Code of Conduct – Compliance Policy
In and for NIXI, the Code of Conduct (CoC) is not just words written on a piece of paper. Rather, these are reflected in the day-to-day behaviour of everyone in the organization, not just internally with one another but also with other stakeholders.
Accordingly, it is a reasonable expectation that everyone within the organization shall sincerely and whole-heartedly comply with the letter and the spirit of the CoC. This compliance policy illustrates the expectations accordingly.
1. Employer Responsibilities Towards Employees
- NIXI shall provide a safe, secure and amicable work experience to all its employees.
- NIXI shall institute and implement fair and reasonable processes and procedures.
- NIXI shall not undertake any retaliatory action against an employee as long as they have reported any genuine complaint or brought up an incident of misconduct supported with sufficient evidence as long as the same is not vexatious, false, mala fide or undertaken or pursued to settle personal grievance, vendetta or scores.
- NIXI shall provide and empower with requisite resources, support and guidance for all employees to enable them carry out their respective responsibilities with sufficient empowerment while also holding themselves and others accountable.
- NIXI is an equal opportunity employer that does not discriminate against anyone based on their gender, caste, religion, region, political views or sexual orientation.
- NIXI would provide opportunities for learning, growth and development. To this end, reasonable and pragmatic support and programs shall be instituted.
- NIXI would reward meritocracy based on objective evaluation and assessment of performance.
- NIXI shall undertake regular communication, training and refresher programs to create awareness and sensitization about the CoC and other extant organizational policies and any modifications thereof.
2. Employee Responsibilities Towards Employer
- Every employee shall familiarize themselves with the Code of Conduct and abide by the same.
- Every employee shall ensure that unreasonable and unnecessary expenditure are avoided and they comply with all the extant policies of the organization.
- Every employee shall work with integrity, sincerity, commitment and always prioritize NIXI’s interests.
- Every employee is committed to ensure and uphold the sovereignty, integrity and security of India.
- In case of actual, likely or perceived conflict of interest, the concerned employees shall proactively and suo moto inform their reporting officer and/or other concerned officials or colleagues of the same and recuse themselves from such decision-making processes.
- Every employee shall behave professionally maintaining due decorum and demeanour expected of those belonging to NIXI. They shall avoid language, actions or gestures that are discriminatory, derogatory or defamatory.
- Every employee shall be punctual, responsive and responsible in the way they conduct and communicate.
- Every employee shall report to the designated authorities as and when they come across any misconduct, whether pecuniary, moral or otherwise that is inappropriate or unsuitable within NIXI.
- Every employee shall maintain confidentiality and not disclose trade secrets or other proprietary information to third parties unless required by law. The third parties include but are not limited to family, friend, business associates or future employers or clients. This non-disclosure agreement shall continue to be applicable even after cessation of employment or contract with NIXI for a period of 2 years.
- Every employee agrees not to undertake any other employment or remunerative activity for or behalf of any other entity.
3. Responsibilities Towards Business Associates
- Interactions with all business associates shall be on fair, professional and responsive manner, while preserving, protecting and perpetuating NIXI’s interests. Business Associates include members, registrars, affiliates, customers, suppliers and service providers.
- No undue delay (for example, in commissioning a link) or haste (for example, in short-cutting the due diligence in procurement process) shall be tolerated.
4. Responsibilities Towards Society
- Being a unique organization owing to its legacy, mandate and crucial functions NIXI is committed to be a model corporate citizen.
- To this end, NIXI shall institute, support and participate in programs, projects, policies and partnerships that endeavour to bring about digital empowerment; social equity, mobility and justice; and, environmental sustainability.
- While respecting diversity, NIXI shall remain apolitical.
5. Implementation of the Code of Conduct (CoC)
- Once duly approved, the CoC shall become applicable to one and all, without anay exceptions or exemptions.
- Every employee shall be asked to read, assimilate, agree to and convey their assent to the same in writing.
- NIXI shall arrange training and sensitization programs.
- In case of any instance of violation of the CoC, the following procedure shall be followed to deal with any instance, pertaining to non-compliance:
- There shall be a three-member disciplinary committee, chaired by the CEO. The other two members shall be nominated by the CEO but shall not belong to the same business unit or function and at least one of them would be from HR, Finance or Legal.
- The committee can take cognizance of the same either suo motu or when any specific case is reported to it either by any employee, MeitY or any other stakeholder.
- The committee shall provide fair and reasonable opportunity to the accused persons to clarify their position even as it reserves the right to undertake suitable interim actions as it deems fit and appropriate.
- The CEO shall be guided though not bound by the recommendations of the disciplinary committee and shall take the final decision in every case that warrants any action.
- The action may include one or more of the following but need not be limited to these:
- Asking for written apology
- Rendering apology to the person or persons aggrieved
- Rendering resignation from the organization
- Asking to undergo specific or additional training, counselling, or coaching
- Referring the case to the Internal Complaints Committee (ICC), if so warranted
- Launching a vigilance enquiry under the Vigilance Policy, if so warranted
- Any other appropriate measure including but not limited to those listed within the Vigilance Policy, as warranted
vi. If any compliant or report of violation or breach of the CoC is found to be frivolous, vexatious, fraudulent or mala fide, the person making such report shall be subject to the same disciplinary actions as those listed above.