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Apraava Sustainability Report 2020-2021  27





            Corporate Policies









                                                                            The Code of Conduct (CoC)

                                                                            covers anti-corruption

                                                                            principles such as avoiding
                                                                            conflicts of interest, no

                                                                            bribery, moderation in gifts

                                                                            and entertainment, and

                                                                            maintaining strong ethics and

                                                                            business integrity.



                                                                            Code of Conduct

                                                                            The CLP Group Code of Conduct instructs employees on how
                                                                            to conduct themselves with integrity in all activities and
                                                                            serves as a tool to combat corruption within the Group. It
                                                                            outlines the principles that every single person working for
                                                                            and with the Company, regardless of location, must follow.


                                                                            The Code of Conduct for Apraava Energy, which was updated
                                                                            in October 2020, is circulated annually to all employees. It is
                                                                            applicable to Apraava Energy and all its subsidiaries. All
                                                                            Apraava Energy employees, contractors and sub-contractors
                                                                            regardless of position or function, are expected to fully
                                                                            adhere to the principles outlined in the Code.

                                                                            Training And Awareness

                                                                            Code of Conduct training is required for all new employees
                                                                            who join the Company. Furthermore, e-training programmes
                                                                            are in place to further strengthen employee awareness of
                                                                            fraud risk. Every four years, the Company conducts an
                                                                            in-person Business Practice Review (BPR) process for all
                                                                            employees to refresh a company-wide understanding of the
                                                                            Code's principles and to ensure that business practices
                                                                            remain compliant.
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