FACT CODE OF BUSINESS CONDUCT AND ETHICS

This Code of Business  Conduct  Summaries the Standards of Business Conduct that guide the activities of all members of the Board of Directors and Officers of the company to ensure that the organization is managed in a manner to protect the interest of all stakeholders. This code applies to all Directors and Officers of FACT and in additions to the provisions/rules contained in the FACT Employees (Conduct, Disciplines & Appeal) Rules 1977, terms and Conditions of the appointment order and the directives issued by the Government from time to time.

This Code of Conduct is issued/prescribed to deter wrongdoing and to promote honest and ethical conduct including the ethical handling of actual or apparent conflict of interest between personal and professional relationships.

1.         Ethical Conduct

All members of Board of Directors of the Company/Officers shall deal on behalf of the Company with professionalism, honesty and integrity,  as well as high moral and ethical standard. Such conduct shall be fair and transparent.

2.         Conflict of Interest

No Director/Officer of the Company shall engage in any business, relationship or activity which might detrimentally conflict with the interest of the Company or the policy issued by the Government from time to time. Directors/Officers should not place themselves or remain in a position in which their private interest conflict with the interest of the Company.  If there is any conflict of interest, the interest of the Company should prevail.

3.         Confidentiality concerning Company Affairs

It is the policy of FACT that the business affairs of the Company are confidential and should not be discussed with anyone outside the organization except for information that has already been made available to the public. No Director/Officer shall derive any benefit or assist others to derive any benefit from the access to and possession of information about the Company which is not in the public domain and thus constitutes insider information. No Director/Officer shall use any insider information for meeting or giving advice on investment decisions on shares of FACT.

4.         Protecting Company Assets

The assets of FACT should not be misused but employed for the purpose of conducting the business for which they are duly authorized. The assets include tangible as well as intangible assets such as land and building, machinery and equipments, systems, facilities, proprietary information, relationship with customers and suppliers etc.

5.         Integrity

Directors/Officers must conduct the business of the Company fairly with honesty and transparency.  Everyone at all time shall ensure the integrity of data or information furnished to the Company.

6.         Excellence

Everyone must constantly strive to achieve the highest possible standards in the days to day activities and the quality of goods and services to the entire satisfaction of all the stakeholders.

7.         Unity

Everyone in FACT shall work cohesively with the colleagues and fair in dealing with the customers, suppliers and other stakeholders and build a strong relationship based on tolerance, understanding and mutual cooperation.

8.         Responsibility

Everyone must continue to be responsible to the Company, and its stakeholders and the environment in which they work.

9.         Accountability

The Board of Directors are accountable to the shareholders and other Officers are accountable to the Board of Directors.

10.       Trusteeship

As professional managers, Board of Directors and other Officers are conscious that FACT has been given to them in trust by all the stakeholders. They will redeem the trust reposed in them by continuously adding value to FACT.

11.       Adherence of Government Policy, Guideline

It is the endeavor of the Board and Officers of FACT to implement various policies and guidelines issued by the Government from time to time.

12.       Innovation

Everyone shall constantly innovate and strive to better our process, products, services and management practices.

13.       Shareholders

FACT shall be committed to shareholder value and comply with all laws/ regulations/ directives that govern and protect the rights and interest of shareholders.

The Board of Directors shall inform the shareholders about all relevant aspects of the Company’s business and disclose such information in accordance with the respective laws/regulations and agreements.

14.       Corporate Opportunities

All members of the Board/Officers of FACT have a duty to provide to the Company the benefits of the opportunities discovered through the use of Company resources and in the course of employment. All Directors and Officers are prohibited from taking for themselves, opportunities that are discovered by using the properties of the Company or through the information or positions they occupy.

15.       Health and Safety

FACT is committed to maintaining the work environment safe and secure and healthy for its employees and others. The Company complies with all applicable laws and regulations relating to safety and health in the work place. It is expected that everyone should promote a positive working environment for all. Any unsafe or hazardous conditions or materials, injuries and accidents connected with the business should be reported. All kinds of threats or acts of physical violence or intimidation are prohibited.

16.       Compliance with Law

It is the policy of FACT to comply with all applicable laws including laws on employment, health, safety and environmental laws. Every Directors and Officers of FACT is expected to comply with all such laws, rules and regulations. Transactions directly or indirectly involving securities of the Company should not be undertaken without prior clearance from the Competent Authorities. All Directors/Officers should consult legal department of the Company before taking any legal action for and on behalf of the Company.

17.       No Rights created

This code is a statement of the fundamental principles and key policies and proceedings that govern the conduct of business of FACT. It is not intended to, and does not, in any way, constitute an employment contract or an assurance of continued employment or create any right in any Employee, Directors, Client and other stakeholders of the Company.

18.       Compliance with Code of Conduct

All Members of the Board and Officers  of the Company shall comply with the provisions of this code of ethics and any violation will attract disciplinary action as deemed fit by the Chairman and Managing Director of the Company. If any Director or Officer knows or suspects violation of this code of conduct, he/she must immediately report the same to the Board of Directors or Chairman and Managing Director of the Company.

19.       Interpretation of Code

Any question or interpretation under this code of conduct will be decided by the Board of Directors of the Company and the decision of the Board will be final and binding to all.