Code Of Ethics

Background, objectives and obligation:

Skyrunway Private Limited is in the direct selling business, Company translated their core values into being fair, fulfilling its commitments, transparent towards entire its shareholders. Company is in the business of direct selling and hence company engaged with its distributors with relationship principal- principal. And hence company ensures conduct of the distributors will reflect the management values and basic principles. Company adhere the code of Ethics very stringently. Distributors expected to uphold this code of Ethics as standards of the company. Distributors who fails to adhere this code of Ethics, management of company have right to terminate his contract with the company as distributors.

Object of Code: Company will ensure that at time of the advertisement and promotion of his product companies employee, distributors not mislead and inceptive to customers, as well as respect the privacy of the customers, provide full explanation of products, disclose full information of the employees as well as distributors, advise full terms and conditions of invoices and provide the comprehensive complaints and dispute resolution procedures.

1 Definitions:

1.1 Direct Selling: The sale of consumer products in a face to face manner away from a fixed retail location.

1.2 The Company The Company means Skyrunway Private Limited.

1.3 Condition of Distributorship It is a condition of distributor of the company is that this Code of Ethics is strictly observed.

1.4 Pledge Distributors of the Company pledge to adopt and enforce a code of Ethics that in incorporates the substance of the provisions of this Code as a condition of admission and continuing distributor of the company. Distributors also pledge to provide copies of this code to the customers.

1.5 Distributors Distributors are the Direct Sellers of the Company are bound directly by this Code.

1.6 Self – Regulation This Code is provides self regulations to the distributors which ensures minimum level of ethical behavior from the distributors of the company. Non-observance of this Code does results into the termination of distributorship

2. Scope a) The Code contains sections entitled “Conduct for the Protection of Consumers,” “Conduct Between Company and Distributors” The Code is designed to assist in the satisfaction and protection of Consumers, promote fair and transparent direct sale. Within the framework of free enterprise and enhance the public image of the company.

b) This Code covers all of management of the company, employees of the company, distributors and other staff of the company

c) A distributors may terminate their agreement and their obligation to adhere to the code by formally terminating agreement along with 15 days notice. This however does not negate the obligation by the distributors to fulfill obligations incurred during the period of their agreement.

d) Obligations to comply with the Code shall not cease until the last obligation to do anything required by the Code has been performed.


2.1 Prohibited Practices Distributors shall not use misleading, deceptive or unfair sales practices. Distributors are not allowed to mislead customers or other person by making false statement such as job availability, fix salary, company make available room etc.

2.2 Identification At the initiation of a sales presentation, Distributors shall, without request, truthfully and clearly identify themselves; the identity of Company; the nature of their Products; and the purpose of their solicitation to the prospective Consumer.

2.3 Explanation and Demonstration Distributors shall offer Consumers accurate and complete product explanations and demonstrations regarding price and, if applicable, credit terms; terms of payment; a cooling-off period, including return policies; terms of guarantee; after-sales service; and delivery dates. Distributors shall give accurate and understandable answers to all questions from Consumers. To the extent claims are made with respect to product efficacy, Distributors should make only those verbal or written product claims that are authorized by the Company.

2.4 Order Form / Receipt company is encouraged to ensure that its Distributors make available a written Order Form/Receipt if asked for by the consumer prior to the time of the initial sale. The order forms should have full details of the Company and the Direct Seller which should include the name, permanent address, telephone number, terms of sale and full details of the cooling off period and buy back guarantee.

2.5 Literature Promotional literature, advertisements and mailings shall not contain product descriptions, claims, photos or illustrations that are deceptive or misleading. Promotional literature shall contain the name and address or telephone number of the Company and may include the telephone number of the Distributor.

2.6 Testimonials Companies and Distributors shall not use any testimonial or endorsement that is unauthorized untrue, obsolete or otherwise inapplicable, unrelated to the offer or used in any way likely to mislead the Consumer.

2.7 Comparison and Denigration Employees of the company and Distributors shall not use comparisons which are misleading. Points of comparison shall be based on facts which can be substantiated. Companies and Distributors shall not unfairly denigrate any Company, business or Product, directly or by implication. Employees of the Company and Distributors shall not take unfair advantage of the goodwill attached to the trade name and symbol of another Company, business or Product.

2.8 Return of Goods Whether or not it is a legal requirement, Employees of the Company and Distributors shall offer a minimum period of 7 days to the customer in writing to return the goods. Return of goods is applicable from the date of delivery to the consumer.

2.9 Respect of Privacy Distributors shall make personal or telephone contact with consumers only in a reasonable manner and during reasonable hours to avoid intrusiveness. A Direct Seller shall discontinue a demonstration or sales presentation immediately upon the request of the consumer. Distributors and Employees of the Company shall take appropriate steps to ensure the protection of all private information provided by a Consumer, a potential Consumer, or a Distributors.

2.10 Fairness Distributors shall respect the lack of commercial experience of Consumers. Distributors shall not abuse the trust of individual consumers, or exploit a Consumer’s age, illness, lack of understanding or unfamiliarity with a language.

2.11 Referral Selling Employees of the Company and Distributors shall not induce a person to purchase goods or services based upon the representation that a Consumer can reduce or recover the purchase price by referring prospective customers to the Distributorfor similar purchases.

2.12 Delivery Employees of the Company and Distributors shall accomplish Consumer orders in a timely manner.


3.1 Distributors Compliance Company shall require their Distributors, as a condition of membership in the Company’s distribution system, to comply with the standards of this Code.

3.2 Recruiting Employees of the Company shall not use misleading, deceptive or unfair recruiting practices in their interaction with prospective or existing Distributors.

3.3 Business Information Information provided by Employees of the Company to prospective or existing Distributors concerning the opportunity and related rights and obligations shall be accurate and complete. Employees of the Company shall not make any factual representation to a prospective Distributor that cannot be verified or make any promise that cannot be fulfilled. Employees of the Company shall not present the advantages of the selling opportunity to any prospective recruit in a false or deceptive manner.

3.4 Remuneration and Accounts Employees of the Company shall provide Distributors with periodic accounts concerning, as applicable, sales, purchases, details of earnings, commissions, bonuses, and other relevant data, in accordance with the company’s arrangement with the Distributors. All financial due shall be paid and any withholdings made in a commercially reasonable manner.

3.5 Earnings Claims Employees of the Company and Distributors shall not misrepresent the actual or potential sales or earnings of their Distributors. Any earnings or sales representations made shall be based upon documented facts. With great care taken to show the differences between newly recruited Distributors (whose earnings may be limited) and experienced Distributors. Employees of the Company that make or allow direct levels.

3.6 Relationship (Cooling Off Period) Employees of the Company shall provide to their Distributors a 1 months cooling off period which will entitle her/him to: 1. Refund of any entry fee paid upon his resigning and returning all materials/goods received by him at the time of joining. 2. Distributor shall also be entitled to return any other product purchased by him during these 30 days period notwithstanding the 30 days limitation provided for a buyback/return of goods which are in good condition, useable, re-saleable & re-stock able.

3.7. Fees Companies and Distributors shall not require Direct Sellers or prospective Direct Sellers to assume unreasonably high entrance fees, training fees, franchise fees, fees for promotional materials or other fees related solely to the right to participate in the company’s distribution system. Any fees charged to become a Direct Seller shall relate directly to the value of materials, products or services provided in return.

3.8 Termination If requested upon termination of a Direct Seller’s relationship with a Company a) Companies shall buy back any unsold, re-saleable product inventory. b) Refund the Direct Seller’s original cost, less a handling charge to the Direct Seller of up to 10% of the net purchase price. c) The Company may also deduct the cost of any benefit received by the Distributor based on the original purchase of the returned goods. d) Whether the distributor has the right to rejoin or cannot rejoin is at the discretion of the company.

3.9 Inventory Company shall decide the package and the limits above which any distributors not allowed to stock the inventory, which is depend on the company’s stock.

3.10 Other Materials Companies shall prohibit Distributors from marketing or requiring the purchase by others of any materials that are inconsistent with company policies and procedures.

3.11 Direct Sellers Training Companies shall provide adequate training to enable Direct Sellers to operate ethically


4.1 Interaction Company shall conduct their activities in the spirit of fair competition towards other members.

4.2 Enticement Employees of Company and Distributors shall not systematically entice or solicit Direct Sellers of another Company.

4.3 Denigration Company shall neither unfairly denigrate nor allow to employees of company and distributors of company to unfairly denigrate another Company’s Products, its sales and marketing plan or any other feature of another Company.


5.1 Companies’ Responsibilities The primary responsibility for compliance of the Company and its Distributors with the Code shall rest with Company. In case of any breach of this Code, Company shall make every reasonable effort to satisfy the complainant.

5.2 Code Administrator Company shall appoint an independent person or body as Code Administrator. The Code Administrator shall monitor Companies’ observance of this Code by appropriate actions and shall be responsible for complaint handling and a set of rules outlining the process of complaint resolution. The Code Administrator shall settle any unresolved complaints of Consumers based on breaches of this Code.

5.3 Remedies The Code Administrator may require the cancellation of orders, return of products purchased, refund of payments or other appropriate actions, including warnings to Distributors or Employees of company, cancellation or termination of Distributors’ contracts or other relationships with the Company, and warnings to Company.

5.4 Complaint Handling Company and the Code Administrator shall establish, publicize and implement complaint handling procedures to ensure prompt resolution of all complaints. Company shall also establish, publicize and implement complaint handling procedures under their individual complaints, handling processes to ensure prompt resolution of all complaints.

5.5 Complaint Redressal Procedure If you have a complaint against distributors of company for any business practice you believe is unethical or illegal and a violation of the Code of Ethics, we recommend the following available options.

1. Address the complaint to the Code Administrator and to the Grievance Committee of the Company.

2. The complaint against the distributors of the Company should be in writing and should include the following basic information:

1)Date and details of the incident

2)The parties involved

3)Identify the violation of the code

4)List the amount and cost of product, if relevant, also give details of invoices and other supporting documents

5)Efforts you have made to resolve the matter (copies of e-mails or letters)

6)Outcome of the efforts made to resolve the matter

7)Responses from the parties to resolve the matter, if any

8)Present status of the complaint On receipt of the complaint it will first be forwarded to the Grievance Committee and the Code Administrator. The company must respond within 21 days. Code Administrator and Grievance Committee to review the reply from the Distributor and if prima facie it is found to be a genuine complaint then the company will have to compensate the complainant – either financially, or replace the product, or give another product in lieu, or as advised by the Code Administrator. If no prima facie case to inform the complainant accordingly. All action to be completed within 21 days. Company must have a Code Compliance Officer/Customer Service Officer

3. If the company disputes the allegations contained in the complaint, or omits or fails to take any action to represent his case within time frame given by the Code Administrator then the Code Administrator should proceed to settle the dispute;

i) On the basis of evidence brought to the notice by the complainant and the opposite party, where the opposite party denies and disputes the allegations contained in the complaint, or

ii) On the basis of evidence brought to the notice by the complainant where the opposite party omits or fails to take any action to represent his case within the time given by Code Administrator.

iii) The Code Administrator may accordingly on the basis of the material available before it either dismisses the complaint or direct the company to compensate the complainant either financially, or replace the product, or give another product in lieu thereof, or issue such other directions as may fairly resolve the dispute between the parties. If still the complainant is not satisfied with the decision of the Code Administrator then it would be advisable for the complainant to seek legal recourse for redressal of his grievances.

5.6 Publication All Employees of the Company are required to publicize Code of Ethics to their Distributors and consumers.