Veremark recognizes its responsibilities as a global organization and is committed to being a responsible corporate citizen.

Veremark believes that it is not only required to abide by the national laws in each country which it operated, but that it must also conduct its business in accordance with internationally accepted practices and procedures.

These core principles, which the board and senior management of Veremark are committed to upholding, are enshrined in Veremark’s values and encapsulated in this Corporate Code of Conduct and Ethics Policy.

Veremark believes that these principles extend to all employees, consultants, contractors and sub-contractors to observe these standards. 

1. Business Integrity

1.1. Honesty, Integrity and fairness. Veremark recognizes the importance of honesty, integrity, and fairness in conducting its business. 
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1.2. Compliance with laws and regulations. All Veremark employees, companies must comply with the applicable laws and regulation of the countries in which it operates. 
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1.3. Shareholders and the financial community. Veremark is committed to increasing shareholder value in conjunction with fulfilling its responsibilities as a good corporate citizen. Veremark is committed to at the fair, timely and accurate disclosure of information to ensure that it shareholders are fully informed

2. Conflicts of Interest

2.1. Veremark prohibits any employee to use any information or assets for personal gain or to compete against the company.
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2.2. Material conflicts of interest such as having a material interest in a customer’s or supplier's business are to be avoided. If such a conflict of interest arises, full disclosure of that conflict must be made, and the person(s), the subject of that conflict, must not take part in any decision-making process relating to the matters giving rise to that conflict.

3. Political Involvement

3.1. Veremark business may represent their views to governments and other third parties on matters that affect their business interests and the interest of the shareholders, employees and others involved in the operations.
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3.2. Veremark businesses must not participate in party politics or make payments to political parties without the approval of the Veremark Board. Under no circumstances will Veremark (or any employee, officer, director or agent), in influencing order to assist the company in obtaining or retaining business for or with, or directing business to, any person, make payments to any political party or official of that party or candidate for public office for the purpose of: 
· Influencing any act or decisions of that party, official or candidate in its official capacity; 
· Inducing that party, official or candidate to do or omit to do an act in violation of its lawful duty; 
· Securing any improper advantage; or 
· Inducing that party, official or candidate to use its influence with a government or instrumentality of that government to affect or influence any act or decision of such government or instrumentality.

4. Bribery and Corruption

Veremark prohibits bribery and corruption. Under no circumstance will Veremark approve any offers, making, requesting or receiving irregular payment or payments in kind to win business or influence a business decision in Veremark’s favor or which has the intention that in consequence a function should be performed improperly. Offers to and the making of bribes, “kick-backs'', secret commissions and similar payments are strictly prohibited. Moreover, they may expose Veremark and relevant employees to criminal prosecution and serious penalties under laws of other countries, as well as those of the country in question. 
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This prohibition also applies to agents and third parties who are employed by Veremark to represent their interests. Care should be exercised in engaging anyone to act in such capacity, and in monitoring their performance to assess their reputation and suitability. In sensitive areas or circumstances, Veremark’s policy and expectations should be clearly communicated to, and accepted by the agent or third party. 
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4.1. Facilitation Payments
It is not uncommon in some countries for employees to be asked to make relatively minor payments, more by way of a gratuity, to lower level officials or government employees. These payments (sometimes called facilitation payments) are sought to expedite routine services or administrative actions provided or performed by those individuals. Veremark is opposed to making such payments as a matter of policy, and every effort should be made to resist them. Veremark recognizes that in some countries, it may be possible to make minor facilitation payments. However, in other countries, strict legislation exists prohibiting facilitation payments of any kind.

5. Gifts

Employees must exercise caution regarding the giving or receiving of business related gifts. Local customs, monetary value of the gift and legal requirements should be considered when establishing whether a gift should be retained by an employee or Veremark representative, handed to the company or returned. 
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Veremark prohibits gifts in the form of money, drugs or other controlled substances, discounts for products or services that are not available to other employees, personal use of accommodation or transportation, and payments or loans to be used to purchase personal property. Employees and Veremark representatives must also not offer, give, request or accept gifts of any kind in circumstances that could be considered as unduly influencing the party involved or creating any business obligation or which has the intention of a function being performed improperly. 
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Additionally, Veremark and employee representatives should not solicit gifts or hospitality from a supplier, customer or other party with whom Veremark conducts business, nor should he/she exchange gifts with representatives from competitors, as such actions may create a conflict of interest. 
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6. Competition

Veremark supports the principles of free competition in the market in compliance with applicable competition laws. However, competition laws which affect business activities vary from country to country. All Veremark employees should ensure that they understand these corporate policies and act on them accordingly or seek guidance if necessary from Veremark’s legal representative. 
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7. Privacy and Information

Veremark respects the privacy of individuals and laws relating thereto. The inappropriate use of confidential information is prohibited. Veremark has a well-defined Privacy Policy which sets out our policies on the collection and management of personal information. 

8. Whistleblowing

Veremark is committed to ensuring that employees can raise concerns regarding illegal conduct or malpractice in good faith without being subjected to victimization, harassment or discriminatory treatment and to having such concerns properly investigated. 
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Veremark will implement a formal Whistleblower Policy which will be provided to employees (where local laws permit) and has in place an independent, externally managed Whistleblower Service, for employees to anonymously report any potential incidents of misconduct.

9. Labor Practices

9.1. Mutual Respect
Veremark is committed to a working environment where there is mutual trust and respect and where everyone feels responsible for the performance and reputation of the Company.
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9.2. Non-Discrimation 
Veremark recognizes the dignity of each employee, and the right to a workplace free of harassment and abuse. Decisions on hiring, salary. Benefits. Advancement, termination or retirement are based solely on the employee’s ability to do the job. There is no discrimation based on race, creed, disability, gender, marital or maternity status, religious or political beliefs, age or sexual orientation. 
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9.3. Freedom from harassment 
Veremark has created a work culture that affords its employee the opportunity to work without fear or intimidation, reprisal or harassment and Veremark will continue to take action to ensure that such a culture is maintained with the Company.
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9.4. Child Labor 
Veremark recognizes the rights of every child to be protected from economic exploitation and respects the laws of each country in which it operates in regard to the minimum hiring age for employees. In any case, Veremark does not employ individuals younger than 18 years of age. 

9.5 Compensation 
Veremark provides wages and benefit that comply with applicable laws and binding collective agreements, including those pertaining to overtime and other premium pay arrangements. 

9.6 Working Hours
Veremark is committed to ensure that its employees work in compliance with all applicable laws and mandatory industry standards pertaining to the number of hours and days worked. 

9.7 Relationships 
Veremark reconizes that conflicts of interest can arise where there is a direct or indirect reporting relationship between employees who have a special relationship, including where the employees are family members or are in an intimate relationship. 
Employees involved in such a relationship are required to disclose the existence of the relationship to Human Resources at the earliest opportunity so that appropriate action can be taken to ensure that any real or perceived bias is avoided.

10. Health & Safety 

Veremark is a remote-first company, as such employees are responsible for maintaining their work environment safe and healthy.

11. Compliance 

11.1 Documentation and transparency
Veremark is committed to the principles of maximum transparency that are consistent with normal commercial confidentiality. Veremark will maintain all documentation needed to demonstrate compliance with this Code of Conduct and Ethics Policy and required local laws. 

11.12 Non-Compliance 
Should Veremark find that an employee, contractor or supplier does not comply with this Code of Conduct and Ethics Policy or any other applicable Veremark policies, Veremark will insist on corrective measures being taken or will terminate its relationship with that employee, contractor or supplier.

12. Where to go for Assistance 

If you believe a decision or action may be inconsistent with the Code of Conduct and Ethics Policy, or if you are unclear about what to do in a specific situation, you should raise the issue promptly. 

Whenever possible, you should first discuss the issue with management. Management refers to your immediate supervisor or manager. If you feel unable to do this, there are a number of other ways for raising a question or concern. You can contact: 
‍· The next level of management; 
· The Human Resources Head ; or 
· The Senior Leadership Team

All instances of actual or suspected fraud should be reported to the Human Resources head and/or the Senior Leadership Team.

The effectiveness of this document shall commence in October 2021. 

Daniel Callaghan 
CEO