Employees Code Of Conduct

At NIRO CERAMIC GROUP, we are committed to maintaining a positive and productive work environment. This Employee Code of Conduct outlines the expectations and standard of behaviour that all employees are expected to comply with. Append below, please find the following:

1. Conflict Of Interest

An employee may own, either directly or indirectly, shares or other forms of beneficial interest in privately own entities which are listed in NIRO CERAMIC GROUP’s list of authorized contractors or suppliers, even if the entities concerned do not derive most of their income from contractual or other business arrangement with NIRO CERAMIC GROUP.

Should an employee become directly or indirectly (e.g. through immediate family) the owner of equity in such entities that have aforesaid relationship with NIRO CERAMIC GROUP, an employee has an immediate obligation to inform NIRO GROUP in writing of the changed circumstances. NIRO CERAMIC GROUP will then be obliged to consult with employee concerned as to the most appropriate way to prevent conflict of interest.

An employee, whose immediate family has interest, whether it is in the form of directorship, partnership, shareholdings or through agencies in entities which are NIRO GROUP’s list of authorized contractors or suppliers which have contractual or supply arrangements with NIRO CERAMIC GROUP, and who are involved in any discussions regarding or dealing (whether directly or indirectly) with such entities in the course of their duties with NIRO CERAMIC GROUP, should informed the Company in writing of such interests prior to entering into any such decisions/dealings. NIRO CERAMIC GROUP will then be obliged to consult with the employees concerned as to the most appropriate way to prevent a conflict of interest.

2. Confidential, Proprietary Information, Record Keeping And Document Retention

All information on proprietary and sensitive documents on employees’ personal data, company’s strategy, trade secret will be deemed as sensitive documentation and all employees must at all time maintain confidentiality. Record keeping and document retention policies must be in accordance to legal and regulatory standards. Any unauthorized access, use or disclosure of confidential information will be subjected to disciplinary action and may lead to termination of employment.

3. Holding Directorship In Other Entities Outside Employment, Political And Other Activities

Employees need to declare or to seek approval prior accepting directorship or engaging in significant outside activities and, to specify the criteria for evaluating whether such activities pose a conflict of interest.

Although NIRO CERAMIC GROUP encourage its employees to participate in public or social activities outside working hours which are voluntary in nature, the employee is advised to avoid unnecessary heavy involvement in such activities which will affect their work performance with NIRO CERAMIC GROUP.

An employee who is appointed or elected as an official of such an organization is obliged to advise the Management of the appointment.

An employee who is elected at State and/or Federal level in a political party shall be required to tender resignation.

4. Securities Trading And Insider Information

The Company strictly prohibits employees from trading securities based on insider information or sharing such information with others

5. Harassment & Discrimination

All Board of Directors of Niro Group shall:
Harassment & Discrimination (sexual or any other forms) that is likely to cause alarm or distress to another party is not at all tolerated. Example of behaviour that may be construed as harassment & discrimination is as follows:

  • Threatening, abusive, or insulting language, comments, or other verbal gesture
  • Cyber bullying
  • Sexual Harassment
  • Stalking

Victim or Complainant (Whistleblower) on harassment & discrimination needs to report the matter Human Resource Department and to adhere to the following:

  • Any employee(s) who experiences or witnesses’ harassment & discrimination must report the incident promptly
  • Report can be made directly to the Human Resource Department by filling in the “Incident Report Form”
  • The Company maintains an open-door communication to ensure confidentiality and privacy during the reporting process

Investigation Process

  • All reported incidents will be promptly or impartially be investigated by the Human Resource Department or an appointed committee (employees without conflict of interest with both harasser and victim) within two weeks from reporting date.
  • The investigation will include interview with the Victim, Complainant and any other relevant witness
  • The Company will take appropriate steps to ensure that the investigation is handle with sensitivity and discretion

Consequences of Harassment & Discrimination

  • If an investigation confirms the occurrence of harassment & discrimination, appropriate disciplinary action will be taken against the perpetrator which may include warnings, suspension not exceeding two weeks, domestic inquiry, termination without notice, downgrading or legal action, depending on the severity of the offence
  • False allegations, made with malicious intent, will also be subjected to disciplinary action.

6. Personal Conduct

A Niro Employee should at all time adhere to the following:

  • Safety: Prioritize our well being by creating and maintaining a secure environment, emphasizing prevention and precautionary measures.
  • Integrity: Uphold honesty, ethics, and transparency in all actions, fostering trust and credibility within the Organization and with stakeholders
  • Leadership: Inspire and guide others towards a common goal, demonstrating accountability, vision, and the ability to empower and develop team members
  • Passion: Infuse enthusiasm and dedication into tasks, promoting a positive and energetic work culture that motivates individuals to excel in their roles
  • Teamwork: Encourage collaboration and cooperation, recognizing the collective strength of diverse talents and perspective to achieve shared objectives
  • Service Excellence: Strive for outstanding customer service, exceeding expectations by consistently delivering quality and value in products or services
  • Global Mindset: Embrace diversity and a broad perspective, acknowledging and adapting to different cultures, markets, and global trends in decision making and strategy
  • Learning & Innovation: Cultivate a culture of continuous learning, embracing change and innovation to adapt to evolving challenges and opportunities, fostering personal and organizational growth

7. Use Of Company’s Assets

All company assets, including but not limited to equipment, intellectual property and information systems must be used for legitimate business purposes only.

8. Anti-trust, Competitive Information/fair Competition

Employee must adhere to all anti-trust laws and regulations. Sharing or obtaining competitive information in unethical manner or illegal manner is strictly prohibited

9. Anti-money Laundering, Anti-terrorism Financing And Proceeds Of Unlawful Activities

Employees are prohibited from engaging in any activities that could facilitate money laundering, terrorism financing or the proceeds on unlawful activities. Compliance with relevant laws and regulations is mandatory

10. Publication Of Books

An employee shall not publish or write any books, e-books or other works which are based on official information except with written permission from NIRO CERAMIC GROUP and subject to conditions deemed necessary by the Company.

11. Making Public Statements

An employee shall not either orally or in writing or in any form make or circulate any public statements or comments on any matters relating to work, policies, or decision of NIRO GROUP except with authorization from the Management.

12. Participation In Social Media

An employee shall not participate in any form of advertisements in broadcasting whether in the print media (newspaper, magazine, etc.) radio, television, Facebook, twitter, tik-Tok or any other media without prior written consent from the Management.

13. Donation, Sponsorship, Gifts, Entertainment, Gratuities, Favors, And Other Items Of Value

Acceptance or offering of gifts, entertainment or other items of value must comply with company policies and applicable laws. Employees should avoid situations that could create the appearance of impropriety.

14. Reporting On Unlawful Or Unethical Behaviour

Employees are encouraged to report any unlawful or unethical behaviour through established reporting channels. Whistleblower protections will be provided.

15. Compliance With Rules & Regulations

All employees must strictly adhere to all Standard Operating Procedures, Policies, Rules & Regulation either expressed or implied and depending on the severity of the of the non-compliance disciplinary shall be taken against the employee(s)