benefit.
Link: https://intranet.kbl.co.in/INTRANET/
Improper Payments CHRMC/Code%20for%20Insiders.pdf
KBL prohibits employees from receiving, offering,
promising, authorising, directing or making,
directly or indirectly, any bribes, kickbacks or Q: In case you are aware that KBL is likely to
payments of money or anything of value to exceed its Quarterly Revenue Estimates, but
obtain business improperly for the company or since the announcement is not made public, you
themselves. To put it simply, no employee shall are likely to gain money after this information
discuss or offer anything to any official who gets out. Can you buy more Company Shares?
may influence an ‘Official Work’. Such payments A: No. What you are thinking of doing is Insider
should not go to: Trading, a violation of KBL policy and applicable
• Government or public organisations Insider Trading Laws. You may buy or sell
company shares only after such information is
• Political parties or candidates for political
made public and after the trading windows open.
office
• Business entities partially or wholly owned by
Government interests Q: In course of your work, you come across some
non public information from a customer, which
• Privately held commercial companies
indicates that the customer is in a better financial
• Company employees condition than it appears on face value. Can you
• Third party buy customer’s shares?
A: No. The customer may have given this
information in good faith, to help his company
Insider Trading determine how to best meet its needs. You cannot
Every employee shall adhere to the strict Insider use this information for personal purposes,
Trading Laws. KBL prevents insider trading of nor divulge it to others. It is a violation of trust,
Company Securities, which is applicable to all violation of KBL policies and the applicable Insider
employees, as they are insiders. Trading Laws. You can only buy such stocks after
Employees shall strictly maintain ‘Price the information is public and it is spread in the
Confidentiality’. They shall not pass on any price financial markets.
sensitive information to any person, whether

18 Code of Ethics
Q: Through the nature of your work, you come and truthful and they must be committed to meet
to know that KBL is acquiring another publicly all such contractual obligations.
traded company. Can you buy stocks in that KBL employees shall not take undue advantage of
company right now? their authority, while entering into any contractual
A: No. This is again a violation of KBL Insider agreement.
Trading Laws and it must be avoided under all
circumstances. It can instigate the trading activity
Q: A customer is ready to sign a contract, but
and affect the security’s price significantly.
is awaiting his board’s approval. He assures you
that his board will approve the transaction when
Q: By now you are aware that you cannot divulge it meets and asks you to allow some period
Insider Information to an outsider, but can you for implementation of the terms. Can you send
reveal or discuss it with your family members or a letter on behalf of KBL, confirming that the
other peers ? customer has some period to implement the
A: No. You cannot reveal such information to contract ?
anybody who does not legitimately need to know A: No. This would imply an unauthorised ‘Side
it, which includes family members, friends and Letter’ modifying the terms of the contract. This
acquaintances. This may result into unfair trading can call for disciplinary action on you, which may
of securities, which is against KBL policies and include termination.
you may expose yourself and the company to
criminal and civil liabilities, even though you may
Q: An employee of KBL, asks your favour to
not personally gain through the same.
obtain a higher, non-standard discount in an
upcoming significant contract with a major
Contracts and Ethics customer. Should you help him?
All employees shall compete fairly and ethically A: No. Employees are strictly restricted to
for every business opportunity. Those involved achieve excess margins from unjustified and/or
in the sale of products/services, in negotiation unapproved non-standard discounts.
of agreements or in the delivery of services
to customers are expected to understand and
honour the terms of the company’s general
contractual agreements. More so, each employee
must ensure that all statements, communication
and representation to customers are accurate

Code of Ethics 19
 Dealing with Government Machinery

This includes Government contracting, Display of our Code of Ethics

procurement integrity, organisational conflict
Pre-qualification documents are the first
of gifts, meals and entertainment, lobbying of
requisite of any governmental bid. It is through
governmental officials, political contribution,
such submissions that we can establish KBL’s
personal political activities, influencing others,
capacities, capabilities, credentials, financials,
public service, etc.
past work references and most important, our
character. We should proudly enclose/submit, our
Familiarisation with Codes of own Code of Ethics along with such documents,
wherein the overall look will be impressive and
Government Organisations the undercurrent will strongly pronounce our
Government and Semi-Government organisations business principles.
have their own codes of conduct and their own
We have to be conscious in our dealings and
policy guidelines for dealing with contractors,
make a positive march from the present to our
vendors, suppliers and procurement through
new philosophies. This should not be taken
tenders. We need to familiarise ourselves
categorically, but has to be done on a case to case
totally while dealing with such organisations.
basis, while conducting our ongoing business.
Awareness about these codes will only help KBL
employees to deal with such organisations and
act with restraint wherever needed, so as to avoid
unethical practices. ‘Ignorance is not always
bliss’ and ignorance can lead to disqualification in
an important bid, which we at KBL need to avoid.

20 Code of Ethics
Gifts and Complimentary Items Meals and Entertainment
Out of proportion gifts have always given a wrong Meals and entertainment are a very routine but
message, sometimes hurting the recipient. They an important aspect in today’s business life
should be avoided like a plague. Gifts are a token and normally a trend, after business meetings,
of appreciation or memory of a relationship. They conferences, events, etc. These also help build
should be more thoughtful, careful and well up a friendly dialogue between the dealing
planned. Gifts with a touch of local speciality are parties. Lunches should generally be working
wise to give. It’s not the price but the thought meals at the company cafeteria while dinners
which makes them unique and appreciable, so could be at a decent and reasonable restaurant
gifts not exceeding a value of INR 500/- which but, of course, with prior approval.
could be office stationary or of similar nature
are acceptable. Gifts are best on occasions and,
fortunately in our country, we are never short of
them. Misunderstandings are avoided as gifts, on
occasions, help to build up relationships.

Code of Ethics 21
 Intellectual Property

It is a world of patents and trademarks. He who continues even after the employee leaves the
invents has the legal and moral right to sell and be company.
benefitted from the proceeds of the same. Ditto KBL, at the same time, respects intellectual
for the creator of information. There are proper property of others. It is against our code of ethics
and improper ways of using this information and, to use, copy, and display or distribute any third
no one, absolutely no one has the right to steal it, party copyrighted software, documents, etc.
infringe it or plagiarise it. without prior permission or approval from its
rightful owner. The final go ahead of the same
At KBL, intellectual property is a very important shall be given by the KBL Legal Department.
asset. It is a pure creation of mind, and it includes:
• Inventions Some basic ethics to be followed while tackling
• Copyrights intellectual property issues:
• Patents • Protect the company’s IP and act responsibly
with sensitive information, be it from vendors,
• Trademarks such as logo, symbols, names,
customers, contractors or other business
images and designs used in commerce
partners
• Trade secrets
• Use confidential information extremely
• International agreements purposefully
• Literary and artistic works, books, plays, • Share confidential information with only those
films, musical works, drawings, paintings, who need to know it
photographs, sculptures, softwares, etc.
• Identify all email communication with
confidential markings
KBL expects every employee to safeguard • Upon separation, deliver all notes, records,
its intellectual property, an obligation which data and equipment back to the company

22 Code of Ethics
 Brand and Logo

Since the inception in KBL expects every employee to safeguard and

1888 by our founder, Shri respect this Intellectual Property, an obligation
Laxmanrao Kirloskar, which continues even after you leave the
followed by the elevation employment of the company.
of the company to
greater heights by his
KBL, at the same time, respects such Intellectual
son Shri Shantanurao
Property of others. It is against our code of ethics
Kirloskar, the company
to use, copy, display or distribute any third party
has actually enriched
brand/logo without prior permission or approval
lives of millions across the globe.
from its rightful owner.
The Brand and Logo of Kirloskar Brothers Ltd. are
its most Valued Intellectual Property and the KBL
Code of Ethics prescribes very strict guidelines Some basic ethics to be followed while handling
towards handling of the same. the KBL brand/logo:
KBL very sternly expects compliance towards • Respect the Kirloskar brand/logo with the
the Brand and Logo handling by each and every highest esteem
employee of Team KBL. • Protect the company’s brand/logo from
This code applies to all personnel employed by misuse and act with maturity and responsibility
or engaged to provide services to the Company, towards the usage of the same
inclusive of the Company’s directors, officers, • Maintain the same respect, strictness and
temporary employees, workers (including agency discipline when the brand/logo is used by your
workers) and independent contractors (hereinafter vendors, customers, contractors and other
referred to as “employees”), advertising business partners
agencies, agencies for print production and every • The Kirloskar brand/logo manual should
single individual/company/ organisation which is be referred by every KBL employee when
‘officially’ permitted to use the Kirloskar Brand.

Code of Ethics 23
 sanction of its usage for any business/social • Brand/logo on the uniform (office/factory)
purpose is to be given. This manual contains should also be respectfully cared for by every
guidelines for brand/logo usage, placement, employee of Team KBL. KBL notes that a brand/
position, colours, font, font size, etc. logo should always be closest to the heart of
• The brand/logo should be allowed to be every employee and that is the reason it is
used only and only where business or image always placed on the upper left hand portion
building of the company is concerned and with in company uniforms, just near the heart
prior approval by the Legal Committee • Upon leaving the company, the KBL brand/
• KBL brand/logo should be used on every logo should be respected, which the company
stationery product used for business expects from all employees of Team KBL
communication e.g. visiting cards, letter heads,
envelopes, note pads, etc. Every employee To sum up the above, let it be known to all
should take care of its proper usage. Avoid employees, business associates, agencies,
misuse (in case of used stationery, it should be contractors, social organisations, government
torn or shredded and put in the waste basket. organisations that KBL shall not tolerate
Throwing it around carelessly might result disrespect, disregard and misuse of its brand/
into someone stepping over it). KBL shall not logo, which is its Legacy and Intellectual Property.
tolerate such disregard towards its brand/logo

24 Code of Ethics
Business Conduct
Financial Integrity
Business Courtesies, Gifts, etc.
Conflict of Interest
Charitable Donations
Protecting Confidential Information
Social Media (Web Logs, Social Networks, LinkedIn, etc.)
Acquiring Information about Competitors or Other Third Parties
Use of Company Resources
Manufacturing
Project Management
Customer Service and Operations Management

Code of Ethics 25
 Financial Integrity

Directors and Finance Department employees at • Never disclose confidential information unless
KBL must adhere to the following principles and authorised or legally obligated and never use it
inculcate a culture throughout the company as a for personal gain whatsoever
whole, which will help in fair and timely reporting • Use all assets employed or entrusted
of financial results and position. responsibly and within control
• Act with honesty and integrity and avoid • Ensure that all company records such as
conflict of interest ledgers, vouchers and expense reports are
• Ensure that the books and records are fair, accurate and complete. If questions arise,
accurate, timely and are understandable respond positively and in case of knowledge
reflections of the company’s operations and of inaccurate records of others, report the
business activities situation immediately to your seniors. KBL
• Provide only correct, complete, objective, shall not tolerate such occurrences
relevant and timely information, which can • Ensure that relevant accounting standards are
help prepare correct reports of the company’s followed while preparing such records
position in documents which are submitted to • Co-operate with auditors and ensure co-
government agencies and public operation of others under you
• Comply with the rules and regulations of • Share knowledge and maintain skills, important
central, state, provincial and local governments and relevant to stake holder’s needs.
as well as other public agencies
• Practice as well as preach ethical behaviour to
• Act in good faith and never allow create a better work environment
misrepresentation of material facts to
• Promptly report any misconduct or violation
avoid their independent judgement to be
of law to higher authorities thereby preventing
subordinated
any mishap in our code of ethics

26 Code of Ethics
• Stay away and report any breach of fiduciary • Undisclosed or unrecorded funds or assets
duty or self interested transactions, which can in relation to any KBL transaction shall not be
create a conflict of interest with our financial maintained for any purpose
code • Payment on behalf of KBL shall not be made
on assumptions that it might be used for the
purpose it was granted for, but shall be made
Violations of the Financial Ethical on absolute accuracy of its use
Standards/Code of Conduct are serious
Violation apart from committing also includes
failure in reporting potential violations of others. Books and Records
Severe disciplinary action inclusive of termination It is KBL’s policy to maintain books and records
of employment can be the result of such an act. with utmost accuracy, fairness and honesty. All
In such a case, report to the Legal Department, transactions whatsoever shall be disclosed,
Senior Management or the Audit Committee of reflecting the honest and correct position of the
the Board of Directors. It is against KBL policy company at any given point of time. Accounting
to retaliate against an employee for reporting practices of any country we operate from shall
in good faith, of any potential or actual code be taken into consideration. Unrecorded, off the
violations. books or “Slush” funds shall never be created or
maintained whatsoever.

Please remember
• Accurate and reliable financial reporting is a Records Retention
must The Records and Retention Policy of KBL has
• No false entries to be made in any financial its explicit guidelines, as regards to the records
books or records to be maintained, the retention period, legal
implications, etc.
• Timely financial accounting to be done in
compliance to KBL policies Every employee has to be aware of the stipulations
and has to maintain records accordingly. No need
• No inappropriate alteration in financial
to maintain unnecessary records but employees
documents and no unauthorised signing
must have knowledge to maintain the crucial
• Funds and assets of KBL shall not be used ones. Every employee therefore should read
unethically or for any illegal purpose and abide by the Retention Policy and Retention
• Handling and disbursement of funds or assets Schedule.
must be authorised and in compliance with
clearly defined procedures

Code of Ethics 27
 The Retention Policy covers: disclosures before being signed and forwarded
• Paper should be checked at every stage, verified and
then passed ahead. In case of any fraudulent
• Email
practice coming to your notice, it should be
• Video duly reported to the higher authorities, legal
• Hard Drive department or audit committee.
• Compact Disc
• Pen Drive or any Other Electronic Storage International Business
Device KBL employees worldwide need to consult
our Legal Department, irrespective of the
Coercion of Auditors geographical location, particularly in issues
like foreign exchange controls, custom duties,
The integrity of the Company’s Audited Financial value added services, etc. If any conflict arises
Documents is critical. No employee shall make between local laws and regulations, and Indian
even an effort to influence, coerce, manipulate laws and regulations, our Legal Department in
or mislead the company’s independent auditors, India should be consulted and no action must be
thereby trying to project a false picture of financial taken without such consultation.
statements of the company.

Foreign Corrupt Practices

Public Disclosure and Financial
KBL employees world over shall strictly abhor
Reporting from offering or making any payments in money,
KBL is committed to making complete, timely products or services, directly or indirectly to any
and accurate public disclosures. We are ethically foreign government employee in order to entice
and morally bound to always present the correct favourable business. As a global company, apart
financial and business picture of the company from the Prevention of Corruption Act, 1988 (India),
to our shareholders and public at large, so also KBL is subject to all relevant anti-corruption laws,
to all governmental authorities in any and every including the U.S. Foreign Corrupt Practices Act
country we operate in. These obligations also (FCPA) (as if it were a U.S. incorporated company)
apply to every employee of KBL while preparing and the Bribery Act 2010 (U.K.). These prohibit
such reports or documents. It is important not bribery of government officials and commercial
to withhold the correct picture and to report partners.
any information on the same. Reports or public

28 Code of Ethics
We should never offer, directly or indirectly, any Q: If our accounting department receives a letter
form of gift, entertainment or anything of value to from a customer’s attorney, demanding that KBL
any government official or commercial partners should fulfill certain oral promises that it allegedly
including customers or their representatives to: made. Your manager asks you to review your
Obtain or retain business; email to assure whether you have any emails that
could support such a promise. You identify one
• Influence business decisions; or
email that could be construed as constituting a
• Secure an unfair advantage promise to a person who was unfamiliar with the
This includes bribes, kickbacks and facilitation customer relationship but you believe, in good
payments. faith that no such promise was ever made to the
customer. Will you delete the email?

Q: Suppose your customer has signed and A: No. KBL’s Records Retention Policy requires
returned an order form, but forgotten to sign an employees to preserve all records that may be
attachment. He has left for a vacation. Can you relevant to a matter in which KBL reasonably
sign on his behalf and process the order? anticipates litigation. You should immediately
contact the Legal Department to help determine
A: No. Altering documents or signing without whether, under the circumstances, there is a
proper authority is illegal and also against KBL’s reasonable anticipation of litigation.
code of ethics. Return the order form and get his
proper signatures before processing the order.
Q: In case you receive a call from an investment
analyst who has heard that KBL is having a bad
Q: In case you come across some old and ‘paid’ quarter, while you know that the opposite is true
invoice file, can you put them in the shredder to – KBL is about to have an amazing quarter. Should
create more filing space? you correct his misconception thinking that it
A: No. All financial records whatsoever have is good to protect and correct the company’s
to be maintained, as they have to be reported, reputation?
reviewed and audited, to be able to present a A: No. You should not. Only spokespersons
correct picture for our shareholders and legal authorised by KBL, at the direction of the
departments. Please see the Retention Schedule Executive Management, are allowed to speak
for guidance. with the financial community about KBL or its
financial prospects.

Code of Ethics 29
 Q: A reporter who wants more information about Q: Your Manager is exerting pressure on you to
a recent product announcement calls you. You “make the numbers work”?
are very familiar with the product. Should you A: Your responsibility is to be honest and accurate.
speak with this reporter? If you feel pressured to do otherwise, speak with
A: No. Not without obtaining prior permission higher-ups or consult with the Legal Department
from the Executive Management, who must or Human Resources. You may also contact the
approve in advance all communication with the Audit Committee of the Board of Directors.
press. They may conclude that you are the best
spokesperson for the company on this issue,
but it is they and not you who must make that
decision.

30 Code of Ethics
 Business Courtesies, Gifts, etc.

You May Extend Q: A commercial customer with whom I do

business occasionally visits our facility. May I buy
Providing meals, refreshments, entertainment
lunch for him?
and event access in conjunction with business
discussions with non-government personnel A: Yes, you may buy lunch. However, some
is a widely accepted practice. You may do so limitations exist. As long as this does not
when it is appropriate to the circumstances. violate any of the customer’s regulations or any
Such practices, however, must not violate contractual obligations between the customer
the standards of conduct of the recipient’s and KBL, and the expenditures are reasonable
organisation, any contractual agreement with an considering the business relationship involved, it
existing or potential customer or KBL policy. You is permissible.
are responsible for familiarising yourself with any
such standards, agreements, and policies and for In any case, business courtesies must be nominal
complying with them. enough not to appear to influence the judgment
KBL prohibits giving anything of value (including of the recipient to secure unfair preferential
charitable donations or sponsorship of events) treatment or gain improper advantage. A final
directly or indirectly to any private individual, test of appropriate business courtesies, even
firm or entity as a means of improperly inducing if allowed under the law, is whether public
business. Employees who make, facilitate and / disclosure would be embarrassing to KBL or the
or approve expenditures for meals, refreshments recipient.
or entertainment, must use discretion and care to
ensure that such expenditures are in the ordinary
and proper course of business and could not
reasonably be construed as bribes or improper
inducement.

Code of Ethics 31
 You May Receive referral fees or other incentive payments or
perquisites from third parties to whom KBL may
Gifts
refer business. Generally, incentive programmes
KBL employees generally may accept unsolicited offered by third parties are discouraged. The
gifts or other business courtesies from actual or Director of the relevant organisation and the
potential customers, suppliers or other business Vice President & Head of Human Resource
partners provided they are not of material value Management of KBL must first approve any such
and are not given with the purpose of influencing incentive programmes.
one’s judgment.
It is never appropriate to solicit gifts or other
Q: If a representative of a supplier, vendor, or
courtesies directly or indirectly. If you are offered
customer presents me with a pen and pencil set
a gift or other business courtesy of material value
with the supplier’s logo as a token of appreciation,
from an individual, firm or representative of a firm
may I accept it?
who has or seeks a business relationship with
KBL, you must demonstrate that the gift could A: Yes. As long as the item is not of a material
not be construed as an attempt by the offering value and is widely available to others under
party to secure favourable treatment. You must similar circumstances, you may keep it for your
obtain written approval from your Sector/CF Head personal use. If the item does not meet these
and from your Regional/Ethics Counsellor before criteria and if you have not otherwise received the
accepting the gift. required approval, politely return it to the donor.
KBL recognises that, in some parts of the
world, gift giving is a common practice and not Q: It is the holiday season and I have just received
accepting a gift could reflect badly on KBL. Even from a vendor, at home, a gift certificate worth the
in those instances, however, where the gift is equivalent of INR 5000/- for a local department
of more than nominal value (say INR 500/-), you store. May I keep the gift certificate?
must obtain the written approval of your Sector/ A: No. You may receive only gifts that are not
CF Head and your Regional/Ethics Counsellor of material value. Rupees Five Thousand is of
before accepting the gift. material value and might be perceived as inducing
Neither you nor any member of your family may favouritism. You should return the gift certificate
accept any loan, guarantee of loan or payment immediately, with a note explaining that KBL
from an individual or firm doing or seeking policy does not allow you to accept such a gift.
business with KBL. Exceptions to this include
only loans from recognised banks and financial
institutions that are generally available at market Q: I have been offered a discount on a product
rates and terms. Similarly, you may not accept sold by one of the KBL suppliers. May I take
advantage of the discount?

32 Code of Ethics
A: It depends. You may accept the discount only always consider the specific circumstances and
if it exists under a program generally available whether your impartiality could be compromised
to KBL employees. Accepting discounts not or even appear to others as being compromised.
generally available to KBL employees may create
the appearance of favouritism to the donor or
Q: I am responsible for organising various
may imply that there will be favouritism in the
meetings, including the selection and bookings
future.
of hotel reservations for extensive KBL marketing
meetings. May I ask the hotel manager for a
Entertainment complimentary room for my personal use, since
we are giving so much KBL business to the hotel?
You may accept occasional meals, refreshments,
or other entertainment appropriate to the A: No. Your request would violate KBL policy.
circumstances in connection with normal Your solicitation of a complimentary room would
business discussions. be using your position to obtain preferential
treatment and could also affect your impartiality
Again, it is inappropriate to accept such favours if
in arranging hotel accommodations for future
they are offered solely to influence your business
meetings.
decision. If an individual or firm doing or seeking
business with KBL offers you entertainment
that is more than modest or routine, you must
obtain the written approval of your Sector /
CF Head and your Regional/Ethics Counsellor
before accepting. Every employee is personally
responsible for ensuring that acceptance of any
business courtesies, gifts or entertainment is
proper and does not reasonably appear to be an
attempt by the offering party to secure favourable
treatment.

Q: May I accept a business meal from a

representative of a supplier or vendor?
A: Probably. In most circumstances, modest and
infrequent business meals may be accepted by
KBL employees. On other occasions, it may be
more appropriate for KBL or the employee to pay
for the meal. Whenever a vendor pays for a meal,

Code of Ethics 33
 Conflict of Interest

A conflict of interest means a situation where proposed activity will be prohibited. It is the
there is a conflict between your (employee’s) employees’ responsibility to fully disclose all
personal interests and the interests of the aspects of the conflict and withdraw entirely
company. An employee, if free from personal from the decision making process.
interests, will always be loyal to the company. Additionally, if anybody observes any situation
Actions taken by employees should be objective involving another employee which is a conflict of
and in the best interest of the company. interest, report the situation to your senior who
Employees should not have any outside interest, shall do the needful. Reports from employees
investment or business relationship that dilutes shall be handled as confidentially as possible.
their loyalty to the company or dedication to the There are many examples where such conflicts
principles. may arise, which may include but be not limited
Relationships in transactions must be kept away to:
to make sure there is no adverse impact on the • Accepting payments, which may influence
company. your business decision
Employees must not use confidential company • Employees shall not directly or indirectly
information for their own advantage or profit. work or consult a competitor or engage in an
They must not disclose confidential company activity that is competitive with the company’s
information in any form to anyone who does business interests
not need to know it in order to conduct the • Potential conflicts between personal and
company’s business. professional relationships
Sometimes, a conflict of interest can develop • Written approval must be obtained by
unexpectedly. In case of such doubt of a conflict, employees from seniors prior to accepting a
actual or potential, the employee must report second job, consultancy, etc., to ensure that it
such details to his/her seniors. The presence of will not conflict with KBL’s interests
a conflict does not necessarily mean that the

34 Code of Ethics
Q: You want to start your own consultancy that Q: A current customer has asked me to be his
will primarily target small businesses, which may consultant in developing a product that would be
include company customers. Could this be a of no interest to the company. I often deal with
conflict of interest under the policy? this customer on the job. Could this be a conflict
A: Yes. This activity will be a conflict of interest if: of interest?
• Your new business keeps you away from A: Yes. This could create a conflict of interest
company work because other vendors, suppliers or customers
might suspect you of favouring this particular
• The services you plan to provide are similar to
company, even if it is not true. The objectivity of
services KBL provides
your business decisions could be questioned. In
• The customers of your new business are also addition, this would create a conflict of interest
actual or potential KBL customers, suppliers or if you are personally performing services for the
competitors customer which may hamper company work.
• Proprietary information of company is used
• You should review the matter with your senior Q: Can an employee teach a course at a local
and obtain his or her approval university/educational institute for pay ?
A: Yes. It is permissible for an employee to teach
Q: I have been approached by friends to invest in at an educational institution with the approval of
a company that will manufacture a product that his or her senior.
could eventually be sold to KBL. This is purely
an investment interest and I will not take part in
Q: I have been asked to take a seat on the board
the management of the company or provide any
of directors of a start-up company. May I accept?
advice. Will this be a conflict of interest?
A: Not without approval. If you wish to serve on
A: It depends a lot on:
the board of directors of another company, you
• The position you hold with the company must receive written approval from KBL. The
• The influence others may believe you have in company for which you serve should not be in
the selection of suppliers a competitive position with KBL and should not
• The amount of your investment. You should be a customer, partner or supplier, and the time
review the matter with your senior and obtain required to serve on the board should not be
his or her approval substantial. You may receive compensation while
serving in an approved position.

Code of Ethics 35
 Charitable Donations

KBL provides funding through a Charitable Trust Q: Can I assure on behalf of KBL, funds for the
(e.g. Vikas Charitable Trust) to organisations that heart surgery of a poor boy ?
address key community needs and, in some A: No. KBL will not donate funds to an individual
cases, matches employee contribution to local entity.
charities. KBL directly contributes to charitable
causes when appropriate. At the same time,
employees should refrain from speaking or Q: Can I request KBL for donation to an
making commitment on behalf of KBL for the organisation which undertakes heart surgery for
benefit of any organisation or cause in which they the poor people of the society.
participate. Should an official KBL authorisation A: Yes. You may request through HR to KBL or
be required or desired, it should be made by an Vikas Charitable Trust.
appropriate KBL official.

KBL will not fund:

1) Organisations that discriminate on the basis of
caste or religion
2) Individuals
3) Organisations outside India
4) Organisations not registered as a Charity or
“Not for Profit” entity

36 Code of Ethics
 Protecting Confidential Information

Our technology and knowledge have given us a We must make sure that all important company
competitive edge. It is critical that we maintain our documents and information are properly
advantage by protecting confidential information maintained or disposed as per defined retention
and maximise its value for our stake holders. period.
KBL employees must protect the company’s Employees should take precaution to ensure
confidential information. that laptops, computers, mobiles phones and
All information related to KBL business, not other devices containing confidential company
intended for public disclosure should be information are not lost, misplaced or stolen.
considered as confidential information, viz.: They should report the disappearances of any
• Employee information such equipment immediately to their supervisors.
• Technical product drawings The obligation to protect confidential company
information and personal information continues
• Software, innovations development (regardless
even after expiry of your employment with KBL,
of the stage of development)
which is expected of you.
• Marketing and sales plan
• Internal performance test results
General Data Protection Policy (GDPR)
• Competitive analysis
Employees are required to abide by the GDPR or
• Potential contract, mergers or acquisitions, any other policy, which the company may issue
confidential or otherwise sensitive company on time to time basis. For more details, please
information should not be filed or stored in a contact data protection officer.
non-KBL location, such as at employee’s home
or on his or her private computer, without prior At the same time, no confidential information
approval obtained during your work with former employers
should be brought on premises or used in any
form in your work at KBL.

*Note: Above list is inclusive Code of Ethics 37

 • Do not give your SAP or other systems A: Yes. Before communicating with suppliers
password without appropriate authorisation or customers about this KBL innovation, you
• Do not enter or allow entry in a restricted area should contact the Legal Department to be sure
that the appropriate confidentiality and non-
• Do not access the computer or allow access
disclosure agreements are first put in place.
to your system or network without appropriate
These will ensure that the other party honours
authorisation
the confidentiality of our intellectual property and
will help protect the company’s interests if there
Q: I am working on an exciting innovation related is ever a dispute about ownership of confidential
to our pump and have been meeting a supplier information.
to discuss the sourcing of the related product.
I have exchanged e-mails with the supplier
containing information about the innovation.
Is there anything I need to do to safeguard the
company’s interest ?

38 Code of Ethics
 Social Media
(Web Logs, Social Networks, LinkedIn, etc.)

We have a commitment and responsibility to Q. I have been asked to speak to a reporter, on

be honest and accurate in our communications one of our businesses and, during the course
to the employees and to the public at large. No of the interview, if the reporter asks my opinion
employee will knowingly/unknowingly make on rumours about a competitor having quality
a false or misleading statement to the media, problems with a key product and I have heard the
financial community, government official, public same rumours, how should I respond?
agency or on a public forum. A. We should not engage in circulating rumours
We will strive to create, establish and follow a either about KBL or our competitors. You
communication process that ensures timely flow should only share facts about KBL and let our
of information throughout the organisation and competitors speak for themselves. Ethics and
creates consistent messages that are delivered integrity demand that we take the high road in
by appropriate individuals in the organisation. such cases.
Only authorised individuals should speak to the
media or financial community. Employees should Q. I have received a call from a local newspaper.
not speak to the media on company related The reporter would like to come to the office
issues or post messages on social media on to interview me for a story on a community
behalf of KBL. organisation in which I am involved. Is this
KBL has a legal obligation to disclose material permitted?
financial information as broadly and equitably as A: Yes. Our employees are not prohibited from
possible. Inquiries from stock market analysts, talking to the media on non-KBL issues. Just
investors or other members of the financial make it clear to the reporter that you are speaking
community should be forwarded to the Head- as a private individual and not on behalf of KBL.
Finance. They can interview at your home as well.

Code of Ethics 39
 Acquiring Information About Competitors
or Other Third Parties

The KBL Code of Ethics recognises that acquiring • Public Presentations

and using information related to competitors is • Product Brochures, Documents and Journals
accepted as a routine business practice. The
• Advertisements
code however directs that such information will
only be sought when there is a reasonable belief • Internet Websites
that both receipt and use of the information is • Market Research Agencies (Information
lawful. collected in an Ethical Manner)
While in process of acquiring information, follow
two principles: Q. I have good relations with a customer who is
1. Do not induce a person to betray trust by also a customer of a KBL competitor. Using my
offering or giving a gift or alluring with relations with this customer, can I influence him
some prospective employment or business to collect the competitor’s product data, new
opportunity. development plan, pricing, etc. for KBL?
2. Do not intrude on reasonable expectations A: No. Influencing or lying to someone to get the
of privacy or confidentiality. Competitive competitors data is not a KBL ethical norm. Only
information includes anything related to the data publicly available or from market research
competitive environment or to a competitor. agencies should be used for competitive analysis.
We may make appropriate observations about
our competitors’ products, market, pricing
or business plan activities based on publicly
available information, such as:

40 Code of Ethics
 Use of Company Resources

Personal Use of Resources • Driving or using a company vehicles, tools,

equipment or other company assets without
Effective use of Company resources is critical to
authorisation
our profitability and image. Company resources
include such things as company time, materials, • Using electronic networks, including the
supplies, telephones, equipment, information, Internet, except as authorised by local policy
electronic mail and computer systems. We • Using any KBL resources for personal financial
provide these resources to fulfil company’s goals gain
and purposes. Your manager or supervisor must • You should report any improper use of
approve any personal, community, charitable company resources to your manager or
or other non-business use of these or other supervisor or the Ethics Counsellor. By limiting
company resources. Protecting company assets company resources to business purposes, you
against loss, theft, misuse and waste is the are helping KBL to control costs.
responsibility of each employee.
Your usage must be lawful, consistent and must
not interfere with the performance of your job Information Systems and the Internet
responsibilities or distract other employees. We rely on our information and technology
Some examples of excessive use of company resources to meet operational, financial and
resources communication requirements. These resources
• Excessive calling or sending fax long-distance include our telephones, fax machines, cell
phones, computers, computer applications,
• Extensive photocopying and printing networks and the information stored in them.
• Copying computer software programmes Use of our networks and information resources
(except when authorised) is both a necessity and a privilege. If you have
• Taking office supplies home access to our networks, use it responsibly. If

Code of Ethics 41
 you use KBL networks from home or other Illegal Use
non-KBL locations, you are subject to the same
It is against KBL ethics to send off-colour jokes to
standards of use as are employees who use it
others or to spread sexual or other discriminatory/
from company premises. Computers and all of
personal gossip through our Company resources.
the information stored on our computers and
This type of activity may be considered
networks are company property and are subject
harassment under the sexual harassment policy
to review anytime.
of company.
You must never use company networks to view,
You should not use computers or networks of upload, download or circulate any of the following
KBL for any of the following activities: materials:
• Accessing Internet, email accounts or using • Sexually related or pornographic messages or
external ‘chat’ or ‘instant messaging’ services material
• Conducting independent business activities • Violent or hate-related messages or material
• Soliciting for commercial, charitable, religious • Bigoted, racist or other offensive messages
or political causes aimed at a particular group, caste or individual
• Sending chain mail letters or broadcasting • Malicious, libellous or slanderous messages or
personal messages material
• Uploading or downloading unauthorised • Subversive or other messages or material
software or copyright-protected information, related to illegal activities
except if authorised
• Sending inappropriate, offensive or disruptive
KBL reserves the right to periodically monitor,
messages
access and disclose the contents of its computer
• Gaining unauthorised access to databases or systems and networks and to block access to non-
information sources at KBL or any other site business related Internet sites. Employees who
• Damaging computer equipment, software or repeatedly or seriously misuse KBL networks are
data subject to disciplinary action, including possible
• Interfering with or disrupting network, services termination of employment.
or equipment

42 Code of Ethics
 Manufacturing

KBL ethics of ‘Manufacturing’ include I) High Standards of Manufacturing

implementing and managing manufacturing Processes and Practices
practices that comply with applicable laws,
environmental standards and the company’s KBL is committed to use high standards of
mission. KBL strives to balance the economic processes and practices at each stage of product
impact while actively promoting the benefits of manufacturing (production, assembly and
product quality. testing). KBL is committed to deliver its products/
services to the customer complying to all the
KBL ethics of manufacturing balances business agreed requirements of quantity, quality and time
priorities (low cost production, quality materials, bound delivery.
need for profits, etc.) with corporate social
responsibility (fair wages, impact of product
consumption and recycling to consumer health, II) Self Discipline
impact on overall environment and long term
KBL encourages a high degree of self discipline
sustainability, etc.)
among its employees at work place, including
KBL is guided by the following ethical prohibition on chewing tobacco, tobacco
manufacturing standards wherever it operates products and smoking.
and its contract factory partners are symbiotically
bound by the same standards. Partners must train
their employees on their rights and obligations as III) Employment Practices
defined by these standards and applicable local KBL is committed to ‘no use of child labour of any
laws. kind’, nor shall materials be purchased that are
produced by child labour.
Core standards of KBL manufacturing are:

Code of Ethics 43
 IV) Harassment or Abuse and conditions. Production facilities shall pay
employees according to the minimum or above
Every employee shall be treated fairly and with
minimum wages applicable by local law and shall
respect and dignity. No employee shall be
provide legally mandated benefits.
subjected to any physical, sexual, psychological
or verbal harassment or abuse.
VIII) Hours of Work and Overtime
V) Non-discrimination Compensation
No employee or job applicant shall be subjected Except in extraordinary business circumstances,
to any discrimination in employment, including employees shall not be required to work for more
hiring, promotion, salary, benefits, advancement, time than as stated in the law of the country of
discipline, termination or retirement on the basis manufacture. Employees shall be compensated
of gender, race, religion, age, disability, sexual for overtime hours at such applicable rate as are
orientation, nationality, political opinion, social or legally prevalent in the country of manufacture.
ethnic origin.
IX) Environmental Compliance
VI) Safe and Healthy Working KBL’s production facilities must comply with
Environment all applicable environmental laws, rules and
regulations of the country in which they operate.
KBL’s production facilities strive to assure
KBL expects the local management of production
employees a safe and healthy workplace that
facilities to make progressive improvements
does not expose workers to hazardous conditions.
in the environmental performance of their own
KBL provides an accident-free environment to
operations and require the same of their partners,
prevent injury to health arising out of, linked with
suppliers and sub-contractors. Production
or occurring in the course of work or as a result of
facilities shall be part of, or shall work towards,
the operation of employer facility / factory.
a global environmental assurance programme
and incorporating sustainable environmental
VII) Fair Wages and Benefits practices into business practices by minimising
waste and pollution, proper disposal of all waste,
KBL shall ensure that its production facilities
reducing carbon emissions; designing and
share its commitment for the betterment of wage
developing sustainable products, materials and
and benefit levels that address the basic needs
technologies.
of workers and their families so far as possible
and appropriate in light of national practices

44 Code of Ethics
X) Gender Equity defect to your notice. This will help in cultivating
ethical culture among all employees as well.
Female workers in KBL receive equal remuneration
including wages, benefits, allowances and
are given the same opportunities, inclusive of Q: KBL has banned the use of any ‘asbestos’
promotion, available to male employees with material in its products, as it is injurious to
the same qualifications. Those taking the legally health. However, a client is insisting for the same
mandated “Maternity Leave” are not unlawfully referring to some old drawings/specifications.
impacted. Should we go ahead and use ‘asbestos’ in the
product to comply with the requirement of our
customer?
XI) Legal and Ethical Business Practice
A: No. You need to educate your customer on
KBL’s production facilities and service providers ‘Asbestos related injury risks’ and distract him
must comply with all applicable laws of the from using ‘asbestos’ in products.
country in which they operate, including but not
limited to applicable laws, rules and regulations
relating to salaries/wages, working hours,
conditions of employment, health, safety,
environment and immigration.

Q: During assembly of a product, one of my

fitters brings to my notice a defect in one of the
components which can cause a problem during
service life of the product. However, I have to
meet my daily assembly targets committed to the
management. Should I go ahead with assembly
using the defective part, as the product will pass
the ‘Third Party Inspection’?
A: No. As an ethical manufacturing practice of
KBL, you just cannot use/hide the defective parts
to meet your targets though the product will
pass the “third party inspection”, as it will cause
problems in its service life later on. In fact, you
need to appreciate your fitter for bringing the

Code of Ethics 45
 Project Management

Follow Good Engineering Practices The project management team needs to be fully
aware of all the rules and regulations to ensure
During Project Tendering, Project Execution
compliance without default at all times. It is
and Site Management, we come across several
very important to revert to the in-house expert,
occasions where our own products/services are
whenever in doubt, to get necessary clarifications
below the normally acceptable standards. It is
and guidelines. Defaults, in case of occurrence,
obvious that a vigilant customer would notice
should be immediately notified to the experts at
and point out the same. Such incidences may
the Head Office for necessary corrective actions.
become grounds for unethical practices, if not
Do not try to use alternative methodologies to
taken positively. These are times when process
resolve a crisis.
correction, learning and improvement takes place
within us. It is recommended that we always
follow good engineering practices and abide Maintain the Dignity of the Code of
by technical codes and internal standards apart
from the client’s technical specifications. This
Ethics
can eliminate major disputes and the aftermath The code of ethics needs to be imbibed by all
thereof. personnel to honourably project the image of
KBL. Display of the code of ethics can be through
simple issues such as the dress code, punctuality,
Follow Statutory Norms and Regulations decency in behaviour, routine correspondence
Project operations during tendering, execution and personal interactions. The code has to be
and site management stages are continuously understood from all these aspects, apart from the
required to conform to various prevailing written rules and guidelines.
statutory norms and regulations as enforced
by government machinery. Taxation, labour
laws, industrial safety and hazard laws, judiciary
Health and Safety Measures
requirements, etc. are some important aspects. KBL employees should strive to bench mark the

46 Code of Ethics
company’s norms and practices on health and Such meals/parties should be limited to
safety to international standards. The guidelines occasions, e.g. completion of a milestone activity,
stated in health and safety manuals should be major equipment erection, commissioning of a
practiced, while within the company as well as plant or handing over of a project site. This can
on business travel. The implementation of these be coincided with the visit of a senior official
should be self-driven and should not require of KBL to the site such as Sector Head/Head of
policing. Department. This will discourage the practice
of the client’s junior officials demanding or
expecting such entertainment from the site
Hospitality to Clients/Officials visiting engineer more frequently.
KBL Offices/Works
Frivolous business activity at KBL may ensure Q. You are a KBL project site in-charge overseeing
high influx of visitors. Customer representatives the work of your sub-contractors at site. A labour
visit our offices and factories due to projects officer who conducts a surprise visit to your site
that we execute for them. It is essential to office finds out that your sub-contractor’s labour
have informality in treatment and follow policy record files are not in order. He threatens to file
guidelines while handling them. Concerned a case against KBL who is the main contractor.
employees should adhere to the guidelines, How would you handle this situation? Would you
especially on facilities related to transportation, bribe him to overlook the default? Would you
accommodation in Pune/works, entertainment encourage you sub-contractor to do the same or
and recreational courtesies (swimming pool, would you remain inactive in this regard, as you
tennis court, golf course, etc.) to be extended on feel this is not your work or responsibility as a site
such occasions. engineer?
A. You should do none of the above. Remember,
Meals and Entertainment at Project our legal department has already circulated
manuals which give guidelines on statutory
Sites
compliance requirements at site which need to
It is a normal expectation at sites that client’s be strictly followed. Hence, first and foremost
personnel who are overseeing our work are ensure that at all times, such files and records
extended invitations for meals. This, if conducted are updated. In case there is a default, normally
on occasional basis is acceptable but when there is a time frame provided as per the law
overdone may lead to unnecessary expenses and for compliance. You need to see that the non-
distraction from the actual work, which needs compliance report raised by the labour officer is
completion. closed within the stipulated time. In case of any
doubt or query, immediately contact our inhouse

Code of Ethics 47
 expert located at head office or regional office for Q. As a site engineer, you are constantly being
his guidance on necessary corrective action. requested by various representatives of the
client for arranging dinner parties at site. This is
affecting your work schedule and also increasing
Q. You are executing a project and find that
your cost at site. How would you handle this
you are continuously facing difficulties in
issue without causing any adverse effect on your
getting equipment accepted by the client after
relationship with the client?
inspection or acceptance of site erection work by
the client’s field engineer. How would you handle A. We propose to issue a guideline document on
this situation? this matter which can be referred. However, as
a policy, you should emphasise on the fact that
A. Most projects have a very detailed technical
celebration or entertainment at site is normally
specification for each and every equipment based
done on completion of major milestone activities
on which Quality Assurance Plan (QAP) and Field
such as foundation laying, commissioning of plant
Quality Plan (FQP) can be prepared and get
or handing-over of project, etc. Site engineers
approved by the client in advance. All inspections
should also try to convey to the client that such
of equipment and erection work should be strictly
events require you to take prior approvals and
conducted as per approved QAP/FQP and the
should be conducted during the visits of senior
inspection results documented in an Inspection
KBL officials to site, thus indirectly reducing such
Report/Site Protocol. This should minimise your
frequent and direct demands from the customer
issues to a great extent.
on the site engineers.

48 Code of Ethics
 Customer Service and
Operations Management

KBL is committed to customer satisfaction and • Help customers in proper selection, operation
shall constantly strive to meet the required and maintenance of products manufactured
national and international standards. by the company
• Deliver ‘value for money’ on sales of products • Obtain customer feedback on the performance
and services of the product, reliability and after sales service
• Supply products as per specifications and • Organise customer meets to share their
deliver them on schedule experience, apprise them with new products,
• Provide prompt ‘after sales service’ added features in products, applications and
services offered

Code of Ethics 49
 Relationship
KBL and its Employees
KBL and its Customers
KBL and its Subsidiaries
KBL and its Suppliers
KBL and its Dealers
KBL and Society

50 Code of Ethics
 KBL and its Employees

At KBL, we encourage and expect you to express We practice and promote such policies at all
your thoughts and ideas for improvement at locations as appropriate under the law. We affirm
workplace and any concerns you may have about this principle of freedom from discrimination in
the workplace or specific job-related problems. all aspects of employment relationship, from
We will not retaliate nor tolerate retaliation against recruitment and hiring through performance
any employee who raises an issue, a complaint or evaluation, compensation, promotions, etc. till the
a concern in good faith. Our goal is to deal fairly end of your employment with KBL. We base our
and equitably with each employee. actions strictly on individual ability, performance,
experience and company needs. We avoid
actions influenced by personal relationships and
Diversity discriminatory practices of any kind. Our goal is to
KBL affirms the principle of equal employment compensate personnel with wages, salaries, and
opportunity irrespective of any protected other benefits in relation to their responsibilities,
characteristic, including but not limited to: performance and services. KBL is also committed
• Race to adhering to wage, hour and minimum age
guidelines provided by applicable laws. It is our
• Religion endeavour to structure the content of jobs so that
• National Origin work provides personal satisfaction, challenge
• Gender and growth.
• Age
• Disability
• Marital Status
• Ancestry

Code of Ethics 51
 Harassment Q: You report what you feel is harassment to your
supervisor, but he doesn’t appear to take your
It is KBL policy to provide a work environment ‘free
concern seriously. Do you have other options?
from harassment’. “Harassment’’ mostly refers
to sexual harassment but it may also include A: Yes. You can take the matter directly to
harassment based upon a person’s race, religion, Regional/Ethics Counsellor. If you prefer not to
country of origin, gender, sexual preference, age, speak about such an issue face-to-face, you can
disability or other protected characteristics. utilise the KBL Ethics Helpline or the KBL Ethics
Incident Reporting Website.
KBL prohibits harassment in any form, whether
physical, verbal or by communication. Report
such instances to your manager or to your Health and Safety
Regional/Ethics Counsellor. Your report will be
kept confidential to the best possible extent and We are committed to protect the health and
no complainant or witness will suffer retaliation safety of our employees, visitors and the public.
because of a report made in good faith. Our policy is to maintain our facilities and run our
business operations in a manner that does not
jeopardise the occupational health and safety of
Q: Most of your work is physically performed employees. Compliance of these laws along with
around a specific person who appears to be KBL policy is mandatory for all employees. Threats
interested in you romantically. He/She often or acts of violence against KBL employees,
makes flirtatious remarks that make you temporary employees, independent contractors,
uncomfortable and this individual tends to get a customers, clients, partners, suppliers or other
little too personal. So far you have ignored his/her persons and/or property will not be tolerated.
behaviour, but lately, he/she has started calling Every stakeholder of this company is required
you at home even at odd hours. One day, he/ to act responsibly and report immediately, any
she asks you for a date. Should you report such potential threats or acts of violence in this regard.
behaviour? In case of an emergency, contact Corporate
A: Yes. You should report such behaviour to your Human Resource Management Department.
supervisor/Human Resource Department. It may
initiate a review and if necessary, an investigation.

52 Code of Ethics
Taxation in achieving results with a proper approach to
business conduct. We expect all employees to
KBL expects all employees to pay income tax and
respect other individuals’ dignity and behave in a
professional tax on all income received from KBL,
manner which will promote a feeling of fairness
including taxes on income from the exercise of
among all employees. As an organisation we are
stock options (if any).
committed to develop a culture which will nurture
Ethical Behaviour among employees, which can
Employee Behaviour be realised only through individual commitment
and discipline.
KBL expects its employees to behave in a manner
which fosters feeling of “Doing the Right Things
in the Right Way”, thereby bringing synergy

Code of Ethics 53
 KBL and its Customers

At KBL, conducting successful business with clients and suggest suitable products and
customers is based on strong relationships, services based on their requirements. KBL will
mutual respect and trust towards our customers. assist private clients if need be, during the initial
To maintain and grow these relationships, we phases of developing their project.
treat everyone in a way we would expect to be
treated i.e. with fairness, honesty and respect.
In our marketing and in our interactions with KBL and Government Customers
customers, we should always represent KBL KBL will deal fairly and transparently with
products and services fairly and accurately. Our Government clients and suggest suitable products
appeal in the marketplace must be based on and services based on their requirements and
the quality of our products, pricing and services, assist them if needed.
along with the competence and honesty of our KBL and Sales to Countries on the Restricted
product and sales presentations. Trade List/Countries under Sanctions
KBL will not deal with countries on the Indian/
KBL and its Dealers international restricted list without clearance
from the concerned agencies.
KBL will present only accurate data to dealers
and adhere to the policies set-forth. All policies
that are updated before their term will be done KBL and Sales to NGO
keeping the dealer informed. KBL will educate
dealers so that they provide accurate information KBL will deal fairly and transparently with NGO
about our products and company to our clients. (Non-Governmental Organisations) and suggest
suitable products and services based on their
requirements and will also pass on special prices
KBL and Private Customers for this segment based on its CSR and Society
policy.
KBL will deal fairly and transparently with private

54 Code of Ethics
 KBL and its Subsidiaries

KBL and its subsidiaries shall provide customers All present and future subsidiaries should adhere
with industry-leading solutions and services. The to high ethical standards, conduct business fairly
senior management team of each operating unit and ethically, avoid engaging in any activity that
or subsidiary is responsible for ensuring that involves even the appearance of impropriety
applicable legislations are complied with and and comply with all local applicable rules and
requirements are appropriately communicated to regulations.
their respective staff.

Code of Ethics 55
 KBL and its Suppliers

KBL believes in maintaining open, transparent and innovative ideas with KBL for mutual
and ethical business dealings with all its suppliers benefit
and is committed to develop, maintain and foster • KBL encourages its suppliers to participate
long term relationship resulting into a ‘Win-Win’ in product/process design and improvement
situation for both parties. to enhance product performance and/or to
reduce cost
• KBL expects its suppliers to ensure • No KBL Employee shall ask a supplier for
confidentiality of data and information shared arranging paid hotel accommodation/hired
by KBL, during the course of business. KBL transport, paid air/train bookings, implicit/
also expects its suppliers to refrain from explicit desire for a gift, etc.
divulging confidential competitive information • KBL expects its suppliers to:
• KBL follows ZERO based costing process and - comply with all applicable laws and
expects its partners to share detailed cost regulations in their operations and also in
elements and have a common understanding the supply of goods and services to KBL
of component costing
- maintain appropriate remuneration as
• Any change in purchase policy/transactional applicable in the region
process/commercial terms/cost shall be
- avoid a child labour
discussed and agreed upon between KBL
and its concerned suppliers. All such mutual - avoid usage of toxic and non-bio degradable
agreements shall be documented and substance in products, packaging and
communicated for clear understanding and processes
future reference KBL encourages its suppliers to subscribe to the
• KBL believes in sharing knowledge and concern for environment, responsibility towards
learning with partners and also expects the society and promotion of health and safety of all
partners to share their knowledge, expertise their stakeholders

56 Code of Ethics
KBL expects its suppliers to follow principles A: Yes. A close relative can be engaged to supply
of honesty and fairness and avoid engaging in services/parts to KBL. Due care should be taken
any activity that even involves appearance of to ensure that the terms and conditions are not
impropriety more lucrative than would be normally accepted
KBL is committed to maintain its part of contract, for a third party supplier (Non-relative).
in letter and spirit, without any bias or prejudices
In case a supplier is harassed or asked for undue Q: I am visiting a city, where our supplier owns/
favours/bribe by a KBL employee, the supplier runs a hotel. Can I stay in his hotel?
is encouraged to bring the case to the notice of A: Yes. You may stay in a hotel owned/run by our
Head-Materials, Head-HR, Head-Operations or supplier. But normal room rent and other charges
Ethics Counsellor must be paid.

Q: If my blood relative is a qualified service

provider or a supplier of parts required by KBL,
can he become a KBL supplier?

Code of Ethics 57
 KBL and its Dealers

KBL shall communicate to its dealers about The dealer shall comply with all applicable rules
relevant aspects of the company’s business and and regulations both in letter and spirit, in all the
disclose such information in accordance with territories in which he operates.
regulations and agreement. Failure to adhere to the Code of Ethics could
The dealer shall strive to make a positive attract the most severe consequences including
contribution, focus on customer satisfaction, ‘Termination of Agreement’.
and deal on behalf of the company, with
professionalism, honesty, integrity as well as high
moral and ethical standards.

58 Code of Ethics
 KBL and Society

KBL is committed to use its facilities, technology example, we seek to reuse and recycle as many
and resources to advance education in resources as we can. We must comply with all
innovative ways, promote diversity, enrich lives applicable environmental rules and regulations.
of communities and protect the environment. We expect you to immediately report any
In balancing the needs of its business with the instances of non-compliance with environmental
needs of the environment, KBL policy emphsises rules and regulations to your local administrator
on maintaining its facilities and running its or your Regional/Ethics Counsellor, else to the
business operations in a manner that minimises KBL Ethics Helpline or the KBL Ethics Incident
any adverse impact on the environment. As an Reporting Website.

Code of Ethics 59
 Enforcement

60 Code of Ethics
 Enforcement

Appointment of the ‘Ethics Counsellor’ shall support him ably and competently. The
and ‘Regional Ethics Counsellors’ Ethics Counsellor will have a team of Regional
Ethics Counsellors identified and appointed
KBL shall appoint one ‘Ethics Counsellor’ to across the global set-up of the organisation and
ensure efficiency and effectiveness of all the will be made responsible for particular segments
mechanisms involved. He will be the Process (geographical or functional). All these Regional
Owner of all the subsequent mechanisms, Ethics Counsellors will report to the Head Ethics
processes and actions involved, to maintain and Counsellor for all relevant matters/cases.
enrich an ‘Ethnocentric Culture’ in KBL. The Ethics
Counsellor shall lead the Ethics Committee which

1. Communicate

4. Reward, Recognise or Punish 2. Measure and Monitor

3. Act and Improve

Business Ethics Process

Code of Ethics 61
 The Enforcement Mechanism
1. Communicate
KBL has identified a Specific Mechanism for its stakeholders to communicate the values and the spirit of
the KBL Code of Ethics and to create awareness and uniform understanding of the same.

Sr.No. Stakeholder Mechanism

• Top management team communicates through CMD
online, etc.
• Shop floor and Class-room programmes by Ethics
1. Employees Counsellors (EC)/Regional Ethics Counsellors (REC) for
employees and workers
• Print media (hoardings, inhouse journals, booklets, etc.)
• Induction programmes for new entrants
• Communication by top management during dealer and
supplier meets
2. Suppliers / Dealers • Ethics Counsellor’s communication during dealer meets
• Our website: www.kirloskarpumps.com
• Training to dealers/distributors/suppliers/transporters, etc.
• Training to Ethics Counsellors of JV and Subsidiaries
• Sharing of experiences
3. Joint Ventures and Subsidiaries
• Central forum for Heads and Ethics Counsellors of
Subsidiaries
• Communication to employees’ spouses
• Communication to school children through awareness
4. Society programmes
• Display of KBL Code of Ethics for public at large on our
website: www.kirloskarpumps.com
• Communication by CMD in the AGM
5. Shareholders • Communication of KBL Code of Ethics through printed
material

62 Code of Ethics
2. Measure and Monitor

Sr.No. Listening Post Mechanism

Channels for reporting concerns
• Personal meets
• ethics.helpdesk@kbl.co.in
• Email to Regional/Ethics Counsellor
1. Concern Management
• Written communication (can be an anonymous letter too)
Measures
• Number of concerns received from employees
• Number of concerns received from other stakeholders
• Employees: Post training and communication
• Suppliers/Vendors: Post supplier/vendor meets
• Distributors/Dealers: Post distributor/dealer meets
2. Feedback
• Shareholders: Post AGM
• Feedback mails on our website: www.kbl.co.in
• Feedback mails on ethics.helpdesk@kbl.co.in
• Vigilance/surprise check
3. Vigilance Check
• Audit in sensitive areas
4. Surveys • Surveys conducted from time to time

Concern Management Process:

STAKEHOLDERS

ETHICS COUNSELLOR

REGIONAL EC

CONCERNED AGENCY VIGILANCE / AUDIT

ACTION TAKEN

Code of Ethics 63
 3. Act and Improve

Sr.No. Stakeholder Mechanism

• ‘Hamara Ethics Month’
1. Employees • Special communication drive to all RECs
• Ethics process
• Supplier Relations Management Centre (SRMC)
• Vigilance check before registration of new vendor
2. Suppliers/Vendors • Direct feedback from our website: www.kirloskarpumps.com
• Enhanced awareness programmes
• Procurement manual
• Visit to customer’s work site
Customers/Distributors/
3. • Talk to transporters
Dealers
• Talk to various distributors/dealers
• Create awareness among female employees about the Sexual
Harassment Policy
4. Others
• Talk to Central Government Labor Department
• Talk to families of employees, school students and Team KBL

4. Reward, Recognise or Punish functions/forums like open house, general

• Action taken on misconduct by employees/ dialogues etc.
vendors • Best Departmental Ethics Co-ordinators
• Misconduct cases along with the concerned rewarded by CMD in functions like Foundation
action taken being reported on Internet Day, etc.
• Reputation champions to be recognised in • Vendors rewarded for ethical conduct

64 Code of Ethics
Critical Success Factors • Continuous communication of Business ethics
at different forums and with all stakeholders
• Role played by the senior management as ‘Role
Models’ - ‘Demonstration by visible actions’, • Periodic structured review of ethical issues by
‘leading efforts personally’ and ‘concocting a the senior management
culture that promotes ethics’
• Creating policies and structures which will act
as guidelines like procurement policies, gift
policies and whistle blower policy, etc.

Code of Ethics 65
let’s come together,
walk together