CODE OF ETHICS
We are committed to conducting business with the highest standards of ethics, integrity, and compliance. As a global company, we recognize the importance of maintaining ethical practices in all aspects of our business, including interactions with customers, partners, employees, and stakeholders.
The Code of Ethics serves as a critical document that outlines the expectations of ethical behavior for all Vaultex employees, officers, and agents. It outlines the fundamental principles and standards that guide our business practices. It is applicable to all employees, officers, directors, and stakeholders of Vaultex Ltd. (“we”, “us”, “our” or “Vaultex ” or “Company”).
The purpose of this Code of Ethics is to provide a framework for conducting business in a manner that upholds Vaultex’s values of integrity, accountability, and respect for all stakeholders. By adhering to this Code of Ethics, we ensure that we are conducting business in a responsible and sustainable manner that benefits all parties involved. The Code of Ethics applies to all employees, officers, and agents of Vaultex, and serves as a guide for ethical decision-making and behavior.
It is the responsibility of each employee and stakeholder of Vaultex to understand and comply with the principles and standards outlined in this Code of Ethics. Any violation of this Code of Ethics will be subject to investigation and appropriate action, up to and including termination of employment or termination of business relationship.
Adherence to the Code of Ethics ensures that Vaultex maintains its reputation as a socially responsible company committed to ethical business practices.
WE ENCOURAGE ALL EMPLOYEES AND STAKEHOLDERS OF VAULTEX TO REVIEW THIS CODE OF ETHICS CAREFULLY AND TO SEEK GUIDANCE OR REPORT ANY CONCERNS THROUGH THE CHANNELS PROVIDED IN THIS DOCUMENT.
By working together, we can ensure that Vaultex remains a responsible and ethical business leader in all of our markets and communities.
1. Introduction
a) Purpose of the Code of Ethics
The aim of this Ethical Code is to offer direction and set criteria for moral behavior among all personnel, executives, and representatives of Vaultex. Its objective is to foster integrity, professionalism, respect, and accountability across all business activities.
This code functions as a reference for conduct and decision-making, aiming to cultivate a corporate environment characterized by integrity, openness, and responsibility. Additionally, it delineates the anticipated standards of ethical behavior and demeanor consistent with the values and ethos of Vaultex.
b) Scope and Application of the Code of Ethics
This code is binding on all staff, executives, and representatives of Vaultex, irrespective of their role or level of authority, as well as any external parties rendering services on behalf of Vaultex. It delineates the desired behaviors and ethical benchmarks that employees are expected to maintain during the course of conducting business for the organization.
The Code of Ethics pertains to all facets of the company's endeavors, encompassing engagements with clients, suppliers, and other vested stakeholders.
c) Compliance with the Code of Ethics
Non-compliance with this Code of Ethics may result in disciplinary action, up to and including termination of employment or business relationship with Vaultex..
2. Definitions
“Accountability” means the obligation to take responsibility for one's actions and decisions, and to be answerable to clients, colleagues, and the public. Accountability is a fundamental principle of the Code of Ethics and is essential for building trust and maintaining professional relationships.
“Code of Ethics” means a set of guidelines and principles that outline the expected conduct of individuals within a profession or organization. A Code of Ethics serves as a framework for decision-making and provides guidance on appropriate behavior in various situations.
“Compliance” means the act of adhering to laws, regulations, and ethical standards. Compliance is a key aspect of the Code of Ethics, and individuals and organizations are expected to comply with the standards and guidelines set forth in the Code.
“Confidentiality” means the obligation to protect sensitive information and maintain the privacy of clients and colleagues. Confidentiality is a fundamental principle in the Code of Ethics and is essential to building trust and maintaining professional relationships.
“Conflict of Interest” means a situation in which an individual's personal interests conflict with their professional obligations. A Conflict of Interest can arise when there is a risk of bias or unfair advantage, and can compromise the integrity and credibility of the individual and the organization.
“Ethical Conduct” means the behavior and actions that align with the principles and values outlined in the Code of Ethics. Ethical Conduct involves behaving in a professional, honest, and responsible manner, and maintaining the highest standards of integrity and moral character.
“Ethical Standards” means a set of principles and values that define appropriate behavior within a profession or organization. Ethical Standards provide guidance on conduct, accountability, and responsibility, and are based on the values and principles of the Code of Ethics.
“Fairness” means the quality of being impartial and unbiased in decision-making. Fairness is a fundamental principle of the Code of Ethics and is essential for maintaining trust and credibility with clients, colleagues, and the public.
“Integrity” means the quality of being honest, reliable, and trustworthy. Individuals with integrity adhere to ethical principles and values, and are committed to upholding the standards outlined in the Code of Ethics.
“Professional Development” means the ongoing process of acquiring new knowledge, skills, and competencies to enhance professional growth and effectiveness. Professional Development is a key aspect of the Code of Ethics, and individuals and organizations are expected to invest in ongoing learning and development to maintain the highest standards of professionalism.
“Social Responsibility” means the obligation to act in the best interests of society and to contribute to the well-being of the community. Social Responsibility is a key value of the Code of Ethics, and individuals and organizations are expected to consider the impact of their actions on society and to act in a socially responsible manner.
“Transparency” means the quality of being open, honest, and clear in communication and decision-making. Transparency is an important principle of the Code of Ethics, and individuals and organizations are expected to be transparent in their actions and decisions.
3. Core Values and Principles
a) Respect: Vaultex remains dedicated to upholding a workplace environment devoid of discrimination, harassment, and any form of mistreatment. Employees are obligated to treat others with respect and dignity, nurturing a culture of inclusivity and diversity regardless of race, ethnicity, gender, sexual orientation, or any other defining characteristic
b) Responsibility: Vaultex committed to responsible business practices, including environmental stewardship, corporate social responsibility, and compliance with applicable laws and regulations. Employees are expected to act responsibly in all aspects of their work, and to consider the impact of their actions on the company, its stakeholders, and the wider community.
c) Integrity: Vaultex upholds a dedication to conducting business with honesty, fairness, and transparency. This commitment entails truthful and precise communication, adherence to laws and regulations, and the avoidance of conflicts of interest. Employees are anticipated to demonstrate the utmost integrity, whether within the workplace or in external environments..
d) Professionalism: Vaultex prioritizes professionalism in all engagements with customers, suppliers, and stakeholders. Employees are required to uphold conduct that enhances the company's reputation positively. Additionally, Vaultex anticipates employees to consistently demonstrate professionalism, encompassing the maintenance of high work standards, respectful interactions with colleagues and clients, and the preservation of confidentiality....
4. Ethical Standards
a) Conflicts of Interest
Employees must avoid situations that create, or may create, a conflict of interest and disclose any potential conflicts of interest that may arise between their personal interests and those of the company. This includes situations where personal interests may conflict with those of Vaultex . Employees are required to disclose any potential or actual conflicts of interest to their supervisor or the Compliance Officer
b) Gifts and Entertainment
Vaultex employees must not accept gifts or entertainment from suppliers, customers, or other stakeholders that could influence or be perceived to influence their business decisions. Employees may accept gifts or entertainment of nominal value, provided that they are consistent with local customs and business practices.
c) Confidentiality and Privacy
Vaultex employees must protect the confidential and private information of the company, its customers, and its stakeholders. Employees must not disclose confidential or private information without authorization, and must take appropriate measures to safeguard such information.
d) Use of Company Resources
Employees are expected to use company resources, including time, equipment, and supplies, in an appropriate and ethical manner and only for legitimate business purposes.
e) Fair Competition
Vaultex is committed to fair competition and compliance with applicable antitrust and competition laws. Employees must not engage in anti-competitive behavior or agreements with competitors, and must avoid any conduct that could be perceived as anti-competitive.
f) Anti-Discrimination and Harassment
Vaultex is committed to providing a safe and respectful work environment, free from discrimination and harassment
g) Health and Safety
Vaultex is committed to maintaining a workplace that is free from discrimination and harassment. Employees must not engage in discriminatory or harassing behavior, and must report any such behavior to their supervisor or the Compliance Officer.
5. Professional Responsibility
a) Competence and continuing professional development
Maintain a high level of proficiency in your field to ensure optimal service delivery to clients. Stay updated with industry advancements, continuously enhance skills, and actively pursue opportunities for ongoing learning and professional advancement. Acknowledge personal limitations and seek guidance from appropriate sources when necessary.
b) Objectivity and independence
Provide impartial and unbiased advice to clients, free from conflicts of interest or undue influence. Prioritize the client's best interests and abstain from personal or financial gains that may compromise the advisory process. Disclose any potential conflicts of interest transparently and seek guidance as needed
c) Confidentiality and privacy
Uphold strict confidentiality and privacy standards regarding client information, trade secrets, and sensitive data at Vaultex. Employ suitable measures to safeguard such information and prevent unauthorized disclosure. Adhere to relevant data privacy laws and regulations.y..
d) Integrity and ethical behavior
As professionals associated with Vaultex, it is imperative to uphold integrity and ethical behavior consistently. This necessitates refraining from any actions that could compromise professional duties or tarnish Vaultex’s reputation. Always prioritize honesty, transparency, and adherence to ethical norms in interactions with clients, peers, and the public.
e) Professional conduct and demeanor
Represent Vaultex with professionalism and respect in all dealings. Maintain appropriate attire, communication etiquette, and behavior conducive to a respectful work environment. Embrace diversity and inclusivity, fostering a welcoming atmosphere for all.
6. Responsibilities of Employees
Comprehend and adhere to the ethical standards outlined in the code of ethics.
Conduct business with sincerity, honesty, and in alignment with all relevant laws and regulations.
Avoid situations that could lead to conflicts of interest or give the impression of wrongdoing.
Safeguard the confidentiality and privacy of sensitive information and personal data
Notify the designated reporting channels, such as the Compliance Officer or senior management, of any suspected violations or breaches of the code of ethics.
Express concerns in good faith, without apprehension of retaliation or reprisal
Collaborate with internal or external investigations associated with the code of ethics.
Non-compliance with the code of ethics will not be tolerated and may result in disciplinary measures, including termination of employment.
Employees are accountable for their actions and must accept the repercussions of any violations of the code of ethics.
7. Responsibilities to Clients or Customers
Employees of Vaultex must exercise due care, diligence, and expertise when delivering services to clients or customers.
Vaultex is committed to meeting the expectations of clients or customers by delivering high-quality products or services tailored to their needs
Vaultex pledges to furnish clients or customers with precise and comprehensive information.
Vaultex employees are obligated to treat clients or customers fairly and transparently, refraining from any unjust or misleading practices
Vaultex is responsible for ensuring that the terms and conditions of its products or services are transparent and easily understandable for clients or customers.
Vaultex undertakes to furnish clients or customers with all pertinent details concerning its products or services, encompassing costs, fees, and associated risks.
Employees of Vaultex must uphold the confidentiality and privacy of client or customer data, refraining from disclosing such information to third parties except where mandated by law.
Vaultex will implement reasonable measures to protect client or customer data from unauthorized access or disclosure.
Prior to collecting, using, or disclosing personal information, Vaultex will obtain appropriate consent from clients or customers.
Employees of Vaultex must steer clear of conflicts of interest between the interests of clients or customers and those of Vaultex or its employees.
Vaultex is obliged to disclose to clients or customers any conflicts of interest that may arise during the provision of its products or services.
Vaultex will take necessary measures to address or minimize any conflicts of interest that may arise.
Vaultex will equip clients or customers with all necessary information to facilitate informed decisions regarding its products or services.
Vaultex will disclose to clients or customers any significant information that could impact their decision to utilize its products or services.
All marketing and advertising materials produced by Vaultex must adhere to principles of truthfulness, accuracy, and non-deception.
8. Responsibilities to Colleagues
Treat all coworkers with courtesy and professionalism, irrespective of their role or position within the organization.
Avoid engaging in discriminatory or offensive conduct towards coworkers based on factors such as race, gender, age, sexual orientation, religion, or other personal attributes.
Promote a collaborative, supportive, and team-oriented culture within the company
Collaborate with coworkers to achieve shared goals and objectives.
Communicate openly and truthfully with colleagues to foster trust and prevent misunderstandings.
Share knowledge, expertise, and resources with coworkers to enhance team performance.
Engage in fair and ethical competition with colleagues, refraining from actions that could undermine their success or reputation.
Refrain from engaging in discriminatory or harassing behavior towards coworkers, including based on race, gender, age, sexual orientation, religion, or other personal characteristics.
Adhere to all relevant laws and regulations governing fair competition and workplace anti-discrimination.
Cultivate a safe and respectful work environment, free from harassment, bullying, or intimidation of any kind.
Promptly report any incidents of harassment or bullying to management and offer support to affected coworkers.
Take necessary steps to prevent and address future instances of harassment or bullying in the workplace.
Maintain honesty and transparency in all communications with coworkers, avoiding false or deceptive statements.
Refrain from spreading rumors or gossip that could damage the reputation or well-being of coworkers.
Respect the confidentiality of sensitive information shared by coworkers and refrain from disclosing it to unauthorized individuals without their consent.
9. Responsibilities to the Organization
Adherence to all relevant laws and regulations governing the organization's operations and activities.
Compliance with internal policies, procedures, and guidelines.
Conducting business with honesty and integrity, adhering to legal and ethical standards.
Protecting the organization's assets, including intellectual property, confidential information, and proprietary data.
Using company resources, such as equipment, facilities, and software, responsibly and solely for legitimate business purposes.
Preventing misuse or theft of company assets and resources.
Reporting any suspected or actual illegal or unethical behavior, including fraud, theft, harassment, or discrimination.
Following the organization's established reporting procedures and channels.
Cooperating in investigations of reported behavior and providing accurate and truthful information.
Identifying and disclosing any potential or actual conflicts of interest that may affect the organization.
Avoiding situations where personal interests may conflict with those of the organization
Prioritizing the organization's best interests over personal ones.
Maintaining the confidentiality and privacy of sensitive organizational information, including client and employee data, as well as financial information.
Adhering to established protocols for handling confidential information and data.
Respecting the privacy rights of employees and clients.
Conducting oneself professionally and respectfully when representing the organization.
Treating colleagues, clients, and customers with dignity and courtesy.
Refraining from any behavior that could tarnish the reputation or image of the organization.
10. Responsibilities to Society and the Environment
Vaultex recognizes the importance of environmental sustainability and strives to minimize its impact on the environment.
Vaultex commits to complying with all applicable environmental laws and regulations.
Vaultex seeks to reduce its carbon footprint by implementing eco-friendly practices in its operations.
Vaultex encourages its employees and stakeholders to adopt sustainable practices in their personal and professional lives.
Vaultex is committed to being a responsible corporate citizen and contributing positively to the communities in which it operates.
Vaultex supports social causes and initiatives that align with its values and mission.
Vaultex encourages its employees to participate in community service and volunteer programs.
Vaultex engages in responsible philanthropy by supporting charitable organizations that have a positive impact on society.
Vaultex recognizes the importance of public welfare and safety and takes measures to ensure the safety of its employees, customers, and stakeholders.
Vaultex complies with all applicable safety regulations and standards in its operations.
Vaultex takes steps to ensure the security and privacy of its users' data and information.
Vaultex takes prompt and appropriate action to address any safety or security concerns raised by its employees or stakeholders.
Vaultex is committed to complying with all applicable laws and regulations related to society and the environment.
Vaultex regularly reviews its operations and policies to ensure compliance with relevant laws and regulations.
Vaultex takes swift action to address any violations or non-compliance issues.
Vaultex is committed to avoiding any actions that may harm society or the environment.
Vaultex takes a proactive approach to identifying and addressing potential risks and negative impacts of its operations.
Vaultex seeks to minimize any negative impact on society or the environment by adopting sustainable practices and policies.
Vaultex takes responsibility for any harm caused by its operations and takes appropriate action to mitigate the impact.
11. Training and Education
Understanding the company's code of ethics, values, and core principles.
Recognizing and navigating ethical dilemmas and conflicts of interest.
Best practices for maintaining confidentiality, privacy, and integrity in business interactions.
Compliance with relevant laws, regulations, and industry standards.
Case studies and real-world scenarios to illustrate ethical decision-making in various contexts
In-person workshops, seminars, and presentations led by experienced facilitators.
Online modules, e-learning courses, and interactive simulations accessible to all employees.
Guest speakers, industry experts, and thought leaders invited to share insights and perspectives on ethical leadership and conduct.
Vaultex is committed to fostering a culture of ethical behavior and decision-making among its employees, officers, and agents. To support this commitment, the company shall provide regular training and education programs on ethical conduct and decision-making.
a) Content of the Training
The training and education programs shall cover a range of topics, including but not limited to:
b) Delivery
The training and education programs shall be delivered through a combination of methods, including:
c) Evaluation and Feedback
Following each training session, participants shall have the opportunity to provide feedback and suggestions for improvement. The company shall use this feedback to continually enhance the effectiveness and relevance of the training and education programs
d) Integration and Application
Vaultex encourages employees to apply the principles and insights gained from the training and education programs in their daily work. Supervisors and managers are encouraged to support and reinforce ethical behavior through coaching, mentoring, and leading by example.
12. Enforcement and Accountability
a) Reporting and investigation of violations
Vaultex promotes a culture of accountability by urging all employees to report any suspected breaches of the Code of Ethics or instances of unlawful or unethical behavior. Employees should convey concerns to their supervisor, the Ethics Committee, or the Compliance Officer. Any reported violations will be treated with seriousness and investigated promptly and thoroughly. Vaultex strictly prohibits retaliation against employees reporting suspected violations in good faith.
b) Sanctions and disciplinary measures
Breaches of the Code of Ethics may lead to disciplinary action, including termination of employment. Such actions will be administered fairly and consistently, aligned with the severity of the violation. Sanctions may also involve corrective measures such as retraining or counseling, as deemed appropriate.
c) Confidentiality and protection of whistleblowers
Vaultex values the confidentiality of whistleblowers and ensures that all reports of suspected violations are handled discreetly and sensitively. Retaliation against whistleblowers is strictly prohibited, and measures are in place to shield them from adverse consequences resulting from their reports.
d) Appeals process and dispute resolution
Employees subject to disciplinary action have the right to appeal through established channels. The appeals process will be impartial, affording all parties the opportunity to present their arguments. Vaultex endeavors to resolve Code of Ethics-related disputes through mediation or alternative dispute resolution methods.
e) Continuous improvement and review of the Code of Ethics.
Vaultex is dedicated to enhancing its Code of Ethics continually, ensuring its relevance and effectiveness. Regular reviews are conducted to align the Code with current laws and regulations. All employees receive training on the Code of Ethics, including updates or revision
13. Responsibilities of Management
Lead by example and promote a culture of ethical behavior
Ensure that the code of ethics is communicated clearly and regularly to all employees and stakeholders
Foster an environment where employees feel comfortable reporting ethical concerns and where retaliation is not tolerated
Provide regular training on the code of ethics to all employees
Communicate updates and changes to the code of ethics in a timely and clear manner
Ensure that all employees are aware of the reporting channels for ethical concerns
Monitor compliance with the code of ethics and investigate any violations or suspected violations
Enforce the code of ethics consistently and fairly
Take appropriate action to address violations and prevent future violations, including disciplinary action and changes to policies and procedures as necessary.
a) Setting the Tone at the Top
b) Training and Communication
c) Monitoring and Enforcement
14. Conclusion
Reporting to Supervisors: Employees who witness or experience any unethical or illegal behavior are encouraged to report it to their immediate supervisor. Supervisors are responsible for investigating the matter and taking appropriate action to resolve it.
Human Resources: Employees who have concerns related to workplace harassment, discrimination, or other employment-related issues can contact the Human Resources department. Human Resources will provide guidance on how to file a formal complaint and will investigate the matter.
Legal Department: Employees who have concerns related to legal compliance can contact the Legal department. The Legal department will provide guidance on how to file a report or a complaint related to legal or regulatory matters.
Compliance Department: Employees who have concerns related to compliance with the Code of Ethics or other policies and procedures can contact the Compliance department. The Compliance department will provide guidance on how to file a report or a complaint related to compliance with policies and procedures.
Vaultex provides a confidential and anonymous reporting system for ethical concerns.
Employees, officers, and agents may report any suspected violation of the Code of Ethics without fear of retaliation
Reports will be investigated promptly and appropriate action taken.
a) Acknowledgment of the Code of Ethics
All employees, officers, and agents of Vaultex must formally acknowledge receipt of the Code of Ethics upon their initial hire. Failure to do so may lead to disciplinary measures.
b) Review and Update of the Code of Ethics
The Code of Ethics undergoes periodic review to maintain its relevance and efficacy. Any modifications are communicated to all employees, officers, and agents of Vaultex . Suggestions for revisions or updates can be submitted to the Ethics Committee.
c) Contact Information for Ethical Concerns