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Code Of Conduct
MyBlood is committed to fostering, cultivating, and preserving a culture of diversity, equity and inclusion. We make every effort to treat all employees, candidates and external stakeholders of all races, religions, genders, colors, ages, national origins, sexual orientation, and physical disabilities equally.
This Policy is without prejudice to any anti-discrimination provisions of applicable law including, but not restricted to, the provisions of:
• The Protection of Civil Rights Act, 1955
• The Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989
• Sections 354 and 509 of the Indian Penal Code, 1860; and,
• The Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995
The objectives of this Policy are to ensure that all :
Individuals and groups within the society work in an environment where all decisions and actions (inclusive of compensation, benefits, transfers, layoffs, society-sponsored training programs, and social and recreational programs) are free of discrimination, where they have equal opportunity based on competencies and requirements of the society.
• Equal Employment opportunity : All hiring and employment decisions at MyBlood are solely made on the basis of professional competence of the applicant and in light of the organization’s requirement. We strive to extend equal opportunity to all aspects of the employment relationship, including but not limited to hiring, promotions, training and development, compensation and benefits, and do not discriminate in any manner against any employee or applicant.
The Society provides equal opportunities to its employees, consultants or other business partners associated with the Society and does no discrimination. All actions of the Society relating to compensation, benefits, transfers, leave, layoffs, training, education, and assistance of the employees will be made in a fair and equitable manner free from any discrimination.
Notwithstanding anything contained in the previous paragraph, if the Society reasonably believes that its employment, workplace or premises do not adequately represent the balance of diversity of persons who share one or more of the Discrimination Characteristics as defined in section 4 of this policy, it may, with the aim only of redressing that imbalance, take positive discriminatory action in respect of persons who share that aspect, or those aspects, of the Discrimination Characteristics that are sought to be adequately represented.
Equal Opportunity for persons with disabilities : In accordance with the provisions of the Rights of Persons with Disabilities Act, 2016 (“RPWD Act”) and Rules, it is our policy to ensure that the work environment is free from any discrimination against persons with disabilities, and is inclusive for everyone alike. The Society shall ensure that no opportunity is denied to persons with disabilities, merely on ground of the disability. Appropriate facilities, amenities and processes will be provided to persons with disabilities to enable them to effectively perform their job responsibilities.
Maintenance of records under the RPWD Act : The HR team will maintain data regarding employees with disabilities in relation to their employment, facilities provided and other necessary information as per the RPWD Act. For this, individuals with disabilities who apply or employees who believe themselves to be covered by the RPWD Act, should contact their respective HR POC. Any information obtained in this regard is voluntary, will be kept confidential, and will be used in accordance with applicable laws. Refusal to provide information will not subject an employee or applicant to any adverse treatment. Employees and applicants will be protected from coercion, intimidation, interference, discrimination or retaliation for filing a complaint or assisting in an investigation under the Act.
Any person who believes himself or herself to have been subjected to adverse discrimination, or impermissible positive discrimination, based on the Discrimination Characteristics as defined in section 4 of this policy, is encouraged to bring the matter to the attention of the Internal Complaint Committee at the earliest practical opportunity.
• Inclusive Policies for MyBlood employees : Our workplace policies are designed to ensure that they are inclusive and cater to the requirements of all employees irrespective of their background. They play an important role in reinforcing a culture designed to ensure inclusion:
1. Prevention of Sexual Harassment: We promote a safe workplace environment which is embracive of diversity by implementing a zero tolerance policy towards sexual harassment. Our policy is applicable to all genders.
2. Parental Leave Policy: We offer equal parental leave to both mothers and fathers, going with the belief that both parents should have the opportunity to assume equal responsibility in the primary care of their children. The Parental Leave Policy also applies to non-birthing parents in cases of surrogacy, adoption, and same-sex partners
3. Period Leave Policy: While we offer equal opportunities to both women and men, we understand that women and men are born with different biological realities and might need additional support to ensure that biology does not interfere with them being able to fully utilize the opportunities available to them. Therefore, women, and transgenders in our organisation can avail up to 10 days of period leaves in a year
1. Medical Insurance Policy: In our continuous endeavour to enable the journey towards good health and well being for all employees and their families and to protect them from anything unexpected that may happen, our medical insurance policy is extended to spouse of the employees, live-in and/or same gender partner.
• Discrimination, Harassment, and Bullying: We strive to maintain a healthy, safe and productive work environment that is free from discrimination or any form of harassment for all employees and external stakeholders. A trained Internal Committee has been constituted for timely and impartial resolution for any complaints that may arise in this regard.
• Inclusive Leadership and Management :
1. Leader’s responsibility:
1. Leaders set the culture and tone of any organization, hence we deem it imperative that diversity and inclusion is valued and demonstrated by the leaders themselves
2. They are expected to display inclusive leadership behaviours, cultural intelligence, pay attention to diverse thinking, psychological safety, and focus on team cohesion
1. Manager’s responsibility:
1. It is the manager’s responsibility to create a discrimination-free work environment for the team and role model inclusivity
2. They are expected to identify breach of guidelines mentioned in the policy and take immediate appropriate action
• Employee Responsibilities: Every employee at MyBlood is responsible for respecting the dignity and diversity of all other employees and creating an inclusive environment that is free from discrimination and harassment. All employees are also required to enhance their awareness of potential unconscious bias to be more inclusive and collaborative with one another. At the same time, they are expected to notify the HR team of any concerns with regard to the conduct of other employees.
• Use of Inclusive Language: Inclusive language refers to language that raises no social stereotypes in relation to gender, race, age or body and avoids the use of words and/or phrases that create or maintain disadvantage or barriers for the people being referenced. To foster inclusive communication both internally and externally, we expect all employees to use inclusive language in all formal/ informal, written/ verbal communication, documents and policies and to avoid the use of discriminatory language. Usage of discriminatory language by employees which may be derogatory or offensive to certain individuals based on their race, religion, sex, gender, color, age, national origin and physical disability, is subject to strict disciplinary action.
Discrimination occurs when someone is treated unfavourably because of a certain attribute. Discrimination may involve some or all of the following:
• Conduct that can be considered harassing, coercive or disruptive, including sexual harassment
• Making offensive ‘jokes’ about another worker’s clan, ethnic background, colour, sex or disability
• Expressing negative stereotypes about particular groups
• Judging someone on their political or religious beliefs rather than their work performance.
• Using selection processes based on irrelevant attributes such as ethnic or clan group, age, sex or disability rather than on knowledge, skills and merit. Parameters of Discrimination – Strictly Prohibited
Employees who believe they have been subjected or are being subjected to discrimination at MyBlood on the grounds of age, religion, sex, color, national origin, sexual orientation, and physical disability, may file a complaint by writing to the Internal Committee (IC), their respective HR POC, or to support@maheshfoundation.org
All employees are assured that complaints will be addressed without delay and judiciously by the Human Resources team (hereinafter referred to as “HR team”) while upholding utmost confidentiality and sensitivity.
Process of redressal:
• The HR team shall address the complaint within 3 (three) working days of receiving such a complaint
• While addressing the grievance, the HR team will connect with the complainant and note down a detailed statement of complaint, investigate the facts and surrounding circumstances while reaching out to the individual against whom the complaint is raised and take testimonies of other relevant persons and review the evidence wherever necessary
• The HR team shall be the responsible unit that ensures the filing and safekeeping of the records
• The HR team will arrive at a decision after carefully and fairly reviewing the circumstances, evidence, and relevant statements. This will be followed by feedback to the complainant about what can, and cannot be done to resolve the grievance
• The HR team will then take necessary follow-up action, recirculate and ensure closure of the case within 90 days of filing the complaint
The HR team will ensure that in the course of investigating a grievance both parties refrain from any form of threat, intimidation, or influencing of relevant persons involved. The investigation will be conducted in such a way as to maintain confidentiality to the extent practicable under the circumstances.
Decisions and Actions
Once the investigation is completed, a determination will be made regarding the validity of the discrimination allegations. If it is determined that discrimination has occurred, appropriate disciplinary action shall be taken against the respondent employee. Disciplinary action may include but is not limited to transfer, suspension, termination of employment and legal proceedings in appropriate courts/forums.
The HR team shall undertake the aforesaid process under the supervision of the Internal Committee.
i. The purpose and our values
The Code of Conduct (hereby referred to as ‘Code’) sets forth Feeding India’s core values, and shared responsibilities into practice. It is built around the recognition that everything we do in connection with our work at MyBlood will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical, as well as aspirational reasons. Our commitment to the highest standards helps us hire great people, build great products, and attract loyal users.
The Code sets out the values and integrity levels of business conduct that MyBlood expects all employees to abide by during the course of their employment at MyBlood and in all business relationships.
The Code cannot possibly address every situation we face at work. Therefore, you are expected to exercise good judgment and seek help for guidance or clarification.
This Code should be read in conjunction with relevant MyBlood policies and procedures and applicable laws.
ii. Your responsibilities
You will receive a copy of this Code at the time of joining MyBlood and each year thereafter. You are required to confirm your acceptance to adhere to the principles enumerated in this Code. Additionally, complete all the requisite training in a timely manner. You must remember that under no circumstances does your failure to:
• read the Code
• sign an acknowledgement or certify online
• exempt you from your obligation to comply with the Code
Employees are mandated to:
• Read and understand the importance of the Code and follow it consistently
• Complete all required training(s) related to the Code and other Feeding India policies and procedures in a timely manner
• Know that violation of the Code will result in disciplinary action (and may include, but not limited to termination of employment)
• Use good judgment and demonstrate a high degree of personal and professional integrity and honesty at all times, even in situations that are not specifically addressed by this Code
• Follow the Code as a guideline for decision making that is paired with integrity
• Lead by example, by modeling ethical decision making
• Consider conduct in relation to the Code and other MyBlood policies
• Seek advice or clarification whenever unsure of the right thing to do
• Report known or suspected violations to appropriate channels, as soon as you become aware of it.
iii. Responsibilities of People Managers:
As a people manager, you should at all times model appropriate conduct.
• Promote a culture of ethics and compliance
• Ensure that your team members are aware of applicable laws, regulations, and Feeding India policies and procedures that govern the respective areas of responsibility/ work and receive adequate guidance and training to perform their jobs the ethical way, as prescribed in the code
• Create an environment of openness and trust where your team members feel secure and comfortable in asking questions and raising concerns, without fear of retaliation
• Discourage your team from achieving business results at the expense of compromising ethical conduct or compliance with the Code or the law
• Escalate any issues or concerns to the appropriate reporting channels in a timely manner.
iv. Speak up: Seek help or report
If you have a concern and/or in doubt regarding any provision of the Code, you should seek clarification, from any of the below reporting channels:
• Your manager
• Your Skip-level manager
• Human Resources
• If you wish to raise a concern about actual or suspected violation of the Code, you are required to write to any of the below reporting channels, as you deem appropriate:
• Human Resources, in case of any violation which relates to personal grievances or your employment, such as (i) superior- subordinate relationship, (ii) relationship with peers, (iii) performance evaluations, and alike
• myblood@maheshfoundation.org, if you believe you have faced any form of sexual harassment
• myblood@maheshfoundation.org, if you believe there is a violation of the Code (such as suspected fraud, bribery or corruption) which may be considered as a Reportable Matter
• Reporting Manager or Human Resources, in case the concern does not fall in any of the above
i. Compliance with Laws and Regulations
MyBlood is committed to full compliance with the laws, rules and regulations of the countries in which it operates. You must conduct business as responsible corporate persons, and must comply with all applicable governmental laws, rules and regulations. You should avoid any activity that could involve or lead to involvement in any unlawful or illegal practice or cause any harm to MyBlood's reputation or image or interest. You must acquire appropriate knowledge of the legal requirements relating to your duties/work/business to recognize potential non-compliances/ dangers. In case of doubt, you must seek help for guidance and clarification from the Compliance/ Legal team.
ii. Free and fair competition
It is in MyBlood’s best interest to promote free and open competition.
• You are obligated to deal fairly with merchants, suppliers and other Third parties engaging/dealing with MyBlood. You should not take unfair advantage of anyone through manipulation, concealment, or abuse of privileged information/position, misrepresentation, or any other unfair-dealing practice.
• MyBlood expects you to maintain a commitment to comply with the antitrust legislations and competition laws applicable to the purpose of MyBlood.
• As a rule of thumb, you must not:
1. Directly deal with, contact or engage with competitors that may create a potential conflict with the provisions of competition law
2. Share or part with Feeding India specific information in an industry forum or enter into agreements with competitors on any matter, unless done after due consultation with the legal department in advance; and
3. Enter into agreements that may be constructed as abuse of dominance or restrictive trade practices, such as price fixation, exclusive tie-in arrangements, limiting the supply of goods or services, collusive bid rigging or predatory pricing.
iii. Anti-Bribery and Anti-Corruption
MyBlood strictly prohibits bribery and corruption in any form. You must comply with all applicable laws relating to gifts, bribery, corruption, facilitation payments and other improper payments. However, even in countries where the local law does not prohibit such conduct, it is strictly prohibited by the internal policy of MyBlood for you to make any payment/s to any person or persons, including public officials, customers, merchants or consultants or any other Third party dealing with MyBlood, to obtain or retain business, influence business decisions or secure an unfair advantage. This includes bribes, kickbacks and facilitation payments.
We uphold all laws relevant to countering bribery and corruption applicable to us in the conduct of our business across all the jurisdictions in which we operate including, wherever applicable, the Prevention of Corruption (Amendment) Act, 2018 and its amendment (PCA); and the Foreign Corrupt Practice Act, 1977 (FCPA);
iv. Anti-Money Laundering and Anti-terrorist financing
Money laundering is the process by which funds generated from criminal activity such as drug trafficking are moved through legitimate businesses in order to hide their criminal origin. Terrorist financing refers to funding for terrorist activities and can come from legitimate or criminal sources.
MyBlood only associates with entities and individuals involved in lawful business activities with funds derived from valid sources and not with those who may be involved in criminal activities or are part of any sanction list. MyBlood is committed to complying fully with all anti-money laundering and anti-terrorism laws throughout the world.
You shall not engage in or aid or abet any other person to engage in the following prohibited transactions:
• Any financial transaction that promotes or results from criminal activity
• The receipt, use, diversion or concealment of the proceeds of any criminal activity
• Any act of terrorism, including providing financial support or otherwise sponsoring or facilitating any terrorist, activity or organization
• Any arrangement or dealing with a Third party, that is or has connection with a Politically Exposed Person (PEP) and/or sanctioned individual/entity
• Any arrangement that would result in a violation of this Code or other MyBlood policies.
• Some forms of payments and payment related activities that have become associated with money laundering include:
• Payments using monetary instruments that appear to have no identifiable link to the customer or merchant or vendor
• Payments in cash
• Unusually complex deal structures, payment patterns that reflect no real business purpose, or unusually favorable payment terms
• Fund transfers to or from countries unrelated to the transaction or not logical for the customer
• Transactions involving locations identified as secrecy havens or areas of known terrorist activity, narcotics trafficking or money laundering activity
• Payment structures that appear to evade record keeping or reporting requirements (for example, multiple transactions below the reportable threshold amounts)
• Requests to transfer money or return deposits to a third party or unknown or unrecognized account.
v. Avoiding Conflict of Interest
MyBlood is committed to conducting business in a manner that ensures one’s business judgment and decision making is not influenced by undue personal interests. Conflict of Interest (COI) may arise when a MyBlood employees places his or her personal interests above the interests of MyBlood and where such personal interests unduly influence business judgment, decisions, or actions.
MyBlood respects each one`s rights and choices and does not wish to interfere with their personal lives, however, avoidance of conflict is an important part of maintaining integrity and sustainability of our business and builds trust and support with our key stakeholders.
Feeding India employees in client facing roles including but not limited to Sales, Sales Support, Neutrality, Media Content and Client Servicing across all transaction/ business/function at Feeding India are prohibited from writing reviews and/or giving ratings or experiences in Feeding India from either their personal or Feeding India accounts. They are also not permitted to influence others to write biased reviews or give ratings.
A conflict situation could be actual or perceived and may be an event or circumstance when a person does or consciously fails to do an act which allows the person to derive personal gains.
If any of the key principles of COI are applicable to you, then you must disclose such interest to the Human Resource team here. It is pertinent to note that, disclosure must take place as soon as one identifies the conflict and whenever possible, but before engaging in the conduct in question. Business and relationships are dynamic and when circumstances change, existing disclosures may no longer be accurate or complete. When this happens, it is your responsibility to freshly disclose the conflict of interest
This clause should be read in conjunction with the Conflict of Interest policy.
vi. Dealing with Third parties
MyBlood is committed to the highest ethical standards in dealing with Third parties. Dealing with Third parties (including but not limited to, service providers, consultants, merchants, distributors, contractors, vendors, suppliers, or other Third party, whether an individual or an entity, who is employed on a contract basis, or retained to assist Feeding India in any function of the business) should be in a fair and ethical manner.
You must adhere to the following:
• Safeguard the confidentiality of all Third party intellectual property and data and shall not misuse such intellectual property and data that comes into their possession and shall not share it with anyone, except in accordance with applicable MyBlood policies or law.
• Understand the business rationale, including its business reputation, and select them on merit basis fairly and transparently.
• Maintain accurate and complete official records with the utmost integrity. All agreements and transactions should be documented. Ensure all Third parties (e.g. merchants) are made aware of the need to comply with the applicable Feeding India policies and guidelines and report any violation thereof.
• Disclose any personal relationship with a potential Third party to your reporting manager and HR POC to ensure they are not involved in the selection process and negotiations.
• MyBlood would not be responsible for any misconduct or misbehavior on your part in an interaction with any Third parties (customers, merchants, vendors). It shall be your responsibility to ensure they do not exhibit any such behavior.
MyBlood is committed to provide a work environment that is open, mutually supportive and free of inappropriate behavior of all kinds and harassment, including but not limited to, harassment based on pregnancy, childbirth, medical conditions (such as HIV positive), race, religious creed, color, sex, gender (including transgenders), gender identity, national origin or ancestry, physical disability, medical condition, marital status, age, sexual orientation, or any other basis protected by federal, state, local law, ordinance or regulation.
MyBlood maintains professionalism through exercising high standards of integrity and honesty at work, mutual respect towards other individuals in building cordial relationships, good business practices and maintaining a high level of competence.
MyBlood is an equal opportunity employer and employment decisions are solely based on merit and business needs.
i. Diversity and Inclusion (D&I)
MyBlood recognizes that diversity is found in any social identity, such as gender, age, culture, nationality, ethnicity, physical abilities, political and religious beliefs, sexual orientation, and other attributes. Inclusion is the process of involving, accepting, and valuing all people in the workplace regardless of their differences and social identity.
MyBlood believes that D&I at the workplace is an instrument for growth and we value and celebrate the uniqueness of every individual by fostering an environment of inclusion and empowerment. Our policies and practices are gender agnostic. We value all of you and each one of you.
ii. Health and Safety in the workplace
MyBlood promotes your well-being and is committed to provide good and safe physical working conditions. You should exercise high standards of safety, hygiene and housekeeping. Health and safety are of paramount importance.
• You must comply with MyBloodhealth and safety norms, as communicated to them from time to time and should bring to the Management’s attention any workplace safety or health hazard.
• It is mandatory on your part to eschew unsafe and dangerous practices or measures, even if these are considered appropriate for business interest reasons. You should attend safety training sessions (as and when organized by MyBlood for increasing safety awareness and adoption of safe working methods.
• MyBlood sets expectations for social responsibility in our partner chain and endeavors to select Third parties (e.g. vendors, suppliers and business partners) who- demonstrate a commitment to the health and safety of their workers and comply with laws regulating wages, hours and working conditions; do not use forced labor, or raw materials or finished goods produced by forced labor; and implement programs to ensure no materials come from sources that are responsible for human rights violations.
iii. Human Rights
MyBlood will not use any form of child, forced, bonded, indentured or prison labor or any form of human trafficking. All work must be voluntary, and you shall be free to leave work or terminate the employment with reasonable notice, as applicable under local law and in compliance with the MyBlood policy.
The term “child” refers to a person younger than 14 years old or such other minimum age as the local law provides in each geography. This standard does not apply to work or service of performers or recording artists or that otherwise by its nature is reasonably necessary to be procured from a child, to the extent permitted by local law (for example, a child actor/ actress).
iii. Zero tolerance for workplace and sexual harassment
• MyBlood is committed to creating a healthy and safe workplace for MyBlood, where they can work without fear of prejudice, gender bias or sexual harassment. We have zero tolerance for harassment, intimidation or humiliation of any kind in the workplace, whether sexual, physical, verbal or psychological.
• Sexual harassment is a serious offence and is therefore, punishable. The objective of the Code and Sexual Harassment policy is to provide a conducive work environment and intolerance to any verbal or physical conduct of sexual nature towards any MyBlood employee that harasses, disrupts, or interferes with, ones’ work performance or that creates an intimidating offensive, or hostile environment.
• We have clear and fair disciplinary procedures, which necessarily include a FI employees’s right to be heard.
This clause should be read in conjunction with the Sexual Harassment Policy
v. Substance abuse and weapons
MyBlood has strict standards regarding substance abuse and weapons. MyBlood strictly prohibits use, sale, possession, or being under the influence of illegal drugs or alcohol or controlled substances while working with MyBlood or at MyBlood sponsored events, whether consumed during working hours or in the MyBlood premises. Only designated areas shall be used for smoking.
• You will not possess, conceal or use weapons, including firearms, knives, clubs, ammunition, explosives or other devices that are primarily used to inflict injury (including recreational weapons, such as hunting rifles or crossbows) while on MyBlood property or when conducting MyBlood.
• Please note, it is your responsibility to report any case of substance abuse to the specified reporting channel.
i. Protection of confidential information
You should exercise enough safeguards and protect confidentiality of MyBlood’s information, which includes everything from business plans, financial projections, strategy, contracts, pricing, contacts, relationships and personal information. MyBlood information should be shared only on a ‘need-to-know’ basis, that is, to the extent the information is needed to perform their job/work responsibilities.
ii. Payroll information
All compensation matters are privileged and to be kept confidential. You must ensure that information about salaries, appraisals and bonuses are not disclosed to other people within or outside MyBlood.
iii. Unauthorized use of confidential information
You shall not disclose or use any confidential information gained in the course of employment or association with MyBlood for personal gain or for the advantage of any other person. No information either formally or informally, shall be provided to the press, other publicity media, or any other external agency, except by the authorized representative. It is strictly forbidden to trade confidential information or insider’s information for individual gain, or to benefit or to put MyBlood’s interest in jeopardy.
iv. Use of MyBlood Assets
• You are responsible for protecting and taking necessary steps to prevent the theft or misuse of, or damage to MyBlood’s assets and property. The assets include all kinds of physical assets, movable, immovable and tangible property, corporate information and intellectual property, such as inventions, copyrights, patents, trademarks and technology.
• MyBlood’s assets and property should be used only for the benefit of MyBlood and in the manner intended. Certain MyBlood policies may allow additional personal use of certain assets, such as a MyBlood provided phone. In using such assets, you are expected to exercise prudent judgment and avoid excessive personal use.
• You are solely liable for any losses incurred by MyBlood in case of damage/loss/theft of these assets.
• Any suspected incident of fraud, misuse or theft should be immediately reported for investigation.
v. Email, Internet and Information Systems
MyBlood's information technology systems constitute a critical component of our business operation and are provided for authorized business purposes only. Use of these systems must comply with our internal policy and acceptable use standards.
You may engage in reasonable incidental personal use of phone, email and the internet, as long as such usage does not:
• Consume a large amount of time or resources.
• Interfere with your work performance or that of others.
• Involve illegal, sexually explicit, political, discriminatory or otherwise inappropriate material
• Relate to outside business interests.
• Violate our Code or any MyBlood policy.
While it is generally not our practice to monitor MyBlood’s employee use of our information systems, MyBlood reserves the right to monitor, record, disclose, audit, and delete without prior notice the nature and content of any MyBlood Employee’s activity using MyBlood’s email, phone, voicemail, internet, and other systems, to the extent permitted by local law.
i. Upholding Financial Integrity and Record keeping a. MyBlood shall prepare and maintain its accounts fairly in accordance with the generally accepted accounting principles, guidelines, financial accounting standards and applicable regulations from time to time. All business and financial transactions must be authorized and recorded in accordance with the internal approved finance document. b. All books of account, financial records, reports and other financial documents of MyBlood must be accurate and preserved in good order and may be disposed of by the Finance Department as per Information storage, archival policy. You are expected to demonstrate integrity, professionalism and due diligence in maintaining accurate records of all financial transactions (e.g., expense reimbursement forms, disclosure forms etc.
ii. Interaction and cooperation with Auditors Our outside auditors have a duty to review our records in a fair and accurate manner. We must cooperate with them in good faith and in accordance with the law. We must never mislead them in any manner regarding financial records, processes, controls or procedures or other matters which they may enquire about.
iii. Interaction and cooperation with Regulators We must fully and truthfully cooperate with any examination or request for information from a regulator or law enforcement agency or other investigation consultant/ agency, if any, as appointed by the management. Only authorized representatives from the legal team will be the point of contact for any communication or flow of information to the regulator, law enforcement agency or others, if any.
i. External Communication and Media
MyBlood does not prohibit MyBlood employee’s to use social media, however, it is recommended that you use it meticulously and responsibly, in order to avoid damaging the brand`s image and reputation or disclosing any confidential information of MyBlood.
All your communication and expression on social media should be followed by a social media disclaimer, as below , in order to give an impression that you are not speaking or posting on behalf of MyBlood.
a. All views, posts and opinions shared are my own;
b. All views are obviously just mine; and
c. All views are personal.
MyBlood shall carefully review the public disclosures, such as press release(s), financial statements, annual reports, and external website content, before they are released to the external parties ( media, stock exchanges, investors, lenders, business partners and others ) and public to ensure they are truthful, accurate, appropriate, and compliant with applicable laws and regulations.
All inquiries or calls from any external parties should be referred to the Corporate Communications team.
ii. Marketing
Marketing is an essential instrument for effective brand building and communicating with all stakeholders. We strive to ensure that our marketing activities are truthful, accurate and are done ethically.
Our marketing activities, displays, and promotions must always be appropriate and sensitive to the culture public in the country in which they are is shown and should avoid political or religious remarks, that may be offensive or defamatory.
In case of doubt regarding the marketing activity, displays, and promotions, that it may be construed as misleading or hurt sentiments, you must seek help for guidance and clarification from the Legal team.
ii. Political activities
MyBlood is an apolitical organization
MyBlood respects your right to engage in political activities in personal capacity, provided you do not act, or give the impression of acting, as a representative of MyBlood and do it solely in your personal capacity. You are prohibited from directly or indirectly utilizing any MyBlood resources for personal political activities, including but not limited to funds, facilities or any property, or the working time of any FI employees, except as authorized by relevant local policies or procedures. You must not be a part of or join an extremist’s organization.
MyBlood’s outlook towards driving social change is governed by two key principles:
MyBlood is an apolitical organization, and has no political affiliations/ aspirations whatsoever; and MyBlood cares for the society, but also strongly believes in the saying, “your opinions don’t matter, your actions do”.
As a MyBlood, you are prohibited from making, sharing, criticizing or endorsing any politically flavored statement on any of your social profiles. In case you post any such message you should clearly state that views are personal and not of MyBlood.
MyBlood believes that its employees will act with utmost integrity, however, if at times, the Investigation team has reasonable cause to believe that a employee has failed to comply with the requirements of this Code or other MyBlood policies and procedures, they shall inform him/her of the basis for such belief and afford him/her an opportunity to explain the reasons for the same.
FI employee must know:
• We take every concern seriously and our Investigation team (or a delegate for locally-managed or other matters) will investigate it thoroughly to determine whether it is qualified for further investigation;
• If yes, the Investigation team shall conduct such investigation in a timely manner and shall submit a written report containing the findings and recommendations in the shortest time possible, not later than 60 days from the date of receipt of the concern;
• The Investigation team will treat all complaints in a confidential and sensitive manner.
• All investigations conducted will be concluded by way of an investigation report.
This clause should be read in conjunction with the Vigil Mechanism & Whistleblower or Sexual harassment policy, as applicable.
i. Action For Non-observance
If the Investigation team arrives at the conclusion that the allegation has been proved, it shall recommend actions, which may include one or more of the following:
• Written apologies
• Warnings
• Reprimand or censure
• Withholding of promotion
• Withholding of pay increments
• Termination of employment
• Recovery
• Legal action
• And any other action, the investigation team deems fit.
ii. Confidentiality
Upon the request of the complainant, the Investigation team will use its best efforts to protect the confidentiality of the complainant for any good faith report. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
ii. Prohibition against retaliation
MyBlood strictly prohibits any reprisal, threats, retribution or retaliation against any employee who has in good faith reported a violation or a suspected violation of law, this Code or other policies or practices of MyBlood, or against any person who is assisting in any investigation or process with respect to such a violation. Any employee who retaliates against someone who has reported a violation in good faith will be disciplined, which can include termination of employment.
ii. Acting in good faith
Any good faith report, concern or complaint is fully protected by this Code, even if the report, question or concern is, after investigation, not substantiated. Anyone filing a complaint concerning a violation/ misconduct or suspected violation/ misconduct must act in good faith and have reasonable grounds for believing that the act reported indicates a violation of the Code or other policies. Any allegations that are proven to be unsubstantiated and found to be malicious in nature, will be treated as a serious disciplinary offense.
No waiver and amendments of any of the provisions of this code shall be valid unless they are specifically approved by the Head of MyBlood.
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