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TOP GEAR AWARD:

For Outstanding Professional Achievement and Managerial Excellence:

Purpose

The Top Gear Performance Award Program is designed to honors and provides recognition to those
managers who are able to make a significant contribution to the success of the organization by
consistently exceeding or going beyond their job requirements.

An ideal candidate for the TOP GEAR Performance Award is one who demonstrates vision, an ability
to apply and leverage contextual wisdom, make things (otherwise thought to be difficult / impractical)
to happen and may be seen as a role model (or potential role model) for others to emulate.

The award is intended to honors and builds visibility for outstanding achievement, support efforts
towards building a superior performance culture in the Group. It is in addition to the annual
increments and performance incentives.

This initiative reflects the commitment of the organization to the principles of employee
empowerment and ownership in achieving the business objectives.

The common drivers across the stipulated criteria for granting awards are as follows:

• High performance orientation
• Employee initiative and versatility
• Total quality improvement activities, in systems, processes or product/service
• Core values espoused by the Group
• Other acts that support the Organization vision, mission, and strategic plan

Selection Criteria

Selection Criteria will be based on evidenced accomplishments that meet any one or more of the
following five parameters:

• Impact on Bottom Line
• Impact on Quality and Customer
• Impact on Process Flow / Work Method / Operational Efficiency
• Contribution outside Scope of Principal Account abilities
• Adherence to / Demonstration of Group Values in action.

Eligibility

• All employees in the Managerial cadre i.e. from Assistant Manager to General Manager Level
are eligible to be nominated.

• Nominees must be employees of the RPG Group at the date of nomination.
• The achievements should have been accomplished in the 12 month period prior to the

nomination for awards.

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• Employees serving their notice period with the organization, temporary staff and employees
resigned or retired (in the 12-month period under consideration) will not be eligible for
nomination.

The Awards

All winners will receive a Holiday package for two, to a South East Asian Countries / Domestic (cost
not exceeding Rs. 1,50,000/- all-inclusive). There is no option of cash in lieu of a holiday package.

Innovation

EUREKA:

Overview

• Eligibility: All employees (Excluding NMS, Field Force)
• Reason: to be awarded to the employee for the new innovative idea for any product or

process. Leading to cost reduction, reduction in cycle time.
• If the idea is found good for implementation and has revenue generating capabilities, it will

be suitably rewarded.
• All ideas received will be adjusted in the upcoming MCM.
• Cultural Pillars: Opportunity orientation.

Awards

• Award: Certificate for participation. And the amount would be decided based on the project
in the MCM meeting.

• Gift Amount up to Rs. 50,000/- to be approved by MCM and HR Head
• Gift Amount above Rs. 50,000/- to be approved by MD.

Checklist

• E-mail to be sent at : [email protected]
• Frequency: Receipt of nomination.
• Objective: to motivate employees for improvement in the current processes and practices

and give recognition and space to new ideas and nurture innovation.
• Process owner: Corporate HR will be responsible for award distribution and coordination.

Parameters & Weightage:

Parameters Weightage Reviewer Score
(1-Lowest, 30-Highest)
Innovation / Different / New in the current system 20
Revenue Generating / Cost reducing 30 1 to 20
Impact on cycle time / TAT 20 1 to 30
Extra effort for superior performance 30 1 to 20
Highest Score 100 1 to 30
Cut of Score 80

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LONG SERVICE AWARD:

Objective:

To acknowledge contribution of those employees who serve the organization for a continuous number
of years.

Scope: Eligibility Gifts
*All employees Momentum
Number of Years in *AM and above on rolls employees Certificate + Silver coin worth 10k
RPGLS *AM and above on rolls employees Certificate + Gold Coin worth 20k
5 years *Officers /Executives Certificate + Gift Cheque 25000
10 Years Any Employee Certificate + Gift Cheque 50000
25 Years
10 Years
25 Years

*In case of continuity of the services with the RPG Group, years of services with the other group
companies will be considered to determine the continuity of long service award.
*The Long service award will be given on the date of anniversary of the employee by respective
MRM of the awardee at the respective locations in presence of fellow colleagues.
*Resigned or employee service notice period will not be eligible for Long service award.

Procedure:

• The employee will receive a Certificate signed by the Managing Director and gift cheque.
• The Location HR Department will be responsible for arranging the certificate and gift cheque

and will ensure that is available in the respective location at least 15 days in advance.
• The certificate and gift cheque will be handed over to the employee at any occasion / function

organized at the manufacturing location.
• At the other locations it will be handed over the Business Head at their Conferences or

Business Development Meetings
• If the Business Head is not available it will be handed over by the respective Vice President’s

only
In case of Non-Management Staff, they would be given as per the settlement agreement.

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Wisdom Quest Program

Objective:

To provide higher education platform which will instill a culture of continuous learning and
development. This will in turn create a strong talent pool and robust set of organizational
capabilities.

Scope:

This program exists over and above an employee’s individual Development Action Plan (DAP). In case
higher education is part of an individual’s DAP, then it will not be part of this program (as that cost will
be borne entirely by the organization). Also, planned higher studies that are part of the employee
contract or other terms of employment (for example with (Self-Managed Teams (SMTs) or High
Performing Teams (HPTs)) are excluded from this program.

Eligibility:

All employees in grades from Assistant Manager and above upto Vice President who have completed
atleast 2 appraisal cycles with a performance rating of not less than 60 on PRIDE in each year.

Guidelines on Application and Approval Process:

• This program is being launched effective 1st April 2018.
• The timeframe for new applications is from April to June every year. Interested employees may

apply only during this window. The application process will be conducted only once in a year as
a single batch.
• Total 10 employees will be considered for the above program during the financial year.
• The approval for the above program will be given based on the relevance of course to the current
function and on first-come, first-serve basis.
• During application evaluation, Top Talent and those employees who have not been previously
benefitted by this program will be given first preference.
• Applicants to inform all exam and contact program schedule during application.
• First approval of application will be done by Line Manager, Reviewer & respective MRM.
• Second approval will be Managing Director & Head – HR.
• If an employee has been a beneficiary under this program, she/he can re-apply after 5 years of
successful course completion.
• If an employee’s application is approved and she/he is selected to be part of the Wisdom Quest
Program, the employee will need to sign a Wisdom Quest Agreement.
• The employee needs to mandatorily work for a minimum period of 2 years post completion of
the course.
• In case the employee chooses to leave the organization within 2 years of completion of the course
or in between the course period, then she/ he will need to return the full reimbursement amount
to the Company.

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Course Details:

Type of Course Any higher education pursuit must necessarily be in the form
Duration of course of a formal academic qualification, and cannot be educational
Mode of Learning courses or training programmes. The course must also be
relevant to the current or planned future roles of the
employee.

Capped upto 4 years except for PH.D.
Long distance / Weekend / Evening / Digital Course
From a recognized or reputed college / university / institutes.

The course should not impact the regular working hours of the
employee.

Applicable Benefits of the Program:

• Company will reimburse an amount not more than INR 2,50,000 or 80% of course fee -
whichever is lower. The amount will be reimbursed after grossing up tax, so that the full
benefit is available to the employee. This amount is reimbursed only on the ‘Tuition fee’
(inclusive of taxes, if any).

• Upto 50% advance reimbursement will be made based on actuals fee schedules. Remaining
reimbursement will be done on successful completion of the course.

• No time-off or special leave will be provided for undergoing the course. Employee will avail
her/ his leave quota for attending classes, exams, etc. in a planned manner and with the prior
approval of the reporting manager.

Support during the Course:

• The Line Manager will be the sponsor for the employee. She/he will ensure course relevance
to the individual’s career during the application process, will take regular updates during the
course and support for successful completion.

Post Course Completion:

• Key stakeholders will be intimated of the employee’s ‘successful learning completion’. This is
also aimed at encouraging constant learning amongst RPGians.

• Employee profile will be updated with necessary documents, etc.
• Company does not guarantee a promotion / career enhancement / role change basis the

course undertaken.
• Employee must ‘Pass’ the course. In case she/he fails (upto 1 re-exam result), the advance

reimbursement amount (if any) will be returned to the Company by the employee.

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Performance Management Plan

For Assistant Manager & above

▪ Asst. Manager onwards the performance of the employee shall be evaluated through PRIDE*
▪ Up to senior executive the performance of employee shall be evaluated through Goals.
▪ Increments are effective from July 01 of the respective year
▪ Calendar year for the purpose of PMS is April to March.
▪ An employee must have completed a minimum of 6 months to be a part of the current year’s

PMS cycle. For e.g.:

Date of Joining PMS cycle
1st April to 30th September Current Year for no. of months served
1st October to 31st March Following Year with pro-rata for current year

The Performance Appraisal form captures the current year’s performance of the employee, his/her
expectations in the future, development needs for the employee and career recommendations for
him/her.

The performance appraisal form is filled up conjunctly by the employee and his/her manager during
the performance management cycle.

PRIDE:

Performance Review and Individual Development Enabler (PRIDE) is our performance management
system that is applicable across all Group companies. An Appraisal cycle extends from April 1 –
March 31 of the FY.

PRIDE comprises of 3 steps, which covers the entire PMS cycle for an employee. Each step has been
explained in detail in the subsequent sections.

Goal Setting Mid year Review Annual
Performance

Review

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Users of the PRIDE System:

Employee: Employee is the appraisee who is undergoing the PRIDE process.
Line Manager: The direct reporting manager of the Employee shall be his/her Line Manager. The Line
Manager will be the Appraiser of the Employee.
Reviewer: The Skip Level Manager of the Employee (i.e., the Line Manager’s Manager) shall be the
Reviewer. It will be the responsibility of the Reviewer to ensure that the PRIDE process for the
Employee has been done as according to the established guidelines, with objectivity and fairness.
Functional Manager: Functional Manager is the matrix or the dotted line manager of the employee.
A Functional Manager is responsible for the functional goals of the employee. The Functional Manager
assesses if the Employee has fulfilled his/her functional responsibilities in addition to fulfilling business
or SBU responsibilities. For example an employee working in the HR department may have the Goal
to Reduce the TAT for Hiring a new employee by 10% (Business Goal) but at the same time, his/her
Functional Goal would be to ensure 100% compliance with the SOP and Policies for Recruitment. It is
the responsibility of the Line Manager to seek inputs and feedback from the Functional Manager (if
any) of the Employee, during Goal Setting and performance assessment in Mid-Year and Annual
Review.

GOAL SETTING:

Goal Setting allows the employees to list their goals for the year, identify performance expectations
and the means to achieve the same. The entire process is to be carried out in discussion between
the Employee, the Line Manager and the Functional Manager.
Timelines:

• For VP and above PRIDE Goal setting will be initiated and completed in February
• For rest of the employees PRIDE Goal setting will be initiated and completed in March

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EXPLAINING THE GOAL SHEET:

Goal Sheet is to be used by the employees for setting their goals. It comprises of the following:
Goal
Within this, the employee needs to define his/ her goals in the form of results that should be
achieved in the year.
Goal Category
There are 2 categories of goals. Every goal should belong to either of these 2 categories
• Business or Functional Goals
• People Goals

Please Note: A Goal sheet can have a maximum of 7 goals and minimum of 5 goals, of which one
has to be a People Goal, unless the employee is an Individual Contributor.
Measure:
A measure is a unit of key performance indicator used to evaluate the achievement of the goal.
Floor:
This is minimum level at which the goal must be achieved. For quantitative goals, floor is 80% of
target or last year’s actual achievement - whichever is higher. In case last year’s actuals is more
than 90% of target, then the floor should be capped at 90% to ensure that there is atleast a 10%
gap between the Target and Floor. For qualitative goals, floor is set at 0 and target at 10.
Target:
This is the level at which the goal needs to be achieved. For qualitative goals, target is set at 10.
Weightage:
Every goal has to be assigned a weightage based on its relative importance to the achievement of
company goals. The weightage for every goal should be between 10% (minimum) and 40%
(maximum). The sum of the weightages given to all goals should be equal to 100%.

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CASCADING OF GOALS:

An employee can cascade his/her goals to a subordinate, by allocating the particular goal to the
subordinate. The subordinate will develop his/her goals based on the goals cascaded to him/her. The
subordinate can further cascade his/ her goals, leading to multi-level cascading of goals

PROCESS FLOW FOR GOAL SETTING:

MID –YEAR REVIEW:

Mid-year Review is an opportunity for the employee to seek formal feedback mid-course so
as to ensure that Annual Goals are achieved. It aims to help the employee take course
correction measures and execute timely actions, if performance is lagging. It also helps to
understand where the employee stands with respect to his / her Annual Goals. This will guide
the employees to decide how they should focus their resources and time.

Please Note: Only the employees joining before October 1, will be eligible for the Mid-Year Review.

Timelines:
Mid-Year Review will be initiated and completed between 15th October – 15th November.

Explaining the Mid-Year Review Form:
The Mid-Year review form comprises of only the Goal Assessment Section. Within the Goal
Assessment Section, the employee needs to fill in the following:

• Actual
Within this the Employee has to fill in his/ her actual achievement, so far. This should be
a numeric input. The Employee will not be rated during the Mid-Year Review. It is only
for the sake of discussion that actual numeric achievement may be recorded. The focus
will be to seek feedback on what is going on well, what needs to be continued and what
should be discontinued.
• Employee Comments
The employee may support his/ her actual achievement against a goal, by providing

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supporting instances, in the comments section. The employee may also use this sub-
section to highlight any difficulties or any support he/she may need to achieve the
concerned goal.

• Manager Comments
Manager’s inputs on the employee’s achievements against a goal are captured in this
sub-section.

MODIFICATION OF GOALS DURING MID-YEAR REVIEW:

Employee Goals for the year is finalized and locked during the Goal Setting done at the
beginning of the Appraisal year. It is only by exception and with the approval of the
MRM/MCM, that goals may be modified in a few cases, during Mid-Year Review. Chairman’s
approval is needed to modify the goals of VP and above level employees, during Mid-Year
Review.

IMPACT OF MID-YEAR REVIEW ON ANNUAL PERFORMANCE APPRAISAL:

Annual Performance Appraisal shall be in continuation to the Mid-Year Review. Although
the employee is not rated in Mid-Year but the Mid-Year Review remarks will be available
during Annual Appraisal. This will serve as reference data allowing the Line Manager and the
Employee to carry out a more comprehensive Performance Review and development based
discussion

PROCESS FLOW DURING MID-YEAR REVIEW:

ANNUAL PERFORMANCE REVIEW:

Annual Performance Review permits the employees to review their accomplishments of the
year. The Annual PRIDE score of the employee along with the performance of the company,
forms the basis for the employee’s compensation revision and performance bonus pay-out.
Please Note: All employees joining before October 1, are eligible for Annual Performance Review
at the end of the current Appraisal Cycle. All employees, joining on and after October 1, will be
eligible for Annual Performance Review (Pro Rata) at the end of the subsequent Appraisal Cycle

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Timeline

Annual Performance Review will be initiated and completed between April – June. Annual
Performance Review, appraises the employee’s performance over the last Appraisal Cycle,
i.e., April 1 – March 31. All Increment and Promotion are effective from July 1, every year.
Performance Bonus is calculated for a period of 1 Appraisal Cycle, i.e., April 1 – March 31 but
disbursed with July’s salary, every year.

Explaining the Annual Appraisal Form)
The Annual Appraisal Form comprises of 4 Sections:

Goal Assessment Section – This section is to be completed by both, the Employee and the
Line Manager in Annual Appraisal. It comprises of the following:

I. Actual: The Employee is required to input his/ her actual achievement against
every goal. This should be a numeric input.

II. Evidence for Evaluation by Employee: This sub-section captures Employee’s
inputs on facts supporting his/her Actual achievement. The Employee may also
use this sub-section to build his case for effort moderation of performance rating,
in line with the effort rating guidelines (Refer 4.3), if his/her actual achievement is
less than or equal to the floor.

III. Evidence for Evaluation by Manager: Line Manager’s inputs on the actual
achievement of the Employee, against every goal is captured here. In case of a
Functional Goal, the Line Manager should get feedback from the Functional
Manager for appropriate assessment.

IV. Rating: This sub section captures the rating of the Employee against every goal.
The Rating for every goal is calculated as per the

Following formula:
Rating = (Achievement – Floor) * Weight / (Target – Floor), when Achievement > =
Floor. If Achievement < Floor, then Goal Rating = 0
The Total Weighted Rating is the sum of the individual Goal Ratings. The Total
Weighted Rating cannot exceed 110% (Refer 4.3).

Please Note: In an exceptional case, if a particular Goal is no longer valid for the
employee at the time of Annual Review, then the
Weightage for that Goal will be redistributed among the rest of the Goals in
proportion to their respective weightages, for the purpose
of calculating the PRIDE Rating.
V. Goal Assessment – Effort Moderated Rating: In line with the Effort Moderation
Guidelines (Refer 4.3), the Line Manager may propose to moderate the Goal Rating
of the Employee upwards/downwards. In case the Line Manager effort moderates
the Employee’s ratings, he/she will also be required to detail the factors
supporting the same, in this sub-section. For functional goals, moderation should

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be done in discussion with the Functional Manager.

All effort moderations are finalized only after approval by the Reviewer and the MRM/MCM
of the respective company. Hence, this sub – section will not be visible to the Employee
during Self-Assessment. Employee will be able to view this sub section only during the
Closure Stage, if his/her rating has been Effort Moderated and the same has been approved

Promotion Recommendation Section – This section is to be completed by the Line Manager
in discussion with the Reviewer only. The Employee will not have the viewing rights to this
section. The recent OMR data is to be used as an input. The recommendations should be
made in line with the Promotion Policy Guidelines, issued by Group HR. However, this
Promotion Recommendation by the Line Manager is only a nomination for the promotion
and should not be considered as final.

Strengths and Areas for Development Section – This section captures the Strengths well as
the Development needs of the Employee.

The Strengths are to be filled in by the Line Manager as well as the Employee.

The Areas for Development along with the Reasons for Development will be filled in by
the Line Manager in discussion with the Employee. These needs- categorized as
Functional, Technical, Behavioral/Leadership will be used as an input for preparing the
employee’s detailed
DAP.

Career Aspirations and Recommendations Section – Career Aspirations is to be completed
by the Employee and Career Recommendations are to be completed by the Line Manager, in
discussion with the Reviewer only. The Line Manager’s Recommendations will not be visible
to the Employee. The data captured in this section shall be used as an input for preparing the
Career Plan for the employee and for OMR. To ensure a holistic approach towards an
employee’s Career Path, Career Aspirations and Recommendations can be captured under 3
different heads of Job Rotation, Job Enrichment and Growth; it should not be associated with
only vertical career movement or promotions.

EFFORT MODERATION AND OVERACHIEVEMENT

What is Effort Rating?
Performance of an Employee against his/ her goals is rated on Actual Achievement. However,
in some situations (specified in the pre-approved List of Effort Scenarios; Refer Effort Rating
Guidelines), the Line Manager may moderate the rating (upwards or downwards) based on
the Efforts put in by the Employee, in line with the Effort Rating Guidelines.

What is Overachievement?
Overachievement is the way of recognizing the efforts of the employees who have surpassed
their targets and achieved beyond that. Overachievement of target, for a particular goal, by
the Employee is calculated automatically, since the Actual Achievement will be greater than

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the Target. Hence, the Calculated rating (as per formula) itself will be greater than the Goal
Weightage. However, please note, that all overachievement cases will be finalized after the
approval of the MRM/ MCM and the rating should not exceed 110% of the Goal weightage
(Refer Effort Rating Guidelines).

Effort Rating Guidelines
I. A pre-approved List of effort scenarios, prepared with the approval of the MCM/ MRM,

will be circulated by every company prior to the Appraisal process.

II. Effort Moderation can be upwards as well as downwards.

III. Upward Moderation: It is advised that the Rating against a goal be
moderated upwards by the Line Manager only when Actual
Achievement against a Goal is less than or equal to the Floor
Value

The non-achievement is due to an extraordinary factor, which was a
sudden,unforseen development severely affecting the achievability of the goal
This factor is covered in the pre-approved List of effort scenarios, prepared with the
approval of the MRM/MCM
The satisfaction of the above 3 criteria’s will only qualify the Employee to be
considered for Effort Rating. However, it does not guarantee upward moderation of
Rating.

IV.Downward Moderation: Penalty in the form of Negative Effort Rating can be applied if the
Goal was achieved through improper process, not in line with the company’s SOP or due to
external favorable conditions and there was minimal or nil employee effort involved. The
downward moderation of the rating can be done, irrespective of what the Actual
Achievement is. There is no cut off limit specified, to which the rating can be moderated
downwards. The Line Manager is required to use his/her judgement for the same.

V. All effort recognitions are to be audited by the HR Business Partners of the SBU/ Function
and finally by the HR Head of the company. All effort ratings that are not supported by
adequate data will be rejected at the HR audit stage. New scenarios or deviation from the
pre-approved effort scenario list, which are backed by supporting evidence, need to be
approved by MRM/ MCM, failing which such effort ratings will be rejected.

VI. Overachievement of Goals by individual Employees will be recognized within this, subject
to:
The Rating for that particular Goal not exceeding 110% of the Goal Weightage
The overall rating score of all the goals not exceeding 110%

VII. Upward Effort moderation should not exceed 10% of total Employee (who are eligible for
appraisal) population in each company. All cases, where Rating for even one (or multiple)
of the goals has been upward moderated, will be counted in the 10 % Employee
Population. This 10% Employee Population will not include cases of downward effort
moderation.

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PROCESS FLOW DURING ANNUAL PERFORMANCE REVIEW:

APPLICATION OF BELL CURVE

The evaluation of employee performance through PRIDE is an objective and quantitative
process. Hence, the Performance Ratings will not be normalized using a Bell Curve.

RPG TALENT ONE – DIGITAL PRIDE MODULE

PRIDE has gone online on our HR Digital Platform, RPG Talent One (SuccessFactors, an SAP
product), since FY 15-16 across Group Companies. All the above process steps are available
to employees during the set timeframe, i.e., Goal Setting from April – May, etc. For further
details on the online PRIDE Manual, kindly refer the PRIDE System User Manual available
with your respective SBU-HR or Corporate HR SPOC.

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For Officers & Executives

INTRODUCTION

Performance Review Process is applicable for employees at Pay Grade – “Officers/Executive”. The
Appraisal Cycle extends from April 1 – March 31 for the Financial Year (FY 2018-19).
Performance Review Process for comprises of 3 steps, which covers the entire Appraisal Cycle for an
employee. Each step is explained in detail in the subsequent sections.

Goal Setting Mid-Year Review Annual
Performance

Review

USERS OF THE PERFORMANCE REVIEW SYSTEM

Employee: Employee is the appraisee who is undergoing the Performance Review process.
Manager: The direct reporting manager of the Employee shall be his/her Line Manager. The Line
Manager will be the Appraiser of the Employee.
Reviewer: The Skip Level Manager of the Employee (i.e., the Line Manager’s Manager) shall be the
Reviewer. It will be the responsibility of the Reviewer to ensure that the Performance Review process
for the Employee has been done as according to the established guidelines, with objectivity and
fairness.

GOAL SETTING:

Goal Setting allows the employees to list their goals for the year, identify performance expectations
and the means to achieve the same. The entire process is to be carried out in discussion between the
Employee, the Line Manager and the Reviewer.

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TimeLine

For Officers/Executives, the Goal setting will be initiated in April and completed in May.

For employees who are transferred to new roles during the Appraisal year, a new Goal form should
be created. For employees joining on and after October 1, Goal setting option will exist and it is
mandatory.

Explaining the Goal form

The Goal form comprises of the two sections:

A. Performance Goals
a. Goal
Within this, the employee defines his/ her goals in the form of results that should be achieved in
the financial year.
b. Goal Category
There are 2 categories of goals. Every goal should belong to either of these 2 categories
- Business or Functional Goals
- Developmental Goals
Please Note: The Goal form can have a maximum of 7 goals and minimum of 5 goals, of which,
one has to be a Developmental Goal.
c. Measure:
A measure is a unit of key performance indicaor used to evaluate thee achievement of the goals

a. Target:
This 0is the level at which the goals needs to be achieved. For quantitative goals, target is set as
10.

d)Weightage:
Every goal has to be assigned a weightage based on its relative importance to the achievement
of company goals. The weightage for every goal should be between 10% (minimum) and 40%
(maximum). The sum of the weightages given to all goals should be equal to 100%.

f) Milestone:
Milestones are the steps/action points to achieve a goal. There is no limit to the number of
milestones one can add to a goal. Milestones are specific to the goal and are not part of
assessment. It only helps track the status. Please note, that this field is not a mandatory field.

Start and End Dates can be set for a goal and recorded on the system. Start and End dates are
specific to the goal and are not part of assessment. It only helps track the status. These fields
are not mandatory
Process Flow for Goal Setting

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MID-YEAR REVIEW

Mid-year Review is an opportunity for the employee to seek formal feedback mid-course so as to
ensure that Annual Goals are achieved. It aims to help the employee take course correction measures
and execute timely actions, if performance is lagging. It also helps to understand where the employee
stands with respect to his / her Annual Goals. This will guide the employees to decide how they should
focus their resources and time.
Please Note: Only the employees joining before October 1, will be eligible for the Mid-Year Review.

Timeline

Mid-Year Review will be initiated and completed between 1st October – 31st October.

Explaining the Mid-Year Review Form

The Mid-Year review form comprises of only the Goal Assessment Section. Within the Goal
Assessment Section, the employee needs to fill in the following:

a. Actual
Within this the Employee has to fill in his/ her actual achievement, so far. This should be a
numeric input. The Employee will not be rated during the Mid-Year Review. It is only for the
sake of discussion that actual numeric achievement may be recorded. The focus will be to
seek feedback on what is going on well, what needs to be continued and what should be
discontinued.
b. Employee Comments
The employee may support his/ her actual achievement against a goal wherever applicable,
by providing supporting instances, in the comments section. The employee may also use this
sub- section to highlight any difficulties or any support he/she may need to achieve the
concerned goal.
b. Manager Comments
Manager’s inputs on the employee’s achievements against a goal wherever applicable, are
captured in this sub-section.

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Modification of Goals during Mid-Year Review
Employee Goals for the year are finalised and locked once the Goals are approved by the Line-
Manager at the beginning of the performance year. It is only by exception and with the approval of
the HODs, that goals may be modified in a few cases, during Mid-Year Review
Impact of Mid-Year Review on Annual Performance Appraisal
Annual Performance Appraisal is in continuation to the Mid-Year Review. Although the employee is
not rated in Mid-Year, the Mid-Year Review remarks are available during Annual Appraisal. This
serves as reference allowing the Line Manager and the Employee to carry out a more comprehensive
Performance and Development based discussion
Process Flow during Mid-Year Review

ANNUAL PERFORMANCE REVIEW

Annual Performance Review permits the employees to review their accomplishments of the financial
year. The Annual Performance Review score of the employee along with the performance of the
SBU, forms the basis for the employee’s compensation revision.
Please Note: All employees joining before October 1, are eligible for Annual Performance Review at
the end of the current Appraisal Cycle. All employees, joining on and after October 1, will be eligible
for Annual Performance Review (Pro Rata) at the end of the subsequent Appraisal Cycle.

Timeline
Annual Performance Review will be initiated and completed between April – June. Annual
Performance Review, appraises the employee’s performance over the last Appraisal Cycle, i.e., April
1 – March 31. All Increment and Promotion are effective from July 1, every year.

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Explaining the Annual Appraisal Form

Please Note: In an exceptional case, if a particular Goal is no longer valid for the employee at the
time of Annual Review, then the weightage for that Goal will have to be redistributed among the
rest of the Goals in proportion to their respective weightages, for the purpose of maintaining the
overall weightage at 100%.
The Annual Review Form, comprises of 4 Sections:

Goal Assessment Section – This section is to be completed by both, the Employee and the Line
Manager in Annual Appraisal. It comprises of the following:

Actual: The Employee is required to input his/ her actual achievement against every goal. This should
be a numeric input.

a. Goal Assessment – Rating: This sub section captures the rating of the Employee
or the Manager against every goal (Refer 4.3).

• Rating by Employee: Employee is to choose the rating against every goal as
per his/her actual achievement against the target.

• Rating by Manager: Manager is to choose the rating against every goal as
per his/her actual achievement against the target. In case of a Functional
Goal, the Line Manager should get feedback from the Functional Manager
for appropriate assessment.

• Rating by Reviewer: Reviewer can approve the rating provided by the Line
Manager or provide a rating that is different from that of Line Manager.

b. Evidence for Evaluation by Employee: This sub-section captures documental
evidence supporting Employee’s Actual achievement.

c. Comments for Evaluation: This sub-section captures inputs on facts supporting
the Rating provided against the goal.

• Comments by Employee: Employee’s inputs on the actual achievement and
the rating of the Employee, against every goal is captured here.

• Comments by Manager: Line Manager’s inputs on the actual achievement
of the Employee, against every goal is captured here. In case of a Functional
Goal, the Line Manager should get feedback from the Functional Manager
for appropriate assessment.

• Comments by Reviewer: Reviewer’s inputs on the overall achievement of
the Employee captured here.

d. Effort Rating: In line with the Rating Guidelines (Refer 4.3), the Line Manager
may propose to moderate the Goal Rating of the Employee
upwards/downwards. In case the Line Manager moderates the Employee’s

65

ratings, he/she will also be required to detail the factors supporting the same,
in the comments section. For functional goals, moderation should be done in
discussion with the Functional Manager. All effort moderations are finalized only after
approval by the Reviewer.

Promotion Recommendation Section – This section is to be completed by the Line Manager
in discussion with the Reviewer only. The Employee will not have the viewing rights to this
section. However, this Promotion Recommendation by the Line Manager is only a nomination for
the promotion and may not be considered as final.

RATING GUIDELINES

A. Rating for Performance Goals: Every Goal is rated on a scale of 1 to 5, 5 being the
highest. The rating is dependent on the Actuals vs Target (% completion).
a. Rating 5 - Substantially Exceeds Expectations: Actual vs Target - 91% & Above

Performance levels and accomplishments far exceed normal expectations.
Performance truly stands out and the individual consistently demonstrates
exceptional accomplishments in terms of quality and quantity of work that is
recognized as truly exceptional.
Rating 4 - Exceeds Expectations: Actual vs Target - 75% - 90%
Performance frequently exceeds job requirements. Accomplishments are largely
above expected levels. Performance is sustained and uniformly high with thorough
and on time results.
Rating 3 - Meets Expectations: Actual vs Target - 65% - 74%
Performance fully meets all the requirements of the position in terms of quality and
quantity of work. It is described as good, solid performance. Minor deviations may
occur, the overall level of performance meets all position requirements.
Rating 2 - Below Expectations: Actual vs Target - 50% – 64%
Performance is noticeably less than expected. Usually performs to and meets job
requirements, however the need for further development and improvement is clearly
recognized.
Rating 1 - Substantially Below Expectations: Actual vs Target - Below 50%
Performance must improve significantly within a reasonable period of time if the
individual is to remain in this position. Employee is not performing to the
requirements of the job. Consider Performance Improvement Plans (PIP).

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PROCESS FLOW DURING ANNUAL PERFORMANCE REVIEW

APPLICATION OF BELL CURVE

The evaluation of employee performance through Performance Review Process is an
objective and quantitative process. Hence, the Performance Ratings will not be normalized
using a Bell Curve.

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68

Employee Seperation Policy

SEPARATION:

The purpose of the separation policy is to ensure a smooth exit and seamless documentation process
for the exiting employees. In this process we will also record valuable feedback regarding current
work practices from employees that are voluntarily terminating their employment with RPGLS.

* Retirement
* Resignation

RETIREMENT:

When an employee reaches his/her retirement age (58years), the HR department will communicate
the date of release to the employee and to Payroll/Accounts department atleast thirty days in
advance. Full and final settlement of dues will be done and given to him in his/her last salary.

RESIGNATION:

Process

• The employee must communicate the decision to separate, in writing, to the immediate
supervisor. Where the immediate supervisor is not available, the communication can be
tendered to the department head.

• The immediate supervisor should forward such request to HR with the comments and the
expected release date, which should be approved by the Department Head.

• HR will review the resignation request and decide on the acceptance of the resignation. The
employee will be formally communicated the acceptance of the resignation.

• The immediate supervisor/head of the department will plan a handover of the duties with the
separating employee.

• HR will process the exit formalities 3 days prior to the employee’s last work date with RPGLS,
which includes:

• Certify completion of handover from the department head
• Duly filled provident fund withdrawal/transfer form by the employee. The respective forms

are available with the Human Resource department.
• Certify that no dues are pending against the employees from the finance & accounts team
• Return of company equipment and property to respective owners i.e. IT Support and

administrative department.
• Complete Exit feedback by the Human Resource department.
• Employee is required to provide all pending investment proofs wherever applicable by the last

work date.
• The relieving letter and service certificate will be issued to the employee on the last work date

subject to the completion of the exit formalities mentioned above.
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• Final settlement for the employee will be processed by HR within 2 months from the last work
date of the employee with RPGLS. This will be subject to the completion of the leaving
formalities mentioned above.

• In the event of the exiting employee having an unused portion of his / per Privilege Leave, the
same will be encashed at the time of exit. Encashment of this leave will be on the basis of the
last drawn basic salary and in no circumstance will exceed 90 days.

Notice Period Recoverable Notice Period
90 Days
Management Level 60 Days
Chief Manager and above
Sr. Manager and below

Description Recoverable
Notice Pay Calculation basis Basic + Management Allowance

• Employees who have completed 6 months of service, are required to serve notice period as
per the above table

• Employees who are yet to complete 6 months of service, at the time of resignation, are
required to serve notice period of 15 days.

• If an employee fails to serve the requisite notice period, as mentioned above, the notice pay
shall be deducted from the final settlement.

Leave Encashment

Description On Resignation On Retirement
Basic
Leave Encashment Calculation basis Basic

FAREWELL:

Retiring Employees

For all management staff:

• Certificate of appreciation
• Gift worth (Officers & Executives – Rs. 5000/-, Asst Mgr & above – Rs. 10000)
• Departmental Snack Party from the Department and HOD and Location Head

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Resigning Employees

Minimum 5 years of service and above:

Officers & Executives Managerial Cadre VP & Above

• Gift worth Rs.1,000/- • Gift worth Rs.3,000/- • Gift worth Rs.10,000/-
• Departmental Snack Party for the
• Departmental Snack Party • Departmental Snack Party resigning member along with the
• staff from the Department and HOD
for the resigning member for the resigning member and Location Head.
All arrangements to be made by the
along with the staff from the along with the Staff from Location HR

Department the Department and HOD

• All arrangements to be made and Location Head

by location HR • All arrangements to be

made by Location HR

*Exceptions to above should be approved by MRM

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72

Gift and Entertainment Policy

Purpose

This policy provides for the standards and limitations governing the acceptance of entertainment and
gifts by an employee, celebrations of employee milestones at office & liquor consumption on official
work.

Eligibility

This Policy is applicable to all the employees, trainees & retainers of RPG Life Sciences Ltd.,

Policy Coverage:

1. Gifts Acceptance
2. Birthday /Farewell Celebration
3. Liquor Guidelines

Gift Acceptance Policy

The GIFT POLICY defines the nature of gifts and circumstances under which the gifts can be accepted.
The cardinal principal would be that the gifts should not be received either to obtain favors/
preferential treatment or in returns of favors/ preferential treatment.

Regardless of the circumstances, employees are generally prohibited from soliciting of gifts,
particularly those which are valuable and have resale value.

• Any such gifts or entertainment should be politely declined and returned to the sender in a
timely manner. In circumstances where it would be awkward to return such a gift, the gift
should be handed over to HR for appropriate disposition.

• However employees may accept gifts of nominal value / corporate merchandises (e.g. pens,
calendars, edible items, etc.).

• Privileges like vacations, cash equivalents, discounts, etc, from any business partner are also
prohibited (except those offered to employees of RPG Life Sciences under corporate plan).

Birthday Celebrations

As a customary practice at RPG Life Sciences, common Birthday celebrations are to be done once a
month at respective location for all the birthday’s falling within that month. Such events can be
organized with cake & refreshments, within reasonable limits.

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Liquor Policy
As an organization, we strictly disallow the practice of having liquor with customers or during internal
team meetings. However, incase consumption of liquor becomes essential in exceptional business
scenarios with some customers / business partners or at annual conferences, then the respective
MCM member will have the authority to approve the same.
In addition to this, consumption of liquor in office during or post work hours, storing liquor in office
and coming to office post consumption of liquor is not allowed as per company guidelines and the
company will take strict actions on individuals indulging in the same.
If an employee has any doubt about whether it is appropriate to accept a certain form of
entertainment or gift, you must promptly disclose the situation to your Supervisor or a HR Manager
and seek appropriate guidance before taking any action.

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75

Virtual Work Place

(Effective Date: December 22, 2016)

Scope
In line with RPG Group Vision, we are pleased to introduce Virtual Work Place policy. The intent of
this policy is to enable employees to strike balance between personal exigency and work.

Applicability
Applicable to all employees based at RPG House, Navi Mumbai & Ankleshwar Plant. The following
work group employees will not be eligible for Virtual Work Place:

• Employees engaged in Manufacturing process
• Those employees whose job profile requires external customer interface & need to be

physically present at work place.
Reasons that could demand VWP include but are not limited to:

• New moms
• Men/women who have developed mobility constraints due to serious illness
• Employees returning back early morning from International / Domestic Trip
• Has some personal exigency for few hours during the day
• Unable to travel to office due to some minor illness

Guidelines
• Respective Departmental Heads in consultation with respective MRM to define the norms for
working virtually without impacting the business.
• VWP can be availed only 2 days in a months with prior approval of reporting manager
• VWP cannot be accumulated or carry forwarded to next month.
• Employee who wishes to avail VWP and are currently being provided desktops are requested
to consult their departmental head / IT department for providing necessary access/usage of
their personal laptop/desktop.
• Depending on the nature of work / business exigencies, the reporting manager has sole right
to reject VWP.

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• Employees on VWP will be governed by terms and conditions in letter of appointment
outlining the employment policy/ contract agreement/ code of conduct.

• New moms and those employees who have developed mobility constraints due to serious
illness can avail VWP only for a maximum period of 60 days. Such employees may be called
to RPGLS premises if presence is required on need basis. Travel reimbursement for these visits
would be paid only in case of employees have to travel to different locations as per existing
travel policy

Process
• Employee will put an application in the prescribed format to the reporting manager and
submit necessary documentation like medical certificate.
• Manager will evaluate the case based on employee role and forward the case to concerned
MCM for approval.
• Manager ensures following on approval
- Inform HR
- Informs concerned employee and get the undertaking signed
• Forwards the signed undertaking to the HR
• RPGLS to provide laptops, data card for easy mail communication as well as access to server
• Mobile bill shall be reimbursed for official communication (itemized bill needs to submitted)
• Incase its required that the person needs to visit office / factory premises once in 15 days for
feedback and reporting purpose to his superiors, it’s possible only if employee is in a position
to travel.

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Objective

The Company is committed to ensure compliance of all the applicable laws, Code of Corporate
Governance & Ethics adopted by it and policies and procedures framed by it from time to time, by the
Dirctors and employees of the Company.

Purpose of this policy is to provide a framework through which all the Directors and employees report
their genuine concerns and actual / potential violations to the designated officials of the Company
fearlessly, as provided in Section 177 of the Companies Act, 2013 and Rules made thereunder.

Who can report?

Any whistle-blower among the employees and directors of the Company can report genuine concerns
and actual or potential violations.

Concerns / violations that can be reported

• Deliberate or unintentional noncompliance of the applicable laws,
• Improper and unlawful practices,
• Cases of frauds,
• Financial and accounting irregularities,
• Misappropriation of Company’s funds,
• Violation of Code of Corporate Governance & Ethics inter-alia non-disclosure of conflict of

interest or indulging in insider trading.

Lodging of Complaints

Complaints on the matters listed at paragraph 3 above, including anonymous, can be directly
reported/ lodged with the following officials:

Name : HN Singh Rajpoot
Address : 213, Bezzola Complex, B Wing,
Sion-Trombay Road,
Phone No. Chembur, Mumbai,
Mobile No. Maharashtra, India
Email id PIN: 400 071
: +912225292155
: +917506337790
: [email protected]

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Investigation Procedure:

• All the complaints received by the designated official as above shall be logged and
thereafter shall be forwarded to the Corporate Governance & Ethics Committee
(CGEC).

• CGEC may at its discretion appoint an Investigation Agency (IA) or ask the Group
Assurance & Internal Audit (GAIA) to investigate such complaints. The IA or GAIA shall
investigate and hear the parties, as may be needed, after due notice, and shall file its
Closure Report or Investigation Report to the CGEC within two months of its appointment
or such other extended time allowed by the CGEC.

• On receipt of the Closure Report or Investigation Report, the CGEC shall recommend
action as it deems fit after considering the Closure Report or the Investigation Report
and other relevant and material facts placed before it.

• CGEC will send a copy of the Complaint, Closure Report or Investigation Report and
the suggested actions to be taken to the Chairman of the Audit Committee for
consideration.

• CGEC shall also declare to the Audit Committee that the person engaged for carrying
out investigation is not a whistle blower or complainant.

• The Chairman of the Audit Committee shall place the recommendation(s) of CGEC
before the meeting of the Audit Committee for consideration. The Audit Committee
may:
- Either accept the recommendation of the Audit Committee for
implementation / taking suitable action, if it finds that no further
investigation is required on the complaint,Or order a further investigation
thereon, and
- Take such action on the complaint as it may deem fit, based on the
finding(s) of the further investigation.

• In case of conflict of interest between the Audit Committee members, the
remaining members of the Audit Committee shall deal with the matter.

• The Company Secretary shall revert to CGEC about action taken by the Company
under (f) above.

Protection and Safeguards:

Both CGEC and the Audit Committee shall ensure
• Protection of complainant/ witness, if any, against any harassment and victimization
• Protection of the complainant identity
•

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Frivolous Complaints:
Audit Committee shall take suitable action against the complainant for any frivolous
complaint.
Miscellaneous:

• All the relevant documents namely complaint or the gist of oral complaint, as the case
may be, information/ document obtained during the investigation as evidence,
including from witness, if any shall be fully secured to avoid any tampering and shall
be preserved for a period of 2 years.

• In exceptional cases as may be decided by CGEC after considering the facts of such
cases, the whistle blower / complainant shall be provided direct access to the
Chairman of the Audit Committee.

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82

(Effective Date: December 22, 2016)

Purpose:

To describe the procedure to be followed to deal with negligence in performing duty at work
place. RPGLS is in the business of producing lifesaving drugs. The negligence in performing
routine job/duty by any employee has a direct or indirect impact on the output/quality of the
drugs produced by the company. This policy is prepared to deal with any situation where the
incident is outcome of negligence by an employee in performing his/her routine job/duty and
to enforce discipline at work place.

Scope:

This policy is applicable to all employees at all sites of RPGLS as well as corporate office.

Responsibility:

Departmental Heads: To provide training on the SOP to all employees in the department and
to ensure compliance to the SOP.
Head – HR: To ensure compliance to the SOP.
Chief Quality Officer: To approve the SOP and control the distribution.

Definition:

Negligence at workplace means failure of an employee to perform his/her job/ duty due to
negligence and not because of system failure.

Minor negligence- Negligent act that causes one or all of following –

• Duplication of documentation
• OOS
• Product repacking
• Reanalysis

Major Negligence-

A negligent act that causes one or all of following –
• Loss of business
• Loss of customer
• Bringing disrepute to company

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• Missing delivery target
• Causing injury to self or fellow employee
• Loss in productivity
• Noncompliance to regulatory norms
• Audit failure
• Dispatch of substandard product to market
• Product recall
• Legal implications to company

Procedure:

• During an investigation into incident, if the root cause is identified as negligence by
employee in performing his/her job/duty then the report will be forwarded to Head -
HR. The report should indicate the name of the employee responsible for negligent
act.

• The Head – HR shall verify the correctness of the report by discussing with the
concerned department head or any other person he feels necessary.

• The Head - HR then assess the type of action required to be taken for the employee
based on the incident the action could be “show cause notice”, “warning letter”,
“suspension letter” or “Termination letter”.

• For minor negligence a show cause notice will be issued asking for an explanation
from employee. If explanation is not found satisfactory a warning letter will be
issued.

• In the event three warning letters are issued to same employee the action as per
major negligence will be initiated.

• For a major negligence HR Head will initiate action in consultation with department
head and MRM. The action will include one of the following –

• Temporary suspension
• Termination of service

Location HR head will keep a record of such actions in his file and provide the report to
Head – HR to track repeat action or as an when required by Head - HR

84

&CGCOOOERDVTPHEEORIOCNRFSAATNECE For Queries & Suggestions write to:
Corporate Governance & Ethics Committee
(Version 4.0) Email: [email protected]
July 1, 2018

CHAIRMAN’S FOREWORD

The RPG Group has always stood for conducting business responsibly
and ethically. The purpose of laying down the Code of Corporate
Governance & Ethics is to clearly outline the principles of corporate
governance that will apply in managing the a airs of our Group.

Personal responsibility and integrity is intrinsic to this Code. While we
have ensured that the Code adheres to the various provisions and
regulations of good governance, it is also true that integrity is a deeply
personal quality and each one of us must take responsibility for the
same. Integrity is a matter of attitude, a way of life that is
non-negotiable. To me, it is not just about obeying the law, thereby,
making it our duty at all times.

I would urge you that whenever you are in doubt about any matter that
may have an ethical implication, you should seek guidance from the
Corporate Governance & Ethics Committee (CGEC).

We are now publishing the 2018 version of the Code, which has
been updated to ensure greater clarity and sharpness with regard to
certain legal requirements.

I request all members of the RPG Group to familiarise themselves with
the contents of the Code. Let us adopt the Code as a template to guide
our daily behaviour, thus helping RPG retain its position as a truly great
institution, which we are all proud to be a part of.

H. V. Goenka

Chairman, RPG Enterprises

July 1, 2018

OBJECTIVES & MONITORING
OF THE CODE

The RPG Code of Corporate Governance & Ethics shall be
observed by every employee in letter and spirit, in all the
companies in the group (the Company).

The Company has set up the Corporate Governance & Ethics
Committee (CGEC) which shall act as a central body for
monitoring this Code.

Any employee or business associate of RPG Group Companies
may represent any suggestion, complaints or report matters of
violation of this Code.

The CGEC can be reached on their email [email protected] or via
their postal address which is:

Corporate Governance & Ethics Committee (CGEC)

RPG Enterprises
C/O CEAT Limited
208/213, 71-Sion-Trombay Road
Chembur
Mumbai – 400 071.

TABLE OF
CONTENTS

01 Definitions
05 Investor Relations
08 Financial Reporting & Records
10 Quality of Products & Services
12 Communication with Media
14 Social Media
16 RPG Logo / Letterheads
18 Ethics
59 Competition
61 Political Non-Alignment
63 Protecting Company Assets
65 Donations
67 Corporate Citizenship
69 Co-operation of Group Companies
71 Compliance with the Code
73 Equal Opportunities
75 Third Party Representation
77 Regulatory Compliance
79 Securities Transactions & Confidential Information
83 Integrity of Data Furnished
85 Whistle Blower Mechanism

1 DEFINITIONS /
INTERPRETATION

“Chief Executive O cer” or “CEO” means the Business Head of the concerned
RPG Company by whatever name called.
“The Company” or “RPG company” used in this Code means a company forming
a part of or a liated with the RPG Group, either by a licensed agreement or
otherwise.

01

“Confidential Information” shall comprise any and all types of proprietary and
confidential information, whether furnished in writing, or electronically, but not
limited to,

Inventions, discoveries, developments, improvements, trade secrets, 1
know-how, ideas, techniques, designs, processes, formulae, data and 2
software, manufacturing process and recipes for products 3
(collectively, "Inventions") 4
5
Plans for research, development, new products, marketing, acquiring 6
and selling 7

Budgetin, financial information and tax planning measures

Production and sales information including prices, costs, quantities and
information about suppliers and customers

Information about business relationships, potential joint ventures and
other business deals being negotiated

Information about skills, compensation of the employees and
consultants of any RPG Company

Confidential or proprietary information of a client or supplier provided
to the Company by such client or supplier in the course of and for the
purpose of its business dealings with the Company. Confidential
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software, manufacturing process and recipes for
products (collectively, "Inventions"),

02

“Companies Act” shall mean the “Listing Agreement” means the
Companies Act 2013 or the listing agreement entered into
Companies Act 1956 to the extent between the Company and the
that the respective provisions are Stock Exchange(s) for listing of
in force as amended or modified the securities of the Company
or replaced from time to time. with the Stock Exchange.

“Code” refers to this RPG Code of “Listing Regulations” means the
Corporate Governance and Ethics,
Version 4.0 Securities And Exchange Board of

“CGEC” refers to the Corporate India (Listing Obligations And
Governance & Ethics Committee.
Disclosure Requirements)
“Company Secretary” means a
Company Secretary, as defined in Regulations, 2015, as amended
the Companies Act, 2013,
employed by an RPG Company. from time to time.

“Employee” or “RPG employee” “Relative” of an employee or a
shall mean all the employees of an director or any other person for
RPG Company. the purpose of this Code shall
mean the relative as defined in
“Insider” means any person who the Companies Act 2013 and or in
is in possession of or having the Listing Regulations and/or the
access to insider information (as Listing Agreement, as amended
defined under this Code) or any from time to time, as may be
person who is a “connected applicable.
person” as defined under
Regulation 2(d) of the SEBI “Close Relative” of an employee
(Prohibition of Insider Trading) or a director or any other person
Regulations, 2015. for the purpose of this Code shall
mean ‘immediate relative’ as
defined in the SEBI (Prohibition of
Insider Trading) Regulations, 2015

03

“Related Parties” to an RPG Company shall mean the related parties as
defined in the Companies Act 2013 and/or the Listing Regulations
and/or Listing Agreement, as amended from time to time, as may be
applicable.
“RPG Enterprises” means a Company incorporated under the provisions
of Companies Act, 1956 having its registered o ce at RPG House, 463,
Dr. Annie Besant Road, Worli, Mumbai 400 030.
“RPG Group” means a conglomerate comprising of various companies
who have been licensed or permitted to use the RPG logo whether as a
copyright or a trademark in the course of its business.
“RPG logo” means any logo or device which incorporates the
letters/trademark “RPG” as a part thereof, as may be decided by RPG
Enterprises from time to time.
Words importing the masculine gender also include the feminine,
transgender and neutral gender.
Words importing the singular number include, where the context admits
or requires, the plural number and vice versa.

04

2 INVESTOR
RELATIONS

Background

Enhancing shareholder value is the primary objective of any
company. With increasing competition for scarce capital, it is
important that shareholders are provided with services that
compare with the best in business. These guidelines aim to
achieve shareholder satisfaction.

05

Guidelines

Investor relations should be ethical, professional, transparent and investor
friendly.

Relevant and accurate information should be disseminated and must be
accurate and not misleading. It shall be informative to meet the needs of
shareholders.

Respond to the queries and observations of the shareholders to the
fullest extent permissible.

No information shall be made available on a selective basis to specified

groups of investors. Handling price sensitive information before it

is made public:

All directors and employees
of the Company shall,

Maintain the confidentiality of all un-published price
sensitive information and shall not pass on, directly or
indirectly, such information to any person with and without
making a recommendation for the purchase or sale of
shares of the Company or otherwise

Keep secure all files/papers containing confidential
un-published price sensitive information

Handle the unpublished price Sensitive Information(s) on
a “need to know” basis, i.e. such information shall be
disclosed only to those persons within the Company who
need the information to discharge their duty and whose
possession of such information will not give rise to a
conflict of interest or appearance of misuse of the
information(s).

06