1.1 The Compliance Program Guidelines are intended to comply with the International Federation of Inspection Agencies (IFIA) under the relevant rules of the meaning of "Compliance". Under the guidance in the Compliance Program, to maintain and improve their work style, with a good reputation reflecting MIS's core values, and creating better business values.
1.2 This program seeks to stop company actions contrary to the Compliance Program and to promote high standards:
a. Honesty and trustworthiness
b. Objectivity and independence
c. Respect for each Individual
d. MIS through compliance with a Compliance Program and social responsibility has positive influence on others
2.1 This procedure applies to all shareholders of the company, officers, employees and consultants, whether they are full-time, part-time, consultants, or temporary office workers.
2.2 Company's shareholders have appointed Rock Zhang as the company's Compliance Officer. If you have any questions about the Compliance Program or would like to report any violations, please contact Rock Zhang at firstname.lastname@example.org.
2.3 At the shareholders' meeting on Feb 27, 2014 MIS adopted and entered into force this Compliance Program.
3.1 All employees must strictly follow the requirements of the Compliance Program strictly executing all points mentioned therein.
3.1.1 All employees of the Company shall be subject to the Compliance Program to ensure that our daily business runs properly. Each employee, no matter what department or position, must be familiar with and comply with all sections and points in the Compliance Program.
3.1.2 All employees should employ good business practices and risk management strategies in accordance with the Business Principles for Countering Bribery as published by Transparency International and Social Accountability International (www.transparency.org).
3.1.3 All employees of the company must be committed to full compliance with local country's laws and regulations.
4.1 Service integrity
4.1.1 All employees of the company should have a professional, independent and impartial way of doing business; we will not tolerate any departure from the relevant methods and procedures defined or reports that do not accurately represent our inspector’s onsite findings. Staff can never succumb to any pressure or influence that can lead to changes in the quality of work.
4.1.2 Data, check results and other important facts will be truthfully reported. Our report and certification must accurately indicate the actual results, professional advice or conclusions.
4.1.3 The company will implement the quality control process and ensure that these requirements are followed.
4.2 Provide authentic documentation and information
4.2.1 Authenticity of financial and accounting documents. All financial and accounting information must be timely and accurately recorded and can be ready to accept internal and external audits.
4.2.2 There should be internal control of financial and accounting information. The company should establish internal control of financial accounting information, implementing procedures to ensure financial and accounting information’s quality and reliability, and to comply with laws and regulations.
4.2.3 Ensure the authenticity of the information and reports. Each employee is required to take responsibility for the information including, financial reports, legal reports, inspection reports, studies and other documents.
4.3 Conflicts of Interest
4.3.1 When company and personal interests are inconsistent, leading to conflicts of interest, we should use the following measures to avoid any possible conflicts of interest:
a. In the absence of prior approval, employees cannot provide family members with jobs;
b. For new employees, you must make a detailed background checks, and the findings are filed. If necessary employee’s background checks can be updated annually to ensure that they are using the latest information.
c. Establish a standard "Compliance Program" to prevent company employees, directly or indirectly, from receiving gifts or bribes.
d. In the absence of prior approval, employees of the company cannot accept employment outside the company;
e. Company employees shall not, directly or through relatives, friends or intermediaries accept competitors, suppliers or customers benefits;
f. No items or resources of the company can be used for personal use.
4.4.1 All relevant customer information is considered confidential and shall be kept strictly confidential, and employee shall not disclose any information about customers to any unauthorized personnel. During an inspection or business discussion or when entering a business venue, all relevant information is considered confidential customer information and shall not be disclosed.
4.4.2 The company's intellectual property. The company's technical information, systems, inventions, the development of technology as well as access to professional confidential information, must be kept strictly confidential.
4.4.3 All employees must enter into a legally binding "confidentiality agreement", the agreement must provide that the employee even after leaving the company will still bear the obligation of confidentiality.
4.5 Anti-corruption / bribery
4.5.1 The Company is firmly opposed to any form of corruption / bribery, the direct or Indirect offering or giving gifts or other bribes, including remuneration and various other methods.
4.5.2 No employee shall accept by other means or channels including customers, agents, suppliers and government officials any improper benefits.
4.5.3 Our company will follow the below measures to prevent corruption / bribery:
a. Monitor the implementation of all operations, the establishment of regulatory bodies, all business activities and other forms of investigation adopted without notice at any time to prevent corruption / bribery;
b. The Compliance Officer is responsible for monitoring the financial expenditures, to prevent political contributions, charitable donations and sponsorships from occurring for the purpose of personal gain.
c. The financial department is responsible for ensuring the accurate maintenance of all transactions between the accounts and records.
D. The Compliance Committee is to remain in contact with all internal staff and external complaints, and they are subject to internal / external supervision.
4.6 Transactions with business partners
4.6.1 All employees in business dealings with the outside world, it is necessary to explain our business objectives openly, fairly and transparently, without any secret operations. We must share all information to the relevant person in charge of the business/company’s "Compliance Program" to ensure that the other party clearly understands the company's practices in relation to current dealings.
4.7 Fair marketing
4.7.1 All employees must comply with antitrust laws, unfair competition laws, and respect the rules of marketing.
4.7.2 The company's sales department should deal in good faith, not cheating or misleading. The Compliance Committee is responsible for assigning a designated officer, checking the sales department drafting business documents, sales catalogs and other relevant information to ensure that sales staff do not sell V-Trust services through illegal means.
4.8.1 In order to maximize the implementation of the "Compliance Program", the Compliance Committee will organize regular staff training; organizational staff will seriously study the guidelines to ensure that each employee has a clear understanding of the "Program";
4.8.2 The Administration Department is responsible for formulating the "Program", providing program training the timely training of new staff and the retaining of all training records;
4.8.3 Each department manager is responsible for the organization of the department's staff from time to time to learn the "Program" at least twice a year, and training records shall be submitted to the Executive Department for archiving;
4.8.4 The Administration Department is responsible for issuing Compliance Program notification to new employees. They should also administrate training and applicable tests to all new employees.
4.8.5 Department managers must sign documentation each year stating that they will operate according to the regulations set by the Compliance Committee and standards written in the "Compliance Program".
4.8.6 Department managers, have the yearly responsibility to sign the Compliance Program to ensure that their department runs in accordance with the "Compliance Program".
4.8.7 The Compliance Officer, at least once a year must have a meeting with members of the Compliance Committee. They should review the implementation of the Compliance Program and make appropriate adjustments if necessary.
4.9.1 Any employee found to have violated the "Compliance Program", has the right to state their case before to the Compliance Committee;
4.9.2 If any employee is forcibly given improper benefits from customers/suppliers, factories or any other agency, they are required to immediately report this to the Compliance Officer or their direct manager.
4.9.3 All informants to the Compliance Committee can be anonymous if they so desire;
4.9.4 If the informant is involved in the violation, it does not absolve his/her responsibility, but according to the reports and employee’s attitude it may be acceptable to give a lighter sentence or exempt them from punishment.
4.9.5 For employees who seriously violated the "Compliance Program", the Compliance Committee will subject him/her to disciplinary action, including termination of employment contract.
Compliance Program Contact Information:
Compliance Officer: Rock Zhang
Mobile phone: +86-13510527691