CODE OF CONDUCT AND ETHICS

Updated on December 2018

INTRODUCTION

The Times Group’s most valuable assets are its people and its brands. As a member of the
Times family, every Employee and Journalist on Contract (Journalist) is expected to play a
multi-faceted role, that of a primary contributor to the business, a citizen of BCCL GROUP
and prominently, an ambassador of the brand and the Group.

To succeed requires the highest standards of behavior from all of us. The purpose of this Code
of Conduct & Ethics (the “Code”) is to conduct the business in accordance with the applicable
laws, regulations, rules and with the highest standard of ethics and values. The matters
covered in this Code are of utmost importance to the shareholders and other stakeholders of
the Company.

This Code shall come into force with immediate effect. Each and every Employee and
Journalist shall be duty-bound to follow the provisions of this Code in letter and spirit. Any
instance of non-compliance of any of the provisions shall be a breach of ethical conduct and
shall be viewed seriously by the Company.

Accordingly, the Employees and Journalists are expected to read and understand this Code
and uphold these standards in their business dealings and activities.

Because the principles described in this Code are general in nature, Employees and Journalists
should also review the Company’s other applicable policies and procedures for more specific
instruction.

Nothing in this Code, in any Company policies and procedures, or in other related
communications (verbal or written), creates or implies an employment contract or term of
employment.

(Authorized Signatory)
Date:
 I. APPLICABILITY

This Code of Conduct & Ethics applies to BCCL (i.e. BCCL and Group Companies/
Subsidiaries comprising of TBSL, TIL, TGBCL, VPL, ZENL, WWM, OMS, TOM and any other
Group Companies/ Subsidiaries from time to time) collectively referred as the “Company”.

Employees and Journalists should sign the acknowledgment form annexed to this Code and
return the form to the HR Department indicating that they have received, read and
understood, and agree to comply with the Code. In addition, all existing conflicts of interest
should be reported in the attached form.

Each year, as part of annual review, Employees and Journalists will be asked to sign an
acknowledgment indicating their continued understanding to the Code.

Note: For Code of Conduct of ENIL Group (i.e. ENIL and Group Companies/ Subsidiaries
comprising of TIMPL, ABSL and any other Group Companies/Subsidiaries from time to time)
refer the ENIL website at http://www.enil.co.in

II. HONEST AND ETHICAL CONDUCT

We conduct our operations with honesty, integrity and openness, and with respect for the
human rights and interests of our Employees and Journalists.

We shall similarly respect the legitimate interests of those with whom we have relationships.

We expect all the Employees and Journalists to act in accordance with the highest standards
of personal and professional integrity, honesty and ethical conduct, while working at the
Company’s or its subsidiaries premises, at offsite locations, at Company’s or its subsidiaries
sponsored business and social events, and/or at any other place where the Employees and
Journalists represent the Company or its subsidiaries.

We consider honest conduct to be conduct that is free from fraud and/or deception. We
consider ethical conduct to be conduct conforming to be accepted professional standards of
conduct. Ethical conduct includes ethical handling of actual or apparent conflicts of interest
between personal and professional relationships.

III. COMPLIANCE WITH GOVERNMENTAL LAWS, RULES AND REGULATIONS

Company is committed to comply with all applicable governmental laws, rules and
regulations. Accordingly, its employees are required to comply with the applicable laws and
regulations. Violations of applicable governmental laws, rules and regulations may subject
Employees and Journalists to individual criminal and/or civil liability. Such individual
violations may also subject the Company to civil and/or criminal liability and/or the loss of
business.

Company principles and its commitment towards various categories have been outlined
below:
1. EMPLOYEES AND JOURNALISTS
Company is committed to diversity in a working environment where there is a mutual trust
and respect, and everyone feels responsible for the performance and reputation of our
Company.

We will recruit, employ, engage on contract and / or promote Employees and Journalists on
the sole basis of the qualifications and abilities needed for the work to be performed. We are
committed to safe and healthy working conditions for all Employees and Journalists. We will
not use any form of forced, compulsory or child labour.

We respect the dignity of the individual and the right of Employees and Journalists to freedom
of association. We will maintain good communication with Employees and Journalists
through Company based information and consultation procedures.

For detailed integrity attitudes expected from Employees and Journalists, refer Annexure
A.

2. CONSUMERS
Company is committed to provide quality products and services at reasonable prices.
Consumer complaints and disputes will be resolved fairly and speedily without undue cost
or burden.

3. STAKEHOLDERS
Company will conduct its operations in accordance with generally accepted principles of good
corporate governance. We will provide timely, regular and reliable information on our
activities, structure, financial situation and performance to all stakeholders.

4. BUSINESS PARTNERS
Company is committed to establishing mutually beneficial relations with our suppliers,
customers and business partners. In our business dealings we expect our business partners to
adhere to business principles consistent with our own.

5. COMMUNITY INVOLVEMENT
Company strives to be a trusted corporate citizen and, as an integral part of society, to fulfill
our responsibilities to the societies and communities in which we operate.

6. PUBLIC ACTIVITIES
Company is encouraged to promote and defend their legitimate business interests. Company
will co-operate with governments and other organizations, both directly and through bodies
such as trade associations, in the development of proposed legislation and other regulations
which may affect legitimate business interests.

7. THE ENVIRONMENT
Company is committed to making continuous improvements in the management of our
environmental impact and to the longer-term goal of developing a sustainable business.
Company will work in partnership with others to promote environmental care, increase
understanding of environmental issues and disseminate good practice.
 8. INNOVATION
In our innovation to meet consumer needs we will respect the concerns of our consumers
and of society. We will work on the basis of sound science applying rigorous standards of
product safety.

9. COMPETITION
Company believes in vigorous yet fair competition and supports the development of
appropriate competition laws. Company and its Employees and Journalists will conduct their
operations in accordance with the principles of fair competition and all applicable laws and
regulations.

IV. VIOLATIONS OF THE CODE

Part of the Employee’s and Journalist’s job, and of his / her ethical responsibility, is to help
enforce this Code along with its annexures. Employees and Journalists should be alert to
possible violations. Any breaches of the Code must be reported in accordance with the
Company policy. The Company expects Employees and Journalists to bring to their attention,
or to that of senior management, any breach or suspected breach of these principles.

Provision has been made for Employees and Journalists to be able to report in confidence and
make any protected disclosure under the Company’s Whistle Blower Policy arising out of
unethical behavior, actual or suspected, fraud or violation of the Company’s Code of Conduct
and Ethics policy.

As per Whistle Blower Policy, protected disclosure can be made and addressed to the Whistle
Blower Committee by e-mailing on the Company’s e-mail id at [email protected]
or sending a written compliant in a sealed envelope written/typed in English/Hindi to “Whistle Blower
Committee, Times of India, 7 Bahadur Shah Zafar Marg, New Delhi – 110001.

The Company will take appropriate action against any Employee or Journalist whose actions
are found to violate the Code or any other policy of the Company as per the procedure
outlined under the Company’s Whistle Blower Policy.

V. WAIVERS AND AMENDMENTS OF THE CODE

We are committed to continuously reviewing and updating our policies and procedures.
Therefore, this Code is subject to modification. Any amendment or waiver of any provision
of this Code must be approved by the Company’s Board of Directors.

VI. NO RIGHTS CREATED

This Code of Conduct and Ethics is a statement of certain fundamental principles, ethics,
values, policies and procedures that govern the Employees and Journalists of the
Company in the conduct of the Company’s business. It is not intended to and does not
create any rights in any employee, customer, client, supplier, competitor, shareholder or
any other person or entity.

VII. ACKNOWLEDGMENT OF RECEIPT OF CODE OF CONDUCT & ETHICS

All Employees and Journalists should fill and sign the acknowledgement form and submit
to HR department. Refer Annexure B for copy of the form.