Code of Conduct

Wipro has a corporation wide Code of Business Conduct (COBC) that provides the broad direction as well as specific guidelines for all business transactions. The COBC is applicable to all business practices and employees, contractor employees and consultants. It covers critical aspects like customer relations, protecting customer information, supplier selection, conflicts of interest, gifts, entertainment & business courtesies, communicating with the public, confidential information, intellectual property, competitive/business intelligence, protecting the privacy of employee and personal information, business records and internal controls, safeguarding company assets, insider trading, anti-trust and fair competition, anti-corruption, political involvement/lobbying, global trade; human rights, diversity and non-discrimination, harassment-free workplace, safe and healthy work environment, and sustainability and corporate citizenship.

The COBC is socialized at multiple points of an employee’s lifecycle - it is first covered as part of the induction program of new hires and subsequently, every employee has to take an online test annually to assert their familiarity with the tenets of the COBC. The code can be accessed at http://www.wipro.com/documents/investors/pdf-files/code-of-business-conduct-and-ethics.pdf

The COBC is the central document on which the Company’s ethics compliance message is disseminated to all employees. Hence, it is constantly reviewed by the Legal & Compliance team to ensure it stays current with trends and changes in corporate ethics, benchmarking with the best and most ethical companies in the world, and keeping up with the statutory changes.

Wipro will take appropriate disciplinary action including termination against any employee, agent, contractor or consultant, whose actions are found to violate the terms of COBC. We have a zero tolerance policy for non-compliance with the non-negotiable aspects of COBC e.g. child labor, anti-corruption etc. 360 degree feedback process rates Wipro managers on how well they align with the principle of unyielding integrity.

Compliance Framework

Compliance processes at Wipro have the oversight of the Board of Directors, the Audit Committee, and the Corporate Compliance Committee. We have a dedicated in-house Legal & Compliance team focused on compliance to identify and analyse the legal and regulatory changes resulting in creation and update of policies and processes. The team oversees compliance with local business laws and regulatory compliance in each of the countries we operate. It is important to assure the stakeholders that internal systems are fair and just. Global Immigration Management System (GIMS), Integrated Risk management and Human Resources have been identified as functions with “material” compliance related risks. As a result, the legal and compliance team reviews the process of these functions. Dashboards are maintained across Business Units and Support Functions and reviewed for contractual compliances periodically. Suitable external consulting firms are engaged for Corporate, Taxation and Labour law compliance activities.

GSCCP Program

In 2014, the Global Compliance Management Project was started with the objective of documenting (replace with “adopting”) a global statutory compliance certification program (GSCCP)framework and automating the framework. The project covers all functions across 24 countries, including India. Under this project, Compliance Landscaping is being done under the broad categories of Corporate and Commercial laws; Industry specific laws; Employment, Human Resource & Immigration laws; Environment, Health & safety; and IT and Data. An external service provider has been engaged for this project. A compliance tracking tool has also been implemented, to track statutory compliance across global operations and ensure compliance with all relevant legal requirements. Audits for select suppliers are also planned for next year.

Anti-Corruption

Our code of conduct and the supplier code of conduct cover requirements of FCPA (Foreign corrupt practices act) and the UK anti-bribery act. High risk functions assessed are procurement, TA, CMF, HR, FMG, Sales and the geographies selected are based on the relative ranking in Transparency International ranking of countries we operate in.

Training programs on ethical compliance and the Ombudsprocess are regularly conducted at various leadership levels. At these interactive sessions, key applicable ethical policies are explained, with real organizational case studies and relevant judicial pronouncements on ethical matters. Statistical data on the complaints / concerns received by the Ombudspersons, and the processes adopted to address these are shared with the participating leaders. Every new hire is required to attend an ethical compliance session titled “Spirit of Wipro Session” where key aspects of the ethics framework are communicated. We have an annual test and certification for all employees on the Code Of Business Conduct. Additionally, specific training through e-learning modules is rolled out on various subjects including anti-corruption, Gifts, entertainment, and Business Courtesies, and is mandated for all employees in a phased manner.

Other modes of maintaining awareness of ethical compliance among employees include focused training sessions organized for various functions- Procurement, Operations and Administration, Human Resources, Finance and Accounts, Internal Audit. At these classroom sessions, key policies relevant to the participants are discussed and feedback is taken for addressing any changes to processes and policies. Mailers on Compliance are periodically circulated by the ombudsprocess group through emails, posters at key employee access locations. External Trainings are organized regularly for Legal & Compliance, Finance, Accounts, and Internal Audit teams on anti-corruption laws of USA and UK, best practices on implementing anti-corruption processes in organizations. These sessions are conducted by US external counsel and consulting firms. In accordance with mandatory local law, all manager-level employees located in the states of California and Connecticut within the US are required to undergo training and certification on prevention of sexual harassment. In addition, special trainings are conducted for Prevention of Sexual Harassment Committee panel members, and SOPs are published for better governance encompassing the requirements under law on sexual harassment.

There have been no significant instances of non-compliance in the last financial year.

The Ombudsprocess

Wipro is committed to the highest standards of openness, probity and accountability. An important aspect of accountability and transparency is a robust mechanism that allows partners, customers, suppliers and other members of the public, to voice concerns in a responsible and effective manner. What this means in concrete terms is that whenever a stakeholder discovers information that reveals serious malpractice, impropriety, abuse or wrongdoing within the organization then the stakeholder should be able to report without fear of reprisal Anyone can report a concern to the ombudsperson online at www.wiproombuds.com

In Wipro, our Chief Ombuds-person works with designated Ombuds-persons in each Business Unit. The process ensures confidential and anonymous submissions. An organization wide multi-lingual Ombudsprcess is available 24 x 7 (phone and internet enabled) for all our stakeholders.

Complete details of the Ombuds process for employees is available at the following links in our website.

In 2016-17, 1692 complaints were received via the ombudsprocess and 1709 complaints were closed. All cases were investigated and actions taken as deemed appropriate. Based on self-disclosure data, 25% of these were reported anonymously. The top categories of complaints were people processes (34%) and workplace concerns and harassment (22%).

A total of 116 complaints of sexual harassment were raised in the calendar year 2016, of which 102 cases were disposed and appropriate actions were taken in all cases within the statutory timelines. This includes all cases reported to the system, even if unsubstantiated. In some cases, a clear action has been taken (warning or separation) and the rest have either not progressed due to lack of information or resolved through counselling.

The ombudsprocess statistics for 16-17 and earlier years are provided below and this information is periodically communicated to the board.

Besides the ombudsprocess, the stakeholders also have the option of sharing their concerns with us via mail mentioned in our website. We have location registers at all our locations which can be used by any stakeholder group to express their concerns. Wipro also invites experts in the field of crime and investigation to conduct master classes on topics relevant to the business.

The concerns about unethical or unlawful behavior, and matters related to organizational integrity which are mandated by law to report are communicated to the relevant agencies as and when such issues happen. In FY 16-17, there was no instance of ethical or unlawful activity which required seeking external advice or reporting to external agency.