Code of Conduct
Premable
This code of conduct is a written document that outlines company values, principles and guidelines in a variety of areas and enables the company to publicly state to its external stakeholders viz. suppliers, customers, consumers and shareholders, the way in which they intend to do business.

All directors and senior members of management of M H Mills and Industries Limited :

(i) Shall endeavor to act in good faith, responsibility, with due care, competence and diligence without misrepresenting material facts while dealing with the third parties and promote ethical and honest behavior within the company;

(ii) Are committed for conducting the business of the company in accordance with the applicable laws, rules & regulations and with highest standards of business ethics.
Applicability
This Code of Conduct and Ethics is applicable to all the Board of Directors and Senior Management. The Senior Management shall include all Executives in Top Management Cadre of the Company (hereinafter referred as Management).
Financial Reporting
M H Mills & Industries Ltd. shall prepare and maintain its accounts fairly and accurately in accordance with the accounting and financial reporting standards which represent the generally accepted guidelines, principles, applicable accounting standards, laws and regulations of the country. Accounting and procedures shall fairly and accurately reflect all the company's business transactions. All required information shall be accessible to Audit Committee of the Company & company auditors and other authorized parties/agencies. There shall be no willful omissions of any company transactions from the books and records, no advance income recognition, and no hidden bank account and funds.
Conflict of Interest
The Management must avoid any conflicts of interest between company and Management. Any situation that involves, or may reasonably be expected to involve, a conflict of interest with the Company, should be informed promptly to the Chairman or Managing Director of the Company.

Some of the more common conflicts, which management must avoid, are mentioned herein under:-
  • Financial interest of an employee of the company or his relatives including shareholding in any company or a share in any firm which is an actual or potential competitor, supplier, customer, or other alliance partner of the company.
  • An employee of a the company conducting business on behalf of his company/firm or being in a position to influence a decision with regard to his company's/firm's business with a supplier or customer of which his relative is an officer or representative, resulting in a benefit directly or indirectly in any form to him or his relative.
  • Award of benefits such as increase in salary or other remuneration, posting, promotion or recruitment of a relative of an employee of the company where such an individual is in a position to influence the decision with regard to such benefits.
  • Acceptance of gifts, donations, hospitality and/or entertainment beyond the customary level from existing or potential suppliers, customers or other third parties which have business dealings with the

  • Company.
    The above illustrations are limited. However other instances of conflict of interest exist due to any reasons, adequate and full disclosure by such interested persons should be made to the management of the Company.
Corporate Opportunities
The Directors or Senior Management personals are strictly prohibited:
  • To take themselves or their companies, opportunities which is discovered through the internal sources/insider information or position as a director or manager of the Company?
  • To use assets/properties of the Company for their personal gain;
  • To compete with the Company for business. However, the Independent directors/disinterested Directors of the Company decide that the Company will not pursue the said opportunities that relates to the Business of the Company, then Directors/senior management may then do so.
Insider Trading and Price sensitive information
All directors and senior managerial personals must comply with the SEBI Insider Trading Regulations, 1992. An employee of the Company or their immediate relatives shall not derive any benefit from the access to and possession of price sensitive information about the Company, which is not available to the general public.

Before making any transaction directly or indirectly as regard securities of the Company, without informing Compliance Officer of the Company and must strictly comply with the Insider Trading Regulations laid down by SEBI.