DOC NO.

: ANNEXURE-3 of VG-F-46

VERGER CODE OF CONDUCT

KSA SALEEM

Dear Client / Factory,

Ethical practice and Integrity are the core values on which VERGER GROUP conduct business and
behave. While mistakes may be forgiven, violations of our ethical code are intolerable. VERGER GROUP
stands for absolute honesty, integrity and professionalism. As a part of VERGER, whether direct or
indirect, you must ensure that VERGER reputation is not compromised by dishonest, disloyal or corrupt
behavior.

INTEGRITY

It is absolutely forbidden to offer, solicit or accept any commission, payment, gift, service, favor or any
other advantage, where you visit or contact for the purpose of auditing to/from any other VERGER
GROUP employee or contractor.

Commissions, payments, gifts, service or favor can be anything like:

- Money or company shares
- kickbacks on any portion of a contract payment or use of other routes or channels including
third parties for provision of improper benefits to, or receipt of improper benefits from,
customers, agents, contractors, suppliers or employees of any such party or government
officials.
- Loans
- Entertainment (shows, nightclubs, hostess clubs, gambling tokens, etc.) and vacation (paid
lodging or tickets)
- Transportation to and from a factory (VERGER tolerate however ground transportation offered
by a factory from or to remote locations if not accessible safely by public transit nor local taxis)
- Meals and drinks in restaurants (whereas takeaway meals valued below 2 USD and eaten in
factory premises, meals in factory canteen and non-alcoholic drinks you may have in factory
premises are tolerated)
- Merchandise, products and any other valuable gift

Any of the above given to one of your relative will also be considered as a breach of our code of ethics.

VERGER shall take strict compliance action against the factory/client offering bribes and the auditors
taking bribe, in any form.

IMPARTIALITY and PROFESSIONALISM

The factory shall carry out audit process in an independent and impartial manner, using appropriate
methods and procedures and following relevant requirements of applicable professional standards.

Both the factory and the auditor shall not get involved in any conflict-of-interest situation (i.e. situation
where your private interest conflicts with the interest of VERGER) or the perception of such conflicts.
The factory shall not misuse their position or authority to pursue their own private interests, which
include both financial or personal interests and those of your family members, relatives or close
 DOC NO.: ANNEXURE-3 of VG-F-46

VERGER CODE OF CONDUCT

KSA SALEEM

personal friends. When actual or potential conflict of interest arises, you will immediately make a
written declaration to VERGER GROUP.
The factory shall not enter into gambling activities with a VERGER employee or subcontractor, through
their chain of management or through one of their subordinates.

The factory shall provide data, test results and other material facts during audit in impartial manner
and will not improperly alter the records.

Any breach of the above-mentioned rules will be considered to a breach of integrity.

CONFIDENTIALITY

We shall treat all information received in the course of factory audit confidential to the extent that
such information is not already published, generally available to third parties or otherwise in the public
domain.

REPORTING UNETHICAL PRACTICES/ACTIVITIES

If any VERGER personnel or subcontracting auditor solicit any payments, gifts, fees or compensation of
any kind, please report this, in the strictest of confidence, via email or call. Confidentiality of your
identity will be strictly safeguarded, and an independent investigation will be setup within 24 hours.
Alternatively, not reporting the facts will make you an accomplice.

COMPLIANCE WITH LAWS - SAFEGUARDS

You shall perform your duty during audit in compliance with applicable laws, regulations and Company
Policies. No Employee is authorized, intentionally or by disregard of procedure, to violate any legal,
environmental, health or safety requirement.

Actions involving violence, threatening behavior, discrimination and harassment are unacceptable.

You will be required to inform management of any condition that creates a danger to the environment,
poses health and safety hazards, or may be a violation of law or ethical conduct referred to above.

While VERGER is customer focused in providing its service, it will not tolerate any breach of ethics, law,
or VERGER policy to satisfy customer requirements, whether stated or implied. Any attempt to subvert
this policy is to be reported to management.
 DOC NO.: ANNEXURE-3 of VG-F-46

VERGER CODE OF CONDUCT

KSA SALEEM

You understand that complying fully with the present code of ethics is your utmost duty. Any breach
of this code will be considered as a critical fault and involve immediate cancellation of audit process
without any notice or more severance.

ACCEPTANCE

This is to certify that I have read the above Zero Tolerance policy, and to the best of my knowledge, I
understand its intention and meaning and my responsibilities. I have the contents explained to me and
the opportunity to ask questions and seek clarification.

Representative Name:

Designation:

Stamp and Signature:

Date: