Code of Conduct & Ethics

Code of Conduct
The Company has framed and adopted a Code of Conduct applicable to all the Board members and Senior Management. The Code is circulated to all the Board members and Senior Management and its compliance is affirmed by them annually. Besides, PHC also procures a confirmation of material financial and commercial transactions entered into by Senior Management with the Company that may have a potential conflict of interest. Along with the Code of Conduct for the Board members and Senior Management, the Company has also laid down a Code of Conduct for its employees. As a process, an annual confirmation is also sought from all employees. All employees are expected to confirm compliance to the Code annually. Regular training programs are conducted across locations to explain and reiterate the importance of adherence to the Code.


Related Party Transactions
Disclosure on material significant related party transactions that may have potential conflict with the interest of the Company is very important. The Board of Directors has a policy on dealing with related party transactions and the policy intends to ensure that proper reporting, approval and disclosure processes are in place for all transactions between the Company and related parties. The Company’s major related party transactions are generally with its subsidiaries and associates. These transactions are entered into based on consideration of various business exigencies, such as synergy in operations, sectoral specialization, subsidiary and associates and all such transactions are on an arm’s length basis.

Disclosure on Risk Management
The Board of Directors has formulated the Audit and Risk Management Committee to optimally identify and manage risks, as well as to address operational, strategic and regulatory risks. In line with the Company’s commitment to deliver sustainable value, this framework aims to provide an integrated and organized approach to evaluate and manage risks. Risk assessment is reviewed by the committee at regular intervals. The Board is periodically updated on the key risks, steps and processes initiated for reducing and, if feasible, eliminating various risks. Business risk evaluation and management is an ongoing process within the Company.

Insider Trading
The Company has an established systems and procedures to prohibit insider trading activity and has issued the guidelines for designated persons, who may have access to the Company’s price sensitive information. The guidelines lays down the procedures to be followed and disclosures to be made, while trading in the shares. PHC follows highest standards of transparency and fairness in dealing with all the stakeholders and ensures that no insider shall use his or her position with or without knowledge of the Company to gain personal benefit or to provide benefit to any third party.

Whistle Blower Policy
PHC has outlined the method and process for stakeholders to voice genuine concerns about unethical conduct. The Company aims to ensure that genuine complainants can raise their concerns in full confidence, without any fear of retaliation or victimization. All employees of the Company, as well as vendors/ partners and any person that has a grievance (excluding standard customer complaints) can raise their complaint. There is a formal process to review and investigate any concerns raised and also undertakes all appropriate actions required to resolve the reported matter.