It is our policy to manage and operate worldwide business activities in conformity with applicable laws and high ethical standards. Management is determined to comply fully with the law, and to maintain the firm’s reputation for integrity and fairness in business dealings with others.


Policy applies to all employees, officers and even on other who joins the firm in due course of time.


Employees, officers and management are expected to adhere to all ethical and legal standards as outlined in this policy and to preserve the firm’s integrity and reputation.


Financial Record-Keeping

It is the policy of the firm to fully and fairly disclose the financial statements in compliance with the applicable accounting principles, laws, rules and regulations and to make full, fair, accurate, timely and understandable disclosures in our periodic reports. Honest and accurate recording and reporting of information is critical to our ability to make responsible business decisions. Accounting records relied to produce reports for the management, and other stakeholders of future, governmental agencies and others. Therefore, our financial statements and the books and records on which they are based must accurately reflect all corporate transactions and conform to all legal and accounting requirements. Our system of internal control is designed to provide this information.

All employees have a responsibility to ensure that the accounting records do not contain any false or misleading entries. Information on which our accounting records are based is the responsibility of all employees. We do not permit intentional misclassification of transactions as to accounts, departments or accounting periods. In particular we require that:

  • Accounting records, as well as reports produced from those records, are kept and presented in accordance with the laws of each applicable jurisdiction;
  • All records fairly and accurately reflect the transactions or occurrences to which they relate;
  • All records fairly and accurately reflect in reasonable detail the assets, liabilities, revenues and expenses;
  • Accounting records do not contain any intentionally false or misleading entries;
  • No transactions are misclassified as to accounts, departments or accounting periods;
  • All transactions are supported by accurate documentation in reasonable detail and recorded in the proper account and in the proper accounting period;
  • All financial reports be prepared in accordance with generally accepted accounting principles; and
  • System of internal accounting controls, including compensation controls, to be followed at all times.

Improper Payments

No payment or transfer of firm funds or assets shall be made that is not authorized, properly accounted for and clearly identified in the books. Payment or transfer of funds and assets are to be used only as specified in the supporting documents. No employee or officer may authorize any payment or use any funds or assets for a bribe, "kickback," or similar payment that is directly or indirectly for the benefit of any individual (including any government official, agent or employee anywhere in the world), company or organization in India or any foreign country, and which is designed to secure favourable treatment for the firm. 

Political Contributions

It is our policy not to contribute any firm’s funds or assets to any political party, committee, organization, or candidate for any office (federal, state or local) in India or abroad. Employees may, on their own time, support individual candidates or political committees, all subject to applicable laws, and may make voluntary contributions to such candidates or committees, including any firm-related political action committee.

Acceptance of Payments

Employees, officers and directors may not seek or accept, either directly or indirectly, any payments, fees, services, or other gratuities (irrespective of size or amount) outside the normal course of the employee's business duties from any other person, company or organization that does or seeks to do business with the Company. Gifts of cash or cash equivalents of any amount are strictly prohibited. The receipt of common courtesies, sales promotion items of nominal value, occasional meals, and reasonable entertainment appropriate to a business relationship and associated with business discussions are permissible.

Business Entertainment

All solicitations or dealings with suppliers, customers, or others doing or seeking to do business with the firm shall be conducted solely on a basis that reflects firm’s best business interests and its high ethical standards. Firm does permit the providing of common courtesies, entertainment, and occasional meals for potential or actual suppliers, customers or others involved with the firm’s business, in a manner appropriate to the firms relationship and associated with business discussions. Expenses in this connection must be reasonable, customary and properly authorized.

Corporate Opportunities

No employees and officers of the firm shall for personal or any other person's or entity's gain deprive the firm of any business opportunity or benefit which could be construed as related to any existing or reasonably anticipated future activity of the Company. Employees and officers who learn of any such opportunity through their association with the firm may not disclose it to a third party or invest in the opportunity without first offering it to the firm.


Employees and officers are responsible for safeguarding and keeping confidential any information that the firm considers to be of a confidential or sensitive nature. Such information includes, but is not limited to financial records and reports, marketing and strategic planning information, employee-related documents, unpublished manuscripts as well as information relating to potential mergers and acquisitions, stock splits and divestitures, and other materials that the firm would not want disclosed to a competitor or any unauthorized recipient, or that might be harmful to the firm or its customers if disclosed whether or not such information is marked "confidential." Confidential information also includes information concerning possible transactions with other firms / companies or information about the firm customers, suppliers or joint venture partners, and any information that the firm is under an obligation to maintain as confidential. Employees, officers and directors may not use confidential information for their own personal benefit or the benefit of persons or entities outside the firm, and must exercise caution and discretion with respect to any appropriate temporary removal of confidential or sensitive information from the firm premises, and should safeguard the information from unintended disclosure or loss. Employees must at all times adhere to the firm’s policies regarding the transmission and storage of confidential and sensitive business records.

Compliance with Laws and Regulations

Firm requires its employees and officers to comply with all applicable laws and regulations in countries where the firm does business. Violation of domestic or foreign laws and regulations may subject an individual, as well as the firm, to civil and/or criminal penalties. Employees have an obligation to comply with all laws and regulations and policies and procedures and to promptly alert management of any deviation from them.

Fair Dealing

Each employee and officer should endeavour to deal fairly with the firm suppliers, competitors and employees. No one should take unfair advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. Information about the firm’s competitors must be used in an ethical manner and in compliance with the law. Under no circumstance should information be obtained through theft, illegal entry, blackmail, or electronic eavesdropping, or through employees misrepresenting their affiliation with the firm or their identity. Any proprietary or non-public information about the firm competitors should not be used if it is suspected that such information has been obtained improperly.

Conflicts of Interest

Firm expects all employees and officers to exercise good judgment and the highest ethical standards in private activities outside the firm that in any way can affect the firm. They shall at all times exercise particular care that no detriment to the interest of the firm may result from a conflict between those interests and any personal or business interests which the individual may have. In particular, employees and officers has an obligation to avoid any activity, agreement, business investment or interest or other situation that might, in fact or in appearance, cause an individual to place his or her own interest, or that of any other person or entity, above his or her obligation to the firm.

The words "in appearance" should be noted particularly since the appearance of an action might tend to impair confidence even if the individual may not actually do anything wrong. To this end, employees and officers must avoid any investments, associations or other relationships that could conflict with the staff member's responsibility to make objective decisions in the firm’s best interests. Any potential conflicts of interest must be reported immediately to the management.

Employment of Relatives

The firm policy is to require advance approval before a relative of an employee is hired, or is engaged as a consultant or independent contractor of the form, if the relative of the employee will be in the same department or chain of command of the Pezzottaite Journals employee. Such approval should be sought from management. A relative may only be hired or engaged with the advance review and approval of both the Proprietor of the firm. A "relative" may include a member of the employee's family (spouse, child, parent, sibling, in-law) but may also include, for purposes of this policy, any individual who is living with or otherwise in a significant relationship with the employee, or a relative of such an individual.

Duty to Report Violations

Each employee and officer is responsible for promptly reporting to the firm any circumstances that such person believes in good faith may constitute a violation of this policy. Except as provided in the next paragraph, suspected policy violations are to be reported (including confidential and anonymous reports) to Proprietor. Any complaint regarding accounting, internal accounting controls or auditing matters must be reported (including confidential and anonymous complaints) to the proprietor. No retribution against any individual who reports violations of this policy in good faith will be permitted. However, the reporting of a violation will not excuse the violation itself. The firm will investigate any matter that is reported and will take any appropriate corrective action.

Violations of Policy

Violations of any of the foregoing provisions may expose the firm and the individuals involved to lawsuits and possible criminal action. Staff members who violate this policy are subject to appropriate disciplinary action, up to and including termination. The firm legal advisors will review any alleged violations of this policy, and they will determine the appropriate action to be taken.