Code of Ethics & Conduct Policy

"I would like to make it clear to all that the Company does not support adoption of any kind of unethical practices, even if it is with an intent to meet the Company’s (not individual’s) objectives. Such reasoning, if applied, is not acceptable to the Company and no employee has the right to take such decisions on its behalf."

Dear Stakeholders

While setting our core values, one value and ethic was unanimously accepted without any debate. Ethical behavior needs to define everything that we do and it is something that we need to not just practice quietly, but demonstrate pro-actively to all our stakeholders; be it employees, contract employees, channel partners, suppliers or any other stakeholders.

Since the definition of ethical behavior can be a point of discussion, we have now defined a Code to be our guideline. I would encourage every stakeholder of the Company to take out time and carefully read this Code. It is also our responsibility to ensure that this Code reaches all stakeholders that we are responsible for, such as channel partners and suppliers. Remember that ignorance of the Code will not be treated as reason for not following it. This Code is designed to be a guide in making decisions that will properly reflect our fundamental principles, and the practices that follow these ideals. It is our duty to ensure that our behavior, attitude, and the decisions we make live up to the principles and core values that govern this Code.

We are a new company and work in a tough environment. The temptation to cut corners may present itself, be it on a personal level or in the interests of the Company. I would like to make it clear to all, that the Company does not support the adoption of any kind of unethical practices, even if it is with an intent to meet the Company's (not individual's) objectives. Such reasoning, if applied, is not acceptable to the Company and no employee has the right to take such decisions on its behalf.

Along with individually practicing ethical behavior, it is equally important to report any violations that are witnessed. Remember, in case you are witness to any violation and do not report it, you are also in violation of the Code. So, it is mandatory to report any violations.We will practice ethical behavior as per this Code, not because the penalty on getting caught is prohibitive, or it will do irreparable damage to our reputation. Though these are also reasons, we will practice it primarily because our conscience tells us that it is the right thing to do and we are proud to work for a company that works in the correct way, and deserves the success that it achieves.

And in this pursuit, I know that each and every one of you will uphold it with full commitment and passion.

Krishan Sachdev

Managing Director

Purpose

Decisions at Carrier Midea India Private Limited are to be made solely in the dealings or relationships in connection with the best interest of the Company, following an objective evaluation of business considerations such as quality and performance to implement Carrier Midea India's core values. Meeting this standard depends on the consistent use of high ethical standards and personal integrity by employees when making decisions on behalf of Carrier Midea India.

Every employee is responsible for demonstrating integrity and leadership in complying with the provisions of this Code of Ethics and Conduct, Company Policies and applicable Laws and Regulations. By including a focus on integrity, we show our commitment to a business culture that promotes the highest ethical standards.

Scope

This Code of Ethics and Conduct applies to all employees, contractors, vendors, dealers, and suppliers of Carrier Midea India and its branches, including the Company Officers and Directors. It applies to Administrators and Company Representatives, according to applicable Laws. Copies of the Code will be available at the Human Resources Department or at the Legal Department, for all employees and entities that are authorised to act on behalf of the Company in areas where the Code is applicable. Administrators, Officers and Directors will be required to sign a Statement of Compliance annually, in addition to this Code. The Directors are responsible for communicating these standards to those who work under them, ensuring that they are understood and observed.

Disciplinary Action

The Company has a "zero tolerance" policy for non-compliance with the Code. Carrier Midea India employees who violate the Code are liable for disciplinary action up to the termination of employment and criminal prosecution, depending upon the severity and frequency of the violation.

No Retaliation Policy

No retaliation will be taken against anyone for complaining, reporting, participating in, or aiding with the investigation of a suspected violator of the Code, unless the allegation or the information provided shall prove intentionally fraudulent. Carrier Midea India will maintain confidentiality of all concerns raised to the maximum extent possible.

Definition

"Applicable Laws" or "Laws" means any national or local law (statutory or otherwise), constitution, treaty, convention, Code, rule, regulation, order, judicial interpretation, policy or other similar requirement enacted, adopted, promulgated or applied by a governmental authority that is binding upon or applicable to the shareholders and/or the Company, as amended unless expressly specified otherwise "MID" means Midea International Division; "CMI" means Carrier Midea India Private Limited and also referred as "Company" Carrier Midea India Private Limited, a private limited company incorporated under the Companies Act 1956, having its registered office at First Floor, Plot No. 51, Sector 32, Gurgaon, Haryana -122001 (also referred to as the "Company", which expression shall, unless repugnant to the context or meaning thereof, be deemed to include its successors, legal representatives and permitted assigns; "Carrier" means Carrier Corporation, a company duly organized and existing under the laws of the state of Delaware, USA, with its main office at One Carrier Place, Farmington, Connecticut, USA; "UTC" means United Technologies Corporation, a public company incorporated under the laws of the state of Delaware, United States of America and having a principal place of business in Hartford, CT, USA. "CMI Values" collectively means Customer Focus, Respect, Agility, Ethics and Innovation.

Effective

The Code shall become effective as of 17th June 2013, subject to clarification and updates by the Company regularly.

Our Commitment to Open and Respect

At CMI, we commit ourselves regarding the relationship with our colleagues as open and honest communication, trust, and mutual respect. Based on this commitment, encourage your colleagues to think creatively and innovatively, and if you are a leader, giving your team the freedom they need to carry out their job functions, give constructive suggestions on how they can improve their performance and be open to take feedback from them.

Your relationship with your supervisor should be based on mutual respect and trust. Employees and managers make teams that share common goals and objectives. Whenever possible, take the initiative. Be innovative in fixing problems. Your cooperation and creativity are essential to achieving the goals of your business unit and of the Company.

To manage the people, CMI commits to:

  • Recruit, train, and compensate all CMI employees based on the skills required for the job they do, with no discrimination related to race, religion, origin, ethnicity, skin color, gender, sexual identity, age, citizenship status, sexual orientation, marital status, disability or any other characteristic protected by law.
  • Reject child labor employment.
  • Maintain a work environment that promotes integration and strives for excellence, attracting and retaining the best people for our Company.
  • Facilitate employee education and create opportunities for career development and progression for all CMI employees.
  • Conduct performance appraisals that provide employees with open and precise feedback to encourage bilateral participation and keep track of personal development plans.
  • Recognize and reward individual and team contributions that go beyond the normal scope of their job functions through a reward plan.
  • Be vigilant in preventing and addressing sexual, moral or any other type of harassment of CMI employees by anyone in the workplace or in the course of any Company negotiations.
  • Reject favoritism or suspected favoritism in the workplace, according to the Company policies and procedures.
  • Respect the privacy of individuals, collecting employee personal information for processing, storage and use only according to business needs and in compliance with the laws of the countries where we operate.
  • Seek to eliminate potential hazards in the workplace and provide a safe and healthy work environment to all CMI employees, complying with all the laws and regulations associated with health and safety in the workplace.
  • Help to maintain a secure, healthy and productive work environment for all of CMI employees and third party contractors, by prohibiting the following:
    • The possession, utilisation, sale or transfer of illicit drugs, Cigarettes & Tabaco Product in all premises of Company including factory.
    • The performance of work duties under the influence of alcohol.
    • The possession of firearms or ammunition within the Company premises or while conducting business for CMI.

Our Commitment to the Human Rights

MID is committed to respect human rights worldwide. To that end, the Company adopts the following standards and seeks partners who equally believe in:

  • Equal opportunity for employees in all grades, independently of skin color, race, gender, sexual identity, age, ethnicity, nationality, sexual orientation, marital status, disability or any other characteristics protected under the law;
  • Secure and healthy workplace where human health and the environment are protected;
  • The payment of employee compensation that will respect local laws being fair according to the employee´s skills and the function to be performed in the Company, in addition to providing opportunities to improve their competencies and skills;
  • Respect for employees' right to legal association; and
  • Cooperation with governments and communities where we do business, so as to improve the level of education, culture, economy, and social welfare of these communities.

As CMI employees, we do our best to comply with Company policies. At the same time, we acknowledge our responsibility and the trust placed in us, and we act with integrity in all circumstances to honor this trust. We protect Company assets and against all conflicts of interest, and other situations that may adversely affect the Company interests.

Conflict of Interest

Purpose

Employees must avoid personal interests or financial activities that conflict, or appear to conflict, with CMI's interests or that influence, or appear to influence, their judgment or actions in performing their duties as employees. Such conflicts may arise in a number of situations. It is not possible to cover all of them in this Code nor will it always be easy to distinguish proper conduct from improper. If you have doubts about any situation, ask your supervisor or the Legal Counsel, HR Head, or the BPO of CMI before you take action. The following guidelines apply to common situations where there is a conflict of interest

Relationships with suppliers, dealers, customers and other business partners

Any employee who owns or acquires, directly or indirectly, an interest in any concern regarding the procurement of goods or services, or competing with the Company, sales distribution with dealers or other business partners, is required to disclose the full detail concerning such interest or relationship. In such circumstances, a conflict may arise if such employee is in a position to influence decisions with respect to any Company transaction involving a business partner; if his or her other interest or relationship is such that it might bring into question his or her continuing ability to make impartial judgment in the Company's best interest. Before you investing, you should seek advice of Legal Department) or HR Department or the BPO of the Company as well as your manager and obtain prior written approval.

Investment

Do not make any investments that might influence your business decisions. The Company Policy prohibits CMI employees from owning stock or share of competing companies or companies in the same industry as MID subsidiaries and Midea. This prohibition does not apply to small amounts of stock (typically less than 5 percent) in publicly-held companies, so long as the amount invested shall not be so significant that it might create a conflict of interest. If you made potentially prohibited investments before joining CMI, please notify the Legal Department or the HR Department of this fact immediately.

Family

Notify your supervisor and obtain approval from your Head of Department and the Legal Department/BPO of the Company before you start negotiations on behalf of CMI with any company where, you, a family member, or friend has an interest that might in any way benefit from your actions or their actions.

Side jobs

Do not work for a competing company while you are working for CMI. Do not do any type of work for third parties or give assistance to third parties that might adversely affect your business decisions in CMI. Do not use Company time, facilities, assets or materials of the Company to do "side jobs" which have no connection to your job at CMI, without authorisation from your immediate supervisor.

Personal Relationships

Although the Company recognises and respects the right of CMI employees to associate freely with their colleagues, we should equally use common sense to ensure that any relationships with our colleagues will not have a negative impact on the performance of our job functions, on productivity, on our ability to supervise third parties, or on the work environment.

Any workplace conduct arising out of a personal relationship between employees may be inappropriate if such conduct should generate an unpleasant work environment for other colleagues. Showing favoritism toward someone or making business decisions based on emotions, fidelity, or friendship rather than the best interests of the Company is forbidden. Individuals should be sure to employ tact, common sense, and respect when proceeding to engage in a personal relationship with a colleague.

Be aware that any member of your family holding a position in the Company could create or seem to create a conflict of interest. Should a situation like this arise, ask your HoD or the l legal department or the HR department for advice.

Participation in the Board of Directors of Other Organisations

Obtain approval from the Board of Directors, before joining the Board of Directors or a similar group in any other company or government agency.

Protection of Company Assets

Purpose

Proper use and control of tangible and intangible assets is important to the success of our company. All CMI assets are to be protected against improper or random use to fulfill our duties to CMI. Therefore, employees shall strive to protect the Company assets as a whole and have the responsibility to protect CMI property in any situation or incident against theft, loss, abuse, embezzlement or unauthorised use, unauthorised access or damage to the Company.

Protection of intangible assets: Company-Private/Restricted Information

Trade secrets of MID/CMI/UTC/Carrier midea, as well as other company-private/restricted information and the majority of company internal data are valuable assets. The protection of these assets, including the maintenance of its confidentiality, plays a vital role in our continuous growth and in our ability to compete. Trade secrets are information pertaining to Midea and/or Carrier midea that are not in public knowledge and should not be communicated outside the company. There is, however, other company-private information such as technical data that must be equally protected.

Carrier Midea India's trade secrets and other company-private information includes, but are not limited to, formulae, concepts, devices or any information utilised in our business, which give the Company a competitive advantage with our competitors. Carrier Midea India's Trade Secret(s) are collectively referred to as CMI's Trade Secret(s). Trade secrets and other company-private information are not exclusively technical in nature. They may include information from business investigation, new product plans, strategic goals, financial information, unpublished pricing strategies, lists of sales people, customers and employees, and information about customer requirements, preferences, commercial traits and plans. Although this is not intended to be an all-inclusive list, it suggests the large variety of information that must be safeguarded.

Your duty with regard to CMI's Trade Secret(s) and other company-private/restricted information is:

  • Do not release company-private information to other CMI employees unless they have a justified "need to know" or "need to use" with business reasons;
  • Do not release company-private information to people outside of CMI without proper authorization;
  • Do not utilise company-private information for your own benefit.

Even if you should leave the Company, your duty to protect CMI's Trade Secret(s) and other company-restricted information remains until the information becomes public or CMI no longer consider it to be a trade secret or company-restricted.

One must also bear in mind that CMI's correspondence, printed documents, electronically stored information, documents or logs of all kinds, process specific knowledge, procedures, special production methods, confidential or not, are company property and should remain in the Company. Evidently, personal skills, acquired or developed while performing your job function are personal property. If you have any questions whether some information is company-restricted in nature or CMI's Trade Secret(s), you should see the Legal Department for clarification.

Responsible Utilisation of IT Resources

We all must utilise the Information Technology resources (referred to as "IT Resources") of CMI responsibly and consistently with Company policies, including policies specific to IT technologies, data protection, company-private/restricted information, and intellectual property rights. CMI IT Resources include all owned, used or leased computer systems of CMI, independent of the physical location, including, but not limited to, PCs, portable devices, network servers, internet access, Midea's intranet, and e-mail access devices. All information communicated through voicemail and other voice systems, facsimile equipment, telephones, instant messaging and information obtained or transmitted and/or communicated over the Internet and the intranet of Midea is also considered part of the Company's IT resources. All IT resources are property of CMI, including all information created, stored or transmitted via the IT resources of the Company. The only information that is not considered to be property of the Company is that obtained during the personal, limited utilisation of the IT Resources of CMI when authorised by the Company or information considered public according to applicable law and regulations.

CMI's IT Resources must be utilised solely for business purposes of the Company, except if limited personal utilisation is authorised by the Company.

  • Messages of harassment, discrimination, defamation, fraud or threat, including offensive messages regarding race, gender, age, sexual orientation, religion, political ideals, nationalities, physical incapacitation, ethnics, sexual identity or any other characteristics protected under applicable law.
  • Sending, accessing, storing, or communicating offensive or obscene matters in any format.
  • Unauthorised distribution of Company-private/confidential information, or CMI's Trade Secret(s)
  • Causing or allowing security breaches or interruption of the network communication, and/or the unauthorised disclosure of your password/pass-phrase to a third party.
  • Violation of any person's or company's rights protected under intellectual property laws, such as, trademarks, trade secrets, patents or any other right under similar laws or regulations.
  • Violation of privacy rights of any person under applicable law.
  • Soliciting on behalf of any external organisation, enterprise or cause unrelated to Midea 's business including, but not limited to, any commercial, religious or political organisation or cause.

Except when limited by applicable laws, CMI reserves the right to monitor the equipment, systems, and activities on the network, including but not limited to email, voice mail, internet utilisation and any information stored under appropriate circumstances and according to applicable laws. Additionally, in order to meet the maintenance, safety, commercial, legal and regulatory requirements of operations, authorised personnel and third party service providers have limited access to the information stored in the IT resources of CMI to the maximum extent permitted by law. CMI reserves the right to limit access of any user to the IT resources at any time, with or without previous notice.

Media Requests for Information

The media or public sometimes requests information about CMI financials. All such requests are to be directed to the authorised person of CMI who has been designated as company officer to handle the press and/or public communications, or any person who has been authorised by the Managing Director of the Company, and such disclosure information should be approved by the relevant department of CMI according to its policy. No one else is authorised to directly respond to these requests for information.

Every one of us is responsible for the image that we convey to suppliers and customers. It is of the utmost importance that we maintain our reputation through the honesty and the fairness with which we negotiate with these groups.

Ethics and Supplier/Customer Relations

Our purpose is to ensure continuous and reliable sources of supply. It is essential to conduct honest negotiations with customers and suppliers to maintain strong, lasting relationships with them. As a consequence, we regard our suppliers as partners and we expect them to realise reasonable profits in our dealings together. We consider all prospective suppliers in a manner that is fair and consistent, making our decisions based on objective criteria such as price and quality, in addition to the supplier's reliability and integrity. We treat every customer with the same business criteria. Giving or taking a "kickback" or payment of any kind as a means to secure business is forbidden which addresses our responsibility to comply with anti-bribery, competition, and anti-trust laws under Part 4.

Respect for Third Party Intellectual Property and Confidential Information

CMI will not willingly infringe upon the intellectual property rights of third parties. We respect the intellectual property and the confidential information of third parties. This aspect is particularly important if you are in possession of intellectual property and confidential information from a former employer. If you have any questions about this subject, you should see the Legal Department of CMI.

Our reputation was built on the quality and the safety of our products. Our commitment to quality and safety is essential to the continuous growth and success of our Company.

We Set the Highest Standards for our Products

CMI is committed to assure that customers can depend on Midea and Carrier branded products for their superior reliability, quality and performance.

The products sold by CMI must not only comply with all standards of safety defined in law, but also our own standards. The customer's health and wellbeing are our greatest concern. As a CMI's employee, it is your duty to immediately report to the head of your business unit any problems that, in your view, are related to the quality and/or safety of the product.

Customer Receptiveness

Since our line of business is supply for the end customer, our success depends on the satisfaction, confidence and goodwill of our customers.

We recognize the importance of anticipating customer requirements and being receptive to the customer with regard to our products. We believe that opinions, concerns and questions from customers about our products are an important source of feedback. Customer needs are always changing, that is why we must always be aware about the products people want and use our creativity to satisfy these changing customer requirements.

Our Publicity is Accurate

Publicity must be creative and competitive, but it also has to be honest, and comply with the law. Our publicity must avoid stereotyping any individuals based on factors such as race, religion, nationality, ethnics, skin color, gender, sexual identity, age, citizenship, sexual orientation, marital status, disability or any other feature protected under the law. Publicity is not simply the product image; the right kind of publicity can build our reputation in terms of confidence and credibility, while the wrong kind can damage it.

In addition, we are extremely careful in selecting the communication media where our message will be shown to the public. We do not allow our messages to use elements of extensive and gratuitous violence or sex, or otherwise anti-social elements, which would adversely affect the reputation or the products of our Company.

We take the principle of business fairness into account when we decide upon our message, the brand names and concepts, so that our products will be successful by virtue of their own intrinsic quality and also by our reputation - not by imitating or taking advantage of a competitor's reputation. Business fairness calls for:

  • Rigorous compliance with legal requirements about brand protection and fair competition
  • Avoidance of copying well-known brand names, slogans, publicity ideas and graphics utilised by multinational companies and regional competitors outside your own location.

Respect for Customer Privacy

We respect and honor our customer's right to privacy. CMI collects, processes, utilizes and maintains customer information in accordance with applicable laws, including the laws that cover the collection and use of personal information of minors, and we make all reasonable efforts to safeguard such information.

Our policy is to not share customers' personal information unless it is required for providing the services our customers need, or to remain in compliance with applicable laws and regulations.

We abide by all the laws that are applicable to MID's business. In fact, our policy is to go one step ahead of what the law strictly mandates and act according to the spirit of the law.

In no circumstances shall the employees of the Company is allowed, either directly or indirectly, to engage in or otherwise be concerned with any transaction, practice, method, or arrangement which is corrupt, illegal, dishonest or improper. The business of the Company and the conduct of its directors, management staff and employees in the course of the business and operations of the Company shall at all times be conducted in accordance with all applicable Laws, rules, and regulations. For any unlawful practice, it is required to report any activity that involves or could lead to the involvement of the Company. Therefore, everyone should consult the Legal Department for clarification if there are any questions. In particular for the following aspects:

Compliance with Competition Law

The competition laws assure that companies will engage in competitive business through lower prices, innovative products and better services, without interference in the market forces of supply and demand. The competition laws also protect companies from abusive and/or unfair practices by dominant companies, providing conditions for everyone to compete openly and fairly. CMI supports the purposes of the competition laws. We firmly believe that our Company achieves better performance in a competitive market.

It is your responsibility to understand the laws of land where you do business, and to seek guidance from the Legal Department as and when required. You must strictly abide by all competition laws and regulations.

The Competition Act, 2002, as amended by the Competition (Amendment) Act, 2007, (the Act) prohibits any agreement which causes, or is likely to cause, appreciable adverse effect on competition in markets in India. Any such agreement is void. It also prohibits agreements between potential or existing competitors that will harm the competition. The key to compliance is independence. CMI must be independent in carrying out its business functions – pricing, discounting, promotions and sales/purchasing terms; customer selection, distributors and suppliers, and the choice of products that will be manufactured, and the amount that will be sold. We must bear in mind that an illegal agreement does not have to be a formal written document. It can be a verbal or implicit agreement made in the course of a business negotiation, or in the form of comments inserted on documents. An agreement does not have to be successfully implemented to be considered illegal.

The Act also imposes some restrictions regarding customer and distributor relations. Any attempt to deprive customers or distributors of their freedom to set prices, terms and sales conditions, or an attempt to place inappropriate limitations regarding the right to operate independently, is a violation of competition laws.

The consequences for CMI and its employees, for failure to comply with competition laws, are extremely severe. The Competition Act provides for significant penalties in case of a finding of infringement which may extend up to (a) 10% of the average turnover of the last three years for anti-competitive agreements or abuse of dominance, or (b) three times the profit or 10% of the turnover for each year of continuance of a cartel.

Whenever you are uncertain about the laws of competition, you should refer to the Legal Department of the Company.

Compliance with Applicable Anti-Bribery Law

As CMI is a joint venture between Midea Group, China and Carrier Corp, U.S.A., the Anti-bribery Act of India, People's Republic of China and United States of America would be equally applicabe to the Company's Directors, senior management, emplees, contractors, vendors, dealers etc.

The Prevention of Corruption Act, 1988 prohibits the direct and indirect offer, payment, solicitation, or acceptance of bribes or similar facilitating payment in any form is unacceptable, thus, be especially careful of the following points:

We do not offer and take improper benefits

To us, it is unacceptable to give or take gifts, payments or other benefits to influence a business decision. Anyone who wishes to give or take a gift, payment or other benefit, should obtain previous approval from the HR Head and Legal Head. Should it be embarrassing for the Company to refuse a business gift, you should notify the HR Head and Legal Head about you taking the gift. The legal advisers will help you to determine an appropriate destination for the gift. Additionally, do not prepare or accept a business gift, payment or any other benefit of a significant value in the name of close family member of someone with whom the Company has a business relationship or would like to establish a business relationship.

Follow this rule: never accept a business gift or service if it will compromise you or give others the impression that it would compromise you. This does not include business meals that are occasional in nature, which may be reciprocal, or business gifts up as per the applicable policy, if any, of the CMI.

No benefit to government officials

You should be aware that there are special rules establishing suitable conduct when negotiating with the local government, and international governments as well. These rules differ from the rules of negotiation with non-government organisations. You should not try to influence the decision of government officials or make a transaction based on a promise of a business gift or any other benefit, or through any other kind of illegal incentive. Therefore, it is very important that you cannot give any gift, or participate in any entertainment event or offer any other object of value to a government official except with previous approval from Managing Director, and Legal Department of the Company.

In addition to that, certain lobbying legislation in certain jurisdictions may require the Company and/or its employees to register and introduce themselves as members of a lobby if they communicate with a government official with the purpose of influencing legislation or any official action. If you are involved in any of these activities, you should notify approval from the Managing Director, and the Legal Department of the Company. The Company policy on corruption strictly forbids our employees or their agents to offer or give money or objects of value – in cash or in kind, directly or indirectly, through a third party – to any foreign official (i.e., foreign government official, foreign political party or office holder or candidate to a foreign government position) to induce such official to influence any government act or decision or to help the Company to secure or to retain business.

To make sure this policy is observed, the Company will not make any payment or offer anything of value associated with the business activities of the Company to foreign government officials, directly or indirectly, except when previously authorised by the approval from the Managing Director, of the Company in a lawful manner under the applicable laws of India, China and United States of America.

Always be straightforward and honest in all transactions and communication with government officials. Any false statement or warrant made to government officials (verbally, or in writing) and, particularly, any false statement or warrant made under oath, may expose the Company and its employees to substantial sanctions.

No Political Donations

No Company fund or asset may be used to make payments to any political party or candidate to a political office in the federal, state, or local level of government. A political donation includes direct donations (i.e., money) and "donations in kind". A donation in kind includes the purchase of tickets for fund-raising events, contribution of products, volunteer work of CMI employees on Company time and the utilisation of CMI facilities for fund-raising events or political purposes. If you have any questions about donations in kind, contact the Legal Department of the Company.

CMI employees are free to make personal donations to candidates or to political parties of their own choice. A personal donation is the sole responsibility of the donating person. CMI assumes no responsibility or liability with regard to a personal donation. No personal donation should be made with the intent of aiding Midea/Carrier or any of its affiliated companies to obtain or retain business.

Compliance with International Trade Rules/Regulations

In national and international business transactions, the Company abides by all applicable import / export laws. These laws impose limitations on the types of products that may be imported. CMI employees must carry out Company operations in full compliance with the laws of the countries where the Company operates. However, it is always good to verify whether there is a conflict between the laws of the two countries or the Company policy. In the event of such a conflict, you should notify Legal Department and/or the BPO of the Company.

Compliance with Securities Laws and Regulations

From time to time, you may come to be in possession of inside information about Midea/Carrier which the Company does business or is in the middle of negotiations – i.e., information that is not yet in the public domain – such as the amount of provisional income, prospective acquisitions or divestiture, marketing plans or the introduction of new products. Then, according to applicable security exchange laws and the policy of the Company:

  • You should not negotiate, for your own benefit or for the benefit of a third party, shares of stock or securities of Media and/or MID/Carrier midea subsidiary to which the relevant inside information is about.
  • You should not encourage or induce a third party to buy or sell shares of stock or other securities based on the inside information about Midea/Carrier subsidiary.
  • You should not disclose inside information to a third party or parties outside of CMI

If you are uncertain whether or not a certain piece of information has been released to the public, you should contact the Legal Department (if applicable) or Midea Legal Department and refrain from negotiating securities/stock of the affected company or to disclose the information until you are notified that the said information is not relevant or has been disclosed and assimilated by the public.

Internal control

CMI's policy is to maintain effective internal control systems to ensure compliance with laws and corporate policies, to protect and prevent misuse of company assets, and to ensure appropriate authorisation for company transactions and other corporate activities. Employees are expected to maintain accurate and complete internal records of all company business activities and arrange for appropriate authorization and documentation of transactions and commitments with business partners according to the applicable internal control policy of CMI.

Any internal control policy of CMI relating to the disclosure of the important information shall comply with applicable securities laws and stock exchange guidelines, with the objective of promoting an orderly market for its publicly traded securities.

Compliance with Company Records Retention Regulations

We abide by all laws and regulations pertaining to the retention of company records (including physical documents and electronic data). The Company policy for document retention establishes the rules and procedures for the retention of records.

Upon receiving any judicial order, legal notice, warning of litigation or threat of government investigation, contact the Legal Department at once. In this case, you should retain all the records that may be connected to the judicial order or legal notice, whether or not they are relevant to the litigation or have any bearing on the investigation. Do not destroy or change these records, as the improper destruction of company records may give cause to severe consequences – including civil and/or criminal sanctions – to the Company and the employee himself/ herself. If you do not know for sure whether or not a certain record relates to the judicial order, investigation, litigation, or the legal notice, refer to the Legal Department for clarification prior to eliminating the record in question.

Upon receiving any judicial order, legal notice, warning of litigation or threat of government investigation, contact the Legal Department at once. In this case, you should retain all the records that may be connected to the judicial order or legal notice, whether or not they are relevant to the litigation or have any bearing on the investigation. Do not destroy or change these records, as the improper destruction of company records may give cause to severe consequences – including civil and/or criminal sanctions – to the Company and the employee himself/ herself. If you do not know for sure whether or not a certain record relates to the judicial order, investigation, litigation, or the legal notice, refer to the Legal Department for clarification prior to eliminating the record in question.

Our Commitment to Sustainability

At CMI, sustainability is a key aspect of business, and critical to the success of our Company. It is deeply rooted in values of CMI and MIDs values as well, of social responsibility, teamwork, and continuous improvement.

Our global sustainability will ensure that Company business will consistently and responsibly increase for the benefit of the people we serve: employees, shareholders and all stakeholders around the globe as we promote the wellbeing of future generations.

Environmental Protection and Preservation

The Company has a long-standing commitment to environmental protection. Therefore, every one of us must comply with all applicable laws and regulations. No individual or Company director is authorised to be noncompliant with this policy, or to authorise, direct, approve or condone such conduct by third parties.

We promote open communication with the public while seeking to establish active and productive partnerships with the communities in which we operate. We will continue sharing information with consumers about our policies and environmental programs, working with community leaders and local organisations so they will join us in our effort to protect the environment for future generations.

In our ever changing world, a socially responsible and respectable method for work is very important for CMI. These efforts continually result in increased efficiency and financial returns for the Company, but there is always room to improve.

Ask us-For Questions:

Should you have questions or concerns about the interpretation or utilisation of the Code, or any policy, procedure or standard associated with CMI, you should discuss the issue with your supervisor/HoD, Human Resources or Legal Department or BPO of the Company with the following contact information:

General Counsel of Carrier Midea India (CMI): Atul K Sharma

Address: 1st Floor, Pearl Tower, Plot No: 51, Sec 32, Institutional Area, Gurgaon 122001,

India; Phone: +91-9810718595

Fax: +91-9810718595

E-mail: atul.sharma@Carriermideamidea.com

Business Practices Officer (BPO) of Carrier Midea India (CMI): P. Balaji

Address: 1st Floor, Pearl Tower, Plot No: 51, Sec 32, Institutional Area, Gurgaon 122001,

India; Phone: +91-9810219956

E-mail: bpo@Carriermideamidea.com