Gift Policy

TATA PIGMENTS recognizes that exchange of gifts with people with whom we do business are acceptable provided the gifts are not costly and unusual.  The receipt and giving of gifts is part of normal social exchange.  Such exchange is neither irregular nor is it unusual.

However, the need is recognized for a stated policy setting norms on the value of such gifts and for defining circumstances under which it would be acceptable or not acceptable to retain gifts.  The cardinal principle would be that gifts should not be given or received either to obtain favours / preferential treatment or in return for favours / preferential treatment.

The policy will apply to all employees of Tata Pigments.

1. Gifts could be either solicited or unsolicited. The Company, regardless of the circumstances, does not permit the soliciting of gifts. This policy defines the circumstances under which unsolicited gifts received either in India or abroad can be accepted and retained.

2. The circumstances under which gifts might be received fall into various categories:

i) Gifts received on New Year and other festive occasions.
ii) Gifts received only on occasions of wedding of self or children.
iii) Gift vouchers / gift cheques received in recognition of a professional contribution made by the recipient, such as for making a presentation, conducting a training programme/workshop for a professional and academic institution etc.
iv) Gifts received on the occasion of a terminal event such as a transfer or on cessation of employment.
v) Gifts of any value received for any other reason (not stated in (i) to (iv), approval to be taken from Ethics Counsellor or CEO.

3. Declaration regarding receipt of gift:

In all instances, the recipient of a gift of more than the approved value, will make a declaration stating the description of the gift that has been received, the estimated value of the gift and the circumstances under which the gift was received and particulars of donor.  Such declaration should be submitted in the office of Ethics Counsellor within 15 days of the receipt.

4. Kind of Gift

A list of the kinds of gifts that might be received is provided below:

(a) Articles of only an edible nature for festive occasions in item 2(i)
(b) Articles of use in an office such as table clocks, stationery, desk accessories on New Year only with company’s logo in item 2(ii).
(c) Gift worth upto Rs.1000/- for wedding only in item 2(ii)
(d) Gift voucher / Gift cheques only in the case of professional contribution in item 2(iii).

5. Circumstances under which gifts can be accepted:

i. Receipt of Cash Gift: Only in the case of retirement or cessation of employment.  Cash gift of Rs.1,000/- and more can be retained by employees.

ii. However, in the case of transfers, collective gift in kind can be received.  The value limit is not applicable in such cases.

6. Gifts received in recognition of a professional contribution made by the recipient, in lieu of making a presentation, conducting a training programme / workshop for a professional and academic institution etc.

Where the receipt of gift is in gift vouchers and gift cheque and more than Rs.1,000/-, the recipient will be permitted to retain the full amount received, if prior permission is taken from the company.  However, information to the Ethics Counsellor should be given.  No cash to be received.

Where the Company has borne expenses, such as travel or lodging, related to the event and such expenses are reimbursed by the organizers, all such reimbursements will be surrendered to the Company.

7. Receipt of gift from parties having business relationship with the Company including gifts from subordinates:

Gifts received from a donor where the donor has a business relationship with the Company and could derive benefits from the recipient should only be of a value up to Rs.1,000/-.  Illustrative categories of parties with business relationships with the Company would be vendors, dealers, contractors, consultant and customers etc.  However, all such gifts should have donor’s Company’s logo or business identity.

8. No gifts should be accepted from any person or party who is in default of the company in any manner.  By way of illustration, parties in default would be parties from whom monies are overdue or parties with whom the Company is engaged in litigation and parties against whom disciplinary action has been taken.

It is desirable that the recipient should check the status of the parties from the departmental concerned viz., Controller of Accounts-cum-Company Secretary or Asst. Officer (Materials) to make sure that the provisions of the above clause are not contravened.

9. It is recognized that at times gift exceeding the value caps contained in this policy are to be received as the return of these gifts may cause embarrassment.  This situation may occur specially during overseas visit of our officers where sometimes expensive gifts are given by the overseas hosts.  In this situation the recipient should surrender the gift at the earliest.  The Company will decide the procedure for utilization of such gifts.    

10. The company considers it good practice to share gifts of a nature which an employee is permitted to receive such as gifts of an edible nature with fellow employees.  The nature of the gift permitting, it would also be good practice to use gifts in the office.

11. Where an employee received gifts exceeding the value caps contain in this policy, it would be advisable to return the gift to donor with a covering letter thanking him for the same and quoting the relevant provision of this policy.  The draft of the letter as and when required may be obtained from the office of the Ethics Counsellor.

12. In case of any clarification / interpretation of this policy the employee should contact the office of Ethics Counsellor, Tata Pigments.

13. The policy will become effective with immediate effect.

For the Tata Pigments Limited,

Managing Director

Dated: 1st August 2007

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