1 Impartiality

Carrying out assigned work in a professional, objective, and impartial manner. Inappropriate behaviour is not allowed, and Conpectus has zero tolerance for breach of integrity, Impartiality and Confidentiality. Further Conpectus associate found to have offered, solicited, or accepted any form of bribe or incentive then service of such personal will be terminated.

Conpectus is committed to being honest & to ensure impartiality in providing Third Party Inspection, Audit, Assessment and product certification services by:

• 1.1. Identifying and evaluating the probable risks to impartiality.
• 1.2. Imparting appropriate measures to eliminate or minimize the potential risk.
• 1.3. Preventing Organizational, Commercial or other pressures from impartiality.
• 1.4. Inculcating impartiality as a culture among associates.
• 1.5. Periodically review the risk and the mitigation to keep them up to date.

2 Independence

Conpectus maintains its independence of judgment and does not surrender to pressure and inducements to misrepresent findings or alter the true & accurate results of its activities (inspections, audits & assessment, product certification) by –

• 2.1. Being neutral and financially/commercially independent.
• 2.2. Being independent of the parties involved and is not linked to any party directly involved in design, manufacture, supply, installation, purchase, ownership, use or maintenance of the items inspected, or similar competitive items or facilities audited and assessed by Common ownership, Contractual arrangements, informal understandings or other means that may have an ability to influence the outcome of any services.
• 2.3. Remunerating associates independent of the activities.
• 2.4. If any of your family members or relatives are about to join Conpectus or attend an interview, you should immediately inform your manager. This information will help Conpectus to avoid future conflicts of interest arising due to family or relative relationships.

3 Conflict of Interest

• 3.1. Conpectus is committed to act as a faithful service provider and not engage in any activity that presents an unacceptable conflict of interest and avoid any perception of the same.
• 3.2. Company has an efficient system in place to avoid/neutralize/mitigate any actual or apparent conflict of interest.
• 3.3. Conpectus and its associates shall never engage in any conduct which is, or could potentially be, harmful to its reputation.
• 3.4. In case conflict of interest arise while dealing with family member, personal investments etc. has been addressed in the Code of Conduct for Associates in the relevant sections.

4 Integrity

• 4.1. Conpectus is committed to conduct its business and govern itself with integrity in a manner that is ethical, transparent and accountable.
• 4.2. Conpectus and its associates shall perform their work being honest, diligent, responsible and not tolerate any deviation from its approved methods & procedures.
• 4.3. Conpectus and its associates shall take due professional care to reflect actual findings in the report which must remain confidential & not be improperly changed on anyone's pressure, threat, favour etc.
• 4.4. All associates are required to abide by the company's code of conduct, policies and procedures.
• 4.5. All associates shall take decisions based on material facts in good faith and best professional judgment. No misleading or untruthful reports or certificates to be issued.
• 4.6. Conpectus and its associates shall engage themselves in those services for which they have the necessary competence.
• 4.7. Conpectus and its associates shall maintain accurate records, reporting and accounting of all financial transactions.

5 Anti-Corruption / Anti Bribery

• 5.1. We at Conpectus have adopted and implemented a zero-tolerance for breach of anti-corruption and anti-bribery policy.
• 5.2. Conpectus associates must never, directly or indirectly through intermediaries, offer or promise or accept or give or solicit:
  • a) any personal or financial or non-financial benefits
  • b) tangible or intangible favours
  • c) accommodations and free transportation
  • d) Gifts, expenses, inducement, reward
  • e) other advantage
  In order to:
  • a) obtain or retain a business or other advantage.
  • b) return or receive preferential treatment.
  • c) impair or be presumed to impair its professional judgment.
  • d) person acting, or refraining from acting, in relation to the performance of that person's duties.
• 5.3. Conpectus and its associates shall not indulge in any Act of utilizing, either directly or indirectly, one's access to a position of power or knowledge to demand unmerited cooperation or compensation because of coercive threats.
• 5.4. Conpectus shall account all its charitable contributions or sponsorships in a separate ledger and consolidate all such payments made by any of the operations that form part of its organisation.
• 5.5. Conpectus and it's all associates will ensure that charitable contributions and sponsorships are not being used as a subterfuge for bribery.
• 5.6. Conpectus consider making facilitation payments as bribe and prohibit them.
• 5.7. Conpectus and its associates are prohibited to make any offer of bribe or inducement to any authority or agency acting on its behalf for securing any advantage to the company.
• 5.8. No employee will be penalised or face any adverse consequences for refusing to pay a bribe or for refusing to engage in corrupt practices or refusing to make a facilitation payment.

6 Legal Requirements & Regulations

• 6.1. Conpectus is committed to fully complying with National & International regulations and laws, including anti-corruption and anti-bribery. Where appropriate, Conpectus cooperate with law enforcement authorities on suspected or actual offenses against these laws.
• 6.2. Committing fraud is severely punished by national laws; Conpectus does not tolerate it in any form.
• 6.3. Conpectus and its associates shall not be knowingly a party of any illegal activity or indulge in acts that are detrimental to the profession or to the organization.

7 Safeguarding Confidential Business Information & Data Protection

As the nature of business that we are in, requires our customers to share with us their confidential business information, we understand the importance of such information. The unauthorized disclosure, while you are employed by the Company and thereafter, of any of the Company's confidential business information or intellectual property such as financial data, formulae, processes, advertising methods or prospective transactions, to any other person, firm or corporate is prohibited. The use – directly or indirectly – of confidential Company business information, while you are employed by the Company and thereafter, for your personal benefit, for the benefit of your immediate family or for the benefit of any other person, firm or corporate is prohibited. The use of such information generally to the possible detriment of the Company also is prohibited.

• 7.1. In social compliance audit service, Handling of sensitive information is very much important. Reporting of sensitive issues which may lead to retaliation against workers, or attempt bribe, threaten, or coerce. Associate auditor shall handle such situations in a manner which protects worker and associate auditor.
• 7.2. Protection of workers shall be prioritized by respecting the confidentiality of information collected during worker interviews. Specifically, if issues raised by workers need to be discussed with auditee management it must be done with caution, ensuring comments cannot be traced back to individuals.
• 7.3. To the extent sensitive information is received by a Member/ Conpectus Inspection service in the conduct of a social compliance service, such information shall be communicated to an appropriate party – whether the client, service requestor, program owner, or authorities – for the benefit of the worker or the Member Auditor / Conpectus associate auditor.
• 7.4. Conpectus shall treat all information received in the course of the provision of its services as commercial-to-confidence to the extent that such information is not already published or made generally available to third parties or otherwise in the public domain. Conpectus protects clients and their factory's confidential information including details of the factory, shipment, etc.
• 7.5. Conpectus is committed to maintain confidentiality and to ensure that all the information in our database remains accurate and complete and are protected from unauthorized access and use.
• 7.6. Conpectus has efficient systems in place to safeguard all collected data is stored & transferred in compliance with applicable law, is secure & is only accessible by authorised persons.
• 7.7. Conpectus associates shall handle, with utmost diligence and care, any sensitive information that is brought to their notice through dialogue or observation and ensure that there is no attribution of the information to specific persons while communicating the findings to the client / factory management.

8 Competency

• 8.1. Personnel: Conpectus is committed to provide reliable services to its client by allocating competent person in desired services.
• 8.2. Supervision: The associates allocated for the services have been well trained in-house and onsite training, verified for their competency by witness audits, appropriate supervisory checks and proficiency testing to ensure all work is performed as directed and supports the conclusions reached.
• 8.3. Conpectus provides equal opportunity to associates to continue their professional / ethical development in their careers.

9 Fair Business Conduct

• 9.1. Conpectus is committed to conduct itself with the highest standard of business ethics and integrity.
• 9.2. Conpectus Respects the interest of all its stakeholders, by understanding their expectations and concerns, and ensuring that they benefit fairly from the value generated by the mutual business.
• 9.3. Conpectus is committed to engage and provide value to its customers in responsible manners.
• 9.4. Conpectus is committed to build its professional reputation on the merit of services and to compete fairly with competitors / within Team.
• 9.5. At Conpectus, we believe in free competition and strive to outdo our competitors through honest and fair business practices. The management, all employees and associates are committed to make only factual claims and not provide any misleading or incorrect information about our competitor, their operations and their services.
• 9.6. Conpectus is committed to adhere to Fair competition & anti-trust provisions and their compliance in accordance with the "Compliance Manual for Enterprises under the competition act 2002" This applies to services provided in India as well as to overseas client. Additionally, specific Fair competition & anti-trust provisions of overseas market are studied for ensuring compliance. Conpectus is committed not to indulge in any malpractice relating to obtaining unauthorized information about its competitors when participating in tenders.
• 9.7. Conpectus is committed to adhere to the revised National Guidelines on Responsible Business Conduct (NGRBC) recently released by the Ministry of Corporate Affairs, Govt. Of India and is taking steps for its full adoption in due course.
• 9.8. The fair business policy includes a strict prohibition to all employees, especially those engage in contractual activities not to obtain any information that is confidentially held by client, competitors through any act of incitement or inducement. Conpectus does not support obtaining any information through commercial espionage and/or data theft.
• 9.8.a Conpectus presents itself & conducts marketing in an ethical manner that is truthful & not deceptive or misleading, including any comparisons / references with its competitors and their services.
• 9.8.b Conpectus does not pay or offer improper incentives in any form for securing Conpectus's business.
• 9.9. Conpectus shall not make any contribution in cash or in any kind, to support a political, religious cause as a way of obtaining advantage in business transactions. Examples include gifts of property or services, advertising or promotional activities endorsing a political party, and the purchase of tickets to fundraising events. But any such contribution made on a personal basis, not on behalf of the Company and reimbursement must not be sought from the Company, directly or indirectly.

10 Fair Labour

• 10.1. Conpectus is committed to promote the wellbeing of all employees including external associates.
• 10.2. Conpectus prohibits any forced / bonded / prisoned labour and human trafficking/modern slavery.
• 10.3. Conpectus is committed to:
  • Ensure that remuneration to all associates including contractual associates meets applicable laws and prescribed limits of minimum wages at all times.
  • provide freedom to all their associates to choose their employment
  • fair recruitment and prohibits forced or bonded labour
  • make the terms and conditions of employment available to all associates before their employment is started – no forced or coerced labour shall be tolerated as part of disciplinary measures
  • not to use any form of prison labour
  • provide an opportunity to associates to continue their professional / ethical development in their career.
  • protect associates who, in good faith, make reports, seek advice or ask questions.
• 10.4. Conpectus shall not engage in business with or cease business with any client (or its supplier/s) or business partner if it gains knowledge that client/ business partner is in violation of applicable child labour, forced/bonded labour or any other form of non-voluntary labour, in relation to services provided by Conpectus.

11 Anti-Discrimination

Each associate is required to respect the rights and cultural differences of individuals. Conpectus is committed to following the applicable labour and employment laws wherever it operates. These include laws pertaining to freedom of association, privacy, child labour and employment discrimination.

• 11.1. Conpectus strongly believes it has the responsibility to engage in employment practices that meet the highest legal and ethical standards, ensuring that no associate will suffer undue harm because he or she raises an issue, reports a Code violation or cooperates with an investigation.
• 11.2. Conpectus ensures equal employment opportunity (Examples are hiring, compensation, access to training, promotion, termination or retirement) without discrimination or harassment based on race, colour, religion, caste, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, union membership, political affiliation or any other characteristic protected by law.
• 11.3. Conpectus prohibits any such discrimination, harassment.

12 Prevention and Prohibition of Harassment (including Sexual Harassment)

Conpectus is committed to providing a safe environment for all its associates free from discrimination on any ground and from harassment at work including sexual harassment. Conpectus requires its associates to respect everyone they work with and does not tolerate abuse, bullying or harassment in any form.

13 Health & Safety

• 13.1. Conpectus is committed to provide its services in a manner that is sustainable and safe.
• 13.2. Associate(s) safety is the first priority than anything else. Conpectus holds paramount the safety, health, and welfare of the public in the performance of professional duties.
• 13.3. Conpectus is firmly committed to a policy enabling all work activities to be carried out safely, and with all possible measures taken to remove (or at least reduce) risks to the health, safety and welfare of associates and anyone else who may be affected by our operations.
• 13.4. Associates have been advised to immediately terminate their work when there is threat to their own safety.
• 13.5. In case the conditions at the work place amounts to inflicting injury or threat to their personal safety, or serious health hazard, Conpectus Associate has been advised to tactfully extricate themselves from the immediate situation, make themselves safe and subsequently report the full details of the incident to the management.
• 13.6. The induction training imparted to all fresh recruits includes specific modules on health and occupational hazards including safety risks during on site work.
• 13.7. Conpectus encourages its associates to report any of the health and safety incidences through normal channels.

14 Raising Concerns

• 14.1. Conpectus is customer focused organisation and customer satisfaction is the utmost priority for us. Conpectus is committed to provide best of services and to handle the customer / stakeholder concerns (complaint / feedback / appeal / observation, etc.) in an appropriate way. Both anonymous and non-anonymous concerns shall be treated equally.
• 14.2. Conpectus views concerns as a tool for improvement in terms of systems, process and skills of internal resources.
• 14.3. The information provided will be kept confidential. Your name will not be disclosed in any situation if you choose to be anonymous. The case will be handled with due respect and actions will be taken appropriately.
• 14.4. It is highly appreciated to suggest / communicate to us, if you find any of Conpectus's or its associates activities are not aligned to our commitment to this code, feel free to express through below contact.

15 Ethics and Conduct Code

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