Code of Business Conduct

Why we have this code

We intend to be trusted for decades by the people who live in what we build, by our partners and by the places where we work. That trust depends on how each of us behaves, especially when no one is watching. This code describes the conduct we expect. It does not replace the law or our other policies; it is the standard we hold ourselves to on top of them.

Who it applies to

This code applies to the designated partners of Hazaar Group LLP, to every employee, and to anyone who acts on Hazaar’s behalf, such as agents and representatives. The designated partners are bound by it first and are accountable for setting the example. The firms we work with follow the Partner Code of Conduct, which sets the same standards for them.

Making the right decision

No code can foresee every situation. When you are unsure, ask yourself:

• Is it legal, and is it consistent with this code and our standards?
• Would I be comfortable if it were recorded in writing and read by the designated partners, a regulator or a journalist?
• Would it still look right in 30 years?
• Does it treat everyone affected fairly, including people who are not in the room?

If the answer to any of these is no, or you are not sure, stop and ask a designated partner before you act.

The law as the minimum

We comply with every law that applies to our work, wherever we work. Where this code or our standards set a higher bar than the law, we meet the higher bar. Where the two appear to conflict, we follow the law and raise the conflict with a designated partner.

No bribery or corruption

We do not offer, promise, give, ask for or accept a bribe, a kickback or any improper advantage, directly or through anyone else, in any form and for any purpose. This includes small “facilitation” payments to speed up an approval or a service. It applies to dealings with public officials and with private businesses alike. We comply with the Prevention of Corruption Act, 1988 and every other anti-corruption law that applies to us.

No one is ever penalised for refusing to pay a bribe, even if refusing costs Hazaar time or business.

Gifts and hospitality

• We may give or accept only modest, occasional gifts or hospitality that are customary and could not be seen as influencing a decision.
• We never give or accept cash or cash equivalents, or anything at all while a tender, approval, negotiation or contract decision is under way.
• All gifts and hospitality above a token value are recorded and reported to a designated partner.
• If you are unsure whether something is appropriate, decline it politely, or ask first.

Conflicts of interest

A conflict of interest arises when a personal, family or financial interest could affect, or appear to affect, a decision you make for Hazaar. Declare any actual or potential conflict in writing to a designated partner as soon as you are aware of it, and step back from the decision until it has been resolved. Having a conflict is not wrong; hiding one is.

Fair dealing and competition

We compete on the quality of our work and the strength of our standards. We deal fairly and honestly with partners, suppliers, customers and competitors. We do not agree prices, divide markets or rig bids with anyone, and we comply with the Competition Act, 2002. We select partners and suppliers on merit, through a fair and documented process.

Honest records

Every record we make, from a site inspection to an invoice, must be complete, accurate and made on time. We never falsify, backdate or destroy a record, and we keep records for as long as the law and our policies require. We are open and honest with auditors, regulators and the authorities.

Confidentiality, data and security

• We protect Hazaar’s confidential information, and the confidential information that others entrust to us, during and after our time with Hazaar.
• We collect and use personal data only for a stated purpose, keep it only as long as needed, and protect it as our privacy policy and the law require.
• We use Hazaar’s systems and devices responsibly, protect passwords and access, and report any suspected security incident immediately.
• We never use confidential information for personal gain or share it with anyone not entitled to it.

Health and safety

Safety comes before programme, cost and convenience. Everyone has the authority, and the duty, to stop work they believe is unsafe, without fear of blame. We follow every safety rule on every site, report every incident and near miss, and never come to work impaired by alcohol or drugs. Read more about safety at Hazaar.

Respect, dignity and inclusion

• We treat everyone with respect and courtesy: colleagues, partners, workers, residents and members of the public.
• We do not tolerate harassment, bullying, intimidation or discrimination of any kind, including on the grounds of religion, race, caste, sex, gender identity, sexual orientation, place of birth, age, disability, HIV status, marital status or pregnancy.
• We follow the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. When the Act requires an Internal Committee, we constitute one. Until then, a complaint can be made to the Local Committee for our district, and to a designated partner.
• We make decisions about people on merit and evidence, and we make reasonable accommodation so that everyone can do their best work. Our inclusion and equal opportunity policy sets out how.

Human rights and fair work

We respect the human rights of everyone affected by our work. We never use, or accept from any partner, forced, bonded or child labour. Everyone who works on our sites, whoever employs them, is entitled to fair and timely wages, reasonable working hours, safe conditions, decent welfare facilities and freedom from abuse. Indian labour law and our Partner Code of Conduct both require this.

Environment

We take care of the land, water, air and trees in the places where we work, and we look for ways to reduce waste, energy and water use in everything we do. Read our sustainability commitments.

Speaking for Hazaar

Only the designated partners, or people they authorise in writing, may speak for Hazaar to the media, investors or the public, or make commitments on its behalf. Everything we say about Hazaar must be true and supportable, including on social media. We never announce or promote a real estate project before the law allows it.

Political activity

You are free to take part in political life in your own name and your own time. You must not use Hazaar’s name, funds or resources for any political purpose, or suggest that your views are Hazaar’s.

Speaking up

If you see or suspect conduct that breaks this code, the law or our standards, speak up. You can raise it with a designated partner, or report it in confidence by email to info@hazaar.co.in with “Integrity” in the subject. See Report a concern for how reports are handled.

We do not tolerate retaliation of any kind against anyone who raises a concern in good faith, or who helps with an investigation. Retaliation is itself a serious breach of this code.

Accountability

• Everyone covered by this code confirms in writing, when they join and again each year, that they have read it and agree to follow it.
• Breaches are investigated fairly and confidentially, and may lead to disciplinary action, up to and including dismissal or the end of a relationship with Hazaar, and to reporting to the authorities where the law requires.
• The designated partners review this code at least once a year and publish any changes here.