Code of Conduct

Code of Conduct

Mission statement and code of conduct of the hubergroup India Private Limited June 2015


A. Who we are

We, Hubergroup India Private Limited(“Company”), are part of a Hubergroup.

Hubergroup, a 250-year-old family business that, through people, quality and service, has positioned itself as one of the world's leading suppliers of printing inks, varnishes, coatings, fountain solution concentrates, printing auxiliaries and related services

1. Mission

According to our motto "More than just ink" we supply high quality and specialized inks for use in information, entertainment, protection and for enabling financial transactions. We advise users with commitment and expertise and we provide exce llent service to help them achieve their goals.

2. Vision

As a global, people oriented, highly integrated and technology based supplier of printing inks we will adapt to the even changing demands in the end - use - markets more rapidly than our competitors. Our competence in attractive end use segments will make us the preferred partner for our customers. Our inks will provide functionality to printers and end users that enable us to generate healthy rates of return and to guarantee the long - term existence and growth of our business. We, the employees of the hubergroup , all work together as a team to achieve this success.

3. Core values

The following core values are at the heart of our every action and are intended to guarantee the successful future of the Company and hubergroup:

  • • Integrity
  • • Innovation
  • • Responsibility
  • • Health & safety and environmental protection
  • • Team spirit
  • • Courage
  • • Respect
  • • Transparency
  • • Trust
  • • Ethical Behaviour
  • • Honesty

With utmost respect to Human Values, we promise to serve our Customer with Integrity, through Innovative practices /solutions, on price quality matrix day after day.

B. Code of conduct

Our code of conduct applies to all employees and office - holders of the compan y around the world. All Company employees an d trainees are expected to read and understand this Code of Conduct, uphold these standards in day - to - day activities, comply with all applicable policies and procedures, and ensure that all agents, consultants, suppliers and contractors are aware of understand and adhere to these standards.

Its purpose is to help us to uphold our social responsibility towards our business partn ers, employees, shareholders and the public at large. To this end, the code sets out the ethical and legal framework for our actions. Its rules and principles give concrete expression to our core values.

The present code of conduct has been brought into line with the latest legislation and is based on laws relating to human rights, anti - corruption and sustainability. It is intended to strengthen the awareness of law and morality as an integral element of our business activitie s.

The present code of conduct represents the essence of our corporate culture. Consequently, all our employees are urged to adopt this code of conduct as the ethical basis of their work at the Company .

This Code of Conduct supersedes all other such c odes, policies, procedures, instructions, practices, rules or written or verbal representations to the extent they are inconsistent. The Company reserves the right to update the Code from time to time without any prior intimation at its sole discretion.

1. Basic standards of conduct

1.1 Lawful conduct

It is a basic principle of the Company to act in accordance with the laws and legal system of every country in which we do business. All employees must comply with the applicable Company guidelines, internal regulations and statutory requirements of the legal system within which they are acting. Breaches of the law must be avoided at all costs.

In the event of a breach of the law, every employee, notwithstanding the legally available san ctions, must reckon with disciplinary consequences for having violated the terms of their employment contract.

1.2 Respect, honesty, integrity

Every employee must respect the personal dignity, privacy and rights of every other individual. We work together with people from different ethnic origins, cultures, religions and of different age, irrespective of disability, skin colour, sexual orientatio n, ideology or gender.

On the basis of our corporate principles and the labour laws of the countries in which we do business, we tolerate no form of discrimination, sexual harassment or other personal attack on individuals. It goes without saying that th e Company must observe human rights and comply with national legislation, the right to freedom of assembly, nondiscrimination as well as reasonable, transparent wages and working times, health and safety in the workplace, as well as environmental protectio n.

These principles apply both to internal working practices between our employees and also to how our employees conduct themselves towards external partners. Decisions with regard to staff, suppliers, customers, other business partners, etc. must be bas ed exclusively on objective considerations. Under no circumstances may decisions be motivated by non - objective considerations.

We are open and honest and stand by our responsibilities. We are a reliable partner and only make commitments we can keep. We expect our employees to be honest in their dealings.

1.3 Responsibility for the reputation of the Company or Hubergroup

The reputation of the Company or hubergroup is highly dependent on the demeanor , actions and conduct of each individual employee. T he unlawful or inappropriate conduct of even a single employee is enough to do significant damage to the company.

All employees are required to respect, uphold and promote the reputation of the Company or hubergroup in whatever country they find themselves.

1.4 Role of executive managers and employees

Integrity and respect for the law start at the top of the company. Executive managers ( Divisional / Department Head s ) are upholders of our corporate mission. They should set an example through their impeccable personal conduct, performance, openness and social skills. Furthermore, they should at all times stress the importance of ethical behaviour and adherence to guideli nes in day - to - day business dealings. They should address and promote such conduct through their personal management style as well as training events. Goals should be formulated in clear and comprehensible language. Executive managers should foster an envir onment in which every employee is able to contribute their abilities and develop their strengths. They should help employees to assume responsibility and take initiative. At the same time, they should make it clear that adherence to the law and Company / huber group guidelines is a top priority under all circumstances and at all times. The executive manager is the point of contact for any questions in relation to compliance with laws and regulations as well as for any professional or personal concerns an emp loyee may have.

Executive managers are responsible in their area of authority for ensuring that employees do not commit any breaches of the law that could have been prevented by proper supervision. However, an executive manager's responsibility does not discharge employees from their own responsibility. Equally, an executive manager cannot delegate away his or her responsibility. Acting as a team, all employees must work to adhere to the laws and to Company / hubergroup guidelines.

2. Conduct towards business partners and third parties

2.1 Competition law and cartel law

For the benefit and in the interests of all consumers, free and fair competition is protected . Every employee is required to abide the applicable rules and regulations.

For this reason, employees must not, for example:

  • • talk to competitors about prices, invitations to tender, profits, profit margins, costs or other competition - influencing factors;
  • • arrange with competitors not to compete, to restrict business dealings with suppliers, to submit bogus bids or to divide up customers, markets, territories or product lines; or
  • • exert an influence on the resale prices of our customers.

Furthermore, it is not permitted to acquire competition - relevant information by means of illegal actions, such as bribery, theft or eavesdropping, or knowingly to disseminate false information about a competitor or their products or services.

2.2 Corruption: granting undue advantage

The Company will only obtain and conduct business legally and ethically. The quality of our products and the efficiency of our services at competitive prices is our greatest tool in our business. Profits do not justify unfair / unethical business tactics.

Corruption produces decisions based on improper grounds, prevents progress and innovation, distorts competition and harms society.

The Company wins its customers through the price and quality of its innovative products as well as through the excellent technical service it provides, and under no circumstances by granting undue advantage to others.

The Company will only obtain and conduct busine ss legally and ethically and Profits do not justify unfair / unethical business tactics. A contribution or entertainment should never be offered under circumstances that might create the appearance of an impropriety. S ome very modest gifts, which may be considered, appropriate to be given in the normal course of business practice may be acceptable if they meet the following criteria;

  • • They are consistent with accepted business practices.
  • • They do not violate applicable law.
  • • They cannot be reasonably construed as payment or consideration for influencing or rewarding a particular decision or action.
  • Their public disclosure would not embarrass the Company / hubergroup.

As a basic rule, any impression of dishonesty or impropriety must be avoided.

2.3 Corruption: accepting undue advantage

No employee may use their position within the company to demand, accept, obtain or exact an undue advantage. This does not include the acceptance of occasional gifts of symbolic value or invitations to meals/events within reasonable limits as long as the l ocal customs and Company / hubergroup guidelines are respected. Any other gifts or invitations to meals/events can create the impression that the individual giving the gift or making the invitation expects to draw an advantage therefrom.

As this can da mage the reputation both of the employee and also of the Company / hubergroup, such gifts and invitations to meals/events must be firmly declined.

2.4 Donations and sponsorships

As a responsible member of society, the Company makes donations, in money and in kind, to science and education, culture and the arts as well as to social and humanitarian projects. Conversely, the Company / hubergroup does not make any donations to politicians, political parties or political organisat ions.

Any donations are made in a transparent manner. This means that the purpose, recipient and donation receipt are recorded and are verifiable.

Sponsorship agreements (under which the Company is provided with advertising opportunities), contribution s to industry associations or membership fees to organisations that serve the Company’s / hubergroup's business interests, do not count as donations.

All sponsorship activities must be transparent, recorded in the form of a written contract, serve a leg itimate business purpose and be commensurate with the consideration offered by the event organiser.

It is forbidden to enter into sponsorship activities for events whose goals are incompatible with the Company’s / hubergroup's corporate principles or eve nts that do harm to the Company’s / hubergroup's standing.

2.5 Business relations with suppliers

We expect our suppliers to abide by the laws and to share the hubergroup's core values. More specifically, the following principles, as defined by the hubergroup for itself, should be applied:

  • • Renunciation of corruption
  • Respect for the human rights of their employees
  • Compliance with legislation against child labour and work in a pro-active manner to eradicate child labour
  • Acceptance of responsibility for the health and safety of their employees and compliance with the relevant national laws and standards on environmental protection
  • Implementation of and compliance with these core values along the supplier's own supply chain.
  • A voidance of forced or compulsory labour

2.6 Selection of suppliers

The Company's suppliers make significant contributions to our success. To create an environment where our suppliers have an incentive to work with the Company, they must be confident that they will be treated lawfully and in an ethical manner. The Company' s policy is to purchase supplies based on need, quality, service, price and terms and conditions. Suppliers should be selected based on merit, price quality and performance. The Company's policy is to select significant suppliers or enter into significant supplier agreements through a competitive bid process where possible. Under no circumstances should any Company employee, agent or contractor attempt to coerce suppliers in any way. The confidential information of a supplier is entitled to the same protect ion as that of any other third party and must not be received before an appropriate nondisclosure agreement has been signed.

3. Avoidance of conflicts of interest

All employees are obliged to act in the company's best interests. Therefore, it is essential to avoid situations in which the personal interests of the employee or his/her relative or significant other or with a business entity , in which a relative or significant other is associated in any signif icant role , conflict s with the interests of the Company / hubergroup. Where there is a conflict, the interests of the Company / hubergroup must not be adversely affected. As a basic rule, all potential conflicts of interest should be brought to the notice of the Company Management by the employee's along with full disclosure of all the facts and a ny dealings with a related part ies must be conducted in such a way that no preferential tre atment is given .

All employees are expected to devote full attention to the business interests of the Company and are prohibited from engaging in any activity that interferes with their performance or responsibilities to the Company or is otherwise in co nflict with or prejudicial to the Company.

3.1 Competition

No employee may run or work for a company that is in competition with the Company / hubergroup.

Equally, no employee may engage in activities that conflict with those of the Company / hubergroup.

3.2 Secondary employment

Potential paid secondary employment must be notified to the competent human resources department and will require prior written consent. Consent to secondary employment will not be given where it conflicts with the inte rests of the Company / hubergroup. Secondary employment can be refused if the employee has official business with the company in question. Any consents that have already been given can be withdrawn if there are such grounds.

The Company may, after consid ering the facts and circumstances of each case, permit certain employees to work for certain Non - Governmental Organisations, Clubs and Charitable Institutions. The employee should ensure that his services do not in any manner affect the Company’s interest.

3.3 Participation in companies

Where an existing or potential direct or indirect participation in a competitor might result in influence being exerted on the management of such competitor, this must be notified to the Compliance department. As a basic rule, a capital stake of over 5% will be deemed to give rise to the possibility of exerting influence. Employees who directly or indirectly hold or acquire an interest in a business partner of the Company or a Company in which the hubergroup holds an interest, must likewise notify the Compliance department thereof if the employee has official business with the company in question or intends to take up a position in such company. Upon notification of such participation in a third - party company, the com pany can take suitable measures to avoid a possible conflict of interests.

4. Use of company resources

In order to achieve our common goals, the Company provides its employees with company resources, which must be used exclusively for company purposes and not for personal benefit and should protect the Company’s assets from loss, damage, misuse or theft . Exceptions and, where appropriate, payment can be agreed locally, provided that use of the resources:

  • • is not in connection with illegal activities;
  • • does not give rise to a conflict of interests or create the impression of such a conflict;
  • • does not result in additional costs, disruption to the Company’s / hubergroup's business activities or other negative consequences for the company, such as through a conflict of interests with regard to the professional duties of the relevant employee or other employees.
5. Use of information

5.1 Records and financial integrity

Our financial records constitute the basis for the governance of our company and guarantee open and effective communication through accurate reporting. In the context of their official duties, therefore, every employee must take steps to ensure that all bu siness transactions are fully, correctly and promptly entered and documented in the books and records in accordance with the other statutory and contractual requirements. The books and records must include all data, audit certificates and other written doc uments required for the purposes of financial reporting and compliance with disclosure obligations, as well as any documents that are collected for other purposes. Employees should never make any false or artificial entries in any records. Standardised pro cesses and oversight regimes ensure that transactions are conducted in conformity with the laws and company guidelines.

5.2 Confidentiality

Every employee is obliged to observe confidentiality towards unauthorised persons in respect of trade and com pany secrets of the Company / hubergroup. Non - public information of or about suppliers, customers, employees, agents, consultants and other third parties must also be protected.

All third party's confidential information has been disclosed to the Company with an obligation to abide by the terms of the relevant non - disclosure agreement , which limit its use to the specific purpose , therefore, every employee should disclosed it or disseminate it only to those employees , who need to know the se information.

Trade and company secrets as well as confidential information can include, in particular:

  • Details about a company 's organisation and facilities, prices, sales, profits, markets, customers and other business affairs
  • Information on developments, plans and t rials/experiments and
  • Internal reporting figures.

The obligation to respect confidentiality extends beyond the end of an employee's employment contract. This is because the disclosure of confidential information, whenever it takes place, has the potent ial to harm the business activities of the Company / hubergroup or its customers. Employees who have access to proprietary and confidential information must take every precaution to keep it confidential.

5.3 Data protection and data security

The use o f modern information and communication technologies is a prerequisite for the effectiveness of our employees and, therefore, for the commercial success of the Company / hubergroup. However, the use of such communications poses risks to personal privacy and data security. Effective precautions against such risks are an important element of information technology management, corporate governance and also the conduct of every individual.

Personal data may be collected, processed or used only where this is necessary for explicitly defined and lawful purposes. All the components of the information processing chain must be so secured that the confidentiality, integrity, availability and verif iability of sensitive information is guaranteed and unauthorised internal or external use is prevented. The use of data must be transparent for the data subject. The data subject's rights to information and, where necessary, to objection, blocking and del etion must be safeguarded. All employees must comply with national laws and regulations in relation to the storage and use of personal data.

Employees should ensure that they use only licensed software and take back - up of all important data. Uses that t hreaten the integrity of the system, the privacy of others or that are otherwise illegal, must be avoided . The company reserves the right to access and monitor all messages and files on its system, including information regarding employee Internet use, as and when deemed necessary and appropriate. The electronic resources shall be used in an effective, ethical and lawful manner only . Users who receive or notice obscene or inappropriate messages are needed to report the same immediately to their manager or H uman Resources Department. The Information Management group (IMG) assigned Company e - mail address should be used for official purposes only.

5.4 Protection of intellectual property

Employee have an utmost obligation to them selves to identify and protect the intellectual properties, trade secrets and other confidential information owned by the Company and it’ s clients or associates because it is critical to Company’s success. "Intellectual Property Rights ” ( IPR) , mean s paten ted or potentially patentable inventions, trademarks, service marks, trade names, copyrightable subject matter, and trade secrets.

6. Environment, health & safety etc.

6.1 Environment

Environmental protection and sustainability are important corporate goals of the Company / hubergroup. Our business activities are made environmentally compatible through appropriate management responsibility and the commitment of our employees. We are res ponsible for continuously improving the environmental compatibility of our products, lowering our emissions and reducing the stress on natural resources. Every employee must contribute to this goal by making appropriate and sparing use of natural resources .

6.2 Health & safety at work

Our employees have a right to health and safety at their workplace. For this reason, the Company / hubergroup complies with statutory and technical standards in relation to health and safety in the workplace. Every employ ee is called upon to support the Company / hubergroup in its efforts to create safe working conditions and to pay constant attention to occupational health and safety issues. Responsibility towards employees and colleagues requires the best possible accide nt prevention measures.

6. 3 Discrimination and Sexual harassmen

The Company endeavors to offer equality of opportun ity to all employees and not to engage in or support discrimination in hiring, compensation, access to training, promotion, termination or retirement based on ethnic and national origin, race, caste, religion, disability, sex or political orientation.

The Company is committed to providing its employees with a productive work environment that is free of intimidation and harassment irrespective of the gender and to m aintain a work environment free of sexual harassment. Therefore, t he Company strongly disapproves of and shall not tolerate any kind of harassment written, verbal or otherwise against a particular gender. Harassing conduct can take any forms, both verbal and physical and in cludes but not limited to slurs, jokes, statements, gestures, pictures, or cartoons regarding a person’s gender, sexual preference, marital status or any other personal characteristic.

7 . Consequences of non - compliance

This code of conduct brings together the applicable statutory and internal company regulations. The obligation to comply with the herein - outlined principles arises either directly from the rel evant laws and internal company regulations, such as guidelines and process instructions, or as a collateral duty under the employee's contract of employment. Violations of these principles do harm to both the Company and the employee and can result in san ctions under both criminal and labour law.

8 . Questions and advice

As the present code of conduct cannot comprehensively cover the entire range of compliance - related topics, therefore, every employee is called upon to contact their HR - M anager or a Compliance Officer if they are in doubt or have a question. All enquiries will be treated in strict confidence.

In order to comply with our voluntary commitment to ethical conduct and to continue to be seen as an honest and trustworthy partne r in the marketplace, we appeal to any employee who discovers a potential violation of the rules set out in this code of conduct to contact a Compliance Officer in strict confidence. Any employee who, in good faith, requests advice or gives information a bout wrongdoing is, in doing so, performing their duty under the present code of conduct. The Company gives assurance that any employee who requests advice or gives information will not suffer any disadvantage of any kind. Nonetheless, we advise of the pos sibility of making an anonymous report to the Compliance department.

The hubergroup will follow up any information given and will, where necessary, instigate appropriate action. All documents will be kept confidential to the extent permitted by the law.

9. General

Compliance with the relevant laws as well as with this code of conduct must be regularly monitored.

9.1 Communications

A ll statements to the media or other communications to any other party about the Company, shall be true and fair, for which only Managing Director or such other person, who is authorized for the purpose, should speak . Disclosure of forward looking statements should be combined with cautionary statements. One should ensure approval of customers , vendors etc. if reference is made about such customers / Vendors . Do not disclose non - public information selectively to a particulargroup.

The outside publication of books, articles or manuscripts which relate in any way to the Company’s business does not require any action if the material is first submitted and approved by the management and provided that in all these communications there is a legend attached to state the following “ The views expressed in this article / presentation are that of mine and h uber group does not subscribe to the substance, veracity or truthfulness of the said opinion ”

9.2 Advertisements

The Company acknowledges that advertising is an essential instrument for effective brand building and communicating with the consumers. However, i t is necessary to ensure that all advertisements of the Company’s products and services are done ethically and in a legitimate manner. Advertising must not misrepresent or be likely to mislead the consumer, as to the character, quantity, composition or safety of the product advertised. The Company requires every employee to protect all trademarks, brand names and other proprietary material of the Company and of third parties and should not disparage products or services of competitors and should avoid political or religious remarks in advertisements.

9.3 Records

9 . 3 Records The Company's legal ly require s to maintain its records, including all recorded information regardless of medium or characteristics. Records include paper documents, CDs, computer hard disks, cloud, email, floppy disks, microfiche, microfilm or all other media. The Company is required by the central, lo cal, state, federal, foreign and other applicable laws, rules and regulations, to retain certain records and to follow specific guidelines in maintaining and managing its records. Civil and criminal penalties for failure to comply with such guidelines can be severe for employees, agents, contractors and the Company .

It should be noted that, a legal hold suspends all document destruction procedures and the Company should preserve appropriate records under special circumstances, such as litigation or government investigations. The Company's Le gal Department will notify to all concerns, if a legal hold is placed on records .

9.4 Waivers

Any waiver of any provision of this Code of Conduct for a member of the Company’ s Board of Directors or Managing Director must be approved in writing by the Company’ s Board of Directors and promptly disclosed.

Any waiver of any provision of this Code of Conduct with respect to any other , Officer, employee, agent or contractor must be approved in writing by the Managing Di rector of the Company .

9.5 Disciplinary Actions

The Company will take appropriate action against any employee, agent, contractor, supplier or consultant whose actions are found to violate these policies or any other policies of the Company. Disciplinary actions may include immediate termination of employment or business relationship at the Company's sole discretion. Where the Company has suffered a loss, it may pursue its remedies against the individuals or entities responsible. Where laws have been viol ated, the Company will cooperate fully with the appropriate authorities.

10 . Contact

Our Compliance Officers are at your service as points of contact.

Alpesh Chaniyara, Compliance Officer

Hubergroup India Private Limited,

Plot No. 808/E, Phase II,

G.I.D.C., Vapi 396195.

Gujarat, INDIA.


Phone:   +91 260 3052100

Fax:       +91 260 3052125

Mobile:   +91 99047 43953

Oscar Wack, Compliance Officer hubergroup

MHM Holding GmbH

Feldkirchener Str. 15

85551 Kirchheim-Heimstetten, Germany


Tel.:     +49 89 9003 202

Information or complaints can be sent, also anonymously, by phone, regular post or email to the Compliance department at the following address:

Plot No. 808/E, Phase II, G.I.D.C

Vapi 396 195. Gujarat. India


Phone:   +91 260 3052556

Fax:      +91 260 3052125