Introduction

These documents are applicable to all who deliver services by and on behalf of Shamkris Global Inspection Services Private Limited (SGIS) and trading as A S Management Systems FZ-LLC (ASMS), referred to CB.

The certification body delivers its service with a commitment to the principles of impartiality, competence, responsibility, openness, confidentiality and integrity. SGIS’s (and t/a ASMS) policy, ‘Conflict of interest and Confidentiality and codes of conduct’ covers a wide range of activities, business practices and procedures within the certification body. It is necessary that individuals and organizations who work with the certification body directly or on its behalf shall commit to the principles that the certification body has adopted and committed to. This conflict of interest and confidentiality shall be signed by all personnel and organizations that work directly or indirectly with the organization and also by those with access to the information held by the organization.

• If a law conflicts with any content in this document, please clarify how to handle the situation.

• You must sign this agreement as an indication of confirmation that you have read and understood the contents.

• Violation of this agreement may result in termination of engagement.

1. Compliance with Laws, Rules and Regulations

Obeying the law, both in letter and in spirit, is the foundation on which this Company’s ethical standards are built. You must respect and obey the laws of the cities, counties/states/provinces and countries in which we operate. Although you are not expected to know the details of these laws, it is important to know enough to determine when to seek advice from managers or other appropriate personnel.  

2. Conflicts of Interest

A “conflict of interest” exists when a person’s private interest interferes in any way with the interests of the Company. A conflict situation can arise when you take actions or have interests that may make it difficult to perform your work objectively and effectively. Such situations may include any financial or personal relationship with another employee, supplier, competitor or anyone who represents, does work for, or on behalf of, the Company, or any relationship that, by its nature, may appear to interfere with your ability to dispassionately and objectively act in the best interests of the Company, its employees, customers or shareholders. Conflicts of interest may also arise when you, or members of your family, receive improper personal benefits as a result of your position in the Company. Loans to, or guarantees of obligations of, employees and directors and their family members may create conflicts of interest and shall not be permitted without the express prior approval of the Company.

It is always a conflict of interest for a Company employee to work simultaneously for a competitor, customer or supplier. The best policy is to avoid any direct or indirect business connection with our customers, suppliers or competitors, except on our behalf or with our written agreement. Conflicts of interest are prohibited as a matter of Company policy, except when specifically approved. Conflicts of interest may not always be clear-cut, so if you have a question, you should consult with the appropriate Company representative.  

The following are some general principles that should be kept in mind:

• Avoid situations where your personal interests conflict, or appear to conflict with, those of the Company.

• This document does not specifically address every potential conflict, so use your conscience and common sense. When questions arise, seek guidance.

3. Use of property and information

You are prohibited from taking for yourself opportunities that are discovered through the use of corporate property, information or your position with the Company without a written consent. No employee may use corporate property, information, or position for improper personal gain, and no employee may compete with the Company directly or indirectly. Employees, officers and directors owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

Stealing proprietary information, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures by past or present employees of other companies is prohibited. Each employee should endeavor to respect the rights of and deal fairly with the Company’s customers, suppliers, competitors and employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice

4. Entertainment and gifts

No gift or entertainment should ever be offered, given, provided or accepted by any Company employee, family member of an employee or agent unless it: (1) is not a cash gift, (2) is consistent with customary business practices, (3) is not excessive in value, (4) cannot be construed as a bribe or payoff and (5) does not violate any laws or regulations. Please discuss with the appropriate Company representative any gifts or proposed gifts which you are not certain are appropriate.

5. Equal Opportunity

The diversity of the Company’s employees is a tremendous asset. We are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. Examples include derogatory comments based on racial or ethnic characteristics and unwelcome sexual advances. Any instances of such behavior, whether the employee is a participant or observer, should be immediately reported to the employee’s immediate supervisor.

6. Health and Safety

The Company strives to provide each employee with a safe and healthy work environment based on current publicly known information. Each employee has responsibility for maintaining a safe and healthy workplace for all employees by following safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions.

Violence and threatening behavior are not permitted. Employees should report to work in condition to perform their duties, free from the influence of illegal drugs or alcohol. The use of illegal drugs in the workplace will not be tolerated.  

7. Records and communications

Business records and communications often become public, and we should avoid exaggeration, derogatory remarks, guesswork, or inappropriate characterizations of people and companies that can be misunderstood. This applies equally to email, internal memos, and formal reports.

8. Confidentiality

Employees must maintain the confidentiality of confidential information entrusted to them by the Company or its customers, except when disclosure is authorized by the appropriate Company representative or required by laws or regulations. Confidential information includes all non-public information that might be of use to competitors, or harmful to the Company or its customers, if disclosed. It also includes information that suppliers and customers have entrusted to us. The obligation to preserve confidential information continues even after employment ends. In connection with this obligation, every employee may be asked to execute a confidentiality agreement with the Company.

9. Protection and Proper Use of Company Assets

All employees should endeavor to protect the Company’s assets and ensure their efficient use. Theft, fraud, and waste have a direct impact on the Company’s profitability. Any suspected incident of theft, fraud or waste should be immediately reported for investigation. Company equipment should not be used for non-Company business; though incidental personal use may be permitted.

The obligation of employees to protect the Company’s assets includes its proprietary information. Proprietary information includes intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business, marketing and service plans, engineering and manufacturing ideas, designs, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information is a violation of Company policy and could be illegal and result in civil or even criminal penalties.

10. Reporting any Illegal or Unethical Behavior

You are encouraged to communicate, anonymously, if desired, with appropriate personnel about observed illegal or unethical behavior and when in doubt about the best course of action in a particular situation. It is the policy of the Company not to allow retaliation for reports of misconduct by others made in good faith by employees. The most important point is that possible violations should be reported and we support all means of reporting them. You are expected to cooperate in internal investigations of misconduct.