Code of Conduct

Anti Bribery & Anti Corruption Policy


Designco is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. It is Designco’s policy to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice, wherever it operates throughout the world, of not engaging in bribery or corruption.

Scope and applicability

This Anti-bribery and Anti-corruption Policy applies to all individuals working in all units of Designco at all levels and grades, including directors, Managers, senior executives, officers, employees ,consultants, trainees, agents, or any other person associated with Designco. In this Policy, “Third Party(ies)” means any individual or organization, who/which come into contact with Designco or transact with Designco and also includes actual and potential clients, suppliers, business contacts, consultants, intermediaries, representatives, subcontractors, agents, advisers, joint ventures and government & public bodies (including their advisers, representatives and officials, politicians and political parties).

Policy details

A bribe is an inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. It is illegal to directly or indirectly offer a bribe or receive a bribe. It is also a separate offence to bribe a government/ public official. A bribe may be anything of value and not just money, gifts, inside information, sexual or other favors, corporate hospitality or entertainment, offering employment to a relative, payment or reimbursement of travel expenses, charitable donation or social contribution, abuse of function and can pass directly or through a third party. Corruption includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery.

Examples of bribery
  • Offering a bribe
  • Receiving a bribe

Gifts and hospitality:- Employees or members of their immediate families (spouse, mother, father, son, daughter, brother, sister or any of these step- or in-law relationships, whether established by blood or marriage including common law marriage) should not provide, solicit or accept cash or its equivalent, entertainment, favors, gifts or anything of substance to or from competitors, vendors, suppliers, customers or others that do business or are trying to do business with Designco. Loans from any persons or companies having or seeking business with Designco, except recognized financial institutions, should not be accepted. All relationships with those who Designco deals with should be cordial, but must be on an arm’s length basis. Nothing should be accepted, nor should the employee have any outside involvement, that could impair, or give the appearance of impairing, an employee's ability to perform his/her duties or to exercise business judgment in a fair and unbiased manner. This Policy does not prohibit normal and appropriate gifts, hospitality, entertainment and promotional or other similar business expenditure, such as calendars, diaries, pens, meals and invitations to theatre and sporting events (given and received), to or from Third Parties. However, the key determining factor for appropriateness of the gift or hospitality and/or its value would be based on facts and circumstances under which such gift or hospitality is provided. The practice of giving gifts and hospitality is recognized as an established and important part of doing business. However, it is prohibited when they are used as bribes. Giving gifts and hospitality varies between countries and sectors and what may be normal and acceptable in one country may not be so in another. Secondly this clause does not apply to brands / buyers having “Zero Tolerance on Bribery & Corruption” and it is mandatory to adhere their no gift policy for all employees. To avoid committing a bribery offence, the gift or hospitality must be:

a. Reasonable and justifiable in all the circumstances

b. Intended to improve the image of Designco, better present its products and services or establish cordial relations The giving or receiving gifts or hospitality is acceptable under this Policy if all the following requirements are met:

a. It is not made with the intention of influencing a Third Party to obtain/ retain business or a business advantage or to reward the provision or retention of business or a business advantage or in explicit or implicit exchange for favors/ benefits or for any other corrupt purpose

b. It complies with local laws and customs

c. It does not include cash or a cash equivalent (such as gift certificates or vouchers)

d. It is appropriate in the circumstances. For example, in U.S. it is customary for small gifts to be given at Christmas time

e. Taking into account the reason for the gift or hospitality, it is of an appropriate type and value and given at an appropriate time

f. It is given openly, not secretly and in a manner that avoids the appearance of impropriety

What is not acceptable? It is not acceptable for any employee of Designco (or someone on his / her behalf) to:

a. Accept an offer of a gift of any size from any Third Party which is in negotiation with, or is submitting a proposal with Designco.

b. Give, promise to give or offer, any payment, gift, hospitality or advantage with the expectation or hope that a business advantage will be given or received or to reward a business advantage already given

c. Give, promise to give or offer, any payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure

d. Accept or solicit any payment, advantage, gift or hospitality from a Third Party that you know or suspect is being offered with the expectation that it will obtain a business advantage for them

e. Threaten or retaliate against, another employee who has refused to commit a bribery offence or who has raised concerns under this Policy

f. Engage in any activity that might lead to a breach of this Policy The points stated above are illustrative in nature and in no way intend to limit the applicability of this Policy.

Facilitation payments and kickbacks

Neither an employee of Designco nor any person acting on behalf of Designco shall make and shall not accept facilitation payments or “kickbacks” of any kind. “Facilitation Payments” are typically small, unofficial payments (sometimes known as “grease payments”) made to secure or expedite a routine government action by a government official. “Kickbacks” are typically payments made to commercial organizations in return for a business favor/ advantage, such as a payment made to secure the award of a contract. You must avoid any activity that might lead to or suggest that a Facilitation Payment or Kickback will be made or accepted by Designco. Facilitation Payments are known to be prevalent in many countries and industry sectors

Charitable donations

As part of its corporate citizenship activities, Designco may support local charities or provide sponsorship, for example, to sporting or cultural events. We only make charitable donations that are legal and ethical under local laws and practices and also within the corporate governance framework of the organization.


Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to Third Parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts will be kept “off-book” to facilitate or conceal improper payments and the same is ensured through effective monitoring and auditing mechanisms in place. Employees must follow all the procedures laid out in other policies which help in anti-bribery and corruption due diligence on suppliers, potential joint venture parties, clients and other Third Parties.

How to raise a concern

Every person, to whom this policy applies too, is encouraged to raise their concerns about any bribery issue or suspicion of malpractice at the earliest possible stage. If he / she is unsure whether a particular act constitutes bribery or corruption or if he / she has any other queries, these should be raised with their respective Manager via written/Verbally or through the mail.

What to do if you are a victim of bribery and corruption?

It is his / her responsibility to inform / report it to their respective Managers via written/Verbally or through the mail as soon as possible if you are offered a bribe by a third party, you are asked to make one, suspect that this may happen in the future or believe that you are a victim of another form of corruption or other unlawful activity. You must refuse to accept or make the payment from or to a third party, explain our policy against accepting or making such payment and make it clear that the refusal is final and non-negotiable because of this Policy.


Those who refuse to accept or offer a bribe or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.


The information received from any one regarding breach of this policy by anyone at any level and the details of person passing the information will be kept highly confidential as it is our duty to think of his safety and confidentiality is also very important to win the confidence of others to cooperate to comply with this policy. The details will be not be shared with anyone who is not concerned with the investigating team or higher Management. It is the full responsibility of GM to ensure the confidentiality.

Who is responsible for the Policy?

The General Manager of Factory has overall responsibility for ensuring that this Policy complies with our legal and ethical obligations and that all those under our control understand and comply with it. Managers at all levels are responsible for ensuring that those reporting to them are made aware of and understand this Policy, undertake training on how to implement and adhere to it and also monitor compliance of it. The Compliance/ HR team which is reporting to GM is responsible for conducting Awareness Program/Training Session to make all persons understand this Policy and for monitoring its use and effectiveness. Management at all levels is responsible for ensuring that those reporting to them are made aware of and understand this Policy and attend regular training on how to implement and adhere to it. Every person to whom this policy applies is responsible for the success of this Policy and should ensure that he / she should use it to disclose any suspected activity or wrong-doing.

Training and Communication

The Compliance and HR Managers team will give the training to all the employees related to corruption and Bribery and will communicate to all the workers so that Corruption and Bribery is totally banned in the Factory. All the managers will ensure the effectiveness of training time-to-time.

Monitoring and Review

The General Manager, Factory Manager will ensure the successfully implementation of this policy in the Factory. Training will be provided to all the employees related to corruption and bribery and will be monitored on each step of training. All the managers will review the effectiveness of policy time-to-time.