1.1  Code of Conduct

The employees shall be subject to such discipline and a code of conduct as may be prescribed by the Company from time to time. PRIMACO maintains certain policies to guide its employees with respect to standards of conduct expected in areas where improper activities could damage PRIMACO reputation and otherwise result in serious adverse consequences. The purpose of this policy is to affirm the required standards of conduct and practices in a comprehensive statement.

PRIMACO shall operate in full compliance with all applicable laws. The conduct of employees shall conform to the requirements of all applicable laws and policies, rules and regulations. It is important to avoid even the appearance of any illegal or unethical behavior. Employees shall behave in a manner that promotes the trust of other employees, and public.

1.1.1 Responsibility
  1. The HR department shall be responsible to obtain at the time of hiring, and subsequently in each calendar year, a code of conduct and ethics statement signed by all the employees indicating their understanding of an agreement with this code.
  2. The GM (HR/GAD) shall have overall responsibility for implementing and updating of the code. He/she shall also be responsible for responding to the queries, providing clarifications and take appropriate action in case of non- compliance with the code.
  3. All heads of departments shall be responsible to ensure that employees under their control, operate within the specific terms and conditions of the Code as well as its intent.
  4. Every employee shall be accountable to PRIMACO for performance that fulfills the specific terms and conditions of the Code as well as its intent.
1.1.2 Procedure

Any question regarding whether a specific behavior is covered by the Code shall be addressed to the GM (HR/GAD), who shall review the question and clarify the position to the employee. However, the Code provides guidance regarding the following areas:

  1. Improper personal benefits

    2. An employee shall not solicit or accept, directly or indirectly, any cash, or monetary equivalents, objects of value or preferential treatment from any person or business that has or is seeking business with PRIMACO, where doing so may influence or appear to influence an employee’s judgment.

  2. Financial interests in other businesses

    3. An employee shall not have an interest in any other business if that interest compromises or appears to compromise an employee’s loyalty to PRIMACO.

  3. Outside employment or activities

    4. Simultaneous employment with or serving as a consultant to or director or employee (with or without consideration) of any other entity is strictly prohibited.

  4. Protection and Proper use of PRIMACO Assets

    5. An employee shall be expected to protect PRIMACO assets and ensure their efficient use, and is prohibited from engaging in theft, carelessness, or waste. All PRIMACO assets should be used for legitimate purposes, but incidental personal use may be permitted if ancillary to a PRIMACO purpose. An employee shall also be prohibited from making any improper use of property such as funds, software, e-mail systems, voice mail systems, computer networks, vehicles and facilities for personal benefit or profit.

  5. Full, Fair and Accurate Disclosure of facts
    1. PRIMACO commitment shall be to provide full, fair, accurate and timely disclosure in the reports, documents and communications filed with the regulatory authorities. Although certain personnel are more directly involved in the preparation of such reports, documents and communications than others; nevertheless, PRIMACO expects all of its employees to accept this responsibility.
    2. Accordingly, all employees shall have an ethical responsibility to provide prompt, complete and accurate information in response to any inquiry related to preparation of PRIMACO public disclosure documents and public communications. In addition, and in order to ensure accurate financial reporting, the personnel who participate in the maintenance and preparation of PRIMACO books, records and accounts must ensure that the transactions and events recorded there in are done so in an accurate and complete manner in compliance with required accounting principles and PRIMACO policies.
  6. Weapons, Workplace Violence, Drugs, Alcohol and Gambling

    7. PRIMACO staff, whether on duty or not, may not possess or use weapons of any kind, ammunition, gunpowder, fireworks, explosives, and other dangerous articles and substances in PRIMACO premises. Individuals employed as contract security guards may be given authorization to carry, keep and handle pistols, firearms and ammunition.

  7. Loans and other Credit Facilities from Financial Institutions

    8. Any loan and/or credit facility obtained on false representations, including, but not limited to, preparing of forged financial statements shall be deemed to be a violation of the Code.

  8. Responding to Inquiries from the Press and Others

    9. Requests for information from regulators or the government shall be referred to the Company Secretary.

  9. Confidentiality

    10. The confidential Information shall include all non-public information, correspondence, documents, papers, records, drawings and data. The employees shall maintain the confidentiality of information entrusted to them or, which comes to an employee’s knowledge because of the position that the employee holds. An employee shall disclose confidential information if the employee is duly authorized by PRIMACO or is legally mandated to do so. Prior to making a disclosure of any confidential information which is legally mandated, an employee shall be required to consult with the head of department.

    1. An employee shall not make or keep for personal use, copies of any confidential information. All confidential information shall be surrendered to PRIMACO when a person ceases to be an employee.
      • This responsibility continues in the case of ex-employees and PRIMACO shall pursue all available legal remedies to prevent current and former employees from benefiting or misusing such confidential information.

  10. Compliance with laws and the Code

    11. An employee shall be expected to comply with, both in letter and spirit, all applicable governmental laws, rules and regulations and the Code, and to promptly report any actual or suspected violations to the HR Department. No one shall be subjected to retaliation because of a good faith report of a suspected violation. If an employee fails to comply with any applicable laws, rules or regulations, the employee shall be subject to disciplinary actions under the rules of PRIMACO, including termination of employment.

  11. Integrity

    12. Integrity on the job means;

    1.  Treating staff fairly.
    2.  Comply with all laws, regulations, rules, and policies that govern the conduct of PRIMACO business, wherever that business is transacted.
    3.  Ensure that all transactions are handled honestly and recorded accurately.
    4.  Avoid conflicts of interest, both real and perceived.
    5.  Not to use PRIMACO assets, information, or relationships for personal gain.
    6.  Refrain from any acts of retribution or retaliation against an employee who has properly reported a business conduct issue or question.
    7.  Respect the right of other employees to fair treatment and equal opportunity, free from harassment.
    8.  Conduct all business dealings with honesty and fairness.