Vestian is committed to conducting business in an ethical and honest manner. To this effect, Vestian has developed and implemented robust and continually improving policies to ensure transparency and accountability in the system.

1. Anti-Bribery Management System Policy

ABMS Policy

Vestian’s business ethos is built on integrity, transparency, and compliance to the laws of the jurisdiction it operates in. As part of our ongoing commitment to ethical business practices, we have a zero-tolerance approach to bribery and corruption; and are committed to implementing, practicing, enforcing and continually improving an effective management system to counter any attempts or acts of bribery and corruption.

Compliance

The compliance function is an independent body and is responsible for overseeing the administration and implementation of Vestian’s compliance program and will report quarterly to the governing body & top management. The Compliance Function has the authority to direct and implement compliance-related changes and to determine the corporate response to compliance-related matters.

Communicating Compliance and Policies

Raising Concerns

Employees may contact direct managers, the Chief Executive Officer, the Chief Financial Officer, the Compliance Officer or the Compliance Committee at abms@vestian.in

Monitoring, Auditing and Investigations

The compliance program includes activities designed to monitor and audit compliance with Vestian’s policies and procedures. The Compliance Officer (or designee) reviews and evaluates concerns to determine the required investigative response. Any findings from such analysis are used to trigger appropriate corrective, preventive actions or improvement. The ownership of these actions is assigned and the same is monitored and tracked till its effective closure.

Corrective Action and Discipline

Vestian management has established procedures for identifying, recording, initiating, tracking and closure of identified corrective and preventive actions for all areas of ABMS.

If it is determined that noncompliant conduct has occurred, appropriate parties are responsible for corrective and/or disciplinary actions. Including termination; disciplining any involved employee(s); disciplining supervisor for failure to monitor employees appropriately.

Updating the compliance program

As Vestian evolves as a company and as regulations change, it may amend its compliance program. The Compliance Function shall be responsible for communicating changes in the policy to employees.

For questions or to obtain a copy, please contact us at abms@vestian.in

2. Business Conduct

Conduct relating to company resources and our business partners

As Vestian employees, we have access to client and/or our own organisation information that is not generally known to the public and provides business advantage the Company and its clients. This confidential information includes, but is not limited to, strategic and business plans, financials, sales or pricing information, customer lists and data, vendor terms with suppliers and promotional plans. Our board and clients rely on us to protect this important business information from unlawful or inadvertent disclosure. Our ability to protect the confidentiality of this information is critical to our ability to obtain and retain clients. Unauthorized or premature disclosure could have a serious financial impact on the Company and our clients and may subject the Company and its employees to liability, including penalties that could include termination of employment for the employees.

As employees of Vestian, we must maintain the confidentiality of sensitive information entrusted to us by the Company, our clients and suppliers, except when disclosure is authorized by a manager (and legally permissible), or legally mandated.

Handling Confidential Information of Others

The company has many kinds of business relationships with many companies and individuals, employees are expected to maintain the confidentiality of information entrusted to them by the company or its customers, suppliers or partners. Employees are required to take special care to handle the confidential information of others responsibly, handling of customer information should be in accordance with the agreements with such third parties.

We Must Never

Disclose confidential information to anyone except in relation to their job duties.
Misuse client or other third-party confidential information.
Inappropriately discuss, disclose confidential client or third-party information.
Discuss confidential Company matters with, or disseminate confidential Company information to, any third party outside the Company, except as required in the performance of Company duties.
Disclose confidential information for personal gain.
Disclose employee information to anyone outside the Company without the employee's prior written consent.

Each employee at Vestian is responsible for his or her own business conduct. The code of business conduct represents a non-negotiable commitment to do the right thing. By being part of Vestian, you are making a personal commitment to understand the policies and laws that apply to your job - and always follow them. If you fail to follow these standards, you put yourself, your co-workers and Vestian at risk. You will be subject to disciplinary action, up to and including termination, and other possible legal consequences.

At Vestian, we have an anti-bribery provision in place that prohibits the following:

Offering or giving money or anything of value to an official for the purpose of obtaining or retaining business.
Offering or giving money or anything of value to an official for the purpose of obtaining favourable legislation, regulations or improper advantage (i.e., relief from regulatory requirements, import duties or taxes).
Offering or giving money or anything of value to a third party (e.g., broker, contractor, joint venture partner, agent or other corporation, organization, person or entity Vestian pays (“Third Party Agent”)), while knowing that some or all of the payment will be given or offered to an official in order to obtain or retain business, or to obtain an improper advantage.

Additionally, we cannot live up to these standards if we, as individuals, fail to speak up when we should. That is why, in addition to knowing the legal and ethical responsibilities that apply to your job, you should speak up if:

You are unsure about the proper course of action and need advice;
You believe that someone acting on behalf of Vestian is doing - or may be about to do - something that violates these standards or the law; or
You believe you may have been involved in any misconduct.

Who Should I Contact for Help?

If you have a concern about a legal or business conduct issue, you have multiple options. Your reporting manager is usually a good place to start. You may also get help and advice from:

Any member of the management team
Any member of the Human Resources team
The most important thing is that you raise the concern quickly and effectively.

Supplier Diversity

The company's suppliers make significant contribution to our success, we recognize the importance of diversity in our suppliers and we value it. The cornerstone of our diversity policy is respect for the broad spectrum of diversity that exists within our workforce and our customer base. It is our goal to strengthen and partner with diverse business communities by contributing to their overall economic growth and to the expansion of our markets. It is our practice to promote and increase business opportunities for minority, women and disabled veteran business enterprises (M/W and DVBEs) to ensure that they receive their fair market share of Vestian's total expenditures for services and are promoted to our clients.

3. Corporate Social Responsibility Policy

Objective

Vestian endeavors to reach out to underprivileged and underserved communities to address fundamental challenges of our society. We focus on the following areas that are aligned to Schedule VII to the Companies Act, 2013 that entails education and skill development, environmental sustainability including water and sanitation, green energy, afforestation, and humanitarian response.

Organisation structure

Framework & Implementation

CSR Committee: CSR Committee comprising of three directors of the Company will formulate Company’s CSR Policy and recommend the same to the board. It will suggest and review CSR projects / initiatives from time to time. CSR Committee shall also recommend amount of expenditure to be incurred and monitor regulatory compliance.
Board of Directors: Board of Directors shall consider recommendations of the Committee and approve CSR policy, projects / initiatives. Board shall ensure that Company executes the projects / initiatives and appropriate disclosures are made in its report as required by law.
Group of Employees: Group of Employees from management team of the Company shall execute CSR activities. Group will interact with approved organizations, plan projects / initiatives with them, get involved in execution of such projects / initiatives, incur expenditure as approved by the Committee and submit progress reports to the committee periodically.

Review

The CSR Committee reviews the Policy over two meetings and propose amendments to the board as may be required due to change in regulations or otherwise. Amendments to this policy is effective after board of directors approve the same.

Escalation point / Reporting

All kind of CSR related activities will be addressed by the CSR committee, within the course of two reviews.

Compliance

A detailed policy has been established and communicated effectively to all stakeholders. Vestian is committed to an environment in which open communication is encouraged, including questions or concerns about the compliance program. Employees may contact the Chief Executive Officer or the Compliance Officer or the Compliance Committee at csr@vestian.in

Evaluation, Monitoring, Improvement

The Compliance Officer reviews and evaluates concerns to determine the required investigative response. Any findings from such analysis are used to trigger appropriate corrective, preventive actions or improvement. The ownership of these actions is assigned and the same is monitored and tracked till its effective closure.

Complete policy

For any questions or to obtain a copy of the entire policy, please email us at csr@vestian.in

Resolution mechanism

Once a concern or a complaint is raised, there are 3 levels of resolution mechanism available for the compliment.

CSR Committee - 1st level
Chief Compliance Officer - 2nd level
Chief Executive officer - 3rd level

To raise any concerns related to any CSR activities mail us at cco@vestian.in

4. Environmental, Occupational Health and Safety (EOHS) Policy

Policy Statement

We are committed to building a healthy and safe working environment for all our essential services & construction staff, employees, stakeholders, general public and customers and ensuring the conservation of resources. We strive towards developing and continually improving our operations in a legally compliant manner. We aim to minimise pollution, EOHS risks, injury and ill health, thus positively impacting the environmental sustainability.

Resources, Roles & Responsibility and Accountability

Vestian has determined and provided resources needed for the establishment, implementation, maintenance, and continual improvement of EOHS management system. Environmental, Occupational, Health & Safety responsibilities are included in employee’s roles & responsibilities and are maintained by the HR professional.

EOSH Organisation structure

Evaluation, Monitoring, Improvement

The evaluation, monitoring and improvement is an ongoing process.

The Management team is responsible for what needs to be monitored and measured, the method for monitoring, measurement, analysis and evaluation of data and information relevant to EOHS and/or compliance. The EOHS Manager is responsible for reporting incidents and general compliance evaluation. MR is responsible for the identification, calibration and maintenance of measuring and test equipment in accordance with stated calibration protocol.

At Vestian we periodically evaluate compliance with relevant EOHS legislation and regulations including other requirements as necessary. We have established a method to ensure our business and system is and remains fully compliant with all legal and other requirements. We have also has established, implemented and continue to maintain the process needed to evaluate fulfilment of its compliance obligations; determine the frequency at which compliance is evaluated, evaluate compliance and act if needed and maintain knowledge, understanding of its compliance status and retain results in the form of documented information as evidence of compliance evaluation.

Complete policy

To know more and get the full policy email us at ert@vestian.in

Concerns

If you have concerns you may raise it up with the Vestian EOHS Committee/ISO Committee or with the management representative and email them at ert@vestian.in

Resolution mechanism

Once a complaint or concern is raised, we first review it thoroughly and immediate corrections are made. Then go on to find out the route cause of the complaint or concern post which corrective and preventive action is taken and reviewed and monitored periodically.