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MINT CODE OF JOURNALISTIC CONDUCT

Last updated April 4, 2015

This code is designed to provide all employees of Mint with guidelines for
appropriate professional conduct. It is intended not as a statement of new
beliefs or a codification of new rules of conduct, but as a reaffirmation of
enduring values and practices.

The central premise of this code is that Mint reputation for quality products
and services, for business integrity, and for the independence and integrity of
our publications, services and products is the heart and soul of our enterprise.
Put another way, it is an essential prerequisite for success in the news and
information business that our customers believe us to be telling them the truth.
If we are not telling them the truth -- or even if they, for any valid reason,
believe that we are not -- then Mint cannot prosper. The company will suffer,
for example, if our customers cannot assume that:

 * Our facts are accurate and fairly presented;
 * Our analyses represent our best independent judgments rather than our
   preferences, or those of our sources, advertisers or information providers;
 * Our opinions represent only our own editorial philosophies; or
 * There are no hidden agendas in any of our journalistic undertakings.

All companies profess business integrity. But the impact of our work on the work
of others, and on their lives and fortunes, places special responsibilities upon
all Mint employees.

The clear implication of these beliefs is that the responsibility for
safeguarding and growing a company that lives up to this code lies with each and
every one of us. Every Mint employee holds a position of trust. Acceptance of a
position at any level or in any part of Mint includes acceptance of individual
responsibility to uphold Mint policies governing legal and ethical business
practices. It also includes acceptance of individual responsibility for
following all legal requirements and ethical business practices, as well as the
responsibility to stress proper ethical behavior among colleagues and
subordinates.

Moreover, it must be clear to each of us that business integrity is necessary in
every business decision- and that it is not the special province of news
employees, or members of the legal department, or anyone else. Business
integrity requires that we make all of our business decisions, and approach all
business questions, objectively and realistically, and in the long-term best
interests of all of our shareholders.

Editors, by virtue of their positions of authority, must be ethical role models
for all employees. An important part of an editor's leadership responsibility is
to exhibit the highest standards of integrity in all dealings with employees,
customers and the world at large. Editors must avoid even implicit or unspoken
approval of any actions that may be damaging to the reputation of HT Media, and
must always exercise sound business judgment in the performance of their duties.

An equally important leadership responsibility is to develop employees'
commitment to our principles and ability to make sound ethical judgments.
Editors must communicate the seriousness of the company's expectations of
ethical conduct, as well as their own personal support for these guidelines.
Ethical leadership includes fostering a working environment that encourages
employees to voice concerns or otherwise seek assistance or counsel if faced
with potentially compromising situations, and also supporting those who raise
such concerns.

Finally, what follows is not intended to be an exclusive or inclusive list of
all laws, regulations and other norms applicable to Mint and with which
compliance is expected. In our rapidly evolving businesses, a complex
environment that often requires quick response under pressure challenges each of
us. No written policy can definitively set forth the appropriate action for all
business situations. Accordingly, this code emphasizes and clarifies a standard
of ethical conduct that must govern all of our business dealings and
relationships.

Introduction: What We Stand For

In our society, the press enjoys a remarkable degree of freedom. With that
freedom comes the responsibility to practice our craft in accordance with the
highest standards, to be accountable for what we publish, and to avoid conflicts
of interest.

We will strive to fulfill these responsibilities. And with good reason.
Otherwise, we could lose our most important asset: the trust of our readers,
online visitors, viewers, and listeners in the credibility of the information
and insights we provide.

In the 21st century, that news is transmitted in more ways than ever before – in
print, on the air and on the Web, with words, images, graphics, sounds and
video. But always and in all media, we insist on the highest standards of
integrity and ethical behavior when we gather and deliver the news.

That means we abhor inaccuracies, carelessness, bias or distortions. It means we
will not knowingly introduce false information into material intended for
publication or broadcast; nor will we alter photo or image content. Quotations
must be accurate, and precise.

It means we always strive to identify all the sources of our information,
shielding them with anonymity only when they insist upon it and when they
provide vital information – not opinion or speculation; when there is no other
way to obtain that information; and when we know the source is knowledgeable and
reliable. It means we don't plagiarize. It means we avoid behavior or activities
that create a conflict of interest and compromise our ability to report the news
fairly and accurately, uninfluenced by any person or action. It means we don't
misidentify or misrepresent ourselves to get a story. When we seek an interview,
we identify ourselves as Mint journalists. It means we don't pay newsmakers for
interviews, to take their photographs or to film or record them. It means we
must be fair. Whenever we portray someone in a negative light, we must make a
real effort to obtain a response from that person. When mistakes are made, they
must be corrected – fully, quickly and ungrudgingly. And ultimately, it means it
is the responsibility of every one of us to ensure that these standards are
upheld. Any time a question is raised about any aspect of our work, it should be
taken seriously.

We believe that our future depends upon preserving and enhancing this trust.
Therefore, we must ensure that:

1. Our integrity is of the highest caliber.

2. We base our unique brand of journalism on accurate information, gathered
honestly and presented fairly.

3. Our professional conduct is unassailable.

4. Our personal conduct, as it reflects on Mint, is beyond reproach.

All members of the Mint editorial staffs must uphold these principles. This
means everyone who works on the magazine, the Web site, or in future TV or radio
operations (including members of the art, production, and systems departments,
all Web developers and programmers, and all assistants and clerical workers), be
they full-time, part-time, interns, or freelancers. Moreover, you are expected
to report to the Editor violations that you or others commit. If you encounter a
potential ethical dilemma that isn't covered by this Code, you must ask the
Editor for a ruling. When the Editor is unavailable, check with the Managing
Editor or, at a minimum, with the person to whom you report. To put it simply,
when in doubt, ask.

Here are the rules by which we must live:

A) INTEGRITY

Church and State

Unquestionable integrity is at the heart of our effort to serve our audiences
with the best business journalism in the world. One way we achieve this is to
strictly observe an invisible wall that separates our editorial operations from
our advertising and other business departments, so as to avoid any chance that
one will inappropriately influence the other.

In every medium, our reporters, editors, and producers prepare and place
stories, graphics, and interactive features based solely on their editorial
merits. Thus, we treat companies that advertise with us exactly the same as
those that don't. We don't favor any company or subject of a story, or
discriminate against any -- for any reason.

Moreover, editors and editorial imperatives dictate the design of our products.
Obviously, we make allowance for the presentation of revenue-generating
elements. However, the design must always make clear the distinction between
editorial and commercial material. In the spirit of that rule, for example, we
do not link, for any reason other than editorial purposes, from within the text
of electronic versions of our stories to an advertiser's Web site.

To ensure that we honor these principles, there generally should be no contact
(beyond social conversations) between the vast majority of Mint editorial and
business staffers. (The Editor or a designated surrogate may grant exceptions as
necessary for the running of the business.)

If you ever feel any pressure from outside, or from our own business
departments, to compromise editorial material -- including pressure to violate
this Code, you must tell the Editor and/or Managing Editor immediately.

B) OUR JOURNALISTIC STANDARDS

Mint specializes in valued-added, interpretive journalism. This gives us license
to go beyond a traditional, just-the-facts approach. At the same time, it puts
an extra onus on us in the following areas:

1. Accuracy.

For the reader to believe our interpretations, we must start with accurate
information, honestly and professionally gathered. Moreover, our interpretation
must flow from the facts and be reasonable.

Inaccurate or sloppy reporting of material that appears anywhere under the Mint
name violates the spirit of this Code. The responsibility for accuracy lies with
everyone who touches the editorial product. If you have any reasonable doubts
about the accuracy of our information, you have a duty to tell your immediate
editor, and if necessary the Editor.

2. Honesty.

All of your dealings with sources -- and with other editorial staff -- must be
truthful.

As an institution, moreover, Mint will always be an independent voice, with no
axe to grind. We do not support political candidates or political parties. We
are not Keynesians, monetarists, or supply-siders. On all matters of politics,
economics, and social policy, we try to bring our own judgment to bear, based on
thorough reporting and reasonable analysis. We do not do stories that are
designed to hew to any ideological agenda other than our belief in free markets,
free people and free societies.

3. Fairness.

We give the subjects of a story -- people, companies, and institutions -- an
opportunity to have their views presented. We include relevant portions of those
views -- or report that the subject declines to comment. We also present
differing or dissenting opinions, though they may be subordinate to the main
thrust of the story.

If someone complains about a story, we will investigate promptly and
even-handedly. If we are right, we will stand by the story regardless of who is
complaining. If we are wrong, we will say so forthrightly and make whatever
amends seem appropriate.

Because we do analytic journalism and commentaries, we do not strive for perfect
objectivity. But we must always strive to be fair.

4. Attribution.

Mint's style book is the final authority on this issue so when in doubt, please
refer to the Style Book especially on how we make attributions in the paper and
online. And if you are unsure of how to interpret the Style Book or if you have
any doubt whatsoever, ask your immediate editor or the Editor. In general, we
use the following ground rules when seeking information from sources:

On the record: You are free to use all material from the interview, including
information and quotations, and to identify the source. We prefer this approach.

Not for attribution: You are free to use information and quotations, but you
agree not to identify the source. "Not for attribution" is an acceptable method
of gathering information, though not the one we prefer.

You generally should have more than one source for information that you can't
attribute, both to double-check its veracity and to guard against being used or
misled by a single source. In situations where you wish to report, without
attribution, extremely sensitive information, you should seek approval
beforehand from your immediate editor, the Editor or in his absence the Deputy
Editor.

Off the record: You agree not to use information from the source. Or you may
agree not to use the information unless you check with the source before
publication. You should avoid this method unless it's the only way to interview
a one-of-a-kind source.

Background: The information can be published but only under conditions
negotiated with the source. Generally, the sources do not want their names
published but will agree to a description of their position. Mint reporters
should object vigorously when a source wants to brief an entire group of
reporters on background and try to persuade the source to put the briefing on
the record. These background briefings have become routine in many venues,
especially with government officials. Deep background: The information can be
used but without attribution. The source does not want to be identified in any
way, even on condition of anonymity. In general, information obtained under any
of these circumstances can be pursued with other sources to be placed on the
record.

Make such decisions carefully because Mint generally will have to honor whatever
arrangement you make. The Editor or a designated surrogate has the right to know
the identity of anonymous sources -- be they not-for-attribution or
off-the-record sources -- and will keep such information confidential.

Routine attribution: "He said" means you got the quote from the source -- in
person, at a press conference, or on the phone. "He said in a statement" or "in
a report" means the quote came from a written statement or press release, or
from a document such as an analyst's report. "He said in an e-mail interview"
means exactly that. If the quote comes from another news outlet, you must credit
it: "President Kalam told the Associated Press." Information taken from the
Internet must be vetted according to our standards of accuracy and attributed to
the original source. File, library or archive photos, audio or videos must be
identified as such. For projects, attribution can be contained in an extended
editor's note, usually at the end, detailing interviews, research and
methodology. The goal is to provide a reader with enough information to have
full confidence in the story's veracity. The use of such notes must be cleared
in advance by the Editor.

4.a. Dealing with Lobbyists and Public Relations executives

4.a.1. Do's

1. As much as possible engage directly with relevant sources. Lobbyists and
Public Relations executives must only be used as a channel to arrange for
access. And not as sources themselves. If they are used as sources, then this
must be clearly stated in the story.

2. In all engagements with Lobbyists and PR people state upfront that you
represent Mint. State that you are talking to them in regards to a particular
story.

3. Reporters must decline to convey any message from Lobbyists or PR people to
senior editors, management, executives in other companies or bureaucrats and
ministers. They are free to do this on their own.

4. It is recommended that you limit your relationship with Lobbyists and PRs
people o a purely professional one, as mentioned in points 2 and 3 above. And
even if you know them at a personal level, there is a reasonable probability
that your interactions will still be taken to have professional implications.

5. If you are engaging with companies or Lobbyists and PR people that have a
reputation for creating or being in trouble, kindly keep your reporting editor
informed of the interaction.

6. If Lobbyists or PR people promise access or information in exchange for tone
or content of coverage, reporters are expected to decline immediately and inform
their reporting editors.

4. a.2. Dont's

1. Discuss aspects of how Mint has covered the Lobbyists and PR people's
clients, or will cover them in the future.

2. Discuss aspects of the story you are working on or what tone it will take.

3.  Ask the Lobbyist's or PR people's opinion of your or the paper's coverage of
their clients. We don't care. If they wish to object they are welcome to do so
to the editor.

4. Act as a go-between or an intermediary. This includes intermediating between
the source and any other reporter in Mint, or any other media outlet. Your
interactions are purely for the purpose of your story and your story alone.

5. Accept any conditional access or information. We will offer nothing in return
for access or information. Except the possibility that it may be used in a story
with attribution. Do not accept such conditions even if you plan to dishonour it
later.

5. Quotations:

The same care that is used to ensure that quotes are accurate should also be
used to ensure that quotes are not taken out of context.

We do not alter quotations. If a quotation is flawed because of grammar or lack
of clarity, the writer must be able to paraphrase in a way that is completely
true to the original quote. If a quote's meaning is too murky to be paraphrased
accurately, it should not be used.

Ellipses and parentheses should be used rarely. When in doubt please paraphrase
or seek a fuller quote.

When relevant, stories should provide information about the setting in which a
quotation was obtained – for example, a press conference, phone interview or
hallway conversation with the reporter. The source's affect and body language –
perhaps a smile or deprecatory gesture – is sometimes as important as the
quotation itself.

Use of regional dialects with nonstandard spellings should generally be limited
to a writer's effort to convey a special tone or sense of place. In this case,
as in any interview with a person not speaking his or her native language, it is
especially important that their ideas be accurately conveyed. Always, we must be
careful not to mock the people we quote.

Quotes from one language to another must be translated faithfully. If
appropriate, we should note the language spoken.

6. Anonymous sources in material from other news sources:

Reports from other news organizations based on anonymous sources require the
most careful scrutiny when we consider them for our report. Mint's basic rules
for anonymous-source material typically apply to pickups as they do in our own
reporting: The material must be factual and obtainable no other way. The story
must be truly significant and newsworthy for us to use. Please flag use of such
un-sourced material to your immediate editor. If the source material is
ultimately used, it must be attributed to the originating provider and note
their description of their sources. Further, before picking up material from
other news agencies for a story of our own, and even if we are crediting that
source in the story, we must make a bona fide effort to get it on the record,
or, at a minimum, confirm it through our own sources.

7. Audio/Video:

Mint's audio/video actualities must always tell the truth. We do not alter or
manipulate the content of a newsmaker actuality in any way. Voice and Video
reports by Mint reporters for online may be edited to remove pauses or stumbles.

Mint does permit the use of the subtle, standard audio processing methods of
normalization of levels, general volume adjustments, equalization to make the
sound clearer, noise reduction to reduce extraneous sounds such as telephone
line noise, and fading in and out of the start and end of sound bites _ provided
the use of these methods does not conceal, obscure, remove or otherwise alter
the content, or any portion of the content, of the audio. The same applies to
Video. When an employee has questions about the use of such methods or Mint's
requirements and limitations on audio or video editing, he or she should contact
the Editor prior to the transmission of any audio.

8. Fabrications:

Nothing in our news report – words, photos, graphics, sound or video – may be
fabricated. We don't use pseudonyms, composite characters or fictional names,
ages, places or dates. We don't use "industry expert" simply to hide a person's
affiliation. We don't create fictional characters to embellish articles, however
dry they might seem.

We don't stage or re-enact events for the camera or microphone, and we don't use
sound effects or substitute video or audio from one event to another. We do not
"cheat" sound by adding audio to embellish or fabricate an event. A senior
editor must be consulted prior to the introduction of any neutral sound (ambient
sound that does not affect the editorial meaning but corrects a technical
fault).

We do not ask people to pose for photos unless we are making a portrait of that
person. This means we don't make them recreate activities for our photograph.

9. Graphics:

We use only authoritative sources. We create work only from what we know.

We post or move a locator map only when we can confirm the location ourselves.

We create charts at visually proper perspectives to give an accurate
representation of data. The information must be clear and concise. We do not
skew or alter data to fit a visual need.

We credit sources on every graphic, including graphics for which Mint
journalists have created the data set or database. If the graphic is created
entirely based on original research then we would credit Mint Research.

10. Images :

Mint pictures must always tell the truth. We do not alter or manipulate the
content of a photograph in any way.

The content of a photograph must not be altered in PhotoShop or by any other
means. No element should be digitally added to or subtracted from any
photograph. The faces or identities of individuals must not be obscured by
PhotoShop or any other editing tool. Only retouching or the use of the cloning
tool to eliminate dust and scratches are acceptable.

Minor adjustments in PhotoShop are acceptable. These include cropping, dodging
and burning, conversion into grayscale, and normal toning and color adjustments
that should be limited to those minimally necessary for clear and accurate
reproduction (analogous to the burning and dodging often used in darkroom
processing of images) and that restore the authentic nature of the photograph.
Changes in density, contrast, color and saturation levels that substantially
alter the original scene are not acceptable. Backgrounds should not be digitally
blurred or eliminated by burning down or by aggressive toning.

When an employee has questions about the use of such methods or Mint
requirements and limitations on photo editing, he or she should contact the
photo editor/art director prior to the use of any image.

On those occasions when we use images that have been provided and altered by a
source – the faces obscured, for example – the caption must clearly explain it.
Use of such images must be approved by the Editor or in his absence the Managing
Editor.

For online video, Mint permits the use of subtle, standard methods of improving
technical quality, such as adjusting video and audio levels, color correcting
due to white balance or other technical faults, and equalization of audio to
make the sound clearer _ provided the use of these methods does not conceal,
obscure, remove or otherwise alter the content, or any portion of the content,
of the image.

Graphics, including those for online, often involve combining various
photographic elements, which necessarily means altering portions of each
photograph. The background of a photograph, for example, may be removed to leave
the headshot of the newsmaker. This may then be combined with a logo
representing the person's company or industry, and the two elements may be
layered over a neutral background. Such compositions must not misrepresent the
facts and must not result in an image that looks like a photograph – it must
clearly be a graphic.

Similarly, when we alter photos to use as graphics online, we retain the
integrity of the image, limiting the changes to cropping, masking and adding
elements like logos. Videos for use online can be altered to add graphical
information such as titles and logos, to tone the image and to improve audio
quality. It is permissible to display photos online using techniques such as
360-degree panoramas or dissolves as long as they do not alter the original
images.

11. Obscenities, profanities, vulgarities:

The Mint Style Book is the final word on how we use such terms.

We do not use obscenities, racial epithets or other offensive slurs in stories
unless they are part of direct quotations and there is a compelling reason for
them.

If a story cannot be told without reference to them, we must first try to find a
way to give the reader a sense of what was said without using the specific word
or phrase. If a profanity, obscenity or vulgarity is used, the story must be
flagged at the top by the reporter, advising editors to note the contents.

A photo containing something that could be deemed offensive must be approved by
the Editor.

We take great care not to refer readers to Web sites that are obscene, racist or
otherwise offensive, and we must not directly link our stories to such sites.

In our online service, we link the least offensive image necessary to tell the
story. For photo galleries and interactive presentations we alert readers to the
nature of the material in the link and on the opening page of the gallery or
interactive. If an obscene image is necessary to tell the story, we blur the
portion of the image considered offensive after approval of the department
manager, and flag the video.

12. Responses:

We must make significant efforts to reach anyone who may be portrayed, and
especially if that portrayal is a negative one, in our stories, and we must give
them a reasonable amount of time to get back to us before we move the story.
What is "reasonable" may depend on the urgency and competitiveness of the story.
Please make sure you consult your immediate editor when in doubt. If we don't
reach the parties involved, we must explain in the story what specific efforts
were made to do so.

13. Corrections & Amplifications Policy:

We will adhere to a zero-tolerance policy in terms of correcting our errors. We
will clearly communicate to all our readers the best way to reach us so we can
promptly correct our mistakes. If we are aware of a mistake, we will correct our
stories irrespective of whether a correction is being sought so that databases
don't contain uncorrected stories. Not informing your editor of an error in your
story, especially if it has been pointed out by anyone, is a serious violation
of this code of conduct and could result in the relevant employee being subject
to discipline up to and including termination.

C) PROFESSIONAL CONDUCT

Every judgment we make as journalists must be free of conflicts of interest --
free even of the appearance of conflicts. Therefore, we must observe the
following rules:

1. Share ownership and trading.

In making personal investments, all employees must avoid speculation or the
appearance of speculation. No employee of Mint may engage in short selling of
shares, including futures and options, such as a put option.

a. Shares you own.

You may not report, write, or edit a story about a company in which you or
members of your immediate family own shares--nor about other companies in the
same industry, unless it has been cleared in advance by the Editor. For
instance, if you own shares in Reliance, you may not report, write, or edit a
story about the company or its key rivals. Nor may you mention such a company on
a broadcast or cable show or Web video except in passing (as in reading a list
of closing market prices). Immediate family means spouse or significant other
and children 18 or younger.

You may, however, invest in all mutual funds and exchange traded funds that are
regulated.

In any instance where a conflict seems likely, you might have to recuse yourself
from participating in the story. Again, when in doubt, ask.

b. Shares you plan to buy.

If your job is such that you write about or edit stories on a wide variety of
companies intermittently, do not invest in those companies.

You may, however, trade the shares of companies you don't cover, in industries
you don't cover, provided you don't act on any information prior to being
published in Mint.

You may not engage in day trading or so-called active trading, or short selling.
Nor may you accept "friends and family" shares from companies that are about to
go public. Nor may you knowingly participate in unethical market-timing schemes
that any mutual fund may engage in. The three-month rule does not apply to
publicly available mutual funds.

Additionally, you may not trade in any share or financial instrument based on
information gathered by anyone at Mint before a story is published. If an
article on the information is not published by Mint but the information becomes
public information the above restriction does not apply. Be aware that we may
report suspected insider trading to the appropriate authorities and will
cooperate fully in any subsequent legal actions. Remember, as well, that people
who are caught engaging in insider trading often spend time in jail.

c. Special situations:

There may be instances in which an editorial employee inherits stock from a
non-spousal relative, or in which a newly hired employee or a person who is
under contract to Mint arrives with stock holdings. In such cases, you have
these options:

--You can divest your holdings.

--You can ask the Editor to let you keep your holdings with the understanding
that you must recuse yourself from covering companies (and their industries) in
which you own securities.

Be aware, though, that even if you get such permission, recusing yourself
extensively could limit your assignments and your ability to perform your job.

2. Reporting share ownership.

You must disclose in a confidential memo to the Editor your ownership of shares
individual corporations and also such holdings of your spouse, significant
other, and other members of your immediate family. Your shareholdings memo does
not have to disclose the number of shares you own, just the company names.

You must submit this memo on your holdings to the Editor every six months using
a form that will be provided to you. New editorial employees must sign this Code
when they are hired--and immediately thereafter submit the required
share-disclosure statement.

3. Reporting other conflicts.

You must include with your financial disclosure memo a description of any other
potential conflict of interest, including your other financial holdings plus any
personal conflict that might arise from family connections or employment. If
your spouse works at, for example, Reliance or The Economic Times, please
disclose this information.

If you own no securities and have no potential personal conflicts, say so in
your memo.

4. Other conflicts.

During the discussion of a potential assignment, you must also disclose other
business activities that may conflict with your Mint work, or that may appear
to. Such activities include but aren't limited to: Holding a part-time job,
working as a consultant, engaging in any form of public relations in any
capacity, accepting speaking fees, ghost writing material for anyone other than
an independent author, accepting compensation in any form for anything other
than journalistic work, writing for publications that Mint considers to be
competitors, and doing commercial photography or design work for the subject of
a story or a broadcast segment you'll be helping Mint prepare.

5. Plagiarism and fabrication.

We don't copy the work of others. And we don't make things up. We do not
plagiarize, meaning that we do not take the work of others and pass it off as
our own.

We must gather and verify every piece of information we present. On the rare
occasion when we can't confirm a critical fact another publication has reported,
we must credit that publication. If you ever have a question about the use of
such material, you should consult the Editor, the deputy Editor, or your
immediate editor. You should also notify all three if you feel that another
publication has plagiarized your work.

A Mint staffer who reports and writes a story must use original content,
language and phrasing. It is okay for a Mint staffer to include in his or her
work passages from a previous Mint story by another writer – generally
background, or boilerplate. This is acceptable if the passages are short.
Regardless, the reporter writing the story is responsible for the factual and
contextual accuracy of the material. We do not transmit news releases in their
original form; we try and rewrite them, so that the approach, content, structure
and length meet our requirements and reflect the broader audience we serve. We
can use information and quotes from releases provided we clearly cite the
source, but we must try check/augment it with information from other sources,
and then write our own stories. A story that appears in our paper and has
plagiarized work from a press release is a serious violation of our Code of
Conduct.

We don't publish forward-looking statements that are not attributed. For
example, a statement in your story that says "Bajaj is set to overtake Hero
Honda in the motorcycles market" needs to be attributed. Companies cannot make
sure statements to market regulators and we must not become a vehicle for them
to make such statements anonymously through us.

6. Relations with sources and other outsiders.

a. Unorthodox reporting techniques.

We do not practice surreptitious entry. You must not misrepresent yourself to
gain access to information for a story. This doesn't preclude us from using
extraordinary reporting efforts, but we always do so above board and as clearly
identified Mint employees. Any other approach could compromise the use of the
material so gathered, and could give rise to a legal claim. Unusual reporting
techniques should have the approval of the Editor. Please get formal approval
for all Right To Information requests that you might seek to make on behalf of
the newspaper prior to seeking such information.

"However, mystery shopping efforts that ultimately benefit the end user are
allowed as long as they have been cleared by the Editor."

b. Disclosure, early and otherwise.

You may need to tell a source what a story is about, so that the person can
provide the information you seek or respond to points in the story. But it is a
violation of the Mint Code to show a pre-publication version of a story, Q&A,
video or audio segment, or any other piece of journalism to anyone outside the
editorial staffs. However, top editors may make exceptions on occasion -- for
example, to accommodate the needs of our publicity department or of our
editorial partners.

Writers and editors may also read or e-mail to sources selected phrases or
direct quotes before publication when there is no other practical way to ensure
the accuracy of a story or a Q&A, or to secure a necessary response. You may
not, however, read or send to sources entire stories or scripts, or extended
sections of either, except with the permission of the Editor.

As a rule, in short, you may not tell sources or anyone else outside the staff
details of what is in a story, when a story will appear, or what stories will
appear, before the paper's official release time, which is 6 a.m. of each
publishing day. Except as otherwise authorized by the Editor, no one may give
sources, advertisers, or anyone else copies of the magazine or electronic
versions of magazine stories before the official release time. Additionally, you
may not tell anyone about the contents of Web-only stories or of broadcast
segments before they go public. It is permissible to convey deadlines in order
to get the information you are seeking from a source but this does not extend to
telling sources when the story will run since stories can be held by your
editor(s).

In addition to leading to potential securities law consequences, the unplanned
distribution of information before its official release can jeopardize important
legal protections we enjoy under the Indian Constitution and under state
constitutions and laws.

Except with the approval of the Editor, you should not do stories that involve
your family, work colleagues, relatives, or friends. For purposes of this Code,
a friend is someone you socialize with outside of normal business settings and
is more than a social contact. When in doubt, let your editor know the nature of
your non-work relationship.

Finally, we must hold our own trade secrets and proprietary information
inviolate. This includes not only cover and story schedules but all internal
memos and discussions or decisions leading to the creation of specific stories.
In addition, you should not disclose to outsiders our discussions of personnel,
strategy, and tactics.

c. Financial dealings with sources and subjects of stories.

We do not pay for information. Period. Moreover, you may not enter into a
financial relationship of any kind with a source, except with the consent of the
Editor.

You may do business with companies you cover for the purpose of securing normal
bank loans, mortgage loans, and credit cards. In all such cases, however, you
may not receive favorable terms that are unavailable to the general public using
your Mint affiliation. This does not apply to any group discounts obtained by
Mint for its employees.

d. Gifts, meals, and entertainment.

You may not accept gifts from companies, from their public relations firms or
agents, or from any other supplier of information -- not a bottle of wine during
the holidays, not a reduced-rate membership for your personal use. During
company visits, you may accept mementos or a sample product of nominal value
(less than Rs100). It is okay to accept reasonable amounts of perishable food
products for a specific festival occasion when refusal or returning to sender
could seem inappropriate. But you must refuse, return, or donate to charity any
unsolicited gifts of more than nominal value -- the choice in the latter three
instances being up to the sender, whom you must contact immediately. Obviously,
you may not solicit gifts. When in doubt please inform the Editor's office of
any issues in this area.

In addition, you generally may accept lunch or dinner only from a source with
whom you are likely to meet often enough to return the favor (the one exception
being an interview over a meal with a source at the person's offices). In all
other instances, you or Mint must pay your tab. It is generally acceptable to
have lunch or dinner if that is part of a group press event and if it does not
interfere with your work.

You must use review copies of books, video games, and the like only for
editorial purposes -- or else, as practicable, forward them to a person
designated by the Editor for product reviews. You may not sell such materials
for any reason.

You may accept the use of a review or test model of a new product -- computers,
software, and any other products, including subscription services -- for only as
long as your reporting needs require. In most cases, this means only a few days
-- and not for an extended period. Please inform your immediate editor ahead of
requesting such a product.

In situations where a company with whom Mint has an editorial partnership offers
you favors, you must comply with the Mint Code of Business Ethics, which states
in part: "No gift having more than nominal value and no loan (other than a
normal bank loan) may be accepted from any person or firm having current or
prospective dealings with the corporation."

e. Travel.

You may not accept junkets--that is, trips paid for by a source or prospective
source, without specific prior approval of your immediate editor. If a trip is
worth taking, Mint will typically pay for it. If it is necessary to fly on a
corporate plane, we will seek to reimburse the host company for the cost. Such
travel must be approved in advance by the Editor or the Managing Editor. In all
cases, you will not make any commitment that promises any specific
coverage—quantity/tone--in Mint.

f. Freelancing.

If you wish to undertake a freelance assignment, have your request approved in
writing by the Editor. We will not grant permission to write for any competing
publication or for any work that first should appear in Mint or that would
interfere with your work here. In general, you can't accept an assignment if it
would inhibit Mint from doing a story.

In addition, all editorial and business employees must get the Editor's
permission before starting a personal blog--outside of HT Media's own web
sites--that focuses on issues or topics that Mint regularly covers. You must
also ensure that your personal blog--whatever the topic--doesn't mention your
affiliation with Mint or HT Media, and that it never damages the reputation of
Mint. News staffers should also not comment on other blogs nor respond directly
to any blogs that mention their work for Mint or any Mint issues. Please bring
to the attention of your editor any such references to Mint if you feel that the
reference needs a response. You are also encouraged not to respond in other
blogs to matters related to your coverage areas or HT Media. If you have a
personal web site that is not aimed at soliciting business or advertising, it
would be permissible to mention your Mint affiliation subject to approval from
the Editor.

Moreover, no one may undertake an assignment of any kind for a company, industry
group, political party, labor union, or any third party with whom your personal
affiliation might undermine the reputation of Mint for impartial and independent
journalism.

Mint encourages its news staff to participate in journalism-related activities,
including taking guest lectures at journalism schools, provided such activities
don't interfere with your work and provided it is made very clear that such
activities are being undertaken in your personal capacity. We will not approve
the use of Mint affiliation in any advertising that the third-party might want
to use to attract students/business to their institute.

g. Personal appearances.

You must get prior approval from the Editor or the Managing Editor for all TV
and radio interviews, speeches, panel discussions and any other public
appearance as a representative of Mint, except when such appearances are
arranged by Mint's publicity staff. You may generally identify yourself as a
Mint employee during discussions or presentations at educational institutions.

No one may accept honoraria or expenses for such appearances without the written
consent of the Editor.

D) POLITICAL AND CIVIC ACTIVITIES:

Many companies, for a variety of reasons, participate in the partisan political
process, at various levels of government. As a publisher, Mint will have a
different tradition. Mint does not contribute, directly or indirectly, to
political campaigns or to political parties or groups seeking to raise money for
political campaigns or parties. All news employees and members of senior
management with any responsibility for news should refrain from partisan
political activity judged newsworthy by their senior editor or in the case of
senior management, the Editor. Other political activities (including "issue
oriented" activity) are permitted, but should not be inconsistent with this
code.

On the other hand, it is not the intention of Mint, or of this code, to dissuade
employees from participating actively in civic, charitable, religious, public,
social or residential organizations. Such activities are permitted, and even
encouraged, to the extent that they:

 * Do not detract from performance or effectiveness at work;
 * Do not, by their extensiveness, cause the company to subsidize or appear to
   subsidize the activity; and
 * Do not otherwise violate this code. In the event that a conflict arises or
   may arise between an outside organization with which an employee is
   affiliated and the interests of Mint, the employee should refrain from
   participating in the conflicting or potentially conflicting activity.

No Mint employee should permit his or her Mint affiliation to be noted in any
outside organization's materials or activities without the express written
approval of a member of senior management or unless of course the employee
serves as a representative of Mint or unless the affiliation is noted as part of
a broader description of the employee's identity.

E) PERSONAL CONDUCT:

1. You may not use your Mint affiliation -- including your business card or
business stationery -- for personal advantage in any way. Period.

Among other things, this means that you will never invoke the Mint name or your
title when seeking to resolve a personal dispute with a merchant, financial
institution, government agency, or anyone else. You may not court favoritism
based on your Mint affiliation. You will, for instance, not try and get tickets
or restaurant reservations, for personal use invoking your role at Mint. Nor
will you seek entry to events that you are attending in your personal capacity
using your Press identity or car stickers.

2. You must avoid high-profile roles in the public spotlight, including in
political campaigns (avoid marches and demonstrations, for example) or in
fundraising that could associate the Mint name with your personal causes or
beliefs.

3. You should never endorse a product, with the exception of the one for which
you work.

4. We respect and protect manufacturers' copyrights on all computer software
used by Mint employees. You may not copy, sell, share, or trade any
company-owned or leased software without the express, written permission of the
copyright owner or approval by the Mint legal department. Nor may you copy
software from one machine to another without the express, written permission of
the copyright owner or approval of the Mint legal department.

5. Computer equipment -- including hardware, software, and any related material
-- that Mint loans to you for use outside the office remains the property of
Mint. You are to return any loaned equipment at the end of the assignment and/or
at the end of your employment with Mint. Software on loaned equipment is owned
by Mint, and you can't copy, sell, share, or trade it without Mint's written
permission.

6. As long as you are an employee of Mint you must keep in mind that you are
always representing the company and could be under public scrutiny. Your
behavior at all events should be exemplary and you will also present yourself,
in terms of what you wear and how you behave, in a manner consistent with the
event, setting and people you are meeting. Working for a business information
newspaper/website also places an extra burden on you to convey a professional
image because you will often be in business and professional settings and your
grooming and attire must be appropriate. All these norms also apply to your
appearance and behavior in the office. As a representative of the paper, you
will be requested to exercise sound judgment in matters such as consuming
alcohol at press or public events that you are attending as a representative of
HT Media. Please remember that as a member of the news media, you will achieve
certain name and face recognition as part of your job and that your behaviour
outside work could sometimes inadvertently reflect on your organization. There
will be no alcohol consumed or stored in the office except when it is a
newsroom-wide official event that has prior approval of the Editor's office.

7. As part of protecting HT Media's intellectual property, you will not allow
access into the newsroom for any outsider. There will be no individual or group
tours of the newsroom unless they have been cleared in advance with the Editor's
office. You will not have meetings with outsiders at your desk or any other
place in the newsroom except for pre-booked conference room areas. This applies
in particular to meetings with other media professionals, including all Public
Relations professionals and corporate executives.

8. This Code of Conduct specifically bars employees from discussing compensation
or salaries of any other employee in the newsroom. Please note that employees
are discouraged from sharing their personal compensation details with outsiders
and the fact that someone voluntarily disclosed his/her compensation is not a
reason to violate the prohibition about discussing someone else's compensation.
We compensate each employee based on their experience, performance, role and
expectations we have of them. Any compensation discussions that you engage in
with your immediate supervisor or HR need to be about your own issues.

9. Mint takes all sexual harassment issues very seriously. Please make sure you
are aware of HT Media's sexual harassment policies that are available with the
human resources department.

F) ACCOUNTING AND FINANCES:

It is essential to the successful operation of Mint as a business, and to the
preservation of investor confidence in the company, that the integrity of our
books and records be resolutely maintained. The responsibility for this does not
rest exclusively with accounting or other financial personnel--we all share it.

Accordingly,

 * No Mint fund, asset or liability which is not fully and properly recorded on
   the company's books and records shall be created or permitted to exist;
 * No transaction shall be effected and no payment shall be made on behalf of
   Mint with the intention or understanding that the transaction or payment is
   other than as described in the documentation evidencing the transaction or
   supporting the payment;
 * All employees shall comply with HT Media' accounting principles, procedures
   and controls, and no false, artificial or misleading entries in any books or
   records of the company shall be made for any reason whatsoever including
   expense records related to travel, telephones and other reimbursements sought
   from Mint.
 * No employee will issue or authorize anyone else to issue any company document
   that is false or misleading;
 * No employee will knowingly accept and treat as accurate any false or
   misleading document prepared by a person not employed by HT Media; and
 * No employee will knowingly make any false or misleading statements to our
   external or internal auditors. Indeed, when questioned by any auditor, all
   employees should be fully forthcoming.

G) EMPLOYMENT:

Mint strives to ensure that all employees are treated with dignity and respect.
Among our goals are to make benefits and services available to employees to
promote their well-being, to communicate effectively with employees, to ensure
equal employment treatment, to maintain a safe work environment, to assist
employees in realizing their potential and maximizing their productivity, and to
fairly evaluate and recognize performance.

For its part, the company expects employees to perform excellent work in a
cost-effective manner, to strive for quality and productivity, to follow
directions and instructions, to properly care for facilities and equipment, to
anticipate problems and suggest improvements, to treat other employees and
clients and customers with honesty and courtesy, and to be energetic in the
performance of tasks and fulfillment of goals.

Mint values the talents and contributions of its employees. The company also
seeks and values diversity among employees, recognizing that a mix of people
enriches the company and encourages creativity and business growth. HT Media'
policy is to provide equal employment opportunities and advancement
consideration to all individuals based on job-related qualifications and ability
to perform the job, without regard to race, color, ancestry, national origin,
religious creed, sex, disability, veteran status, sexual orientation, age or
marital status. It is also HT Media' policy to provide a working environment
that is free of intimidation or harassment based on any of these factors,
especially sexual harassment. This also extends to what you view on your work
computer and what you display in your work area within the office or what you
communicate orally or through emails with other colleagues.

Complete statements of policies setting forth the company's standards regarding
personnel matters, and other matters relating to employment with Mint, are
available from Mint human resources department. These policies meet legal and
regulatory requirements of various jurisdictions in which Mint does business,
and employees of Mint are required to comply with these policies.

H) ENVIRONMENTAL CONCERNS:

Mint is committed to maintaining a safe work environment by eliminating all
significant recognized hazards in the workplace, and to conducting business in
an environmentally sound manner based on scientific understanding, customer
needs and local requirements. Employees are required to comply with all
applicable health, safety and environmental laws and regulations, and all
related company policies.

I)  SOCIAL MEDIA POLICY

Overview:

A number of Mint employees have personal accounts on social networking sites
(like Facebook, Orkut or Myspace) and may also maintain personal blogs and/or
micro blogging accounts.

Use of these sites is certainly permitted, and Mint realizes that these sites
can be useful ways to gain information pertinent to the work we do. But it is
important that employees not use such sites in any way that could compromise
Mint's impartiality, editorial integrity, or code of conduct.

The following guidance note sets out the principles to which Mint staff members
are expected to adhere when using the Internet for social media interactions.

In general:

- Staff should always act in a transparent manner when compiling or altering
online sources of information. - Employees should not engage in activities on
the Internet, which might bring Mint into disrepute.

- They should not use the Internet in any way to attack or abuse Mint
colleagues, whether by name or in general.

- They should not post derogatory or offensive comments on the Internet. If such
comments can be traced back to a Mint employee, there is a chance of "crank" or
frivolous litigation against the organisation. Such litigation may not succeed,
but Mint does not wish to invite such litigation in the first place.

- If an employee is recognized to be an employee of Mint (either via byline or
any other way), their personal blog / Twitter account / online profiles should
include the following disclaimer: "The views expressed herein are the author's
own, and do not reflect the opinions of Mint in any way."

- Any content / document that resides purely within the Mint system / network
should not be posted online (for wider access) without the written permission of
a reporting manager.

On using social media sites like Facebook / Orkut / Myspace:

In addition to following general online behaviour guidelines as outlined above:

Mint staff should refrain from mentioning that they are employees of Mint on any
personal accounts they maintain on such sites.

Refrain from providing a URL or user name or avatar that refers to Mint on your
personal profiles. (This includes permanent links to any blogs/columns that you
may author for Mint)

Editorial staff and staff in sensitive political / business beats should never
indicate a political / corporate allegiance on social networking sites, either
through profile information or through joining political / corporate groups.

Business and political reporters in particular should be careful of divulging
confidential / controversial information and opinions about their specific
beats. For politics reporters, this would mean not openly supporting the
Congress or the BJP; for an energy reporter, this would mean not openly
supporting Mukesh Ambani versus Anil Ambani. The weight of such opinions could
be misconstrued to indicate biased coverage – and whether that is true or false,
that misconstruction should not be allowed to exist.

Editorial staff and staff in sensitive political / business beats should also be
careful about joining campaigning groups. They should discuss this in advance
with their reporting manager.

Any rare exception to this must be approved in advance by the employees'
reporting manager. For instance, it may be appropriate to join Facebook groups
related to causes for reasons of research. Where this is approved, the employee
should be transparent and clearly state why he/she is joining the group.

Staff members are free to link to / play up Mint content on their Facebook pages
as long as it is done without commentary or conflicting opinions.

On using professional networking sites like LinkedIn

When using professional networking sites like LinkedIn, it is important for
staff to not misrepresent their designations / responsibilities on their
professional profiles.

Staff should not use the portal to write abusive/dismissive/damaging things
about their colleagues – be it on their own profiles, or as recommendations on
other people's profiles.

Staff should in no way refer to any information that is considered confidential
to Mint. Any confusion can be cleared up with a reporting manager. 

Consideration towards other staff members when posting photographs / blogging /
micro blogging etc . Most social networking sites allow photographs, videos and
comments to be shared with thousands of other users. However, it may not be
appropriate to share work-related information in this way.  For example, there
may be an expectation that photographs taken at a private event will not appear
publicly on the Internet, both from those present and perhaps those not at the
event. Mint may also have objections to such content appearing online.

Staff should be considerate to their colleagues in such circumstances and should
not post information when they have been asked not to. They should also remove
information about a colleague if that colleague asks them to do so.

Blogs, Twitter and other content-generation platforms

In addition to following general online behaviour guidelines as outlined above:

Mint staff should not identify themselves by their designation / association
with Mint, except with blogs on the Mint web site.

Where a staff member's association with Mint is recognizable by name / byline,
staff should be careful of the information and opinions they disclose on such
platforms.

This pertains in particular to the beats that reporters cover. Business and
political reporters in particular should be careful of divulging confidential /
controversial information and opinions about their specific beats. For politics
reporters, this would mean not openly supporting the Congress or the BJP; for an
energy reporter, this would mean not openly supporting Mukesh Ambani versus Anil
Ambani. The weight of such opinions could be misconstrued to indicate biased
coverage – and whether that is true or false, that misconstruction should not be
allowed to exist.

Indeed, it would be preferable if beat reporters did not maintain individual
blogs about their beats. So a political reporter would ideally not have an
individual blog outside the Mint ecosystem that deals with politics. Beat
reporters would also do well to not Tweet indiscreetly regarding their beats or
the companies they cover (indeed, it is preferable they don't tweet
indiscriminately at all) because this can be construed to imply bias and
prejudice.

If a staff member is contacted about his / her Tweets or blog posts by the
press, for comments or further explanation, he / she should speak to their
reporting editor before responding. This is in line with the Mint Code of
Conduct stipulation that staffers check with their reporting editor / manager
about ANY interview requests that may pertain to Mint content / operations.

Staff members are free to link to / play up Mint content on their blogs or
Twitter, as long as it is done without adverse commentary or conflicting
opinions.

Again, in line with general online behaviour guidelines, Twitter and blogs
should not be used to attack / abuse colleagues, whether by name or in general.

Editing online content

In addition to following general online behaviour guidelines as outlined above:

Mint staff members should, in general, refrain from editing content in open
access Wiki-web sites from computers at the workplace, because these web sites
track IP addresses from which changes are made. These changes may thus be
inaccurately attributed to Mint's editorial stances.

Mint staff members are free to otherwise edit content about subjects they are
familiar with, from non-workplace computers, as long as they provide the sort of
substantiation / supporting links that these web sites require. These changes
should not be attributed to Mint's editorial stances.

Such interventions, of course, should not include derogatory or abusive comments
of any nature.

When editing online encyclopedia content about Mint, staff members should be
transparent about their association with the newspaper. Corrections should be
restricted to factual content and not to subjective criticism; if such criticism
is only abusive in character, it must be reported to the web site's
administrator for action to be taken.

Such corrections should also not involve conflicts of interest on the part of
reporters, editors, and other Mint staffers.

J)  ETHICS COMMITTEE

Mint's ethics committee will be composed for four senior employees selected by
the editor. The committee members will serve for a year. In this period, they
will hear interval as well as external complaints against journalists. The
committee will hear each case, only when it deems it worthy of hearing (which
means trivial complaints will be dismissed). It will also send its
recommendations to the editor, in writing. The committee will also present, in
writing, to the board every year, a note on the cases it has heard in the course
of the year.

COMPLIANCE WITH THIS CODE

Mint takes this code of conduct very seriously.

All employees of Mint are responsible for compliance with all aspects of this
code. All new employees shall be required to read this code at the outset of
their employment, and to attest in writing that they have done so; all Mint
employees shall be required, at the time this code is first promulgated, to read
it and so attest. Such written attestations shall be required every six months.

Any employee having a question about a possible violation of this code by that
person or any other person, or in connection with any practice, should discuss
it with his or her supervisor, or the Editor. Every effort will be made to
maintain the confidentiality of such discussions.

Mint is committed to this Code. At the same time, we realize that no document
can anticipate all possible circumstances that may arise in the future. To
reiterate: When in doubt, please ask.

It may be necessary, from time to time, to clarify this set of rules or to
modify them. The Editor, as necessary, will decide on any clarifications,
exceptions, or modifications to this Code. We expect, however, that
clarifications will be rare, and that exceptions will be narrow.

Please remember: Mint's reputation is its most important asset, and anything
that damages that reputation damages both Mint and all of us. The matters
addressed by this code are sufficiently important that any lapse in judgment
within the areas covered here may be considered serious enough to warrant
discipline up to and including dismissal.



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