Code of Conduct - SKYSEA Multipurpose Herbal Pain Relief Oil

Code of Conduct

Code of Conduct


Model Code of Conduct for the Product selling Agents (Holten King Distributor’s) is a non-statutory code issued by M/S HOLTEN KING (Hereinafter referred to HOLTEN KING) a Leading Product selling Entity in India headquartered at Himachal Pradesh for adoption and implementation by Product selling Agents (Hereinafter referred to HK/HOLTEN KING Distributor/HOLTEN KING Distributor’s) while operating as Agents of M/S HOLTEN KING.


These codes of conduct shall in addition to the HOLTEN KING Distributor Agreement with the M/S HOLTEN KING. Further, the HOLTEN KING Distributor, shall abide with the agreement of Product selling and its terms & conditions.


The Model Code of Conduct for Product Selling Agents outlines the ethical standards and professional practices that should be followed by agents who are selling products on behalf of a company. The code of conduct serves as a guide for agents to ensure that they represent the company in a professional and ethical manner and that they adhere to industry standards and regulations. Our Code of Conduct is the first step for our HOLTEN KING Distributors to get clarity on any questions relating to ethical conduct. It sets forth our core values, shared responsibilities, global commitments, and promises, and general guidance about the HOLTEN KING’s expectations. However, our Code cannot possibly address every situation we face at work. Therefore, the Code is by no means a substitute for our good and unbiased judgment. We must remember that each of us is responsible for our own actions. Making an ethical decision is always the best suited option.

To work effectively, all of us need a healthy and safe work environment. We provide a
work environment free of coercion, discrimination, and harassment. Therefore, respect,
inclusiveness and shared ethical values are at the heart of our core values. Irrespective
of one’s department and rank, he/she should conform with our equal opportunity policy in all aspects of the work, from recruitment and performance evaluation to interpersonal

Need for Social Media Guidelines

Given its characteristics to potentially give “voice to all”, immediate outreach and 24*7 engagement, social media offers a unique opportunity to governments to engage with their stakeholders especially citizens in real time to make policy making citizen centric.Many governments across the world as well many government agencies in India are using various social media platforms to reach out to citizens, businesses and experts to seek inputs into policy making, get feedback on service delivery, create community-based programmes etc.

However, many apprehensions remain including, but not limited to issues related to authorisation to speak on behalf of department/agency, technologies and platform to be used for communication, scope of engagement, creating synergies between different channels of communication, compliance with existing legislations etc.

We comply with all laws, whether local, national or regional. All our HOLTEN KING
Distributor and those acting on our behalf must protect the HOLTEN KING’s legality. They should comply with all environmental, safety and fair dealing laws. Violations of law can result in significant harm to the HOLTEN KING, including financial penalties, denial of government contracting privileges, imprisonment for criminal misconduct and damage to our business relationships and reputation. People associated with us are expected to be ethical and responsible when dealing with our HOLTEN KING’s finances, products, partnerships, and public image.


Representation of HOLTEN KING Distributor :-

• Product Knowledge: Thorough understanding of the products being distributed, including the benefits, features, and limitations of the products. All Product selling should be legal, decent, honest and truthful.
• Every product sales transaction should be performed with an appropriate sense of social and professional obligation.
• No product sales should be executed in a manner that undermines confidence in the product selling profession and hampers consumer trust.
• All product sales actions should align with the principles of fair competition that are widely recognized in the business community.

Conduct towards consumers

 Impartiality by the HOLTEN KING Distributor
• All product sales practices should treat consumers with impartiality and fairness.The interests of the consumer should be taken into consideration, and the sales process should be transparent, honest, and not involve any deceptive or misleading tactics.

• The distributor should provide consumers with clear information about the product, its features and benefits, and allow them to make informed decisions about their purchases. It is important to build trust and confidence in the company and the product being sold.

• Strategy should be planned and executed in a manner that minimizes the potential for complaints from customers.This involves taking the necessary steps to ensure that the product is of high quality, the sales process is transparent  and straight forward, and customer inquiries and complaints are handled promptly and professionally.

• Maintain a positive reputation for providing high-quality products and exceptional customer service.

• Misleading, deceptive, or unethical sales tactics should not be employed. The distributor should not make false or           misleading claims about the product.

• High-pressure tactics which might be construed as harassment should be avoided.

• Be transparent and straightforward in all product sales activities and no product sales should be misrepresented to the consumer as a form of market research.

• HOLTEN KING Distributors should not betray the trust of individual consumers and must not take advantage of a          consumer’s vulnerabilities and and should not exploita consumer’s age, consumer’s data, health status, limited comprehension, or language proficiency.


Privacy confidentiality and disclosure


All communication should be made in a considerate manner and duringappropriate hours to avoid causing inconvenience.

• When a consumer has indicated, in a clear and unmistakable manner (such as by posting a “no soliciting” sign), that they do not wish to be contacted by distributors of HOLTEN KING, this preference must be honored.

• HOLTEN KING Distributor should stop any demonstration or sales pitch if the consumer requests it.

• Data collection and processing must be conducted in a confidential and secure manner, ensuring that all information is handled with utmost care and sensitivity.  

• Confidential and Proprietary Information Integral to M/S HOLTEN KING business success should be protected. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic
information about other companies, including current or potential suppliers and vendors.




• At the start of any sales demonstration, the representatives from HOLTEN KING  Distributors should voluntarily and truthfully introduce themselves to the consumer  and clearly state their affiliation with M/S HOLTEN KING, the products they offer,  and the reason for their approach. 

• During party selling, HOLTEN KING Distributors must ensure that both the  host/hostess and the attendees are fully aware of the purpose of the event. 

• Any promotional literature, advertisements, or mailings produced bythe HOLTEN  KING Distributor must include their mode of communication, name, address, or  telephone number, and must be approved by M/S HOLTEN KING.




The offer’s terms and conditions must be clearly stated, allowing the consumer to  understand the specifics of what is being offered and the obligations involved in  making a purchase. It is important to ensure that all disclosures in public  documents are complete, truthful, accurate, timely, and easily understandable. 




Product selling presentations and other materials must not include any product  descriptions, claims, illustrations, or other elements that could directly or indirectly  mislead the consumer. The information provided must be truthful, accurate, and  not intended to deceive the customer in any way. 


Explanation and demonstration


• The demonstration and explanation of the product being offered must be accurate  and thorough, specifically regarding pricing and any relevant credit conditions,  payment terms, cancellation periods, return policies, warranty information, customer service, and delivery details. All  communications must be consistent with  the policies set by M/S HOLTEN KING. 

• The HOLTEN KING Distributor should provide information, which is trustworthy,  unbiased, and up to date, so that consumers can make informed decisions about  the products they are interested in purchasing. By ensuring that consumers are  well-informed, the HOLTEN KING Distributor can build trust and credibility with its  customers and help to ensure the success of its business. 

• The product demonstration should be tailored to meet the specific needs and  requirements of the target consumers. 

• The representatives from HOLTEN KING Distributors must provide accurate and  easy-to-understand answers to any questions posed by the consumer regarding  the product and the offer. 

• The consumer must be provided with the opportunity to thoroughly review the  contract form without any pressure or coercion. 

• The distributor should ensure that the information is communicated in a way that  is easily understood by the individual consumer, regardless of their level of  technical knowledge.  


Order form

• A written order form should be delivered to the consumer at the time of sale, which should identify the Product selling HOLTEN KING and the HOLTEN KING  Distributor and which should contain the full name, permanent address and  telephone number of the Product selling HOLTEN KING or of the HOLTEN KING 
Distributor and all material terms of the sale. 

• All terms should be clearly legible. 


Comparisons, denigration and exploitation of goodwill


• HOLTEN KING Distributors must avoid making deceptive comparisons that do not align with the principles of fair competition.

• To avoid unfairness, the selection of points of comparison must rely on substantiated facts.

• HOLTEN KING Distributors should avoid directly or indirectly disparaging any individual, company, or product. Additionally, companies that sell products and HOLTEN KING Distributors must not exploit the positive reputation associated with the trade name and symbol of another product or company.


• In any presentation which represents any offer, the use of testimonials, endorsements, or supporting documents must be genuine, verifiable, and relevant.

• Obsolete or misleading testimonials or endorsements must not be utilized, considering the time that has passed.


• HOLTEN KING Distributor should not state or imply that a “guarantee”, “warranty” or other expression having substantially the same meaning, offers the consumer rights additional to those provided by law when it does not.

• Consumers should be able to access the terms of any guarantee or warranty, along with the name and address of the guarantor. Limitations on consumer rights or remedies, where allowed by law, must be clearly and noticeably stated.

Safety and Packaging

• When delivering products, including samples if relevant, appropriate packaging should be used.

Fulfilment of the order

• Orders should be fulfilled within 30 days from the date of the order is signed by the consumer, unless otherwise stipulated in the offer.

• HOLTEN KING Distributors should inform the consumer of any undue delay as soon as it becomes known to them.

• In such cases, any request for cancellation of the order by the consumer should be granted, and the deposit, if any, should be refunded immediately.

• If it is not possible to prevent delivery, cancellation and refunding may be made conditional on the customer’s returning of the product at the HOLTEN KING Distributor’s cost within a reasonable amount of time.

Substitution of products

• If a product becomes unavailable due to factors outside of the control of the Product selling HOLTEN KING or HOLTEN KING Distributor, it may be substituted with another product. However, the consumer must be informed of the substitution and the replacement product must have materially similar or superior characteristics and qualities, while being sold at the same or lower price.

• If such a substitution occurs, the consumer must be provided with an explanation of the substitution and informed of their right to return the replacement product at the expense of the HOLTEN KING Distributor.




• All complaints, whether from the public, consumers, or HOLTEN KING Distributors,  should be resolved following the procedure specified by the Consumer Redressal  Committee. 

• To make a complaint, customers can utilize the helpline number, email ID, or  complaint box, all of which are accessible on HOLTEN KING’s website. 

• The policy and process for grievance redressal is both effective and equitable for  consumers and all other parties involved. 

• Any complaints received should be acknowledged and confirmed within 24 hours. 

• The decisions taken must be communicated to the complainant within a  reasonable timeframe. 

Payment Terms 

The payment process must comply with the terms outlined in the Product Selling  Agreement. 

Code of Conduct for in the interest of consumer Protection 

• HOLTEN KING Distributors must refrain from denigrating HOLTEN KING, any  business, or product, either directly or indirectly. 

• HOLTEN KING Distributors are expected to refrain from taking unfair advantage  of the positive reputation and symbol associated with other HOLTEN KING  products, businesses, or trade names. Any such conduct would be considered unethical and may result in legal action being taken against them. 


Code of conduct for Social Media Marketing


These Rules apply to HOLTEN KING Distributors using social media sites such as  Twitter, YouTube, What’s app, Telegram, Facebook, Pinterest, and Snapchat  as well as online communities such as blogs. 

The Rules are That “Self-Regularization”  HOLTEN KING motto in concerning the Internet and social media marketing and  advertising is that “Self-Regularization” 

• Distributor shall fully follow the Rule “Self-Regularization” in sales, promotion and  marketing. 

• HOLTEN KING Distributor should avoid unethical and misleading in the business  of Internet selling and advertising. 

• HOLTEN KING Distributor must follow when selling or marketing on the net as  below :- 

a. All forms of advertising material must be aimed at serving the public and  upholding the truth

b. A clear differentiation factor must be maintained between corporate  communications, press releases, sales collateral, and advertisements.

c. All terms and conditions must be disclosed clearly and upfront by the publisher,  as consumers may not always notice asterisks (*) or fine print located at the  end of the document. 

d. It is necessary to inform users beforehand if cookies are utilized for monitoring  their preferences, personal data, and online behavior while browsing your  website.

e. Ads must not block or interfere with the user’s view and should not be camouflaged as editorial content.

f. Regardless of whether sales are conducted online or offline, advertisers must  comply with federal, state, and local advertising regulations.

g. HOLTEN KING Distributors need to know and adhere to the HOLTEN KING’s  Code of Conduct, Distributor Handbook, and other HOLTEN KING policies  when using social media.

h. HOLTEN KING Distributors should recognize the impact their actions can have  on both their personal image and the HOLTEN KING brand image. Any content  posted or published by HOLTEN KING Distributors on social media may  become public information for an extended period.

i. HOLTEN KING Distributors should acknowledge that HOLTEN KING may monitor the content and information they share on social media. It is advisable for HOLTEN KING Distributors to exercise caution in posting content that is not detrimental or inappropriate for HOLTEN KING, its customers, or Distributors.

j. While the list is not comprehensive, certain examples of unacceptable social media behavior include sharing content, comments, or images that are harassing, defamatory, libelous, pornographic, proprietary, or could result in a hostile work environment.

k. HOLTEN KING Distributors must not disclose or share any non-public or confidential information. If there is uncertainty about what constitutes confidential information, HOLTEN KING Distributors should seek clarification from their supervisor or the Human Resources Department.

l. Social media platforms, blogs, and other online content may occasionally result in legal inquiries or media attention.HOLTEN KING Distributors must direct such requests to authorized HOLTEN KING spokespersons; 

m. If HOLTEN KING Distributors come across a situation on social media that has the potential to become hostile, they must disengage from the conversation politely and seek guidance from a supervisor.

n. HOLTEN KING Distributors can display promotional materials on private property only after receiving written permission from the owner.

o. (To document consent, HOLTEN KING Distributors may take permission from HOLTEN KING through the Email/ letter/personally)

p. HOLTEN KING Distributors are prohibited from displaying advertising materials on public property, including utility poles, streetlights, traffic signals, parking meters, or road signs.

q. HOLTEN KING Distributors are accountable for any HOLTEN KING-related content they publish on the internet. If HOLTEN KING Distributors employ social media platforms for their HOLTEN KING enterprise, they must unmistakably and prominently disclose their name and status as an Independent HOLTEN KING Distributor.

r. HOLTEN KING retains the sole and complete authority to decide whether any recordings or images, as well as their method of use, violate the Rules or harm HOLTEN KING reputation. HOLTEN KING may request the removal of any such recordings or images. When using pictures or recordings of other individuals on social media sites, HOLTEN KING Distributors must adhere to privacy laws, intellectual property laws, social media platform guidelines, terms of use, conditions, guidelines, and HOLTEN KING Rules.

s. HOLTEN KING Distributors must not buy followers or likes or engage in any misleading or deceitful tactics to enhancethe apparent popularity of their social media accounts or pages.

t. HOLTEN KING Distributors can upload audio/video material on social media sites like YouTube as long as the content adheres to the Rules.

u. Distributors should refrain from replying to negative posts about themselves, other Distributors, or HOLTEN KING’s products. Negative posts may be reported via email.

v. Distributors must adhere to the terms of use, terms and conditions, terms of service, acceptable use guidelines, or comparable terms of the social media platforms utilized in their HOLTEN KING business.

w. HOLTEN KING Distributors must comply with the privacy policy and terms of use of each social media platform and internet service provider while utilizing social media and other digital platforms to conduct their business.

x. Data mining and website scraping tactics (including but not limited to the use of web spiders, crawlers, and bots) are considered deceptive and are prohibited.

y. That in the name of M/S HOLTEN KING, the Distributor should not claim or create any you tube channel, Blogs, Twitter account, Facebook or any other social media platform.

z. The Distributor shall not do the following activities without the prior consent of the HOLTEN KING – 

For creating YouTube channel, websites, mobile apps, podcasts, and blog  concepts, social media page such as Facebook, blogs, twitter, etc. in the name of HOLTEN KING to promote HOLTEN KING or its Brand or promote/sell the product of HOLTEN KING. 

 To post or create Blogs on any youtube channel, websites, mobile apps, podcasts, and blog concepts, social media page such as facebook, blogs, twitter, etc. in the name of HOLTEN KING to promote HOLTEN KING or its Brand or promote/sell the product of HOLTEN KING. 

 To host digital or virtual events in connection with the HOLTEN KING Direct Retailer’s/Seller’s business. 

To record, and post video and audio of live HOLTEN KING sponsored events on the channel in the name of HOLTEN KING. Before-and-after testimonial images and videos 

a. That the Distributor shall produce/market/distribute only HOLTEN KING authentic Business/commission Plan, opportunity, products or services and they would be truthful, accurate, and not misleading. 

b. That the Distributor shall use language specifically approved by HOLTEN KING and may not be altered in regard to the Business/commission Plan, opportunity, products or services contents. 

c. That the Distributor shall not use non-HOLTEN KING business dedicated properties to promote, recommend or sell HOLTEN KING products or services, or promote the HOLTEN KING opportunity. 

d. That the Distributor shall not be engaged in the false or misleading communication against the HOLTEN KING during the period of Distributor or after ceasing Distributor from the HOLTEN KING on any YouTube channel, websites, mobile apps, podcasts, and blog concepts, social media page such as Facebook, blogs, twitter, etc. 

e. That the Distributor shall legally abide with the terms and conditions of the company as mentioned in the Product selling agreement and Product selling Guidelines & Rules and Regulation. 

f. That the Distributor shall not promote or sell or market all the products which are manufactured by HOLTEN KING on any e-commerce portals without HOLTEN KING prior written consent. 


Code of Conduct for Marketing


The Code is and is deemed to be adopted and included in the Agreement between M/S HOLTEN KING and the HOLTEN KING Distributor. This code will apply to all individuals involved in marketing and distribution of any product of the M/S HOLTEN KING. 

The Product selling Agent (HOLTEN KING Distributor) / Product selling Team (DST) and its Tele-Marketing Executives (TMEs) & field sales personnel must agree to abide by this code prior to undertaking any direct marketing operation on behalf of M/S HOLTEN KING. 

Any HOLTEN KING Distributor or his team member or its staff found to be violating this code may be blacklisted and such action taken be reported to the M/S HOLTEN KING from time to time by the HOLTEN KING Distributor. Failure to comply with this requirement may result in permanent termination of business of the HOLTEN KING 

Distributorship with M/S HOLTEN KING. 

A declaration is to be signed and obtained from team members or staff by the HOLTEN KING Distributor before assigning them their duties is annexed to this Code. 

Tele-calling a Prospect (a prospective customer)

 A prospect is to be contacted for sourcing a HOLTEN KING product or HOLTEN KING related product only under the following circumstances: 
– When prospect has expressed a desire to acquire a product through any mode or  has been referred to by another prospect/customer or is an existing customer of the HOLTEN KING who has given consent for accepting calls on other products of the  HOLTEN KING. 
– The HOLTEN KING Distributor should not call a person whose name/number is flagged in any “do not disturb” list made available to him/her. 

When you may contact a prospect on telephone
Telephonic contact to a prospect must normally be limited between office timings. However, it may be ensured that a prospect is contacted only when the call is not expected to inconvenience him/her. 

Calls earlier or later than the prescribed time period may be placed only under the following conditions: 
• When the prospect has expressly authorized to do so either in writing or orally. 

Can the prospect’s interest be discussed with anybody else? 

HOLTEN KING Distributor should respect a prospect’s privacy. The prospect’s interest may normally be discussed only with the prospect and any other individual/family member such as prospect’s accountant/secretary /spouse, authorized by the prospect. 

Leaving messages and contacting any person other than the prospect Calls must first be placed to the prospect. In the event the prospect is not available, a message may be left for him/her. The aim of the message should be to get the prospect to return the call or to check for a convenient time to call again. Ordinarily, such messages may be restricted to: 

• “Please leave a message that ______________ (Name of officer) representing M/S HOLTEN KING called and requested to call back at __________ (phone number)”. 

  As a general rule, the message must indicate: 
• That the purpose of the call is regarding selling or distributing products of M/S HOLTEN KING. 

No misleading statements/misrepresentations permitted HOLTEN KING Distributor should not – 

• Mislead the prospect on any service / product offered; 
• Mislead the prospect about their business or organization’s name, or falsely represent themselves; 
• Make any false / unauthorised commitment on behalf of M/S HOLTEN KING for any 

Telemarketing Etiquettes PRE CALL 
No calls prior to official hours unless specifically requested. 
– No serial dialling 

– Identify yourself, your representation with M/S HOLTEN KING and your principal; 
– Request permission to proceed.
– If denied permission, apologize and politely disconnect. 
– State reason for your call.
– Always offer to call back on landline, if call is made to a mobile number.
– Never interrupt or argue.
– To the extent possible, talk in the language which is most comfortable to the prospect. 
– Keep the conversation limited to business matters.
– Check for understanding of “Most Important Terms and Conditions” by the customer if he/her plans to buy the               product.
– Reconfirm next call or next visit details. 
– Provide your telephone no, your  name or your M/S HOLTEN KING officer contact details 
   if asked for by the customer; 
– Thank the customer for his/her time; 

– Customers who have expressed their lack of interest for the offering should not be called for the next 3 months with the same offer; 
– Provide feedback to the M/S HOLTEN KING on customers who have expressed their desire to be flagged “Do Not Disturb”; 
– Never call or entertain calls from customers regarding products already sold. Advise them to contact the Customer Service Staff of the M/S HOLTEN KING. 

Precautions to be taken on visits/ contacts HOLTEN KING Distributors should: 
• Respect personal space – maintain adequate distance from the prospect; 
• Not enter the prospect’s residence/office against his/her wishes. 
• Not visit in large numbers – possible whenever required. 
• Respect the prospect’s privacy; 
• If the prospect is not present and only family members/office persons are present at the time of the visit, he/she             should end the visit with a request for the prospect to call back; 
• Provide his/her telephone number, your’s name, if asked for by the customer; 
• Limit discussions with the prospect to the business – Maintain a professional distance. 

Appearance & Dress Code 

HOLTEN KING Distributor’s must be appropriately dressed – 

   For men this means 
– Well ironed trousers.
– Well ironed shirt, shirt sleeves preferably buttoned down.

For women this means 
– Well ironed formal attire (Saree, Suit, etc.); 
– Well-groomed appearance. 


Jeans and/or T Shirt, open sandals are not considered appropriate. 
 Handling of letters & other communication 
Any communication sent to the prospect should be only in the mode and format approved by the M/S HOLTEN KING. 

Other Ethics 
1. Distributor shall not use misleading, deceptive or unfair recruiting practices in their interaction with prospective or existing customers as well as other Distributors and maintain cordial relationship. 
2. 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 M/S HOLTEN  KING and may include the telephone number of the Distributor. 
3. M/S HOLTEN KING prohibits HOLTEN KING Distributors from marketing to other  HOLTEN KING Distributors any materials that are not approved by the M/S HOLTEN KING and that are inconsistent with M/S HOLTEN KING policies and procedures. 
4. HOLTEN KING Distributors who sell M/S HOLTEN KING approved, legally allowed promotional or training materials, whether in hard copy, electronic, or any other form,shall :-

(i) offer only materials that comply with the same standards to which the M/S HOLTEN KING adheres.

(ii) be prohibited from making the purchase of such materials a requirement of other Distributors.

(iii) provide sales aid at a reasonable and fair cost, without any significant profit to the Distributor, equivalent to similar material available. 

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