Ethics Policy

Definitions

FCPA” means U.S. Department of Justice’s Foreign Corrupt Practices Act

Human Rights” means universal rights of every person to be treated with dignity and equality, in particular with regards to freedom of speech, privacy, health, life, liberty, security, and an adequate standard of living.

NCT Holdings, Inc.” is the parent company of VeraSci

VeraSci Senior Management” means President, CEO, Vice Presidents, Senior Directors, Directors, and Managers

VeraSci Staff” includes regular employees, contractors, and interns

PO” means policy

References

United Nations Global Compact –
www.unglobalcompact.org

United Nations Universal Declaration of Human Rights (and subsequent iterations) –
http://www.ohchr.org/EN/UDHR/Documents/UDHR_Translations/eng.pdf

International Covenant on Economic, Social and Cultural Rights –
http://www.ohchr.org/EN/ProfessionalInterest/Pages/CESCR.aspx

International Covenant on Civil and Political Rights –
http://www.ohchr.org/en/professionalinterest/pages/ccpr.aspx

OECD Guidelines for Multinational Entreprises –
http://www.oecd.org/daf/inv/mne/48004323.pdf

The Basic Labor Standards as defined by the International Labor Organization –
http://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang–en/index.htm

U.S. Department of Justice, Foreign Corrupt Practices Act –
https://www.justice.gov/criminal-fraud/foreign-corrupt-practices-act

UK Bribery Act –
http://www.legislation.gov.uk/ukpga/2010/23/contents

Policy

VERASCI HUMAN RIGHTS COMMITMENT
VeraSci is committed to every individual’s basic human right to dignity, equality, and respect, both within our own work environment as well as for individuals impacted by our extended business dealings globally. Endeavoring to foster a corporate philosophy of shared values for all employees, VeraSci believes in creating a receptive workplace environment which bolsters inclusive, free discussion and enables merit-based opportunity in order to promote growth. As part of our philosophy, VeraSci subscribes to the principles of the United Nations Global Compact, the United Nations Universal Declaration of Human Rights (and subsequent iterations), the International Covenant on Economic, Social and Cultural Rights, the International Covenant on Civil and Political Rights, the OECD Guidelines for Multinational Entreprises, and the Basic Labor Standards defined by the International Labor Organization.
Every VeraSci staff member, in all aspects of business operations, will responsibly uphold the following principles to ensure these rigorous standards are met:

  • VeraSci condemns forced labor – VeraSci will only employ individuals of legal working age for a given country and we denounce exploited child labor, human trafficking, and slavery of any kind.
  • VeraSci respects lawful freedom of association – VeraSci recognizes the right of all persons to participate in collective bargaining for the promotion or defense of their occupational interests.
  • VeraSci will provide fair compensation – For any contracted work to be done on behalf of the company, VeraSci will ensure a reasonable living wage is provided, basic needs are able to be met, and a safe, healthy working environment is offered to all staff members.
  • VeraSci does not discriminate – No form of discrimination on the basis of race, gender, age, religious beliefs, sexual preference, or any other legally protected characteristic will be tolerated.

VeraSci will not be complicit in any human rights abuses and commits to swiftly address any potential non-compliance with these basic principles which we discover within our business activities.

FRAUD, ANTI-CORRUPTION & ANTI-BRIBERY
VeraSci operates globally with a focus on ethics and integrity, setting the expectation that all of its business operations shall be performed in good faith. As such, we comply with all relevant fraud, anti-corruption and anti-bribery laws, including but not limited to the U.S. FCPA and the U.K. Bribery Act, in all countries where VeraSci or any of our contracted third parties operate on our behalf. Specifically, VeraSci will not tolerate the following behavior from any of its employees or third parties:

  • Improper payments or offers of value given, offered, or promised to anyone (not only to government officials), directly or indirectly, as inducement or reward, in particular for the purpose of securing undue favor or advantage in business dealings or to obtain/retain business; nor will any VeraSci employee or anyone on behalf of the company accept improper payment of like kind, directly or indirectly.
  • Knowing inaccurate or misleading maintenance of books, records, and accounts of completed business transactions

VeraSci Senior Management should be notified immediately of any indication of potential violation, on the part of VeraSci or a contracted third party, of this policy.

COMPLIANCE AND MONITORING OF THIRD PARTIES
VeraSci demands ethical and transparent behavior in every area of its business practices and requires the same of any party with which it conducts business. VeraSci takes a precautionary approach in carefully evaluating third parties with which it has working agreements to determine risk, as well as towards compliance with any applicable laws or regulations for the country of location. Third parties under contract with VeraSci shall be obligated to adhere to VeraSci’s ethics policies and guidelines, with any appropriate training to be provided or made available by VeraSci.

An environment of trust and openness is considered essential to allow for continual improvement of all VeraSci working relationships. VeraSci will ensure that all commitments made by the company under agreement are met, and insists on the same in return from contracted third parties. Open monitoring of third parties by VeraSci will occur to ensure adherence and to highlight potential areas of improvement. Any concern regarding non-compliance will be addressed promptly and collaboratively by VeraSci. However, any ongoing or egregious performance or compliance concerns will likely result in termination of continued association.

Version 2, Dated 12 Oct 2018