IFGL Refractories

This Code of Conduct shall be applicable to the following persons (hereinafter referred to as 'concerned persons').

Concerned persons are expected to read and understand this Code and comply with all applicable laws, rules and regulations and all applicable policies and procedures adopted by the Company.

It is expected that concerned persons will act in accordance with the highest standards of personal and professional integrity, honesty and ethical conduct. Honest conduct means the conduct that is free from fraud or deception. Ethical conduct means the conduct conforming to the accepted professional standards of conduct. Ethical conduct also includes ethical handling of actual or apparent conflicts of interest between personal and professional relationship.

Duty of concerned persons to the Company demand that he or she avoids and discloses actual and apparent conflicts of interest. A conflict of interest exists where the interests or benefits of one person or entity conflict with the interests or benefits of the Company. Examples include:

Employment/Outside employment : In consideration of employment with the Company, concerned persons are expected to devote their full attention to the business interests of the Company. Concerned persons are prohibited from engaging in any activity that interferes with their performance or responsibilities to the Company, or is otherwise in conflict with or prejudicial to the Company. Company’s policies prohibit concerned persons from accepting simultaneous employment with suppliers, customers, developers or competitors of the Company, or from taking part in any activity that enhances or supports a competitor's position. Additionally, concerned persons must disclose to the Company’s audit committee, any interest that they have that may conflict with the business of the Company.
Outside Directorships : It is conflict of interest to serve as a director of any company that competes with the Company. Concerned persons must first obtain approval from the Company’s audit committee before accepting a directorship.
Business Interests : If a concerned person is considering investing in any customer, supplier, developer or competitor of the Company, he or she must first take care to ensure that these investments do not compromise on his/ her responsibilities to the Company. Company’s policy requires that concerned persons first obtain approval from the Company’s audit committee before making such an investment. Many factors should be considered in determining whether a conflict exists, including the size and nature of the investment; the concerned person’s ability to influence the Company’s decisions; his or her access to confidential information of the Company or of the other company; and the nature of the relationship between the Company and the other company.
Related parties : As a general rule, concerned persons should avoid conducting Company business with a relative, or with a business in which a relative is associated in any significant role. Relatives include spouse, siblings, children, parents, grandparents, grandchildren, aunts, uncles, nieces, nephews, cousins, step relationships, and in-laws. The Company discourages the employment of relatives of concerned persons in positions or assignments within the same department. Further, the Company prohibits the employment of such individuals in positions that have a financial dependence or influence (e.g. an auditing or control relationship, or a supervisor/subordinate relationship).
Payments or gifts from others : Under no circumstances may concerned persons accept any offer, payment, promise to pay, or authorization to pay any money, gift or anything of a value from customers, vendors, consultants etc that is perceived as intended, directly or indirectly, to influence any business decision, any act or failure to act, any commitment of fraud, or opportunity for the commitment of any fraud. Inexpensive gifts, infrequent business meals, celebratory events and entertainment, provided that they are not excessive or create an appearance of impropriety, do not violate this policy. Gifts given by the Company to suppliers or customers, or received from suppliers or customers, should be appropriate to the circumstances and should never be of a kind that could create an appearance of impropriety. The nature and cost must always be accurately recorded in the Company’s books and records.
Corporate opportunities : Concerned persons may not exploit for their own personal gain, opportunities that are discovered through the use of corporate property, information or position, unless the opportunity is disclosed fully in writing to the Company's board of directors and the board declines to pursue such opportunity.