Menu

     COBRA

Security Services

                                             ETHICAL BUSINESS PRACTICES                                                                                                               CODE OF BUSINESS CONDUCT

COMMITMENT TO QUALITY

It is the policy of COBRA™ to provide the highest caliber of services and products to all customers, while remaining committed to respecting human rights and ethical and proper treatment of all employees and individuals affected by its operations.

Consistent with our commitment, company services must be provided in a manner that meets or exceeds requirements for safety, reliability, quality, and performance. To this end, all COBRA™ employees should be dedicated to performing their job functions at the highest level of quality and contract conformance. Opportunities should be given to the security staff to receive further training for enhancement of the skills. Furthermore, COBRA™ employees shall be responsible for ensuring that services and products supplied by consultants, subcontractors, suppliers, and other entities doing business with COBRA™  meet COBRA’s™ high level of quality expectations. Report any concerns regarding the quality of our services to your manager or Quality Assurance.

FAIR COMPETITION FOR BUSINESS OPPORTUNITIES

COBRA’s™ long-term success depends on upholding the integrity of the procurement process in bidding, negotiating, and performing contracts for local, state, national, and international customers. The Company competes fairly and ethically for all business opportunities. Employees involved in proposals, bid preparations, and contract negotiations must be certain that all statements, commu­nications, and representations to prospective customers and suppliers are accurate and truthful. Once awarded, all contracts must be performed in a manner which meets or exceeds specifications, requirements, and clauses.

CONFLICT OF INTEREST

The Company recognizes an employee’s right to engage in outside financial business opportunities, however, any employment outside the Company must be approved in advance by the HR HEAD or his authorized representative. In addition, any outside activities that result in a conflict of interest, diminished ability to perform Company duties, or the misuse of the Company’s name, image, assets, or resources are prohibited.

A conflict of interest may exist when an employee or a member of his or her family is involved in an activity or has a personal interest that could affect the employee’s objectivity in making a business decision. Outside activities that are illegal, interfere with an employee’s Company duties, or involve the misuse of the Company’s name, image, assets or resources are also considered conflicts of interest and are explicitly prohibited.

An actual conflict of interest does not need to exist to be a violation of this policy. Any activity that gives the appearance of a conflict of interest must also be avoided. Any outside activities that may give the appearance of a conflict of interest must be reported, and approval must be obtained before the employee or member of his/her family engages in the activity. Employees should contact the HR HEAD for guidance.

The following list provides examples of activities that may create a conflict of interest, although it is not inclusive of all activities that may be a violation of this standard:

- Working or consulting for a competitor, supplier, or customer of the Company;

- Working for any business that affects your ability to satisfactorily perform your job duties for COBRA™;

- Having a financial interest (either by you or an immediate family member) in a Company competitor, supplier, or customer;

- Participating in business opportunities between the Company and family members;

- Using confidential Company information, such as knowledge of pending contracts, acquisitions, divestitures, or supplier relations, for personal gain or for the gain of another; or

- Receiving discounts or other benefits from suppliers or customers which are not available to all employees.

Each COBRA™ employee is required to report potential conflicts of interest or other ethically ques­tionable behavior to the HR HEAD. Failure to report conflicts of interest or ethically questionable behavior may result in COBRA™ taking disciplinary action up to and including termination of employment.

MARKETING AND ADVERTISING MATERIALS

In preparing and using Company marketing and advertising materials, we must ensure that (1) no false or misleading statements are used; (2) all Company proprietary data are properly marked with the appropriate legends; (3) information or photos that identify clients or programs are used correctly and with the express permission of the client or program manager; and (4) trademarks of another company are used correctly and with appropriate authorization, and their owners are given proper attribution. All disclosures made in materials released to the public must be current, accurate, complete, and timely.

SUPPLIERS AND CONTRACTORS

The Company shall engage in business with suppliers that have exhibited high standards of ethics and business integrity and have demonstrated compliance with all applicable laws and regulations. The manner in which COBRA™ selects suppliers requires the utmost care and due diligence. The character of the suppliers that we select is highly reflective of the way that we conduct business. The Company must exercise continuous and diligent oversight of the operations and practices of the suppliers and subcontractors that we select. Suppliers and subcontractors shall be held responsible for delivering quality services and materials, meeting contractual requirements, operating with ethical business principles, and complying with applicable laws and regulations.

OFFERING BUSINESS COURTESIES

Business courtesies, such as gifts, entertainment, services, or favors (collectively, a “gift”), offered to commercial, non-governmental customers, or other business associates should be infrequent and nominal, appropriate under the circumstances, legal, and offered in a way that does not create the appearance of impropriety. In determining whether a gift may be appropriate, remember that an employee should never give a gift for the purpose of persuading an individual to take action in favor of COBRA™. For further information about this topic, consult HR HEAD, regarding the appropri­ateness of the gift prior to giving it.

RECEIPT OF BUSINESS GIFTS

COBRA™ employees must report all business gifts, other than promotional items of nominal value (less than Rs.100), such as coffee mugs, calendars, and pens, to the HR HEAD or his representatives for disposition. The HR HEAD or his representative will determine the proper gift disposition based on the business relationship the COBRA™ employee has with the source of the gift and the gift’s dollar value. This requirement also applies to immediate family members of an employee if a gift is received at home.

Employees must report free meals, regardless of value, to the branch manager. Branch Manager shall complete a report describing the sources, circumstances, and estimated value of the free meal and provide the report to his or her manager.

Employees who purchase goods or services for COBRA™ or are involved in the procurement process must treat all suppliers uniformly and fairly. In deciding among competing suppliers, employees must objectively and impartially weigh all facts and avoid even the appearance of favoritism.

For this reason, individual procurement officials may not accept gifts or meals from suppliers or vendors, except advertising or promotional items of nominal value (less than Rs.100), such as coffee mugs, calendars, and pens, or generally similar items displaying a company’s logo. Business divisions or groups within the Company that procure products or services must seek authorization from the HR HEAD before accepting any other gifts or meals.

Acceptance of Gifts by COBRA™ Employees in Non-Procurement Functions

Although employees may not use their position at COBRA™ to obtain business courtesies, employees not involved in purchasing of goods and services may accept appropriate meals, hospitality, and entertainment, provided that these courtesies further legitimate Company business interests (such as relationship building with actual or potential business partners) and that

- The acceptance will promote goodwill and successful business relations;

- The courtesies are not lavish or extravagant under the circumstances;

- The courtesies are not frequent and do not reflect a pattern or the appearance of a pattern of frequent acceptance of courtesies from the same entities or persons;

- You would feel comfortable discussing the courtesies with your manager or a coworker, or having the courtesies disclosed to the public; and

- The courtesies have a market value of Rs.100 or less. Acceptance of any gift above Rs.100 in value must be reviewed with, and approved by, the HR HEAD or his representative.

If there are any questions about the propriety of accepting a business courtesy, contact your supervisor or the HR HEAD or his representative for guidance. An employee should never accept a gift of greater than nominal value (more than Rs.100) if it could appear that his or her judgment might not be objective as a result of that gift. It is your personal responsibility to ensure that your acceptance of a business courtesy does not create the perception that favors were granted to secure favorable treatment.

KICKBACK

Solicitation of business courtesies is always prohibited. COBRA™ employees shall not seek or accept any payment, gift, or other thing of value from current or potential subcontractors, suppliers, customers, or business partners for the purpose of obtaining or acknowledging favorable treatment under a contract or subcontract of any kind. To do so constitutes a “kickback” and is a crime. Employees who have knowledge or information regarding potential kickback violations must report them immediately to the HR HEAD.

ANTITRUST AND COMPETITION

It is COBRA’s™ intention and good business to obey the antitrust and competition laws of every country in which the Company does business. The following conduct could violate antitrust laws and is highly problematic:

- Fixing prices, agreeing with a competitor on prices, or setting prices in concert with a competitor;

- Bid rigging or agreeing with a competitor to set the terms or direct the outcome of a bidding process;

- Boycotting suppliers or customers to coerce the suppliers or customers to stop dealing with a competitor;

- Pricing intended to drive competitors out of business;

- Disparaging, misrepresenting, or harassing a competitor;

- Engaging in bribery, accepting kickbacks, or stealing trade secrets;

- Entering into agreements or understandings with competitors to divide the market in which they compete by allocating territories or markets and/or limiting the production or sale of products or product lines;

- Conditioning the sale of one product/service on the sale of another unwanted product/service;

- Conditioning the sale or purchase of products/services on the requirement that the seller or purchaser not do business with competitors of the Company.

Employees will avoid engaging in or discussing any of the above activities with competitors, suppliers, or customers and must report any instance in which such activities are proposed or discussed to the HR HEAD or his representative. 

Unfair methods of competition are also prohibited, including engaging in industrial espionage, inducing a competitor’s customer to breach a contract, paying bribes, making false or disparaging comments regarding a competitor’s product, and making misleading advertising claims. 

MONEY LAUNDERING

COBRA™ does not condone, facilitate, or support money laundering, and the Company is committed to complying with money laundering laws worldwide. All employees should be alert for any unusual financial transactions that may indicate money laundering, such as irregularities in the way payments are made, payments made by third parties for the benefit of another party, and payments from offshore banking locations. Any suspicious financial activities or transactions should be reported to the HR HEAD or his representative.

INSIDER TRADING

During the course of their employment at COBRA™, employees and other applicable third parties may become aware of “material insider information,” which is material information that is not publicly available and could lead a reasonable person to buy, sell, or otherwise trade in stocks or securities. Examples of material insider information include contract awards, contract cancellations, acquisitions or divestitures of corporate subsidiaries, and the hiring or termination of key employees.

Company employees and applicable third parties are prohibited from trading stock of any company— such as a customer, supplier, competitor, potential acquisition target, teaming partner, or alliance— while in possession of material insider information about that company. Insider trading is illegal and consequences of insider trading can be severe, including loss of employment, substantial fines, and imprisonment.