Since its inception, VCS has been governed by its core values. They shape the culture and define the character of our company. Four fundamental objectives that guide the operations of our business are
Integrity
Client Value Creation
Best People
Respect for the Individual
VCS has adopted ‘Code of Business Conduct and Ethics’ designed to deter wrongdoing and to promote:
dedicated customer focus to create customer value
honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships
full, fair, accurate, timely and understandable disclosure in reports and documents we file with or submit to the Government authorities
compliance with applicable laws, rules and regulations
Code of Business Conduct and Ethics
Responsibilities of all individuals working with VCS
To our customers, suppliers, competitors, Government departments and to the company
Protect Client data/ information
You must handle the non-public information of others responsibly and in accordance with our agreements with them. Non-public information of others includes notes, reports, conclusions and other materials prepared by a company employee based on the non-public information of others. You should protect this information as it is your company’s information.
Protecting the company’s information
In the course of your involvement with the company, you may come into possession of information that has not been disclosed or made available to the general public. This non-public information may include, among other things:
financial data and projections
proprietary and technical information, such as trade secrets, patents, inventions, product plans and customer lists
information regarding corporate developments, such as business strategies, plans for acquisitions
or other business combinations, divestitures, major contracts, expansion plans, financing transactions and management changes
personal information about employees
non-public information of customers, suppliers and others
It is your responsibility to understand the confidentiality agreement and sign it as soon as you join the company.
No conflict of Interest
Your decisions and actions in the course of your employment with the company should be based on the best interest of the company, and not based on personal relationships or benefits. You should seek to avoid situations where your personal activities and relationships conflict, or appear to conflict, with the interests of the company. This includes situations where you may have or appear to have an indirect conflict through, for example, a significant other or a relative or other persons or entities with which you have a relationship. A conflict may also arise when you take actions or have interests that make it difficult for you to perform your work for the company objectively and effectively. You should not indulge in such actions that may or may appear to, conflict with the interests of the company.
No Misrepresentation
You should respect the rights of, and deal fairly with, the company’s customers, suppliers, business partners and competitors in compliance with law. You should not take unfair advantage of anyone through deception, misrepresentation, coercion, abuse of privileged information or any intentional unfair business practice.
Safeguard Company Assets
All employees, agents and contractors are responsible for the proper use of company assets. This responsibility applies to all of the company’s assets, including your time, work and work product; cash and accounts; physical assets such as inventory, equipment, vehicles, computers, systems, facilities and supplies; intellectual property, such as patents, copyrights, trademarks and trade secrets; and other proprietary or non-public information.
You should use all reasonable efforts to safeguard company assets against loss, damage, misuse or theft.
You should be alert to situations that could lead to loss, damage, misuse or theft of company assets
You should report any loss, damage, misuse or theft as soon as it comes to your attention
You should not use, transfer, misappropriate, loan, sell or donate company assets without appropriate authorization
You must take reasonable steps to ensure that the company receives good value for company funds spent.
You may not use company assets in a manner that would result in or facilitate the violation of law
You should use and safeguard assets entrusted to the company’s custody by customers, suppliers and others in the same manner as company assets
Accuracy of records and reports
It is important that managers and other decision makers, creditors, customers and auditors have complete, accurate and timely information. False, misleading or incomplete information undermines the company’s ability to make good decisions about resources, employees and programs and may, in some cases, result in violations of law.
Even if you are not directly involved in financial reporting, you are likely involved with financial records or reports of some kind—a voucher, time sheet, invoice or expense report. In addition, most employees have involvement with product, marketing or administrative activities, which can affect our reported financial condition or results.
Therefore, the company expects you to use all reasonable efforts to ensure that every business record or report with which you deal is accurate, complete and reliable.
No Improper payments
You should not authorize, offer, promise or give, or solicit or accept, money, gifts, entertainment, privileges, benefits or other items of value intended to improperly influence, directly or indirectly, any business decision or that otherwise violate law or create the appearance of impropriety.
Have Free and fair competition
It is our policy to lawfully compete in the marketplace. Our commitment to fairness includes respecting the rights of our competitors to compete lawfully in the marketplace and abiding by all applicable laws in the course of competing.
Public communications and filings
The company files reports and other documents to regulatory authorities. In addition, from time to time the company makes other public communications, such as issuing press releases. You are expected to use all reasonable efforts to provide complete, accurate, objective, relevant, timely and understandable answers to inquiries related to the company’s public disclosures.
Individuals involved in the preparation of public reports and communications must use all reasonable efforts to ensure full, fair, accurate, timely and understandable disclosure in our public reports and communications. If you believe that any disclosure is materially misleading or if you become aware of any material information that you believe should be disclosed to the public, it is your responsibility to bring this information to the attention of all the Directors.
Procedural Matters
Code of Business Conduct and Ethics has been put at VCS public site. Those who are working with VCS have the responsibility to check it regularly to see the changes, if any.
Reporting violations
You should promptly report violations or suspected violations of this Code to both the Directors. If your situation requires that your identity be kept secret, your anonymity will be preserved to the greatest extent reasonably possible. If you wish to remain anonymous, send a letter addressed to the Managing Director, Value Chain Solutions (India) Pvt Ltd, 209-212, ORNET Arcade, Opp. Simandhar Tower, Vastrapur, Ahmedabad – 380015, Gujarat, INDIA. If you make an anonymous report, please provide as much detail as possible, including copies of any documents that you believe may be relevant to the issue.
Investigations
The Board of Directors or its designated committee will be responsible for investigating violations and determining appropriate disciplinary action for matters involving members of the Board of Directors or executive officers.
Disciplinary action
The company will take appropriate action against any employee, agent or contractor whose actions are found to violate the Code. Disciplinary actions may include, at the company’s sole discretion, oral or written reprimand, suspension or immediate termination of employment or business relationship, or any other disciplinary action or combination of disciplinary actions as deemed appropriate to the circumstances.
Additional Information
Nothing in this Code of Business Conduct and Ethics creates or implies an employment contract or term of employment. Employment at the company is employment at will. Employment at will may be terminated with or without cause and with or without notice at any time by the employee or the company. Nothing in this Code shall limit the right to terminate employment at will. The policies in this Code do not constitute a complete list of company policies or a complete list of the types of conduct that can result in discipline, up to and including discharge.
Revision Date – July 1, 2009
