1.Introduction and Purpose
Novel IRS is subject to various Indian laws on Anti-Corruption, including the Prevention of Corruption Act, 1988 (PCA), and the laws of any other countries in which Novel IRS conducts business. In certain circumstances Novel IRS provides services directly or indirectly in other geographies, thereby exposing Novel IRS to international laws and regulations on Anti-Corruption. Novel IRS is committed to compliance with all applicable Anti-Corruption legislations including the PCA. For definition of terms used in this policy, please refer Annexure I.
Novel IRS may contract with Third Parties, who act as vendors for goods/services or in the capacity of a client service provider to market/deliver services jointly, on behalf of or under the supervision of Novel IRS. The purpose of this document is to provide guidance to all such Third Parties who associate with Novel IRS, to help them understand their duties, responsibilities and obligations in ensuring compliance with relevant Anti Corruption laws.
This Policy describes broadly the circumstances and extent to which business courtesies and any other thing of value may be provided to, or received from, Government Officials, commercial parties, current/prospective clients of Novel IRS, other third parties and business partners. Third Parties associated with Novel IRS are required to read, comprehend and comply with this policy.
No Third Party may authorize, offer, promise or make any payment or give any other thing of value, directly or indirectly, to a government official or to a commercial party, in order to influence or reward an action or decision, or to gain an improper advantage. Likewise, no Third Party may, directly or indirectly, request, agree to receive or accept payment of money or any other thing of value, unless authorised as per this policy.
3.Novel IRS’s Anti-Corruption Programme
3.1 Corrupt payments/bribery
Novel IRS’s Anti-Corruption compliance programme is based on leading international and Indian Anti-Corruption frameworks and/or relevant Anti-Corruption legislations, such as the PCA, World Economic Forum’s Partnering Against Corruption Initiative (WEF-PACI), Novel IRS’s Global Anti-Bribery Standards, and other relevant laws, regulations, and standards.
Applicable Indian Law makes it illegal to offer or pay bribes to Indian Government Officials. Novel IRS’s Operations and its associated Third Parties may also be subject to the Anti-Corruption laws of other jurisdictions that prohibit the acceptance, offer or payment of bribes to any individual, commercial party or government official, with the intention of improperly influencing official acts or decisions, obtaining/retaining/directing business to any person or entity, securing an improper advantage, or for the personal gain of an individual. Anti-Corruption laws also prohibit the indirect payment of bribes through intermediaries, agents, contractors, or other third parties.
A corrupt payment/bribe can take many forms, including an irregular payment of money (such as “kick-backs”, secret commissions, and similar payments), a payment in-kind (e.g. non-cash items such as travel, hotel, car service, tickets, club memberships, internships, hospitality and entertainment, employment opportunities, use of influence, special privileges, personal favours, financial arrangements on favourable terms, benefits and services) or gifts.
All Third Parties are expected and required to conduct business ethically and lawfully and are prohibited from making/receiving any corrupt payments to/from any government officials or commercial parties, for securing or attempting to secure, any benefit in connection with Novel IRS’s business or the business of Novel IRS’s current or prospective clients. However, if a Third Party or its employees, perceives a danger to liberty, personal safety or security arising from an officials demand for a corrupt payment, he/she should use their judgment and subsequently report any such ‘personal safety payments’ to the Novel IRS Ethics Helpline (Refer para#6 of this policy).
This policy not only prohibits making any corrupt payment, but also prohibits all Third Parties from taking/accepting such corrupt payments. Third parties may not directly or indirectly request, agree to receive, or accept kickbacks, payoffs or other payments or transfers of anything of value in connection with Novel IRS’s business or the business of Novel IRS’s current/prospective clients.
The policy not only prohibits Third Parties from directly making/receiving such corrupt payments, but also indirectly making/receiving such payments through consultants, agents, subcontractors, and vendors or other third party service providers, on behalf of Novel IRS or on behalf of Novel IRS’s current/prospective clients.
This means that the Third Parties may not be involved in:
Bribery/Corrupt payments to Government Officials – Third Parties may not directly or indirectly offer, authorize, promise, or give bribes, kickbacks, payoffs, other payments or give any other thing of value to any Government Official except as set forth in this policy. This policy is broad and strictly prohibits payments or gifts of any sort to Government Officials, whether made directly or indirectly, whether intended to bribe the official to take or omit a discretionary act or simply to expedite the performance of a ministerial act for example expediting, speeding up, or facilitating any government decision or action;
Facilitation Payments – Third Parties are prohibited from making facilitation payments, either for themselves, Novel IRS, or on behalf of current/prospective clients of Novel IRS. For purposes of this policy, facilitation payments are considered as bribes and hence must not be paid either directly or indirectly through an agent or consultant. Any type of facilitation payment is prohibited, large or small. Even where such payments are perceived as part of common local business practices and even if others engage in such practices, such payments are not permissible. If you are unsure whether certain administrative and/ or expediting payments which resemble the definition of facilitation payments are permissible, contact the Novel IRS Ethics Helpline (Refer Para#6 of this policy).
Bribery/Corrupt payments to Commercial Parties – Third Parties may not directly or indirectly offer, authorize, promise, or give bribes, kickbacks, payoffs, or other payments or transfers of any other thing of value to commercial parties, for the purpose of obtaining or retaining Novel IRS’s business or the business of Novel IRS’s current/prospective clients, or for securing any improper advantage.
Accepting/receiving Bribes/Corrupt payments – Third Parties may not, directly or indirectly, request, agree to receive, or accept kickbacks, payoffs or other payments or transfers of any other thing of value, for the purpose of obtaining or retaining Novel IRS’s business or the business of Novel IRS’s current/prospective clients, or for securing any improper advantage.
Providing pro-bono services to any current/prospective clients of Novel IRS, government official or commercial party, directly or indirectly, for the purpose of securing any improper advantage or for obtaining or retaining Novel IRS’s business or the business of Novel IRS’s current/prospective clients.
3.2 Extending Business Courtesies
It is customary to extend business courtesies including meals, refreshment, entertainment, and modest gifts, in order to foster successful business relationships. When extending such business courtesies for the purpose of obtaining or retaining Novel IRS’s business or the business of Novel IRS’s current/prospective clients, Third parties should ensure that the following mandatory requirements are met:
i. The business courtesy is justified by a clear and legitimate business purpose, such as the promotion, demonstration, or explanation of products or services or the execution or performance of an engagement;
ii. The business courtesy is not offered to influence or reward an action or decision of the recipient or to obtain any improper advantage;
iii. The nature and value of business courtesy is reasonable and appropriate to the recipients position and to the occasion, and is not likely to be reasonably understood by the recipient or viewed by a reasonable and independent observer as a bribe;
iv. When taken together with courtesies previously given to the recipient, the proposed business courtesy will not, in nature, value or frequency, give rise to an appearance of impropriety;
v. The business courtesy will not impose a sense of obligation on the recipient, nor is there any expectation that Novel IRS, Novel IRS’s current/prospective clients or anyone else will receive anything in return;
vi. The business courtesy is allowable under applicable law.
Third parties should not give, or offer to give, any gifts, entertainment, meals, business hospitality, travel, or any other thing of value to any Government Official or commercial party, for securing or attempting to secure, any benefit or improper advantage.
Gifts, entertainment, meals, and other business courtesies and business hospitality like travel, seminars and marketing events must be permitted by local law, satisfy the mandatory criteria described above, and any rules or regulations (e.g., international laws) applicable to the recipient.
Clients’ of Novel IRS may have diverse policies on giving/receiving gifts, entertainment, meals and other business courtesies. To avoid placing clients or Novel IRS in an awkward or compromising position, as far as practicable Third Parties should familiarise themselves with the client’s policies before giving/receiving gifts, entertainment, meals and other business courtesies. As a general principle, gifts, entertainment, meals, and other business courtesies should be such that a reasonable and independent person would perceive them as business courtesies only and not designed to influence a specific decision or compromise the integrity or objectivity of the recipient.
Third parties who exchange gifts during various occasions (weddings, ceremonies, festive occasions etc), either directly or indirectly, with government parties, commercial parties or other business related third parties, engaged for the purpose of obtaining or retaining business of Novel IRS or that of current/prospective clients of Novel IRS, should ensure compliance with this policy. Broadly, gifts can include sweets, chocolates, fruit, office stationery (e.g., pens, clocks, desk accessories etc). Gifts must not include cash or cash equivalents (e.g., gift certificates/gift cards, shopping cards, pre-paid vouchers or other forms of marketable instruments), or gifts that are excessive in value individually or in the aggregate. Benefits in-kind, including non-cash items such as, travel, hotel, car service, tickets, club memberships, internships, hospitality and entertainment, employment opportunities, use of influence, special privileges, personal favours, financial arrangements on favourable terms, and services, are also considered as gifts.
3.2.2 Meals and Entertainment
Third parties may invite existing/prospective clients of Novel IRS, suppliers, joint venture/strategic alliance partners, and other business related third parties (engaged for the purpose of obtaining or retaining Novel IRS’s business or the business of current/prospective clients of Novel IRS) for a meal as part of business process to help create goodwill and enhance business relationships. However such invitations to meals may be extended only if such meals are business related, to hold bona fide business discussions, satisfy the mandatory criteria defined in the policy (Refer Para#3.2).
‘Entertainment’ includes, but is not limited to, meals, sporting events (such as golf, cricket, football, Formula 1 etc), plays and concerts. Inviting existing/prospective clients of Novel IRS, suppliers, joint venture/strategic alliance partners, and other business related third parties (engaged for the purpose of obtaining or retaining Novel IRS’s business or the business of current/prospective clients of Novel IRS) for entertainment, including social invitations, events organised by Novel IRS, cultural and sporting events, may not have direct relevance to the business relationship or to the professional duties of a Government Official. Accordingly, this may be perceived as improper or as entertainment being provided for the purpose of influencing a business decision, and may adversely impact Novel IRS’s reputation. Third Parties should use good judgment in selecting entertainment. Inappropriate entertainment (Example: Adult Entertainment) is prohibited.
Third parties should not extend any meal or entertainment invitation to a Government Official when there are pending matters (relating to Novel IRS’s business or the business of current/prospective clients of Novel IRS) before the concerned official. Similarly, other invitees to the meal/entertainment must not be in a position to substantially influence a pending decision to award business or other advantages to the Third Party, for the purpose of obtaining or retaining Novel IRS’s business or the business of Novel IRS’s current/prospective clients, or for securing any improper advantage.
3.2.3 Events including Seminars, Thought Leadership, Marketing and Promotional Events
Third Parties may conduct various events, seminars, thought leadership meets and other marketing, promotional and interactive events, sponsor certain events and also provide promotional items/gifts as part of such activities. Such activities are not immune from bribery risk and Third Parties should ensure that care is taken while engaging in such activities. Sponsoring guests directly or indirectly (for the purpose of obtaining or retaining Novel IRS’s business or the business of Novel IRS’s current/prospective clients) for such events, especially Government Officials, and associated costs such as travel and accommodation, could be perceived as bribery. Accordingly, all such events and promotional items distributed at such events should be in accordance with the detailed guidelines prescribed under this policy. It is also to be noted that the Third Party organising such events is strongly discouraged from incurring travel costs, including air travel and long distance car hire, for participants of such events.
Accordingly, Third Parties organising any such event should consider the following matters:
Clearly communicate to each invitee that acceptance of the invitation should be subject to the invitee’s local laws and organizational policies;
The following types of expenses – if incurred directly by the Third parties on behalf of the invitees in connection with the event, and aligned with this policy, are generally permissible, and may include:
This policy does not allow travel costs to be incurred on behalf of or reimbursed to the participants attending such events. Entertainment provided to participants in connection with these events should be reasonable and as prescribed under this policy.
Promotional items (e.g., bags, pens, notebooks, shirts) given to participants attending such events should align with this policy. Promotional items distributed during an event should not include cash or cash equivalents such as gift certificates, gift cards, or vouchers.
3.3 Lobbying, Political Activities, and Political Contributions
In general Third Parties are prohibited from lobbying/interacting with lobbyists, taking part in political activities or making political contributions, to unlawfully or unethically influence any legislations or decree, to improperly benefit Novel IRS’s business or the business of Novel IRS’s current/prospective clients. Third Parties need to take due care to ensure that any services does not constitute lobbying or seek to influence the decisions of legislators to improperly benefit Novel IRS or the business of Novel IRS’s current/prospective clients.
Third Parties should not engage in activities which are perceived as endorsing a political or ideological position or engage in matters that appear to support lobbying, that may adversely impact the reputation of Novel IRS or Novel IRS’s current/prospective clients.
Novel IRS is committed to and supports a functioning democratic constitution and a transparent and fair electoral system in India. Novel IRS does not support, directly or indirectly through Third parties, any specific political party or candidate for political office. Novel IRS does not make contributions in cash or kind, directly or indirectly to political parties, candidates for public office or political organizations, or campaigns. Accordingly, Third parties are required to be in compliance with this policy.
While Third Parties may participate in the political process using their own personal funds and resources, decisions to do so are entirely personal and voluntary. Third Parties engaging in political activities are required to do so in their own individual capacity and must at all times make clear that their views and actions are their own, and should not in any way link Novel IRS or Novel IRS’s current/prospective clients into the same.
3.4 Charitable Contributions
Third Parties are prohibited from making any charitable contributions on behalf of Novel IRS or Novel IRS’s current/prospective clients, to influence the decisions of Government Officials or commercial parties and/or to obtain an improper advantage for Novel IRS or its current/prospective clients.
3.5 Interacting with other Third Parties
Third parties should engage in business transactions or otherwise interact with other business related parties (Example: suppliers, joint venture/strategic alliance partners, and other business related parties), only if there is a reasonable assurance that such parties will not initiate or otherwise participate in corrupt, unlawful or unethical practices, for the benefit of Novel IRS’s business or the business of current/prospective clients of Novel IRS. Necessary due diligence procedures should be performed by Third Parties to obtain such assurance. It is important for Third parties to be alert for ‘red flags’, throughout their relationship with such business related parties.
Examples of “red flags” that requires seeking additional information and/or pursue further inquiry include (but are not limited to) the following situations, where the other business related party:
If any “red flags” are identified, the responsible Third Party should consult with the Novel IRS Ethics and Compliance Team (Refer Para#6) to resolve any concerns.
What is not permissible under this policy should not be subcontracted or outsourced to someone else. Turning a blind eye or ignoring red flags that something may be wrong, does not exonerate any Third Party from criminal liability or other potentially negative consequences of improper conduct.
All Third Parties engaged by Novel IRS are subject to Anti-Corruption due diligence process to check compliance with all relevant laws, regulations, and standards. All Third Parties doing business with Novel IRS may need to provide adequate documentation and other information necessary to complete the due diligence process, failing which they may not qualify to be associated with Novel IRS. Third Parties who may interact with Government Officials for or on behalf of Novel IRS or Novel IRS’s current/prospective clients present greater risks with respect to bribery and/or corruption matters. Such Third Parties may be subject to additional due diligence procedures.
5.Record keeping and Audits
Third parties should record all business transactions, payments, reimbursements, and expenditures properly and accurately in their books and records. Falsification of any documentation relating to support for receipts or expenditures incurred in relation to the work done for Novel IRS (e.g., expense reports, reimbursements, and petty cash documents) is prohibited. Third Party must maintain records and accounts regarding transaction related to work done for Novel IRS, thataccurately and fairly reflect transactions and dispositions of assets and must monitor internal accounting controls to ensure compliance with Anti-Corruption laws and this policy.
Novel IRS reserves the right to audit books and records of the Third Party as they may relate to transactions with or on behalf of Novel IRS or that of Novel IRS’s current/prospective clients. False, misleading, inflated, or incomplete entries in the Third parties books and records are prohibited. For expenditures incurred on behalf of/billed to Novel IRS for gifts, entertainment, meals, events, or other business courtesies, supporting documentation maintained should include the original expense voucher/report, original receipts, the business purpose, the names and affiliations of all participants, and record of the disbursement.
Third Parties are obliged to report concerns related to real or perceived wrongdoing and/or violations of this policy, laws, regulations, PwC Third Party Code of Conduct, and other concerns that arise during the course of doing business.
For seeking guidance on matters prescribed under this policy or for reporting concerns, Novel IRS’s Ethics and Compliance Team acts as the expert resource and may be consulted using the Toll Free Helpline or email mentioned below:
Help Line Number (give number); Email address (email id);
Inquiries or reports may be made anonymously if preferred. Anonymity will be maintained within the limits of the law and to the extent it will not impede or hinder the investigation process. If confidentiality is not possible due to the nature of the complaint, every attempt will be made to limit disclosure of the individual’s identity, and notice where reasonably possible, would be given to the complaining party.
Novel IRS will review/ investigate all reported complaints or concerns. Third parties are required to fully and promptly co-operate with the investigation process and must respond fully and truthfully to any questions, requests for information, and documents. Any failure to completely cooperate or any action to hinder the investigation or audit, including for example, hiding or destroying any information or documentation, providing false answers or false information, deleting email or other documents, or discussing confidential reviews with others, will be grounds for termination of the business relationship, subject to applicable laws.
Violation of the principles contained in this policy may result upto termination of the contract and appropriate legal action as considered necessary, subject to applicable laws. Violation of Anti-Corruption laws may also result in criminal prosecution of individuals, as well as the Third Party. Such criminal prosecution is severe and can include imprisonment and significant fines. Fines imposed on the Third Parties or its employees will not be reimbursed by Novel IRS.
All Third Parties are required to provide adequate training to educate and spread awareness among its employees, on the obligation to comply with Anti-Corruption laws, regulations and this policy.
All Third Parties are required to confirm understanding and compliance with this policy, every six months. Such confirmations are required to be submitted in the format prescribed in Annexure II.
Novel IRS Software is committed to providing innovative technology solutions to better serve our customers’ business needs. In furthering this commitment, it is critical that Novel IRS’s intellectual property assets be protected, and that its copyrights, trade secrets, trademarks, patents and license agreements be enforced. Novel IRS respects the intellectual property of others and asks our partners, end-users, and third-parties to do the same with Novel IRS products and the intellectual property embodied in them.
Novel IRS will take all necessary steps to protect our intellectual property rights and aggressively pursue those who violate our copyrights, trade secrets, trademarks, patents and license agreements. In that regard, Novel IRS considers the following activities, among others, to be unacceptable violations of our intellectual property rights:
Users of pirated or unauthorized software also risk system degradation or failure caused by software corruption, bugs, and lack of technical support.
In order to preserve the integrity of our products, it is important that suspected incidents of software piracy, license non-compliance, and other abuses or violations of Novel IRS’s intellectual property be brought to Novel IRS’s attention.
Reporting can be done by contacting:
Novel Inductive Reasoning Software Pvt. Ltd.
Road No-10, Jubilee Hills,
Telangana – 500033
This Non-Discrimination and Equal Opportunities Policy (“Policy”) states the internal policy of Novel Inductive Reasoning Software Pvt. Ltd. (“Novel IRS”) with regard to non-discrimination at the workplace and equal opportunities during recruitment.
This Policy is internal to Novel IRS and is meant to provide a safe, diverse and comfortable workplace at Novel IRS. This Policy is not legally mandated and, therefore, is not judicially enforceable in India. This Policy is without prejudice to any anti-discrimination provisions of applicable law including, but not restricted to, the provisions of:
The Novel IRS Code of Conduct (the “Code”) provides guidance about business behavior expected of the Novel IRS community as you work and interface with fellow employees, customers, suppliers, business partners and other stakeholders.
The Code is supported by corporate-level policies, which are available on Novel IRS’s Corporate Policy Site. You may also be subject to additional regional and/or departmental policies. However, this Code and the policies cannot answer every question or address every possible business situation. Therefore, you are expected to use good judgment and seek guidance when you have questions about the appropriate course of action.
Scope and Compliance
The Code is applicable to all officers, directors, and employees of Novel IRS. The Third-Party Code of Conduct governs the conduct of contingent workers and business partners acting on Novel IRS’s behalf.
Failure to comply with the Code, including not reporting actual or suspected violations of which you are aware, may result in disciplinary action, including but not limited to termination of employment.
Novel IRS’s business success depends on our ability to build trusted relationships—with each other, as well as with our customers, suppliers, governments and communities. This means that you have a responsibility to:
Ask Questions and Report Concerns
Raise Your Concerns Promptly
The Novel IRS Compliance & Ethics Office is dedicated to giving you the support and advice you need to comply with this Code, corporate-level policies and applicable laws and regulations.
If you have any reason to believe this Code, corporate policies or applicable laws and regulations have been or may be violated, you are expected to immediately report such activity to any of the following resources:
The Novel IRS Ethics HelpLine, a confidential reporting option provided by a third-party service, is available via phone and online:
Retaliation is Not Tolerated
Novel IRS does not tolerate retaliation against any employee who, acting in good faith, reports suspected misconduct, asks questions or raises concerns.
Cooperate with Investigations, Lawsuits and Legal Proceedings
Novel IRS’s commitment to conducting business with integrity requires that we take all credible good-faith reports of suspected misconduct seriously, investigate them fairly and confidentially, and take action where needed. You must cooperate fully in NOVEL IRS-authorized internal investigations and audits, which may be conducted by representatives from Legal, Compliance and Ethics, Internal Audit, Security and Human Resources, as well as members of NOVEL IRS’s external audit and legal firms.
Lawsuits, legal proceedings and investigations by government or regulatory agencies involving Novel IRS must be handled promptly and in an appropriate manner. You should bring all such matters immediately to the attention of the Legal Department.
You should retain documents relevant to any lawsuit, legal proceeding or investigation. All external requests for information must be forwarded to the Legal Department. The Legal Department will oversee information gathering and coordinate Novel IRS’s response to the external party. When you are asked to provide relevant records, you must promptly provide them to the Legal Department.
You are to avoid discussing any lawsuit, legal proceeding or investigation with anyone inside or outside of Novel IRS without prior approval of the Legal Department.
Conduct Business with Honesty and Integrity
Conduct Business with Honesty and Integrity
Follow Acceptable Contracting Practices to Prevent Side Agreements
Side agreements are strictly prohibited. Novel IRS policy is to contract with customers and other parties only through formal, written agreements that have been approved by Novel IRS’s Legal Department and that have been executed by authorized signatories, as further described in the Contract Approval and Signature Authority Policy and the Procurement Policy.
Side agreements include any commitment, whether verbal or written (including by electronic transmission, e.g., email), that was not part of the original agreement with the counterparty in order to complete a sale or purchase or applicable transaction. Side agreements often substantially change the terms of the original agreement and potentially expose NOVEL IRS to a risk of breaching the agreement and impacting the agreement’s accounting treatment. Any modifications to an original agreement must be reflected either in: (i) a new written agreement, or (ii) a written amendment to the original agreement, either of which must be properly approved and executed by an authorized signatory.
Avoid Conflicts of Interest
You should avoid any activity that conflicts with, or appears to conflict with, the interests of Novel IRS. A conflict of interest is a situation in which you or a member of your family has professional or personal interests that could affect your objectivity in making decisions as a Novel IRS employee. Conflicts of interest may arise when you or a member of your family receives improper personal benefits as a result of your position with Novel IRS. Loans to, or guarantees of obligations of, an employee or an employee’s family member may also create conflicts of interest.
It is usually a conflict of interest for a Novel IRS employee to work simultaneously for a competitor, customer or supplier. Employees are not allowed to work for a competitor as a consultant or board member. The best practice is to avoid any direct or indirect business connection with Novel IRS competitors, customers or suppliers, except on behalf of Novel IRS.
Conflicts of interest may not always be immediately evident. If you have questions or if you become aware of a conflict of interest or a potential conflict of interest, you should contact the Compliance & Ethics Office.
Facilitate Accurate Financial Reporting
Novel IRS is a global company and must comply with various securities laws, regulations and reporting obligations, as well as applicable statutory laws and regulations for local country financial and tax reporting. Novel IRS must disclose full, fair, accurate, timely and understandable information regarding our business, financial condition and results of operations to our shareholders and debt holdersas well as to other statutory agencies. Accordingly, you must maintain accurate business records, respect all internal controls and cooperate in all internal and external audits.
Any concerns that may involve a violation of Indian securities laws or a fraud against Novel IRS shareholders or debtholders should be raised to management, the Finance Department, Internal Audit, the Legal Department or the Compliance & Ethics Office.
Maintain Novel IRS Records Appropriately
NOVEL IRS is responsible for ensuring that its business records, including paper and electronic records, are created, managed and disposed of properly. An effective, efficient records management program allows NOVEL IRS to meet its business needs and to comply with all legal and regulatory obligations. You are responsible for periodically reviewing the records in your possession and assuring you are in compliance with the Records Management Policy and any pending preservation orders.
Follow the Letter and Spirit of the Law
Obeying the law, both in letter and in spirit, is the foundation ofNovel IRS’s ethical standards. We must act in accordance with the applicable laws and regulations where NOVEL IRS does business. If you believe the requirements of the Code conflict with local law, please consult the Compliance & Ethics Office or the Novel IRS Legal Department.
Uphold Applicable Anti-Corruption Laws
Novel IRS takes a zero-tolerance approach to bribery and corruption and is committed to operate and enforce systems and policies to detect and deter bribery. You may never give or promise to give anything of value directly or indirectly to any third party in connection with any Novel IRS business to assist Novel IRS in obtaining an improper business advantage, whether or not any benefit is received.
Offering Gifts, Entertainment and other Hospitality
Normal, occasional and appropriate gifts, entertainment or other hospitality offered to customers, potential customers, suppliers, or other persons connected to Novel IRS business to foster goodwill and enhance business relationships is generally permissible. However, the following gifts, entertainment and other hospitality are strictly prohibited, even if you do not submit the expenditures for reimbursement from Novel IRS:
You may not require or encourage a third party acting on behalf of Novel IRS to make any of the abovereferenced prohibited gifts, entertainment or hospitality. For additional information regarding acceptable and unacceptable gifts, entertainment and other hospitality, as well as the related approval process, please refer to the Anti-Corruption Policy. You should contact the Compliance & Ethics Office to discuss and resolve ambiguous situations.
Receiving Gifts, Entertainment and other Hospitality
All business meals and entertainment must be customary, unsolicited, infrequent, in good taste, reasonable in value and provided for legitimate business purposes. Additionally, except as noted below, you may accept occasional, unsolicited gifts of nominal value, such as promotional or commemorative items. You must receive advance approval from your vice president for any gifts, entertainment or hospitality in excess of $100USD (or equivalent), including, for example, travel and conference fees. If you are a vice president or above, you must receive advance approval from your direct supervisor before accepting any gift, entertainment or hospitality in excess of $100USD (or equivalent). If you purchase goods and services for Novel IRS (e.g. procurement employees), you may not accept gifts from suppliers in excess of $25 USD (or equivalent).
You should never accept:
Restrictions on Political Contributions and Activities
You may not contribute funds, assets or services for or on behalf of Novel IRS to any political candidates, political party, charity or similar organizations, unless such contribution is expressly permitted by law and authorized by Novel IRS, as set forth in the Anti-Corruption Policy.
Promote Fair Competition
Novel IRS will succeed in a fair and competitive marketplace by providing customers with superior products and services at reasonable prices. We follow laws designed to preserve free and open competition, often referred to as “antitrust laws.”
Generally, applicable antitrust laws prohibit the following conduct:
Antitrust and trade regulation laws in various countries may differ, and any question about specific conduct or a specific situation should be directed to the NOVEL IRS Legal Department.
Avoid Insider Trading
From time to time, you may obtain material, non-public information (e.g., unannounced financial data, mergers or acquisitions, stock splits, unannounced products, marketing plans, vendor contracts or procurement plans) concerning Novel IRS or other companies. You may never use or share inside information to trade or influence the trading of stock or otherwise use or share the information for personal advantage or the advantage of others, as further detailed in the Securities Trading Policy.
Protect the Privacy of Personal Information
Novel IRS complies with applicable data protection and privacy laws in all countries where NOVEL IRS does business. Novel IRS has received approval of the Binding Corporate Rules both as Controller and Processor (BCR) by European data protection authorities. You have a responsibility to safeguard the privacy, confidentiality and security of personally identifiable information and other private information of our employees, customers, partners and other third parties in Novel IRS’s possession. It is your responsibility to follow the Confidential Information Protection Policy, Data Privacy Binding Corporate Rules Policy and other relevant data privacy policies to protect personal information of others and prevent its unauthorized use or disclosure. You may share it only for legitimate business needs within the scope of your duties with authorized persons and in accordance with applicable laws.
Treat Each other with Dignity and Respect
Value Diversity and Equal Opportunity
Novel IRS values the diversity of its workforce. The Novel IRS approach to diversity is defined by inclusiveness, respect and fostering a culture that allows each individual to contribute to his or her fullest potential. Novel IRS leaders must set a strong, ethical example and create a civil, professional work environment. As set forth in the Equal Employment Policy and the Non-Harassment Policy, NOVEL IRS does not tolerate any form of harassment, discrimination or retaliation.
Ensure a Safe Workplace
A workplace free of violence, weapons and other disruptive behavior keeps all employees safe and able to concentrate fully on business. Violence or other deliberate acts intended to harm another person or their property, including threatening, menacing or intimidating comments and behavior, is prohibited. Violence or threats of violence should be reported immediately to Global Security.
Where legally enforceable, Novel IRS prohibits the possession, concealment, use or transfer of the following items on Novel IRS premises, whether owned or leased: any firearm or other weapon, including knives, clubs, explosives or other devices that are primarily used to inflict injury.
Maintain a Workplace Free From Substance Abuse
Alcohol, illegal drugs and controlled substances can adversely affect safety, productivity, reliability and judgment. We are prohibited from consuming or being under the influence of alcohol or possessing, distributing or being under the influence of illegal drugs while engaging in NOVEL IRS business, with the exception of lawful, moderate and prudent alcohol consumption during legitimate business entertainment. You can find more details in our Substance Abuse Prevention Policy.
Protect Novel IRS’s Assets and Reputation
Use Company Assets and Systems Appropriately
Novel IRS assets, including but not limited to equipment, supplies, facilities and systems, should be used for Novel IRS’s benefit. Novel IRS reserves the right to monitor Novel IRS systems and there should be no expectation of privacy. You must followNovel IRS guidelines for protecting Novel IRSsystems including following password guidelines and incorporating NOVEL IRS-approved virus protection.
Additionally, posting content about your job at Novel IRS, the jobs of others at Novel IRS, Novel IRS’s business or Novel IRS’s customers on social media and networking sites must always be done in accordance with the Social Media and Networking Policy.
Prevent Theft and Fraud
Theft and fraud are crimes and will not be tolerated. Fraud is a type of theft by deception that results in your personal gain, profit or advantage or harm or loss to another person or entity. You are expected to report any suspicious activity immediately.
Safeguard Intellectual Property and Confidential Information
The Novel IRS Information Security Policy serves as the foundation for Novel IRS’s information management policies, standards, and procedures. Employees are personally accountable for ensuring that their Novel IRS information assets are adequately secured and for complying with Novel IRS information security policies, standards and procedures.
Novel IRS owns all inventions, conceptions, discoveries, improvements, ideas, works of authorship and trade secrets created by you on the job or created using Novel IRS’s assets. You are a steward of the trade secrets and confidential information owned by Novel IRS or third parties that are entrusted to you. Accordingly, you are expected to take appropriate administrative, physical and technical measures to properly safeguard them and prevent their unauthorized access, use or disclosure, as further described in the Confidential Information Protection Policy and on the Novel IRS Legal Department Site relating to the protection of intellectual property.
When it is necessary to share Novel IRS confidential information with customers, partners or other third parties, you are responsible for ensuring that the proper confidentiality agreements are signed and properly executed in accordance with the Contract Approval and Signature Authority Policy before the information is shared.
Moreover, you may not use without authorization or make unauthorized copies of another person’s or company’s confidential, non-public information, content, documents or materials, whether written or electronic, or computer software. Additionally, most countries now have laws governing trade secrets and confidential information. There are serious legal repercussions for anyone who violates these laws by misusing Novel IRS’s or another person’s or company’s trade secrets for the economic benefit of anyone other than the owner.
You must ensure that business travel is intended to further NOVEL IRS business interests, and that travel and entertainment expenditures are reasonable, prudent and in accordance with the corporate Travel and Business Expense Policy.
Be a Responsible Corporate Citizen
For Novel IRS, corporate responsibility means achieving business success in ways that demonstrate respect for our communities. Novel IRS prohibits the use of child labor, physical punishment or forced or compulsory labor, as well as any other forms of human abuse including human trafficking. Novel IRS is committed to respecting the environment and to conserving resources. Accordingly, Novel IRS promotes compliance with all applicable environmental laws and regulations in the countries where we do business.
The Novel IRS Ethics HelpLine, a confidential reporting option provided by a third-party service, is available via phone and online:
Novelirs.com is a property of Novel Inductive Reasoning Software Private Limited, an Indian Company having its registered office at PLOT NO-490, ROAD NO-10 JUBILEE HILLS, HYDERABAD,TELANGANA – 500033
Information we collect
Contact information. We might collect your name, email, mobile number, street, city, state, pincode, and country.
Payment and billing information. We might collect your billing name, billing address and payment method when you buy the product. We NEVER collect your credit card number or credit card expiry date or other details pertaining to your credit card on our website. Credit card information will be obtained and processed by our online payment partner CC Avenue.
Information you post. We collect information you post in a public space on our website or on a third-party social media site belonging to novelirs.com
Demographic information. We may collect demographic information about you, events you like, events you intend to participate in, tickets you buy, or any other information provided by your during the use of our website. We might collect this as a part of a survey also.
Other information. If you use our website, we may collect information about your IP address and the browser you’re using. We might look at what site you came from, duration of time spent on our website, pages accessed or what site you visit when you leave us. We might also collect the type of mobile device you are using, or the version of the operating system your computer or device is running.
We collect information in different ways.
We collect information directly from you. We collect information directly from you when you register for a resource. We also collect information if you post a comment on our website or ask us a question through phone or email.
We collect information from you passively. We use tracking tools like Google Analytics, Google Webmaster, browser cookies and web beacons for collecting information about your usage of our website.
We collect information from you passively. We use tracking tools like Google Analytics, Google Webmaster, browser cookies and web beacons for collecting information about your usage of our website.
We get information about you from third parties. For example, if you use an integrated social media feature on our websites. The third-party social media site will give us certain information about you. This could include your name and email address.
Use of your personal information
We use information to contact you: We might use the information you provide to contact you for confirmation of a purchase on our website or for other promotional purposes.
We use information to respond to your requests or questions. We might use your information to confirm your registration for an event or contest.
We use information to improve our products and services. We might use your information to customize your experience with us. This could include displaying content based upon your preferences.
We use information to look at site trends and customer interests. We may use your information to make our website and products better. We may combine information we get from you with information about you we get from third parties.
We use information for security purposes. We may use information to protect our company, our customers, or our websites.
We use information for marketing purposes. We might send you information about special promotions or offers. We might also tell you about new features or products. These might be our own offers or products, or third-party offers or products we think you might find interesting. Or, for example, if you buy tickets from us we’ll enroll you in our newsletter.
We use information to send you transactional communications. We might send you emails or SMS about your account or a ticket you raise.
We use information as otherwise permitted by law.
Sharing of information with third-parties
We will share information with third parties who perform services on our behalf. We share information with vendors who help us manage our online registration process or payment processors or transactional message processors. Some vendors may be located outside of India.
We will share information with the event organizers. We share your information with event organizers and other parties responsible for fulfilling the purchase obligation. The event organizers and other parties may use the information we give them as described in their privacy policies.
We will share information with our business partners. This includes a third party who provide or sponsor an event, or who operates a venue where we hold events. Our partners use the information we give them as described in their privacy policies.
We may share information if we think we have to in order to comply with the law or to protect ourselves. We will share information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests. Or, we might also share information when we are investigating potential fraud.
We may share information with any successor to all or part of our business. For example, if part of our business is sold we may give our customer list as part of that transaction.
We may share your information for reasons not described in this policy. We will tell you before we do this.
You can opt out of receiving our marketing emails. To stop receiving our promotional emails, please email email@example.com. It may take about ten days to process your request. Even if you opt out of getting marketing messages, we will still be sending you transactional messages through email and SMS about your purchases.
Third party sites
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Mr. Srinivas Reddy Vadde
JUBILEE HILLS, HYDERABAD,TELANGANA – 500033
If you have any questions about this Policy or other privacy concerns, you can also email us at firstname.lastname@example.org
Updates to this policy
The User shall be deemed to have accepted and agreed to the following terms and conditions upon the Users usage of the website www.novelirs.com