CODE OF CONDUCT www.vfsglobal.com
1
INTRODUCTION 1.1
Message from the CEO
05
1.2
Our Code of Conduct – why is it important?
07
1.3
Our Values and Principles
10
1.4
Who is our Code of Conduct for?
12
2
RESPONSIBILITIES 2.1
Your Responsibilities
14
2.2
Place Ethics at the Centre of All Decisions
16
2.3
Speak Up and report breaches of the Code
18
3
MANAGING RISK – REGULATORY AND THIRD PARTIES 3.1
Compliance with the Law, Regulations and Guidelines
21
3.2
Reject All Forms of Bribery or Corruption
23
3.3
Conflicts of Interest
26
3.4
Gifts and Hospitality
28
3.5
Competition and Fair Trading
30
3.6
Anti-Money Laundering and Counter Terrorist Financing
32
3.7
The UK Modern Slavery Act and abolishment of child labour
34
4
MANAGING RISK – INFORMATION, COMMUNICATIONS AND ASSETS 4.1
Protecting Data and Confidential Information
37
4.2
External Communication, Advisory and Social Media
39
4.3
Use of Information Technology
42
4.4
Use and Protection of Company Property
44
5
PEOPLE, CULTURE AND SOCIAL RESPONSIBILITY 5.1
Health and Safety
47
5.2
Corporate Social Responsibility, Donations and Sponsorship
50
5.3
Human rights, Cultural Diversity and Non-Discrimination
53
5.4
Sexual Harassment
55
5.5. Corporate Events and Corporate Social Gatherings
57
6
CONCLUSION 6.1
Glossary of Terms
61
6.3
Contact Details
62
1 INTRODUCTION
4 | 1. Introduction
1.1 MESSAGE FROM THE CEO
Dear Colleagues, I am very pleased to introduce you the 2nd edition of our Code of Conduct – a very important document providing guidance about our actions and behaviour. As a pioneer and market leader of outsourced visa and technology services for governments worldwide, it is our fundamental obligation to conduct ourselves and carry out our business in the most responsible and ethically sound manner. It is important to always bear in mind that the respect and market leadership that we have established is solely due to the commitment, professionalism, and most importantly integrity demonstrated by each one of us – individually and collectively as an organisation.
1. Introduction | 5
Over the years VFS Global has developed its business and its esteemed reputation based on a culture driven by values of integrity, commitment and entrepreneurship. Respect of the law and overall professionalism are also integral to our culture. We firmly believe that these values and our overall culture will remain key success factors for us in the future. The “VFS Global Code of Conduct 2.0” elaborates key tenets of our corporate culture and has been prepared to assist us all in imbibing the values that we cherish in our daily operations and help us make the “right choices”. I urge you to please use our Code of Conduct as a resource to overcome situations that are challenging or not encountered before by embedding these virtues in the daily operations. This code is applicable to VFS Global’s Board of Directors, Executive Board and all personnel of VFS Global as well as to all our Facility Management Companies. Please do remember that all of us must stay vigilant to identify and prevent any illegal, unethical or inappropriate behaviour. On behalf of the Board of Directors and the Executive Board, I would like to encourage employees to report any such issues to their reporting Manager or to the Head of Compliance. All such cases will be treated with the utmost confidentiality and in no manner result in any disciplinary action or retaliation against the person reporting the same.
Always remember, it is important to do things the right way as we continue to grow together and cross many more milestones as a trusted partner to governments and diplomatic missions worldwide.
Sincerely,
Zubin Karkaria CEO VFS Global Group
6 | 1. Introduction
1.2 OUR CODE OF CONDUCT Why is it important?
The Code of Conduct The VFS Global Code of Conduct (“the Code of Conduct�) has been designed to help VFS Global employees make the right ethical decisions and embrace a culture of openness and trust. Our core values of Integrity, Commitment, and Entrepreneurship are at the heart of the way we work. They articulate the values we want you to apply in your daily work and are the foundations for our long-term success.
Integrity
Entrepreneurship
Commitment 1. Introduction | 7
Commitment to the Code Your personal commitment to the Code of
Your commitment
Conduct, ethical conduct, and compliance is
to abide by the
mandatory. Intentional breaches of the Code
Code of Conduct is
of Conduct, unethical decisions, or breaches
critical to support the
of policies and procedures can put VFS Global
sustainable growth
at risk and just as importantly, can result in
of VFS Global and
personal consequences for individuals.
foster a healthy work environment.
It is your obligation as an employee of VFS Global to follow the rules, abide by the Code of Conduct, and report misconduct or malpractice to your supervisor or through the Speak Up channels. If you are unsure about the right choice in any circumstance, then ask for assistance.
8 | 1. Introduction
Our unique culture has been built on the creativity of our employees and our ability to adapt quickly, while taking appropriate risk. We encourage you to continue to think outside the box, be brave, be creative, and be agile, but do it in an ethical and sustainable manner.
In a constantly evolving business
IT STARTS WITH YOU
environment, the responsibility to do what is right lies with each and every one of you irrespective of location, designation or any other such factor. A negative action by a single individual has the potential to hurt our goodwill, reputation and business. - Zubin Karkaria, CEO
1. Introduction | 9
1.3 OUR VALUES AND PRINCIPLES
Our Values
1 Integrity • Act with integrity and honesty at all times • Speak up about risks or concerns that you become aware of • Lead by example. Be genuine, be reliable
2
Commitment
• Turn words into actions – deliver on what you promise • Believe in your vision, stay determined, and follow through • Recognise and reward long term success
3 Entrepreneurship • Embrace an entrepreneurial spirit – turn ideas into business • Create a vision, seize the opportunity, and shape its success • Support your employees to be innovative, confident, and empowered for success
10 | 1. Introduction
Our Principles The Code is based upon the following principles: • Place ethics at the centre of all decisions • Be committed to excellence • Do not tolerate any form of bribery or corruption • Protect confidential information • Speak Up and report breaches of the Code • Comply with laws and regulations • Respect and abide by human rights laws and principles • Be fair, courteous and respectful to your colleagues, supervisors, and staff • Be professional, courteous and helpful to our customers, shareholders, authorities, business partners and the public • Respect other cultures and opinions • Embrace an open, transparent and constructive business style • Protect the environment and minimise waste
1. Introduction | 11
1.4 WHO IS OUR CODE OF CONDUCT FOR? The Code of Conduct applies to all employees of VFS Global including; • the Board of Directors • the Executive Board • all employees of VFS Global including contractor employees • to all Facility Management Companies (FMCs) employees engaged in VFS Global’s operations.
The internal regulations, policies, procedures and guidelines issued by VFS Global shall supplement the values and principles as specified in the Code of Conduct. The Code of Conduct is an integral part of VFS Global’s corporate governance framework.
12 | 1. Introduction
2 RESPONSIBILITIES
1. Introduction | 13
2.1 YOUR RESPONSIBILITIES
Each employee is personally obliged to abide by the Code of Conduct. Each Chief Operating Officer (COO) or business unit head must ensure that the Code of Conduct is included in staff training as extensively as possibleand monitor whether it is being appropriately complied with by his or her staff.
Your role as a Manager and Reporting Head: As a Manager, you are required to set the right example for your staff and ensure that you have oversight over your teams. In your role, you are required to: • Understand the regulatory, reputational, and operational risks applicable to your business or function and ensure that the controls sufficiently mitigate those risks • Ensure your staff understand and comply with the Code of Conduct and the procedures relevant to their roles • Ensure your staff complete all of their mandatory compliance and operational training • Support your team members to be responsible for their conduct by clearly communicating expectations (setting the right tone) • Encourage your team members to Speak Up if they know or suspect a violation of the Code of Conduct or other policies and procedures • If a Code of Conduct violation is reported to you, be empathetic to the person raising the concern. Maintain the confidentiality of the report and inform the Head of Compliance where there is an allegation of a breach of the Code of Conduct or procedures. Follow the Speak Up procedures and do not investigate the incident on your own
As a Manager, it is your responsibility to create and foster an environment where colleagues can feel confident about raising their concerns, without fear of victimisation.
14 | 2. Responsibilities
Your role as an employee: All VFS Global employees are responsible for adhering to the Code of Conduct and complying with policies and procedures that are relevant to their roles. In your role, you should • Behave professionally and ethically in all areas of your work • Take responsibility for your actions and decisions • Understand and comply with VFS Global policies and procedures relevant to your role • Report any non-compliance or breach of the Code of Conduct to your supervisor or through the Speak Up channels • Seek assistance when dealing with situations where you are unclear on what to do (use the decision-making framework in the Code of Conduct to help you) • Disclose any personal activities that conflict with your duties at VFS Global • Complete the mandatory training needed to support your understanding of your role and the Code of Conduct’s requirements • Provide constructive solutions to any ineffective process or procedure • Fully co-operate with any Compliance, Human Resources, or Audit review
What Happens if I Violate the Code of Conduct? Violations of the Code of Conduct or other relevant policies and procedures can result in disciplinary action up to and including dismissal.
2. Responsibilities | 15
2.2 PLACE ETHICS AT THE CENTRE OF ALL DECISIONS VFS Global employees should put ethics at the centre of all decisions and consider the risks and consequences of their actions. Ethics is defined as the moral principles that govern our behaviour or the conducting of an activity. Ethical dilemmas often occur when the right choice is not completely clear and pressure is placed upon you to make the wrong choice. The guidance below is designed to assist you in making the right ethical choices at all times.
Why is this important? Whilst VFS Global has comprehensive policies and procedures to help you perform your role, you may face situations where you are unsure about the right choice. As a multinational company, we are subject to local and international laws and regulations which in many cases are complex. In performing our jobs, we may encounter situations where the right choice is not always clear, or we perceive that there is pressure on us to fulfill certain targets or obligations. If you are faced with an ethical dilemma or difficult decision, use the questions in the Q&A table on page 24.
Your Responsibilities • Follow the VFS Global Code of Conduct and relevant policy and procedures • Consider the ethical and legal implications of your decisions • Behave ethically and honestly at all times • Consider whether your actions could result in any unacceptable risk for VFS Global • If you are not sure about the correct course of action, then ask • Report non-compliance or breach of our Code immediately or raise any concerns you may have over conduct issues and behaviour to your supervisor or through the Speak Up channels If there is still uncertainty about how best to proceed, consult your Manager, your local HR representative, the Regional Legal Representative or Compliance.
16 | 2. Responsibilities
Questions
What you can do
• Have I consulted with the appropriate stakeholders or requested information to assist in making an informed decision?
• Involve others, including your Manager or other senior colleagues, and seek their input • If there is more you need to know, refer to relevant Group policies and procedures
• Is my decision in line with VFS Global business objectives?
• Notify your supervisor of your concerns • Seek confirmation from the Business Head
• Is the proposed action in accordance with all relevant laws?
• Assess the potential legal risk of your decision • Seek input from your supervisor and internal subject matter experts • Consult legal early and notify them of your concerns
• Is my decision in accordance with the Code of Conduct?
• Ensure your decision is consistent with VFS Global’s values and principles • Ensure that you consider any potential regulatory, reputational or operational risks in making your decision
• Is this decision within my authority?
• Understand your delegated authority and whether you are able to make this decision on behalf of VFS Global • Consider referring the decision to those who are authorised to make such a decision
• Would I be comfortable if the situation was written about in the press or shared in the local community?
• Consider the consequences of this decision or situation, and what reputational risks to VFS Global might be cause by it • Consider the consequences of this decision or situation on yourself and your colleagues
• Am I setting a good example?
• Understand how this decision may be viewed by your colleagues, supervisors and the broader VFS Global team • As a Manager, ensure that the decision is clear and not misunderstood or misinterpreted 2. Responsibilities | 17
2.3 SPEAK UP & Report breaches of the Code
As a Manager
As an Employee
It is your responsibility to create
You have a duty to report any actual or
and foster an environment where
suspected violation of the Code of Conduct
colleagues can feel confident
or breaches of other VFS Global policies and
about raising their concerns,
procedures. All Speak Up reports will be treated
without fear of victimisation.
in strict confidence. When reporting concerns, we encourage you to provide your name so that your concerns can be assessed accurately and fairly. Speak Up reports can be lodged anonymously, but be aware that this may limit our ability to accurately assess and investigate the concerns that are raised.
How do I Speak Up?
There are a number of ways you can raise a concern: • Speak to your Supervisor or a Manager in your management chain • Speak to the Head of Compliance or a member of the Compliance Committee • Send an email to SpeakUp@Vfsglobal.com which is managed by the Head of Compliance
18 | 2. Responsibilities
Why is this important? Misconduct is damaging for everyone. VFS Global is a trusted partner for Governments around the world and maintaining our reputation of integrity and trust is imperative. Employees who are involved in misconduct or illegal activity are betraying the trust of all of us and put the organisation at risk. We all have an important role in protecting VFS Global and the Speak Up channels provide a confidential way to report your concerns. Further, VFS Global employees, who raise their concerns about inappropriate conduct or illegal actions by staff, should not be subjected to victimisation or retaliatory actions by other staff members. Any employee involved in the victimisation of other staff members may face disciplinary action up to and including dismissal.
Your Responsibilities • You should Speak Up if you are aware of staff or management misconduct, breaches of the Code of Conduct, and breaches of laws or regulations • When you Speak Up, you must be honest and make your report in good faith. You do not need to be certain of all the facts to Speak Up, as it is sufficient to have a reasonable belief that a breach has taken place or could take place • Please be aware that knowingly reporting false and/or untrue information is not acceptable. It is a breach of the Code of Conduct to make any malicious reports or provide information that is known be false
Note: If you have a general employment related concern that affects you personally, please speak to your Manager or Human Resources under the Employee Grievance Policy.
Link to relevant procedures
Knowledge Corner
• • • •
Speak Up Policy Dignity at Work Policy Employee Grievance Handling Policy Employee Handbook for your Country 2. Responsibilities | 19
3 MANAGING RISK– REGULATORY AND THIRD PARTIES
3.1 COMPLIANCE WITH THE LAW, REGULATIONS AND GUIDELINES All VFS Global employees must observe and comply with all international laws and applicable local laws and regulations in the countries in which we operate in, and the countries that we serve i.e. our client governments. We must ensure that all VFS Global operations, as well as the products and services offered, are in compliance with both the spirit and letter of the law.
VFS Global is committed to complying with applicable laws, especially the following laws:
Data protection and confidentiality laws
Anti-Bribery and Corruption laws
Human rights and employment equity laws
Anti-human trafficking and slavery laws
Anti-discrimination & sexual harassment laws
Anti-money laundering and counter terrorist financing laws
Copyright laws and software licensing
Taxation and finance regulations
Insider trading and securities laws 3. Managing Risk – Regulatory And Third Parties | 21
Your Responsibilities Be familiar with the laws, regulations, and guidelines which are relevant to your role and abide by those laws
Treat people with respect and dignity irrespective of their gender, sexual orientation, religion, country of origin, race or disability
Protect confidential information and do not use confidential information for personal gain
Reject all forms of bribery and corruption
Do not participate in any form of harassment including sexual harassment or bullying
Report any breaches of laws, regulations and/or guidelines (policies and procedures) to your supervisor or through the Speak Up channels
Do not participate in any form of fraud, theft, dishonesty, or misuse of VFS Global Assets or funds
Link to relevant procedures
Knowledge Corner
• Anti-Bribery and Corruption Procedure • Data Protection & Privacy Handbook • Diversity and Inclusion Policy • Dignity at Work Policy • Anti-Money Laundering and Terrorist Financing Procedure
22 | 3. Managing Risk – Regulatory And Third Parties
• VFS Global Policy under the UK Modern Slavery Act • Information Security Policy • Anti-Trust / Anti-Competition policy • Employee Handbook for your Country
3.2 REJECT ALL FORMS OF BRIBERY OR CORRUPTION VFS Global is committed to conducting business in an ethical manner. A core principle of our commitment to ethical practices is zero tolerance to bribery in all forms including the payment of bribes to gain or retain business, the receipt of bribes, and the making of facilitation payments to expedite a government process. You must not offer, pay, or accept a personal payment, gift or favour in return for favourable treatment or to gain a business advantage. You must not request or allow anybody else to bribe on your behalf. You must abide by all applicable bribery and corruption laws including the local laws of the countries we operate in, and the laws of our client governments.
Examples of bribery which would violate the Code of Conduct include: Paying a Public Official money in order to win a contract
Asking a third party to pay a Public Official on our behalf to win a contract
Offering a holiday to the Finance Director of a corporate client to receive better pricing in our contract
Receiving a gift to award a procurement contract to a supplier Further examples of bribery and corrupt activity are contained in the Anti-Bribery and Corruption Procedure. 3. Managing Risk – Regulatory And Third Parties | 23
Why is this important? The success of VFS Global depends upon the trusted relationship we have with our Government and corporate clients around the world. Concerns or allegations of bribery involving VFS Global employees may damage our reputation, and serious incidents could result in VFS Global or its employees being subjected to regulatory investigations. Further, bribery and corruption have a devastating impact on developing countries, impeding economic growth and perpetuating a cycle of poverty that affects many people.
VFS Global is committed to undertaking business ethically. This may mean not gaining new business due to integrity risks, or not using the services of particular agents or business partners, who do not do meet VFS Global’s ethical standards.
24 | 3. Managing Risk – Regulatory And Third Parties
Your Responsibilities
Comply with the VFS Global Anti-Bribery and Corruption Procedure and reject all forms of bribery and corruption
Identify potential bribery and corruption risks in your area of work and assist with the implementation of controls to prevent such activity
Be aware that VFS Global can be legally accountable for the actions of our business partners, particularly FMCs and consultants. We need to ensure that we conduct appropriate due diligence on these parties and be vigilant to any indications of this activity
If you become aware of any incidents involving bribery or corruption you must report to your supervisor or escalate your concerns through the Speak Up channels
Link to relevant procedures
Knowledge Corner
• • • • •
Anti-Bribery and Corruption Procedure Speak Up Policy Gifts and Hospitality Policy Sponsorship Policy Employee Handbook for your Country 3. Managing Risk – Regulatory And Third Parties | 25
3.3 CONFLICT OF INTEREST
A ‘Conflict of Interest’ may occur when our external activities and our personal interests conflict, or appear to conflict, with our responsibility towards VFS Global. A conflict can also include situations when we use our position with VFS Global or information we have acquired during our employment, in a way that creates a conflict between our personal interests and the interests of VFS Global.
Examples of a Conflict of Interest (actual or perceived) include:
1
You or a member of your immediate family are involved in external business activities that relate to VFS Global either directly or indirectly
2
You are involved in an outside business activity (paid or unpaid role) without obtaining prior approval
3
You invest in a third party (without appropriate approval) that has business arrangements with VFS Global
4
You have a close personal relationship with another member of staff who is in your reporting line
5
You request VFS Global to sponsor a friend or relative’s activities without disclosing your relationship or association
26 | 3. Managing Risk – Regulatory And Third Parties
Why is this important?
How do I manage potential conflicts of interest?
You are expected to act in VFS Global’s best interests and
If you are concerned that any of your personal
exercise sound judgment when
activities could result in a conflict with your role at
working on its behalf. This means
VFS Global then it is imperative to disclose those
that business decisions should
activities to your Supervisor and Compliance. It is
be made free from any conflict
your obligation to identify and disclose conflicts of
of interest or external pressures
interest through the Conflict of Interest Compliance
which could compromise your
Questionnaire. Please remember, if you do not
judgment. Conflicts of interest
disclose potential conflicts you may create the
can damage the reputation of VFS
perception of wrongdoing. Disclosing the potential
Global and in some cases may be
conflict will enable you to reach the best outcome in
in breach of laws or regulations.
balancing your career and personal activities.
Link to relevant procedures
Knowledge Corner
• • • • •
Conflict of Interest Procedure Anti-Bribery and Corruption Procedure Gift and Hospitality Policy Sponsorship Policy Employee Handbook for your Country 3. Managing Risk – Regulatory And Third Parties | 27
3.4 GIFTS AND HOSPITALITY The exchange of gifts and hospitality establishes goodwill and enhances relationships with business parties and clients. However, in some situations the giving or receiving of gifts may create a conflict of interest or give the wrong perception. The giving or receiving of any gift must be in accordance with the VFS Global’s Gift and Hospitality Procedure. Under no circumstance are you permitted to give a gift or provide hospitality with the intention of improperly influencing a client or business partner.
Why is this important? Whilst the giving of appropriate gifts and entertainment can enhance relationships, you need to ensure that it does not create a perception that you are trying to improperly influence a client or business partner. In addition, a large percentage of our clients are Government Departments and we need to take particular care in our dealings with their employees – and other Public Officials. The laws and regulations in this area are more complicated, and the risk to you and VFS Global can be higher.
28 | 3. Managing Risk – Regulatory And Third Parties
Your Responsibilities
Follow the VFS Global Gifts and Hospitality Policy
Seek pre-approval in accordance with Gift and Hospitality Policy pre-approval requirements
Enter all gift and hospitality events (given and received) into the Gifts and Hospitality Register, where the value is above the required threshold
Identify whether the recipient is a Public Official and follow the approval requirements relating to Public Officials
Use good judgment and identify potential situations where giving or receiving a gift will create the wrong perception
Do not give or receive gifts in cash or equivalent
Link to relevant procedures
Knowledge Corner
• Gifts and Hospitality Policy • Anti-Bribery and Corruption Procedure • Employee Handbook for your Country
3. Managing Risk – Regulatory And Third Parties | 29
3.5 COMPETITION AND FAIR TRADING VFS Global promotes fair and open competition and seeks to compete fairly, ethically, and within the framework of all applicable international anti-trust and anti-competition laws. Practices that are contrary to promoting a fair and open competition can hamper the business and reputation of VFS Global which may include behaviours such as:
1
2
Exchanging sensitive information with market competitors
Discussing, debating and/ or agreeing on prices, margins, terms of sale, price changes, discounts with competitors
3
4
Agreeing with a competitor to divide regions of operations providing effective monopolies to each party in those areas
Attempting to seek information about competitors and their practices using illegal or unethical means
30 | 3. Managing Risk – Regulatory And Third Parties
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1234
Why is this important? All employees in VFS Global must comply with all relevant anti-trust and anti-competition laws and regulations. Any violations may result in substantial fines for VFS Global and fines or prison sentences for offending employees. In particular, price-fixing among competitors (verbal, written or in any other form), market allocation, exchange of information and any other practices which may inhibit free competition, are prohibited.
Your Responsibilities Follow the VFS Global Anti-Trust / Anti-Competition Policy Do not discuss or exchange VFS Global confidential information with competitors or other external parties Do not discuss, agree or arrange pricing, margins, VFS Global discount policies/processes or market share with competitors or other external parties If you have any doubts, questions or concerns, please consult with the Head of Compliance
Link to relevant procedures
Knowledge Corner
• Anti-Trust / Anti-Competition Policy • Employee Handbook for your Country
3. Managing Risk – Regulatory And Third Parties | 31
3.6 ANTI-MONEY LAUNDERING AND COUNTER TERRORIST FINANCING
VFS Global is committed to complying with all applicable laws including international anti-money laundering and counter terrorist financing laws. All VFS Global employees must be vigilant to any potential transactions which may be linked to terrorism or other illegal activity and ensure that we comply with global anti-money laundering laws and other relevant laws in countries where we operate.
Why is this important? Money laundering and terrorist financing are criminal offences and any breaches of relevant laws and regulations could result in significant fines and/or imprisonment. Unlawful activity by business partners or other third parties associated with VFS Global could adversely affect our reputation and in certain circumstances VFS Global may be held accountable for their actions.
32 | 3. Managing Risk – Regulatory And Third Parties
Your Responsibilities Do not deal with criminals or other external parties of concern nor with suspicious transactions and business dealings involving them You must ensure that you comply with all appropriate VFS Global policies and procedures including our Third Party Due Diligence and Procurement Procedures so we know who we are doing business with Do not attempt to hide the origins or the source of customers’ payments nor the background of suppliers’ accounts, if known
Do not knowingly assist with, nor support the ownership or control of criminal proceeds or assets
If you have knowledge or suspicion that a customer or supplier is involved in money laundering, you must immediately advise the Head of Compliance or the Head of Legal. Do not discuss your concerns with the customer or the supplier
You should know your customers and suppliers and do not assume that appropriate third party screening has cleared them.
Link to relevant procedures
Knowledge Corner
• Anti-Money Laundering and Terrorist Financing Procedure • Third Party Due Diligence and Procurement Procedures
3. Managing Risk – Regulatory And Third Parties | 33
3.7 THE UK MODERN SLAVERY ACT AND ABOLISHMENT OF CHILD LABOUR
VFS Global prohibits all forms of modern-day slavery, human trafficking, and use of child labour. We must ensure that our supply chains are free from slavery and human trafficking and use children in the workforce. VFS Global is committed to abolishing all forms of child labour and implementing effective systems and controls to ensure that modern slavery is not occurring anywhere in our own business or those of our suppliers.
Why is this important? Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking – all of which have in common the deprivation of a person’s liberty in order to exploit them for personal or commercial gain. Children are particularly vulnerable to being forced or coerced to work before that are legally permitted. VFS recognises the important role that international organisations have in preventing child labour and we are committed to ensuring that our business partners and suppliers abide by employment laws. VFS opposes modern slavery and child labour in all its forms. We are committed to preventing it within our means, and demand the same from all who work for us, and all with whom we have business dealings – especially through the supply chain that provides support through the different aspects of our business.
34 | 3. Managing Risk – Regulatory And Third Parties
Your Responsibilities
Report your concerns about slavery and human trafficking that you might identify either within our operations or in those of our supply chains
Do not knowingly support or deal with any suppliers or other businesses in our supply chain that you know, or suspect, are involved in slavery or human trafficking
Do not ignore or attempt to hide potential activities by any suppliers or other businesses in our supply chain that you know, or suspect, are involved in slavery or human trafficking
Notify your managers, senior management or the Head of Compliance if you know or suspect that any of our suppliers or businesses in our supply chain are involved in slavery or human trafficking
Link to relevant procedures
Knowledge Corner
• Policy under the UK Modern Slavery Act • Employee Handbook for your Country
3. Managing Risk – Regulatory And Third Parties | 35
4 MANAGING RISKINFORMATION, COMMUNICATIONS AND ASSETS
4.1 PROTECTING DATA AND CONFIDENTIAL INFORMATION
As a market leader in visa and consular service solutions, our organisation handles personal data in a secure environment by establishing robust data protection measures. As a business, it is important for us to respect and protect privacy of all our applicants, employees or business partners unless such divulgence is required by law. We are committed to handling confidential information, including personal data, respectfully and appropriately in line with our responsibilities and as per applicable data protection and privacy laws. Any processing of personal data must be reasonable and lawful and must not be acquired by any illegal means. VFS Global shall also provide the technical use and organisational means required to ensure that personal data is protected against unauthorised processing.
Why is this important? Breaches of confidentiality or privacy can significantly damage the trusted relationship that VFS Global has with its Clients, business partners and applicants. In addition, stringent privacy laws such as the EU General Data Protection Regulation (GDPR) and similar types of laws in many countries, place regulatory obligations on VFS Global to protect personal information and report any losses or breaches of confidential data to regulators. Breaches of the GDPR or other privacy laws can result in significant penalties, including fines, reputational damage and under certain circumstances, closure of our business activities.
4. Managing Risk – Information, Communications and Assets | 37
Your Responsibilities Understand that ‘Personal Data’ is a very broad term and includes but is not limited to a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person Understand your role in protecting this confidential data and any actions which could result in a privacy breach Do not access any confidential information, including personal data, unless you are authorised to do so within your role Follow VFS Global Data Protection Policy and ensure all confidential data is removed from VFS Global Systems when appropriate and in line with our procedures and local law requirements Do not disclose confidential information including personal data to any person who is not authorised to access or view that data. Remember, you have only borrowed the personal data to perform a task for the individual. It is not yours to do as you please with it Do not disclose confidential information, including personal data, on any social networking sites Be vigilant for any signs of cyber threats, including phishing emails and other social engineering practices designed to illegally obtain confidential information Speak Up and report any breaches of VFS Global policies and procedures or weaknesses in VFS Global systems or processes
Link to relevant procedures
Knowledge Corner
• • • •
VFS Global Data Protection Policy Protection of Company Assets Procedure Speak Up Policy Employee Handbook for your Country
38 | 4. Managing Risk – Informatio, Communications and Assets
4.2 EXTERNAL COMMUNICATION, ADVISORY, AND SOCIAL MEDIA
External Communication VFS Global supports and provides regular communication to our clients, communities, media and other relevant groups in our industry. The aim of our external communications is to promote and sustain overall knowledge and awareness of VFS Global among these stakeholders. It is important that all information about VFS Global and its employees and affiliates, be communicated in a way that reflects VFS Global’s goals and objectives. Additionally, all public statements attributed to VFS Global and its employees should be carefully considered and personal views be kept separate. Specifically:
• Employees should not speak publicly for the VFS Global unless specifically authorised by Executive Management • If an employee is asked by a media representative to comment on our business, the request should be directed to the VFS Global Corporate Communications Department • VFS Global employees are not permitted to use VFS Global or its branding in communications which involve non-VFS business • Employees should not associate the VFS Global with, or imply endorsement of, personal opinions when communicating or engaging in personal affairs unless authorised to do so by the Executive Management • When publishing articles, delivering speeches or lectures on business, professional or managerial topics, employees should be clear that they are acting as private individual(s), and not as representative(s) of VFS • Do not provide advice or consultancy on any VFS Global products unless you are expressly authorised to do so
4. Managing Risk – Information, Communications and Assets | 39
Social Media The rapid pace of technological change in the past few years has also significantly altered the way in which people interact and offer their views across the world. This is particularly true for social media platforms where posting and communication can be accessed by clients, employees and applicants instantaneously. While the use of social media platforms presents a huge opportunity for VFS Global to enhance its brand image, we must all be aware of the risk of publishing information about VFS Global that we are not authorised to publish or communicate publicly. VFS Global’s participation in social media communication can only be authorised and approved prior to broadcasting by our Executive Board, Chief Communications Officer and the Head of Corporate Communications.
Advisory and Consultancy VFS Global employees are not permitted to offer consultancy or provide advice on any VFS Global product including visa services, citizen services, and identify management services unless authorised to do so. Designated operations staff who are expressly authorised to give information or assistance as part of their duties are the only employees who are permitted to do so. Applicants / external parties who seek advice or support on any VFS Global Products must be directed to VFS Global websites or call centres, where information is available.
Why is this important? As an employee of VFS Global, statements and publications made by you on Social Media have the potential to impact the reputation of VFS Global. The unauthorised publication or sharing of confidential information owned by VFS Global or its clients is strictly prohibited and could result in regulatory consequences for the responsible parties. 40 | 4. Managing Risk – Informatio, Communications and Assets
Your Responsibilities Review and understand the VFS Global Social Media Policy and the Communications Policy & Guidelines
Do not speak publicly for VFS Global or publish any items on behalf of VFS Global on social media or channels unless specifically authorised by Executive Management
Ensure you direct any requests for public comment to the VFS Global Corporate Communications Department
Do not make any form of references to client governments, business partners or applicants. Employees must abstain from posting any information regarding client governments, applicants, partners, suppliers or third party agency products or vendors, especially their confidential details
Do not associate VFS Global with, or imply VFS Global endorsement of, personal opinions when communicating or engaging in personal affairs unless authorised to do so by Executive Management
When publishing articles, delivering speeches or lectures on business, professional or managerial topics, employees should be clear that they are acting as private individuals, and not as a representative of VFS Global
Link to relevant procedures
Knowledge Corner
• Social Media Policy • Communications Policy & Guidelines • Employee Handbook for your Country
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4.3 USE OF INFORMATION TECHNOLOGY
All VFS Global employees, contractual staff, third parties and other individuals using VFS Global’s information, processing systems, and facilities shall adhere to VFS Global’s Information Security Policy. Adherence to this Policy is mandatory and breaches may result in disciplinary action.
Why is this important? VFS Global relies on the use, storage, and exchange of information for all aspects of its operations. It is essential that we use this information responsibly and only for its intended purpose, especially when it comes to data such as personal details, commercially sensitive information, and intellectual property – including that of others. Breaches of the VFS Global Information Security Policy may cause significant damage to the reputation of VFS Global, and result in a financial loss and/or regulatory penalties.
Your Responsibilities VFS Global Information Security Policy contains the full details of your responsibilities when using VFS Global computers and systems. The following points summarise your responsibilities with respect to information security and use of VFS Global systems:
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Your Responsibilities
Only use VFS Global information and information processing systems for official purposes
Maintain confidentiality of your password and do not share it with other individuals
Do not access, store, send or post pornography or other indecent or offensive material
Do not transmit VFS Global confidential or restricted information through untrusted public networks, unless authorised
Do not introduce unauthorised copies of licensed software and hardware to VFS Global information processing systems
Do not subscribe to any forums using your company email account
Do not perform any illegal activities, including gambling, accessing or downloading pornographic, offensive or illegal material
Do not modify or disable any security settings on your work computer or any other VFS Global systems
Link to relevant procedures
Knowledge Corner
• Global Information Security Policy • Employee Handbook for your Country
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4.4 USE AND PROTECTION OF COMPANY PROPERTY
All employees should exercise due care and responsibility in their use and handling of VFS Global’s assets and property. All of our assets, including computer systems (hardware and software), documents, data, furnishings, offices equipment, company accommodation and stationery, should be used for legitimate VFS Global business purposes only. Our assets should not be used for personal benefits, sold, lent, given away or disposed off inappropriately and/or without proper authorisation.
Why is this important? Each employee has a responsibility to protect our company assets and information and doing so is critical to building and maintaining client and industry trust and loyalty. Improper or careless handling of assets and property (particularly information and data) could harm VFS Global’s reputation and image. In addition, these violations could adversely affect a client’s or business partner’s decision to engage with VFS Global.
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Your Responsibilities Do not inappropriately remove any VFS Global assets or property from our offices without proper authorisation and approval Do not damage, destroy or otherwise alter VFS Global’s assets or property without authorisation
Do not access proprietary, confidential or personal data without appropriate authorisation and purpose
Ensure that any destruction of documentation or data is undertaken appropriately and according to VFS Global Document Retention guidelines
Report your concerns about any unauthorised use or disposal of VFS Global’s assets or property
Link to relevant procedures
Knowledge Corner
• Protection of Company Assets Policy • Information Security Policy • Employee Handbook for your Country
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5 P E O P L E , C U LT U R E AND SOCIAL RESPONSIBILITY
5.1 HEALTH AND SAFETY
VFS Global is committed to providing a safe and healthy work environment and abiding by the relevant health and safety laws and regulations in the countries in which we operate. The safety and well-being of our employees and clients is of utmost importance and management is committed to ensuring: • A safe working environment • Safe processes and work activities • Support for the welfare of all employees • Information, instruction, training and supervision that is reasonably necessary to ensure that each worker is safe from injury and risks to health • Commitment to consult and co-operate with workers in all matters relating to health and safety at the workplace • Commitment to continually improve our performance through effective safety management
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Our commitment to a safe work environment is jeopardised when any VFS Global employees illegally uses drugs during or out of work hours; comes to work under the influence of alcohol or drugs; or possesses, distributes or sells drugs or drug paraphernalia in the workplace.
Consumption of alcohol and/or illicit substances at the workplace is prohibited except in the following situations: • Specifically prescribed and appropriately used drugs as medication for an ailment and; • Consumption of reasonable quantities of alcohol at approved social occasions, gatherings, and functions.
Violation of this policy will result in disciplinary action, including termination and disclosure to local authorities.
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Why is this important? All employees have a mutual obligation to abide by all VFS Global health and safety regulations. Failure to comply with our work safety practices can increase the risk of injury to yourself, your colleagues or our clients. Employees often become complacent about work safety because they have not experienced a significant safety event or do not anticipate that an accident could involve them. Work safety governance is only noticed when unforeseen events occur. Accordingly, you need to remain vigilant and be aware of the health and safety risks in your workplace.
Your Responsibilities Comply with safe work practices Take care of the health and safety of yourself and others Comply with any direction given by management for health and safety Comply with the directions of Corporate Security, particularly in an emergency Do not misuse or interfere with anything provided for health and safety Report all accidents and incidents in the workplace immediately, no matter how trivial Report all known or observed hazards to your supervisor, Manager or Corporate Security
Link to relevant procedures
Knowledge Corner
• Drug Free Workplace Policy • Occupational Health & Safety Procedures • Employee Handbook for your Country
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5.2 CORPORATE SOCIAL RESPONSIBILITY, DONATIONS AND SPONSORSHIP
VFS Global is committed to good corporate governance and takes into account the current and future economic, social and environmental impacts of our business. We recognise our responsibility to our communities and support sustainable community development programs. As part of this support, VFS Global makes charitable contributions to worthy causes and participates in corporate social responsibility activities in the communities that we operate. However, VFS Global will not use charitable donations as a substitute for political donations.
CSR and Donations As an employee of VFS Global, we encourage you to actively participate in your communities and support our Corporate Social Responsibility (CSR) initiatives. It is important you ensure that any charitable contribution or CSR activity conducted on behalf of VFS Global is for legitimate and worthwhile purposes.
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As part of our commitment to CSR, we may also make charitable contributions and donations to worthy causes in the communities that we operate such as contributions to protect the environment or to support under privileged people. All donations and CSR contributions must be for lawful purposes and align with the Values and Principles of VFS Global.
Sponsorship Sponsorships are marketing activities designed to promote the VFS Global brand and raise awareness of VFS Global business initiatives and capabilities. There must be a legitimate business purpose for all VFS Global sponsorships and recipients must be engaged in legal and acceptable activities prior to receiving sponsorship. The following standards apply to all proposed Sponsorship activities: • Only permitted where the activities are aligned with our business objectives, values and principles • Not permitted to improperly influence a third party including clients or Public Officials • Not to be made in cash • Not to be used for any political purposes • Not to be used for any unlawful purpose or made to any third party which does not abide by VFS Global’s zero tolerance to bribery and corruption
Why is this important? CSR and charitable donations can have a profound impact on improving the lives of underprivileged people. It is important that careful consideration is given to supporting the right initiatives to ensure that we achieve the best outcomes for the communities in which we operate. All donations are considered and approved by the relevant Country Head where the applicants work. Further information regarding this process is contained within the AntiBribery and Corruption Procedure.
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Your Responsibilities
Follow the VFS Global CSR and Donations procedures and the Anti-Corruption Procedure
Do not use VFS Global funds for any political purposes or contribute to any political parties
Ensure that the activity or donation is for a legitimate and worthwhile cause
Do not use VFS Global funds or resources to improperly influence another party
Consider when the activity or donation could create a conflict of interest or perceived conflict of interest
Seek assistance from Compliance or Corporate Communications
Link to relevant procedures
Knowledge Corner 52 | 5. People, Culture and Social Responsibility
• • • •
Anti-Bribery and Corruption Procedure Corporate Social Responsibility & Donation Policy Sponsorship Policy Employee Handbook for your Country
5.3 HUMAN RIGHTS, CULTURAL DIVERSITY, AND NON-DISCRIMINATION
As an international organisation, VFS Global employs people from many different nations. We take pride in this diversity, which enriches our working culture, and we value the diversity of our workforce as a competitive advantage. We encourage a corporate culture that fosters innovation, professional growth, career development and work/life balance. As a diverse workforce it is important that we are open-minded and empathetic to one another. VFS Global is committed to ensure equal opportunities and employment at the workplace. Our interactions with one another must be courteous, fair, open and respectful. VFS Global does not tolerate any form of harassment discrimination for any reason such as an individual’s race, religion, belief, nationality, sex, age, sexual orientation or disability. VFS Global is committed to supporting human rights and fostering an environment which respects the basic rights of all people. Human rights principals are embodied throughout the VFS Global Code of Conduct, and we expect all our staff to support equal opportunity, not engaging in discriminatory practices, and respect the rights of other employees and customers.
Discrimination and harassment Any employee who harasses, disrupts or interferes with another’s work performance or creates an intimidating, offensive or hostile environment should be reported immediately to Human Resources or to the Head of Compliance for investigation and action in accordance with applicable local laws.
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Why is this important? VFS Global values diversity and places great importance on the safety and well-being of our employees and clients. Discriminatory or harassing behaviour is damaging to the work environment and in many instances unlawful. All employees must be respectful to one another and understand the effect that their actions and words can have at the workplace.
Your Responsibilities Be aware of how your own behaviour may affect others Treat your colleagues with dignity and respect Do not harass or discriminate any other person for any reason such as their race, religion, belief, nationality, sex, age, sexual orientation or disability Take a stand if you think inappropriate jokes or comments are being made in the workplace Make it clear that you find harassment and bullying unacceptable If you become aware of an instance of harassment or discrimination report it to your supervisor, Human Resources or through the Speak Up channels
Link to relevant procedures
Knowledge Corner 54 | 5. People, Culture and Social Responsibility
• • • •
Dignity at Work Policy Diversity and Inclusion Policy Anti-Sexual Harassment Policy Employee Handbook for your Country
5.4 SEXUAL HARASSMENT
VFS Global adopts and promotes a zero tolerance policy with regard to sexual harassment – whether verbal or physical. Sexual harassment includes any comments of a sexist nature and any conduct or behaviour, verbal or physical, of a sexual nature. This relates to all VFS Global employees with regard to their conduct and behaviour with their colleagues, including their managers, other supervisors and their reporting staff, and includes behaviour when dealing with VFS Global clients, customers, applicants and other VFS Global third parties.
Why is this important? VFS Global respects the dignity of its employees and others we work with, and we strive to ensure that our workplace is safe, healthy and respectful to all individuals. We promote a working environment in which all employees can work together to complement each other as equals, and provide circumstances that encourage maximum productivity.
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Your Responsibilities Be aware of how your own behaviour may affect others
Treat your colleagues with dignity and respect
Do not submit your colleagues, either explicitly or implicitly, to conduct that is sexually intimidating, hostile or offensive
Do not make unwanted or inappropriate physical contact, including touching or propositioning your colleagues
Do not verbally harass other staff with sexual or lewd comments, jokes of a sexual nature or offensive references to others which may be of a sexual nature
Do not make comments that are demeaning, insulting, intimidating or sexually suggestive (either orally or in writing)
Do not display in the workplace demeaning, insulting, intimidating or sexually suggestive objects, pictures or photographs
Link to relevant procedures
Knowledge Corner 56 | 5. People, Culture and Social Responsibility
• • • •
Anti-Sexual Harassment Policy Dignity at Work Policy Diversity and Inclusion Policy Employee Handbook for your Country
5.5 CORPORATE EVENTS AND CORPORATE SOCIAL GATHERINGS
VFS Global employees that attend corporate events or corporate social gatherings must conduct themselves in a professional manner and be courteous to their managers, colleagues,and clients attending the event. Employees must behave in accordance with the VFS Global Values and Principles and remain aware that the Code of Conduct applies regardless of whether the event is held in VFS Global premises, client premises or other locations.
Why is this important? All employees attending corporate events and corporate social gatherings are representing VFS Global. Corporate events allow us to build strong working relationships our clients and colleagues and interact with each other in a less formal environment. We need to be mindful that we are still at work and need to ensure that we maintain the same professional standards.
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Your Responsibilities Be a good ambassador for VFS Global
Interact with VFS Global clients and your colleagues in a professional manner
Abide by the Code of Conduct
If you consume alcohol, ensure that it is in moderation and in accordance with VFS Global policies.
Link to relevant procedures
Knowledge Corner 58 | 5. People, Culture and Social Responsibility
• • • •
Dignity at Work Policy Anti-Sexual Harassment Policy Diversity and Inclusion Policy Employee Handbook for your Country
6 CONCLUSION
The Code of Conduct sets out the Values, Principles and expected behaviour of all employees. By following the practices detailed in our Code of Conduct, you will support the sustainable growth of VFS Global and be able to manage the professional and personal risks that may arise during your work. However, as the Code of Conduct cannot cover every potential issue and risk that you may face, you should seek the advice and guidance from your Manager, the Head of Compliance, the Head of Legal or your relevant Head of Human Resources when necessary. And remember – if you see, hear or suspect that someone has breached or is about to breach the Code of Conduct, Speak Up through the available channels.
“Always remember, it is important to do things the right way as we continue to grow together and cross many more milestones as a trusted partner to Governments and Diplomatic Missions worldwide”.
- Zubin Karkaria, CEO
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6.1 GLOSSARY OF TERMS “CEO” means the Chief Executive Officer of VFS Global Services PLC. “Conflict of Interest” is a situation where you as an employee of VFS Global have competing interests, financial or otherwise, with VFS Global’s business. This ‘conflict’ or situation may also adversely affect the manner in which you make decisions on behalf of VFS Global, to the benefit or yourself or to a third party. “COO” means the Chief Operating Officer of the concerned region of VFS Global. “CSR” means Corporate Social Responsibility, which is an initiative to assist VFS Global to be more socially accountable to the communities in which we operate. It covers aspects of economic, social and environmental factors, and provides guidance for VFS Global to operate in a manner to enhance our societies and the environment. “Ethics” are the moral principles that govern and direct the behaviour or conduct of an individual, group or organisation. “FMC” means Facilities Management Companies. References to “FMC” “FMCs” “ or “Facilities Management Company” include the management and employees of the relevant FMC. “GDPR” is the EU General Data Protection Regulation, a European Union regulation which governs data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). Personal Data includes but is not limited to a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person. “Manager” includes direct line manager, supervisor or Reporting Head. “Personal data” includes but is not limited to a name, an identification number, location data, an online identifier, or to one of more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person. “Speaking Up” describes the purpose and process for staff to raise their concerns about inappropriate actions and practices of other VFS Global employees, managers or relevant third parties. It also describes the mechanisms and channels for staff to raise these concerns.
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6.2 CONTACT DETAILS
Bernard Martyris Chief of Human Resources Tel: + 971 (0) 4 3059000 Email: MBernard@vfsglobal.com Rodney Hay Head of Compliance Tel: + 971 (0) 4 3059032 Email: RodneyHa@vfsglobal.com Office 3207, 32nd Floor, Jumeirah Business Centre, 1 Tower, Cluster G, Jumeirah Lakes Towers, P.O.Box 114100, Dubai, UAE
Version 2.0 | February 2019
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