Veratex Telemarketing Services

HR Policy

Code of Conduct
Policy Effectivity Date: <21/12/22>

No part of this documentation may be reproduced or transmitted in any

form or by any means, electronic or mechanical, including photocopying
or recording, for any purpose without express written permission of
the Senior Management Team of Veratex Telemarketing Services.

© 2022, Veratex Telemarketing Services. All Rights Reserved.

Revision History
 Ver Change File Prepared Reviewed Approved Date
No. Description Type By By By

1 First Draft JPCC RSB RSB 12/12/2022

2 Proofreading RSB BDM BDM 12/13/2022

3 Second Draft JPCC CEO CEO 12/13/2022

1.0 Overview
 Ethical behavior is an essential part of your position with

VERATEX and is a personal responsibility that should be taken very

seriously. We need and expect each Employee, Contractor, and

Consultant to be accountable for their work and behavior and to

support the values, principles, and standards upon which VERATEX

business reputation rests. This Code of Conduct (the "Code") is a

guide to help you live up to the company’s values, abide by VERATEX's

policies, and respect the best interests of our customers and

stakeholders.

The purpose of the Code is to describe principles of business

conduct and to provide guidance in ethical decision making. Many

sections of the Code reference matters for which specific policies

exist; this is because the Code encompasses standards of behavior set

forth in other VERATEX policies. You are expected to become familiar

with VERATEX policies that directly impact your daily work.

The Code is especially important for VERATEX as a legally-

registered company because laws, rules, and regulations are in place,

which govern the disclosure of information about the business of

legally-registered companies. The Code outlines the basic legal

obligations of all VERATEX employees, contractors, and consultants. As

a legally-registered company VERATEX affairs will be under scrutiny by

shareholders, regulators, and the legal community. We must be aware of

our obligations and conduct ourselves in accordance with the highest

ethical and moral standards.

Although all questionable activities may not be mentioned in this

Code, ask yourself the following questions to decide if an activity

should be reported or discussed with your manager:

 Does it seem right?;

 Is it legal?;

 Is it aligned with VERATEX’s vision and values?

 Would I feel uncomfortable if I read about it in a

newspaper?

 Would other people at VERATEX feel uncomfortable if they

read about it in a newspaper?

Although the Code lays out fundamental principles of ethical and

legal conduct, it cannot anticipate every ethical dilemma or situation

you may encounter in performing your daily work. If at any time you

are unsure about the proper course of action discuss your concerns

with your manager, immediate superior, or any relevant authority in

the company who has ample knowledge.

2.0 Introduction

Code of conduct can be defined as the principles, values,

standards, or rules of behavior that guide the decisions, procedures,

and systems of an organization in a way that contributes to the

welfare of its key stakeholders, and respects the rights of all

constituents affected by its operations.

All employees of VERATEX must follow the Code of Conduct defined

in this manual. Appropriate disciplinary actions shall be taken in

case of non-compliance of the Code. The Head of Human Resource (in

such a case that the Human Resource department’s leadership role is

still unfulfilled, an interim head will be appointed) will ensure that

every employee is given a copy of the Code at the time of joining.

3.0 Objectives

The goal of this Policy is to ensure that all employees of the

company understand the relevance of Integrity, Objectivity, Competence

and Professionalism. These are the objectives that this document aims

to achieve:

 To have clarity on the organization’s mission, values, and

principles;

 To link aforementioned elements towards creating a clear and

concise standard of professionalism;

 To have a clear definition of what constitutes accepted and

acceptable behavior within the company; and

 To have systems and processes that will safeguard the

Integrity of the company, its employees, partners, and

affiliates.
4.0 Scope

The Code applies to all employees, contractors, and the members

of the Board of Directors, which for purposes of the Code are referred

to as "Employees". Contractors include any consultants, suppliers, and

vendors who are required to have access to the companies confidential,

business, and proprietary information to perform their duties.

5.0 Definitions of Terms

TERM DEFINITION

Absence Absence is defined as the failure

of an employee to report for work
when he or she is scheduled to
work.

Excused absence occurs when all

the following conditions are met:
 The employee provides to his
or her supervisor sufficient
notice at least 48 hours in
advance of the absence.
 The absence request is
approved in advance by the
employee's supervisor.
 The employee has sufficient
accrued paid time off (PTO) to
cover the absence.

Unexcused absence occurs when any

of the above conditions are not
met.

If it is necessary for an
employee to be absent or late for
work because of an illness or an
emergency, the employee must
notify his or her supervisor no
 later than the employee's
scheduled starting time on that
same day. If the employee is
unable to call, he or she must
have someone make the call.

Line Manager/Immediate Superior The first layer of management

above the front-line workers.
They are accountable for their
department, or part in the
business. They manage one or more
members of staff and oversee and
evaluate employee contribution,
performance, and development.

Nepotism The act of using your power or

influence to get good jobs or
unfair advantages for members of
your immediate family, extended
family, and chosen family (more
commonly referred to as friends).

Non-Discrimination The practice of treating peoples

with different sexes, genders,
religious affiliations, political
inclinations, ethnographic
profile, nationalities, and
socio-economic status equally and
with equitability.

Confidentiality The principle and practice of

keeping sensitive information
private unless the owner or
custodian of the data gives
explicit consent for it to be
shared with another party.

Retaliation To hurt someone or do something

harmful to someone because that
person has done or said something
 harmful to you.

6.0 Roles and Responsibilities

Role Responsibilities

Chief Executive Officer (CEO) Review and approval of all

provisions of this document.

Business Development Head (BDH) Creation and alignment of all

policies within the company.

Head of Human Resource (HHR) Review, and approval of all

provisions in this document.

Recommend necessary improvements

to this document and submitting
them to the BDH.

Monitoring and policing of the

provisions under this document.
Coordinates with the OM for its
implementation and policing.

Operations Manager (OM) Review, and approval of all

provisions in this document.

Recommend necessary improvements

to this document and submitting
them to the BDH.

Implementation of the provisions

of this document in coordination
with HHR.

Reporting of any violations to

this document and submitting them
to the HHR.
Team Leader (TL) Recommend necessary improvements
to this document and submitting
them to the OM.

Implementation of the provisions

of this document in coordination
with the OM.

Reporting of any violations to

this document and submitting them
to the OM.

Employees, Contractors, and Recommend necessary improvements

Consultants to this document and submitting
them to the TL.

Strict compliance to the

provisions written within this
document.

Reporting of any violations to

this document and submitting them
to the TL.

7.0 Conflict of Interest

A conflict of interest is a set of circumstances that creates a

risk that professional judgment or actions regarding a primary

interest will be unduly influenced by a secondary interest. Each

employee shall be free of any personal interest that could influence

his or her judgment or action in the conduct of services or affect his

or her responsibility in managing the affairs of VERATEX Telemarketing

Services. An employee must not only avoid situations that give rise or

could give rise to a conflict of interest, but also situations that

create the appearance of a Conflict of Interest. Following polices

shall be applicable to all employees of VERATEX regarding conflict of

interest:

 Employee must be alert to any situation that could compromise the

position of trust the employee holds at VERATEX, and avoid any kind of

conflict between your personal interests and those of VERATEX.

 Employee may not engage in outside activities that can cause

conflict with the interests of VERATEX, interfere with the

responsibilities of employees, or damage or misuse the reputation,

relationships, confidential information, or other property of VERATEX.

 From time to time, situations shall arise that are not clear-cut.

If employees are uncertain about the propriety of conduct/ business

relationships, the employee must consult his supervisor or legal

advisor.

 Employees must ensure that their personal interests do not

conflict with the duties which are owed to the VERATEX or which

VERATEX owes to its stake holders. This includes engaging in any of

the following activities without the prior written approval of the

management.

 Negotiating or contracting on behalf of VERATEX with an entity in

which the employee or a relative has an interest.

 Accepting any employment (whether part time, temporary or other),

consultancy, directorship, or partnership outside VERATEX.

8.0 Non-Discrimination Policy

Notwithstanding the applicable laws of Republic of the

Philippines, VERATEX Telemarketing Services aims to provide equal

employment opportunities to qualified individuals regardless of race,

color, ethnicity, sex, gender, nationality, origin, ancestry,

religion, age, disability, or marital status. Any discrimination

against any employee at any level shall be reported to the line

manager or any relevant authority in the company, and the HR function

shall ensure that complete complaint redress procedure shall be

leading to disciplinary action. The company ensures no form of

discrimination shall be tolerated within its walls to ensure a good

work environment for all.

9.0 Confidentiality Policy

All employees must protect confidential information, and prevent

such information from being improperly disclosed to others inside or

outside VERATEX. All employees must learn, to a greater or lesser

degree, facts about the VERATEX activities, plans, operations, etc.

that are not known to the public or other agencies. Any employee may

not disclose any confidential information of VERATEX obtained from

his/her role at VERATEX to others or use any such information for his
own or someone else’s benefit. VERATEX employees should not

communicate or transmit confidential or sensitive information through

external online communications services, such as the Internet.

Appropriate disciplinary actions will be taken in case of negligence

in complying with the above policy. During the employment tenure or

even after employment terminates, the employee must never disclose or

request disclosure of proprietary or confidential information about

VERATEX or its beneficiaries to anyone.

10.0 Gifts and Entertainment

It is the policy of VERATEX that gifts are not to be accepted

from any person or organizations, related to VERATEX. Employees,

contractors, and partners of VERATEX shall ensure that they shall not

accept any gifts offered to them and/or they shall not demand or

request any gifts from any stake holder of VERATEX.

Exception to this policy is in cases where refusal of a gift

would be regarded as an affront or it would be impractical or

impossible to return the gift then in certain cases it can be accepted

provided the gift is:

 Not in the form of cash.

 Clearly not in return for any consideration or in the

anticipation of the same.

 The value of gift is not material.

 Any departure or proposed departure from the above must be

reported through the HHR to the CEO/Secretary of board for a ruling on

acceptance. Appropriate disciplinary actions shall be taken in case of

negligence in complying with the above policy.

11.0 Sexual harassment

Sexual harassment includes abuse of a sexual nature including,

but not limited to, commentaries on the victim’s body, suggestive

objects, and pictures in the work place, degrading words used to

describe the victim, or proposition of a sexual nature. Sexual

harassment also includes the threat or insinuation that lack of sexual

submission will adversely affect the victim’s employment, wages,

advancement, assigned duties or shifts, academic standing or other

conditions that affect the victim’s “livelihood”. In case any employee

feels that he/she is victim of sexual harassment, they should report

the event to the immediate superior or any officer of the company.

Anonymity of complaints shall be ensured to ensure safety of

complainant. The CEO and Head of HR shall ensure appropriate

disciplinary action is carried out against such complaints.

12.0 Fiscal Improprieties

VERATEX expects its entire staff to maintain the highest

standards of ethical conduct and to ensure their compliance with all

applicable laws, regulations, and accounting principles. Any

accounting fraud or other fiscal impropriety is strictly prohibited.

These includes forms of tampering of financial records that employees

have access to in relation to their work within the company.

13.0 Nepotism

The employment of relatives in positions where they may be

required to supervise and evaluate each other can cause significant

conflicts of interest and poor morale. Accordingly, new employees

shall be asked during the application process if they are related to

any current VERATEX employee, consultant, or contractor. The HR and

Admin function shall deal with such relationships on a case-by case

basis to assure that there is fairness to employees and to applicants

and that there is no Conflict of Interest or appearance of

impropriety. Exceptions to this rule shall only be allowed by approval

of the ethics committee of the company which shall composed of the

officers of the company.

14.0 Equal Employment Opportunity

VERATEX does not discriminate in any employment decisions based

on race, religion, color, creed, age, national origin or ancestry,

sex, gender, marital status, domestic partnership status, physical or

mental disability, genetic predisposition/carrier status, sexual

orientation, gender identity, citizenship status, familial status or

any other personal characteristics protected under applicable law.

15.0 Training and Development

Training and skills development programs are made available to

employees to assist them in their job functions and to provide

opportunities to realize their potential.

16.0 Drugs and Alcohol

Being under the influence of alcohol or illicit drugs can

seriously impair an individual’s judgement and reactions leading to an

increased risk of accidents and injuries occurring. Alcohol and drug

abuse problems can also have a detrimental effect on work performance

and behavior. The Company policy involves two approaches:

 Providing reasonable assistance to the member of staff with

an alcohol or drug abuse problem who is willing to co-operate in

treatment for that problem (see help and support below)

 Disciplinary rules, enforced through disciplinary

procedures, where use of alcohol or drugs (other than on prescription)

affects performance or behavior at work (see enforcement below)

16.1 Provisions
  Employees may not consume alcohol or any illicit drugs in

the workplace during work time or during a period prior to work where

they may still be under the influence of alcohol and drugs effects

which may carry over to the working hours. This includes business

functions where the employee is representing the Company. Special

rules may apply in relation to alcohol, where the Company sponsors an

event for staff e.g., the Christmas party. In these circumstances any

variation to the no-alcohol policy will be communicated in advance of

the event.

 No employee shall be in possession of alcohol or illegal

drugs in the workplace.

 No employee should try to report to work when unfit due to

alcohol or illicit drugs.

 No employee shall supply others with illicit drugs or alcohol

in the workplace.

 Employees who are taking prescription drugs should ensure

that they are aware of any side effects and advise their

manager or a member of the management team immediately of any

side effects of prescription drugs, which may affect work

performance or the health and safety of themselves or others

16.2 Help and Support

 Employees with an illness related to alcohol and drugs are

encouraged to disclose this at the earliest opportunity to ensure

support and help with treatment. Those who admit to having a problem

with alcohol or illicit drugs will be fully supported as follows:

 The Line Manager will help the employee to recognize the

problem. This will be through in the first instance

encouraging them to seek help through their own General

Practitioner. Under these circumstances and with the

employee’s consent, a referral will be made to the qualified

diagnostic, or counselling service.

 Time off may be allowed (normally unpaid) for employees and

contractors to obtain treatment or attend support groups.

 Support during a period of treatment. This may include a

period of sick leave or approved other leave, restricted

duties, or temporary transfer to other work (if this is

feasible).

It is recognized the policy has limitations. If an employee fails

to co-operate in referral or treatment, no special assistance will be

given and any failure in work performance and behavior will be dealt

with through disciplinary procedures.

17.0 Professionalism
 We protect the reputation and integrity of the business while

also safeguarding the legal rights of all is employees, partners, and

other entities who are working under the umbrella of the company.

17.1 Open Door Policy for Problems

You are encouraged to share ideas and comments with department

heads and administrators, as well as to inform supervisors of any

concerns or questions you may have about any aspect of the employment

and agreement. Every effort will be made to provide you with a prompt

response. The company is responsible in making sure your feedback is

valued.

17.2 Outside Employment

You may not accept outside employment if it may potentially

interfere with your employment at VERATEX, negatively affect your job

performance, or pose as a conflict of interest. All outside employment

must be timely disclosed to an employee’s supervisor.

17.3 Intellectual Property

Employees, individual contractors, and consultants must safeguard

VERATEX’s rights in its intellectual property, such as trademarks,

service marks, patents, copyrights, inventions, and trade secrets.

Employees will not reproduce, distribute, or alter copyrighted

materials without permission of the copyright owner, unless otherwise

permitted by applicable law.

17.4 Research Principles and Standards.

Employees are expected to maintain the highest standards of

professional conduct and integrity in research. Employees should

propose, conduct, and report research with integrity, objectivity and

honesty and should protect people and humanely treat animals involved

in research or teaching.

Employees should only use research funds for their designated

purposes, should comply with all approved protocols and all federal

and state laws and regulations. Plagiarism, falsification, or

fabrication of research data, or other scientific misconduct is

prohibited.

17.5 Attendance

Punctual attendance of scheduled workdays is an essential

responsibility of each employee VERATEX. Employees are expected to

report to work as scheduled, on time and prepared to start work at the

beginning of their scheduled shift. Employees are also expected to

remain at work for their entire work schedule, except during break(s),

meal period, authorized work-related travel or emergency. Late

arrival, early departure or other deviations from scheduled hours are

disruptive to business operations and can negatively impact coworkers.

Proper notification of any unscheduled absence, tardiness, or

unscheduled early departure must be made as far in advance as

practicable.

17.5.1 Sufficient Notification

An employee who is unable to report to work as scheduled, tardy,

or leaving early must contact their supervisor (or other as set forth

by a department’s call-out procedures) as far in advance as

practicable and at the latest one hour prior to the start of their

shift or the departure (if leaving early). Notification and

acknowledgment of tardiness, unscheduled early departure, or

unscheduled absence is not excusable. Employees are responsible for

notifying their supervisor of absences, late arrivals, or early

departures each day of the absence, tardiness, or early departure,

unless otherwise directed by the supervisor.

Employees with three or more consecutive days of excused absences

because of illness or injury must give VERATEX proof of physician's

care and a fitness for duty release prior to returning to work.

Employees must take earned PTO for every absence unless otherwise

allowed by company policy (e.g., leave of absence, bereavement, etc.).

17.5.2 Scheduled Absence

 Requests for scheduled absences (e.g., vacation, personal days,

etc.) must be requested in advance and is subject to approval, not to

be unreasonably denied. It is the employee’s responsibility to request

the leave and to submit appropriate documentation for approval.

18.0 Safeguarding Assets

We protect institutional resources, including facilities,

equipment, funds, information and data against loss, theft, and

misuse. We also protect property entrusted to VERATEX by others.

18.1 Use of Resources

Employees use resources responsibly and effectively, solely for

the purposes of furthering VERATEX activities. We must not use these

resources, including VERATEX facilities, resources or other property,

or our position for personal benefit or for the benefit of family

members, friends, or others.

18.2 Use of Funds

VERATEX funds are used only for legitimate business purposes of

VERATEX. When employees submit payment requests, they provide all

required supporting documentation and approvals. Research funds are

used only for their designated purposes. Employees comply with all

approved protocols and all federal and state laws and regulations.
Expenditures of funds are recorded and accounted for in an accurate

and timely manner.

18.3 Obsolete Furniture and Equipment.

Furniture, office equipment and other property that is excess,

obsolete, junked or no longer needed is reported to the Facilities

Management Department for evaluation. No property is moved or

transferred to another location, removed, or otherwise disposed of

except in accordance with our policies.

19.0 Environmental Considerations

VERATEX provides a safe, functional, and effective environment in

which the health, safety, privacy and comfort of employees, students,

contractors, and visitors are the priority.

19.1 Program Development

Department heads, administrators and managers are responsible for

developing programs to eliminate or minimize any hazards to health and

safety in accordance with applicable law. We follow all safety

policies and rules.

19.2 Safety Violations

 Employees, contractors, and consultants report any practice or

condition that may be hazardous or that may violate safety standards

to their supervisor, Security, or Environmental Health and Safety

19.3 Hazardous Materials

Employees, contractors, and consultants who deal with hazardous

materials and medical waste comply with all applicable environmental

laws and regulations and follow the environmental and safety

procedures explained in training programs. We strive to minimize the

generation, discharge and disposal of medical waste and hazardous

materials.

19.4 Sustainability

We must exercise leadership in our workplace by modeling ways to

minimize and reverse the impact of our activities and facilities on

the environment.

20.0 Issues and Concerns

Open communication is essential for accomplishing VERATEX’s

mission. The success of the compliance program depends on maintaining

effective channels of communication and reporting problems, especially

those that have regulatory implications. Everyone has a duty to report

any suspected violations of the Code without fear of reprisal.

Department heads, administrators and managers are required to maintain

an open-door policy and be receptive to all concerns brought to them

by any employee.

20.1 In the Event of a Problem

If you become aware of an activity that you think may be a

problem, or if you have any questions about the Code of Conduct,

please contact your supervisor immediately. If you are not comfortable

doing that, contact the complaint hotline or the appropriate

department listed in the directory at the end of the Code of Conduct.

20.2 Following Up the Chain of Command

If you are unsatisfied with the response or have additional

concerns, you should continue to raise the issue through the

supervisory structure or to the Vice President for Human Resources.

20.3 Investigation

As an organization, VERATEX commits itself to investigate any

suspicions of fraud, waste, or abuse swiftly and thoroughly and

requires all employees to assist in such investigations. Failure to

report and disclose or assist in an investigation of fraud and abuse

is a breach of the employee’s obligations to VERATEX and may result in

disciplinary action.

20.4 Retaliation:
 Retaliation against any employee for reporting something he or

she sincerely believes may be a violation, or for participating in

good faith in an investigation of suspected misconduct, is prohibited;

you will be protected, even if the report of misconduct is mistaken.

Acts of retaliation should be reported immediately and will be

disciplined appropriately. However, deliberately, and knowingly making

a false report is not a protected activity and will result in

appropriate discipline. Self-reporting an employee’s own violation

will not provide immunity from appropriate disciplinary action.

However, if an employee comes forward to report his or her own

violations, appropriate leniency in the discipline to be applied will

be considered.

20.5 Legal Inquiries

Employees, contractors, and consultants should refer all legal

and government inquiries to officers of the company. Employees,

contractors, and consultants should not respond to such inquiries

unless authorized by counsel or required by law.

21.0 Enforcement

The policies will be strictly enforced. Disciplinary action in

accordance with the Company disciplinary procedures will be undertaken

where breaches of the policy occur. In the case of agency workers or

contractors, services may be terminated immediately upon a breach of

the policy.