Code of Conduct

Imperial Chemical Industries (Pvt) Limited
Employees of Imperial Chemical Industries Ltd are expected to do the right thing – follow the law, act honourably, and treat each other with respect. In other words act in a manner which is ethical and represents the company positively.
We expect all of our employees and Board members to know and follow this Code of Conduct equally and regardless of position the failure to do so can result in disciplinary action, including termination of employment. However in certain limited circumstances exceptions may be made. Any such waivers of this Code for directors or executive officers must be approved by the Board, who will set the limits of those waivers.
If you have questions or concerns regarding the code of conduct speak to your manger, or if not appropriate, the human resources department. You can also follow this process to report breaches of this code. Imperial Chemical Industries Ltd has systems in place for investigating possible violations of this code. Copies of these are available from human resources on request. Never retaliate against anyone who reports or participates in an investigation of a possible violation of the Code as they are acting to protect the reputation of the company, and to retaliate would in itself breach the spirit of the code of conduct.
I. Avoid Conflicts of Interest
A conflict of interest may arise at any time, competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of this company or our customers. Avoid conflicts of interest and circumstances that reasonably appear to be a conflict. Sometimes a situation that previously didn’t present a conflict of interest may develop into one.
When faced with a potential conflict, ask yourself:
• Would this activity create an actual or apparent incentive for me to benefit myself, my friends, or my family?
• Would this activity harm my reputation or hurt my ability to do my job?
• Would this activity embarrass Imperial Chemical  Industries Ltd. or me if it showed up in the press?
If the answer to any of these questions is “yes,” the relationship or situation is likely to constitute a conflict of interest, and you should avoid it. If you are unable to avoid such a situation it is vital that you discuss the matter with human resources as soon as you are able. In this way the issue can be effectively managed so as to avoid any negative impact on yourself or the company.
II. Ensure Financial Integrity and Responsibility
It is the duty of all employees to ensure that money is appropriately spent, our financial records are complete and accurate, and our internal controls are honoured. This extends to safeguarding any company property and other assets which an employee uses or has contact with.
If your job involves the financial recording of our transactions, make sure that you’re familiar with all relevant policies. Never interfere with the auditing of financial records and never falsify any company record or account. It is vital that records are kept accurate and ‘off the book’ funds are not permitted in any circumstances.
If you suspect or observe any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them.
III. Obey the Law
The company and its employees will comply with all applicable legal requirement. It is important that you take the time to make sure you understand the major laws and regulations that apply to your work. There are some specific laws are easy to violate unintentionally and they have been highlighted within this document. If you have any questions about these laws or other laws governing our work, please consult our legal counsel.
1. Trade Controls
Various trade laws control where we can send or receive our products and services.
These laws are complex and apply to:
  • Importing and exporting goods to or from the Islamic Republic of Pakistan and other countries
  • Exporting services or providing services to non-Pakistani persons If you are involved in sending or making available products, to one country to another, work with your manager to ensure that the transaction stays within the bounds of applicable laws.
2. Competition Laws
Be sure you follow all laws designed to promote free and fair competition and protect consumers.
These laws generally prohibit
  • Arrangements with competitors that restrain trade,
  • Abuse of market power to unfairly disadvantage competitors, and
  • Misleading or harming consumers. Some of these laws carry civil and criminal penalties for both individuals and companies.
3. Insider Trading Laws
Do not use non-public information which you come in contact with through your employment at Imperial Chemical Industries Ltd to buy or sell stock, or to pass it along to others so that they may do so. That could constitute the crime of insider trading, even if you do not directly benefit financially from the sharing of that information.
4. Anti-Bribery Laws
Various laws that prohibit bribery in different settings. Our rule is simple – don’t bribe anybody, at any time, for any reason.
Non-government relationships. Be careful when you give gifts and pay for meals, entertainment or other business courtesies on behalf of Imperial Chemical Industries Ltd . Avoid the possibility that the gift, entertainment or other business courtesy could be perceived as a bribe. Provide such business courtesies infrequently and, when you do, to keep their value moderate. It is key that any courtesies do not obligate, or appear to obligate, the person receiving to a particular course of action.
5.Dealings with government officials.
Various laws prohibit seeking to influence official action by offering or giving anything of value to government officials, candidates for public office, employees of government-owned or -controlled companies, public international organizations, or political parties. Avoid not only traditional gifts, but also things like meals, entertainment, travel, political or charitable contributions, and job offers for government officials’ relatives. With pre-approval, it may be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., a modest meal at a day-long demonstration of our products).
This does not prevent employees from being involved in civic affairs or political activities. However this must be undertaken as an individual, at their own expense and in their own time. No company resources or facilities may be used to carry out such activities.
IV. Conclusion
We rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all members of Imperial Chemical Industries Ltd  to be guided by both the letter and the spirit of this Code.


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