induction 2011 12

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2011-2012

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Part – I

Ethics Campaign

Corporate Policies – CBC• Treatment of Each Other at Work Policy• Non-Retaliation Policy

Investigations & Ethics Issues Categories

FAQs

Part – II : Treatment of Each Other at Work Course

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Business ethics and legal compliance

Worldwide NGP community

Code of Business Conduct (CBC) embraces both

the spirit and the letter of all governance-related

laws and regulations

It is an aid in promoting and maintaining an

ethical culture.

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CBC is built around 10 “Statements of

Ethical Principles” that provide thefoundation for ethical behavior at NGP.

The principles are backed by Corporate

Policies and other key documents that give

specific guidance on topics and issuesaddressed by the statements.

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We will follow the law everywhere.

We will embrace diverse perspectives and

backgrounds, and treat all people with dignity

and respect. We will compete fairly and honestly.

We will avoid conflicts of interest.

We will demand that everything we do leads to a

cleaner, healthier and safer environment.

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We will protect our technology, our informationand our intellectual property.

We will demand that our financial records are

accurate and that our reporting processes areclear and understandable.

We will strive to improve our communities.

We will communicate honestly and with integrity.

We will create a culture where all employeestake responsibility for ethical behavior.

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Treatment of Each Other at Work Policy.

Equal Employment Opportunity (EEO) &

Affirmative Action (AA) Policy.

Employee Non-Retaliation Policy.

Nelsons Physical Security Policy. Alcohol and Illegal Drugs Policy.

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Treatment/Sexual Harassment

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Treating each other with dignity and respect means:

• Each employee must treat others in a way that makes theother employees feel respected.

• Treat every employee with dignity and respect -- no matterwhether the person reports to us, is our supervisor, a co-worker, customer, contractor or supplier.

• No one should make statements to others that areembarrassing or humiliating or to which the other persondoes not feel free to respond.

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Treating each other with dignity and respectmeans:• NGP prohibits discrimination based on race, gender,

color, disability, national origin, age, religion, union

affiliation, sexual orientation, veteran status,citizenship, gender identity and/or expression, or other

status protected by law.

• We are also committed to acting affirmatively to

ensure that all employees are treated with respect andprovided an equal opportunity to succeed.

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Harassment is Prohibited:

• There is no place in our company for an employee who uses

demeaning symbols or words, or engages in activities seen as

demeaning or showing hostility towards an individual because of

the individual's race, gender, color, disability, national origin,

age, religion, union affiliation, sexual orientation, veteran

status, citizenship, gender identity and/or expression, or other

status protected by law.

• Such activities will be subject to severe disciplinary action, up to

and including dismissal, regardless of whether the employeehad malicious intent or was merely joking.

• This no-tolerance policy also applies to conduct from or

toward customers, suppliers and contractors.

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Harassment is Prohibited• Prohibited sexual harassment includes offensive

physical contact such as grabbing, patting, pinching or

brushing against another's body; sex-oriented kidding,sexual-orientation gestures, teasing or jokes; sexual

flirtations, advances or propositions; obscene or

sexually oriented printed or visual materials.

•

Also prohibited is the use of company computers toview pornographic or sexually suggestive materials.

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Harassment is Prohibited• Types of conduct prohibited are epithets, slurs,

negative stereotyping or intimidating acts based on an

individual's race, gender, color, disability, nationalorigin, age, religion, union affiliation, sexual

orientation, veteran status, citizenship, gender identity

and/or expression, or other status protected by law.

• It includes graffiti or the posting of written or graphic

materials.

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If a personal or romantic relationship arises orexists between a manager and a subordinateemployee, it is the obligation of both parties to

bring the relationship to the attention of theHuman Resources department, or the manager'ssupervisor.

The Company will take appropriate action toaddress the situation, which may includechanges in reporting, transfer, reassignment, ortermination.

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Company policy protects employee who discloses information to a government or law enforcement

agency, Where employee has reasonable cause to believe that the

information discloses a violation or possible violation of law or

regulation; or provides information or assists in an investigation regarding any

conduct that involves a violation of:• criminal law relating to securities fraud, mail fraud, bank fraud, or

wire, radio and television fraud, or• any rule or regulation of the Securities and Exchange Commission,

or• any provision of law relating to fraud against shareholders

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However, an employee who files a report or

provides evidence which he/she knows to be

false or without a reasonable belief in the

truth and accuracy of such information will notbe protected by the above policy statement and

may be subject to disciplinary action, including

termination of employment.

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Disrespectful behavior will not be

tolerated in the workplace. By that wemean that we will take swift and

deliberate action to stop such behavior

when we know it is happening.

Discipline may include termination. Certain

behaviors are mentioned in our Treatment

Policy but it is not an all inclusive list.

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Responsibility of EVERYONE.

Support from Management and Human Resources. We promise prompt and serious attention.

Confidentiality and non-retaliation.

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■ Fear of retaliation.

■ Lack of trust in a fair investigation.

■ Fear of impact on job.

■ Don’t know what is/ is not allowed.

■ Fear of betraying friends or teammates.

■ Don’t know how to raise concern.

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Violation of CBC in Nelson premises vis-à-vis violationoutside premises ?

Some examples -

• Rash and drunken driving ?

•

Molestation/outraging modesty of a lady on the road?• Complaint by neighbor against Nelsons’ employee of filing false

police complaint ?

• Shop lifting ?

• Nelsons employee detained by Police at a ‘dance bar’ ?

• Default in credit card payment/ housing loan ?• Use of corporate credit card for personal use

• Submitting inflated/ false bills

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When in Doubt, Ask Yourself …

How will it look in the newspaper?

Are my actions legal? Do they comply with the Company’s Code of Conduct?

Am I being fair and honest? Will my action stand the test of time?

How will I feel about myself afterwards?

Will I sleep soundly tonight?

What would I tell my child to do?

Remember: When in doubt, seek help – you will be supported.

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