Date:04-September 2016,

To All stakeholders and interested parties,

I am pleased to confirm that Vee Gee Industrial Enterprises pvt.Ltd. reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption

n this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,
Deepak Soon
Export Manager
Vee Gee Industrial Enterprises Pvt.ltd.
NIT,Faridabad,Haryana ,India

We respect the law of United nation and its principles,we have adopted the Universal Declaration of Human Rights
The International Covenant on Economic, Social and Cultural Rights,The International Covenant on Civil and Political
Rights,The United Nations Convention on the Rights of the Child,The United Nations Convention on the Elimination,of All Forms of Discrimination Against Women,The United Nations Convention on the Elimination,of All Forms of Racial Discrimination

We have implemented our polices and procedures on International Labour Organization (ILO) conventions has adopted more than ten conventions addressing problems related to child labour, among which the Minimum Age Convention 138 (1973) and the Worst Forms of Child Labour Convention 182 (1999) are the two cornerstones. In addition to the major international and national initiatives focusing on the prevention and elimination of child labour.

The key requirement of Convention 138 is that national governments pursue a national policy designed to ensure the effective abolition of child labour and to increase progressively the minimum age for admission to employment to a level that enables “the fullest physical and mental development of young persons.” Though Convention 138 (with Recommendation 146) set a minimum age for general employment at 14 and a minimum age for light work at 12, the goal is to urge member and we have decided to keep the minimum working age is above 14.

We also implemented the ILO Convention 1 (Hours of Work – Industry) and Recommendation 116 (Reduction of Hours of
Work)ILO Conventions 29 (Forced Labour) and 105,(Abolition of Forced Labour),ILO Convention 87 (Freedom of Association) ,ILO Convention 98 (Right to Organise and Collective Bargaining),ILO Conventions 100 (Equal Remuneration) and111 (Discrimination – Employment and Occupation),ILO Convention 102 (Social Security - Minimum Standards),ILO Convention 131 (Minimum Wage Fixing),ILO Convention 135 (Workers’ Representatives),ILO Convention 138 and Recommendation 146
(Minimum Age),ILO Convention 155 and Recommendation 164,(Occupational Safety and Health),ILO Convention 159 (Vocational Rehabilitation and Employment - Disabled Persons),ILO Convention 169 (Indigenous and Tribal Peoples)
ILO Convention 177 (Home Work),ILO Convention 182 (Worst Forms of Child Labour),ILO Convention 183 (Maternity Protection)ILO Code of Practice on HIV/AIDS and the World of Work

We have strongly follows our land of law and international best practices,We have formed the four types of communication channels to enhance the human rights and workers rights at the factory.We have formed works committee,Grievance committee,anti sexual harassment committee and health & Safety committees which performed after every three months,We have also installed grievance/ suggestion box at the main entrance and workers' toilet to drop their grievances for initiate the action.also for visitors and stake holders,we have kept a grievance register where they can lodge any grievances/suggestion to inform to the management directly.Regularly we are conducting the training and awareness programme on this to workers.A training officer is evaluating the training needs and identification and deliver the training and then effectiveness of the training is also measure .The factory has appointed a welfare officer to look after this mechanism and also take help from the various consultants to measure their needs and implement as per their legal requirements and human values.A documented human resource manual also formed and annual training calendar also formed for various aspects.

There are three dedicated monitor and one external consultant measure the effectiveness of the process and annual performance measures during the management review meetings.Annual open house also evidence of direct interaction of top management with workers so that by pass all the channels by workers and explain directly in an open house to reduce the impact of the grievances and provide proper solution.

We have develop a management system to effectively meet the SA8000 performance requirements for SA8000 in related to human rights and ILO convention implementation,We have already conveyed above on this,however some roles has been displayed below for reference.

1)Freedom of Movement:
We ensure workers’ freedom of movement. Workers must be able to leave their place of work at the end of a standard work day or shift (e.g. 8 hours). Workers are not to be forced to remain at the work premises to work overtime hours. This ensures that all overtime hours are voluntary. Organisations may not lock workplace doors nor allow barriers to the free use of the exit doors of work premises. Workers cannot be locked into their workplace and must be able to leave if necessary (e.g. in case of danger or threat to their person). as per international journal,the main reported problem often involves such practices as locking the workplace door from the outside, or accumulation of work product, work materials or equipment in front of an exit door. In addition to the obvious safety threat this causes, it also denies workers the right to perform their work voluntarily. Workers must also have appropriate freedom to leave their workstation for specific purposes, such as a bathroom break, a hydration break or to access medical attention.
2)Withholding Documents:
We provide workers a secure place that they can freely access to keep their valuables and personal documents. We have not require workers to transfer their original identification papers to the organisation under any circumstances, even under claims that they are “protecting” the documents for the workers. Such documents may be passports, birth certificates, religious records of age, work or residence permits, travel documents or any other documents that may have legal impact on workers’ legal status, freedom to travel or change jobs. We never hold workers’ original identification documents by seeking workers' consent to any part of this prohibition. Similarly, we not require or seek to influence workers to sign voluntary letters allowing the organisation to hold worker’s original identification papers. Even if workers reportedly consent, such actions are prohibited under SA8000. Withholding workers’ original identification documents and establishing a system to allow the worker to retrieve them quickly is nevertheless considered forced labour. The time needed to retrieve the documents is irrelevant, because workers are denied freedom of mobility if they must apply to their employer for access to their personal papers.
3) Debt Bondage As noted above, we are prohibited from engaging in any form of debt bondage. For this reason, we never prohibited from requiring workers to pay any employment fees or costs in whole or in part.
4. Private Employment Agencies:
We conduct due diligence of any entities that supply labour to make sure that they do not create circumstances that may make workers vulnerable to forced or compulsory labour. We ensure that such entities have effective policies and procedures to prevent workers from being charged fees or expenses to obtain employment. we also review the labour practices of directly subcontracted/purchased goods and services (for example, entities that supply materials, goods, transportation services, security services, cleaning services, or food preparation services).
5. Resignation Letters

We are prohibited from making workers sign advance resignation letters upon joining the organisation or commencing their employment. This practice is not acceptable under SA8000 because it forces the worker to sign a letter that they do not necessarily want to sign and in many cases could be interpreted as the worker waiving his or her rights to disciplinary processes, legal severance payments, unemployment benefits, and other aspects of fair employment.
6. Human Trafficking
The prohibition against trafficking is broad and total. We and ours suppliers cannot be part of any stage of trafficking. They cannot act as the recruiter, the transferor, intermediary, holder, or as the receiver of those who have been trafficked for the purposes of work. This covers the organisation’s use of every type of provider of trafficked labour whatever they may be called, such as labour contractors or employment agents

We are the active member of Sedex advance system where are the policies and procedures related to human rights,labour relation,health & safety,environments,regular employments,child labour,forced labour,freedom of association,discrimination ,disciplinary practices,working hours,remuneration and suppliers and subcontractors control are measure,An audit was conducted and we have achieved good rating on all the sections and hence our social aspects towards workers are positive and moving into right direction.We also achieved a good rating in self assessment and assessment done by third party.

We do not discriminate or engage in or support discrimination in hiring, remuneration,access to training, promotion, termination, or retirement based on race, national or social origin, caste, birth, religion, disability, gender,sexual orientation, family responsibilities,marital status, union membership, political opinions, age, or any other condition that could give rise to discrimination.
We do not interfere with the exercise of personnel’s rights to observe tenets or practices, or to meet needs relating to race, national or social origin, religion,disability, gender, sexual orientation, family responsibilities, union membership, political
opinions, or any other condition that could give rise to discrimination.

We do not allow any behavior that is threatening, abusive,exploitative, or sexually coercive, including gestures, language, and physical contact, in the workplace and, where applicable, in residences and other facilities provided by the company for use by personnel.
We have recently audited by Sedex global auditors and report uploaded at the Sedex server with good rating and no major violation observed.
Mr. Deepak Sood has been nominated to looks these results on a regular basis and suggested the changes as per the control mechanism and for further improvements.Mr. Tarun Sharma also appointed as management representative for taking care of workers grievance and sorted out within the time frame as discussed..

we have been taking care of our environments and aspect and impact has been checked for further improvements and target has been set for achieved the necessary requirements of global footprint.An assessment related to green house gases has been initiated and information is being collected to give something to our environment instead of our consumption of natural resources.
We provide a safe and healthy workplace environment and shall take effective steps to prevent potential accidents and injury to workers’ health arising out of,associated with, or occurring in the course of work, by minimising, so far as is reasonably
practicable, the causes of hazards inherent in the workplace environment, and bearing in mind the prevailing knowledge of the industry and of any specific hazards.The goal towards the energy savings and reduce the uses of natural resources has been initiated.

A training calendar is also includes the awareness on environmental protection and workers participation to control it.we do not create any products which impact on environments and our initiate is as per legal requirements of the country.A responsibility matrix has been created to check the performance area and take action for further improvement.We have achieved the environmental management system and our certification are based on global requirements of the ISO14001:2014.Our audit at suppliers/subcontractors/stake holders evidence that all the supply chains are aware about the environmental protection system to improve the global green house gases system.A regular visit to suppliers is an effective tools to promote this scheme at suppliers site.

Our Environmental management system tool create environmental management programmes which updated and regularly assessed as per the EMS 14001:2014 requirements and aspect impact is the tools to assess this system effectively.External third party audit done by JAS ANZ approved certification body and these assessment also checked by the government inspection agency.

Our basic codes are the main heart is focused on corruption and anti bribery:
VEEGEE INDUSTRIAL ENTERPRISES PVT. LTD.
Admn.Office & Works : 31-B, Industrial Area, NIT., FARIDABAD-121001(INDIA)
Phones : +91-129-2231368, 2234298, FAX : 091-129-2234924

VEE GEE INDUSTRIAL ENTERPRISES PVT.LTD.

Prevention – a key factor in fighting corruption

The role of a new training concept

VEE GEE INDUSTRIAL ENTERPRISES PVT.LTD.

31-B,NIT,INDUSTRIAL AREA,FARIDABAD,HARYANA,INDIA

1. Definition of corruption

The following definition of corruption was identified in India:
Corruption is:
• the misuse of any office, political mandate or function in trade and industry ,
• gives advantage to another person,
• carried out with the intent to gain some benefit for an official or for another person,
• detrimental or causes damage to the public (in the case of a public or political figure) or for a company (in the case of an business function).

This definition is the basis for the following presentation and anti-corruption concept.

2. Introduction to the phenomenon of corruption

2.1 General

In many countries, corruption has become part of political-administrative everyday life. Bribery, embezzlement or other kinds of corruption have caused damage in economy, politics and society. This has prompted many countries to put a greater emphasis on controlling corruption. Whether in politics, administration or economy, one thing is certain: corruption is spreading like cancer. Corruption has become a
pivotal obstacle to economic development.

Today the issue of corruption plays a totally different role in science and politics. Scandals in democracies supposedly free of corruption are the reason why the assumed causal relation between market economy and democracy, on the one hand, and integrity of civil servants, citizens and enterprises, on the other hand, are called into question. Corruption can survive for a surprisingly long time even in developed democracies and open markets and it can even develop anew. The phenomenon of corruption in western democracies has developed only recently. That is why this issue has inevitably gained importance in international circles over the last few years. The European Union as well has recognised that corruption causes severe damage and has declared a comprehensive campaign against it.

However, the fight against corruption seems to be like Hercules’s fight against the dreadful Hydra. As soon as one head is cut off, two new ones grow in its place. officials and civil servants are being bribed, managers misdirect enormous amounts into their own pockets, and politicians are being "oxygenated" – the insiders' euphemism for bribery.

2.2 Trends in fighting corruption

The new trend in the fight against corruption is putting an emphasis not only on efficiency but also on transparency and accountability of the public sector. The lack of transparency inherent to this sector is even intensified by such principles as official secrecy.

In places where the public administration has become even less transparent for its own administrative bodies, citizens often fight a losing battle. The conditions of accessing information alone often exert a very regulative influence. This determines the behaviour of officials as well as their clients. That is why many states have inverted the legal position to basically grant citizens access to all the information, while the state has to separately set necessary restrictions.

However, corruption is a system and corruption has a system. Therefore, it can only be combated with a system. Anti-corruption measures on the government-agency level must, therefore, be bundled together into a systematic concept of prevention. A framework concept, which can be described as being "state of the art", should be understood as an aid to orientation and as an aid to formulate tailor-made anti-corruption strategies in government authorities. It is a way to prevent and combat corruption in government agencies in a systematic way.

3. Identifying corruption: indicators of corruption

Indicators are not evidence. Therefore, they mostly do not have any or only very little meaning, when considered alone. Only if they occur repeatedly, frequently or in certain combinations are they suitable for contributing towards the growth of a suspicion.

The handling of corruption-indicator grids assumes a particular sensitivity on the part of the user. If used excessively or thoughtlessly, they can lead to unjustified suspicions and inadmissible conclusions instead of making a positive contribution towards the fight against corruption. Under no circumstances should such a grid of indicators be used with the goal of initiating a "witch-hunt".

3.1. Neutral indicators

Neutral indicators are to be seen, as a rule, in connection with personal manners and behaviour. Not infrequently, they are socially accepted or even favourably interpreted by the viewer. Nevertheless, these are indicators which are found relatively frequently in corruption structures. Examples include:

 lavish lifestyle that can not be explained by a person's income; presentation of status symbols,
 suddenly changing lifestyle,
 social and personal problems (dependency, addiction, indebtedness, bragging, etc.),
 outside employment that is critically close to one's official duties,
 acceptance of invitations (e.g. on the occasion of visits to trade shows or companies); paying for food and beverages for others in restaurants, bars, etc.,
 frequent private meetings with public contractors or bidders; participation in private or business events,
 granting unusual special terms for purchases (e.g. purchase price / discounts/ financing / reduction in the usual waiting periods),
 delivery of lavish "advertising" gifts (incl. to one's home address); unusual generosity on the part of contractors; offers to sponsor activities,
 presuming oneself to be indispensable; giving up one's free time, coming to work despite being ill (to avoid having others look into one's work),
 additional work assumed on one's own initiative (e.g. going to allegedly important meetings outside the office on days off),
 taking work (cases) home,
 inexplicable isolation; taciturnity towards colleagues and superiors,
 sudden, inexplicable changes of opinion (e.g. advocating a project which was previously rejected),
 inexplicable refusal to accept reassignments or promotions (in particular, if this means an improvement),
 unusually casual tone between employees and contractors or applicants,
 Absence of complaints or conflicts where they are customary or to be expected; impeccable processing of difficult cases where the employee does not have sufficient specialised knowledge / or expertise.

3.2. Specific indicators

In contrast to the indicators that are neutral with respect to corruption, corruption-specific indicators are to be assessed as warning signals or signs, which - in particular in cases of repeated or simultaneous occurrence - should lead to the suspicion of existing irregularities. Examples of this include the following:
 inexplicable decisions which should not have been made in this fashion,
 different assessment or processing of cases having the same or very similar facts,
 abuse, unilateral interpretation or overuse of one's discretionary powers,
 waiver of controls or audits, even though there is reasonable cause,
 manipulating the handling of a case by other departments or employees within an agency or police authority,
 deliberately bypassing decision-makers or superiors in critical cases,
 repeated exercise of outside appointments without any plausible explanation of their relation to work,
 inadmissible expansion of the powers delegated,
 entering into an agreement with unfavourable terms which bind an agency for a long period of time
 repeated preference for or support of certain bidders or contractors during the procedure for awarding contracts ("purveyors to the court"),
 noticeable indulgence during contract negotiations,
 missing receipt or stamp with date and time on correspondence with bidders and contractors,
 guideline made by a superior that a critical case be processed "favourably" without any additional reviews,
 inexplicable acceleration of a case,
 neglecting doubts as to the lawfulness of an act, bypassing regulations (e.g. waiving the imposition of special conditions or duties, ignoring the principle of thrift),
 sealing off individual departments or employees or allowing them to become independent, supposed uncontrollability,
 bypassing public tenders; lack of variety in offers,
 splitting/reducing the volume of an order in order to enable a discretionary award,
 procurement of unnecessary or technologically obsolete logistics systems,
 purchases at excessive prices that are not in line with market conditions,
 splitting or duplicating remittances of invoice amounts,
 frequent subsequent amendments to and supposed arithmetic errors in bidding documents,
 noticeable discrepancy between invoice and offer amounts,
 missing or superficial records of decisions, meetings, local inspections, etc.,
 disappearance of important bidding or contract documents,
 superficial processing of work; missing or deficient records,
 playing out of assumed positions of power by contractors,
 constant visits by contractors to certain employees or visits only when certain employees are present,
 repeated official trips to certain companies without any plausible work reason (in particular, when not really necessary overnight stays occur),
 complaints by contractors or administrative customers who were bypassed in competitions or disadvantaged when their applications were reviewed,
 ambiguous statements / references by employees to incorrect procedures, rumors within a certain environment.

4. General anti-corruption measures

General measures and recommendations to prevent corruption are independent of any particular task or department. They are directed towards the abstract threats and risks to which the entire organisation or the staff in general are exposed. They are aimed at the heads of the government agency, or the organisation as a whole, and at employees. During their implementation, managers have a special responsibility, due to their duties of administrative and work supervision as well as to their function as a role model.

4.1 Formulation of a code of conduct

The purpose of a code of conduct for enployees is threefold:
 it is a statement of the ethical climate that prevails in the factory;
 it spells out the standards of ethical conduct expected of factory;
 it tells members of the public what to expect of official in conduct and attitude when dealing with them.

Furthermore, as a well-drafted code of conduct describes in a coherent way the main elements of a corruption prevention strategy, it could be used as the ‘charter’ or the starting point for the elaboration of a prevention strategy or plan.

The code of conduct or code of ethics for employee recommended by the Vee Gee Group essentially comprises standards which employees should also adopt.

Employees . . .
. . . must recognise without any reservations that their official function is a position of trust which obliges them to act in the interests of the general public.
. . . must exercise their office with integrity and loyalty to their employer and perform the tasks assigned to them lawfully and conscientiously.
. . . must perform their tasks with fairness and impartiality. They may not unjustly favour or prejudice anyone or misuse the official powers transferred to them in any way.
. . . may not use their public office or official powers to promote their own interests. They may not undertake actions, or aim for positions or offices or pursue financial, economic or other comparable interests, which are or could be incompatible with their official functions.
. . . must ensure that they lead settled lives whose economic and social circumstances are orderly and they must ensure that their private lives do not give rise to any impairment of their official duties.
. . . may not directly or indirectly demand, accept promises for or accept any gifts or other benefits related to their official function or to the fulfilment of their official duties or which could affect their judgments.
. . . must report all (part-time) employment outside the agency to their employers. Such outside employment may not adversely affect the public's trust in the impartial performance of their official duties.
. . . are obliged to preserve official secrets and to treat all of the information acquired in connection with their duties confidentially, unless they are explicitly released from this obligation.

4.2 Establishment of an internal auditing unit

A risk analysis is not a one-time event but a continuous process. The implementation and effectiveness of measures resulting from a risk analysis should be monitored on a continuous basis. Therefore the management of a service or administration may want to establish an internal control mechanism, for example, in the form of an internal audit unit.

Internal auditing is an instrument of management. It supports the duties of administrative and work supervision and the monitoring of the organisational structure and the processing of operations in the form of the implementation of auditing activities. Another focal task of internal auditing is the internal prevention of corruption. Internal auditing conducts risks analyses, initiates general and specific anti-corruption measures within the agency and supports their implementation.

4.3 Performance of risk analyses

As a constant task, the Internal Auditing Unit (or the Corruption officer) will examine the organisational structure and the operating processes of the factory for areas of risk as well as susceptibilities and weak spots, which can induce or favour corruption.

Increased susceptibility can exist, in particular, wherever there are outside contacts (e.g. police presence in the public, conduct of investigations, exercise of local inspections) and/or decisions are made or prepared, which could favor or disadvantage third parties (e.g. awards of public orders). Even dealings with sensitive data (e.g. search data) are to be designated as such an area of risk.

On the basis of the risk analysis, target-group-oriented concepts to prevent corruption can be developed and adequate counter-measures or other preventive measures and control mechanisms can be installed as needed.

4.4 Monitoring outside employment

Outside employment can not only have a negative impact on the deploy ability and motivation of employees, but also can represent possible "docking areas" and gateways to corruption. Here the need for information by businesses or by the media (e.g. prospects for access to data) can play a significant role.

Due to their basic importance in the prevention of corruption, taking stock of and auditing sidelines is a major prerequisite for a realistic assessment of the potential for risk. This measure is thus an important component of risk analysis.

4.5 Accepting rewards and gifts

Regulations pertaining to the acceptance of rewards and gifts - as provided in India for all employees - are a major orientation aid with respect to preventing corruption when delineating the permitted scope of action for actions with a criminal intent. These regulations must be emphatically communicated to all employees.

4.6 Regulating sponsorship

Strict regulation is also necessary when third parties are prepared to support the task of the government agency. The sponsorship policy should be clearly regulated.

4.7 Reviewing service regulations

Service regulations frequently contain regulations which collide with the interests of preventing corruption, or even counteract them in specific cases (e.g. recommendations on the subject of "lean government", standards on simplifying and accelerating procedures, expansion discretionary powers for individual judgments, delegation of decision-making powers, etc.)

4.8 Task-specific or department-specific anti-corruption measures

Special anti-corruption measures are to be individually tailored to different departments, units, areas of tasks and functions for which increased susceptibility may be supposed due to their respective jurisdiction or the description of the tasks to be performed and related contacts with outsiders.

Special anti-corruption measures do not stand alone, but are always understood to be in combination with or as a supplement to general measures. Thus there are recommendations which are equally implementable in several target areas and also those which are very specific and thus can only be applied in restricted areas.

In all areas which have proved to be particularly at risk as a result of a risk analysis, special measures suitable for reducing the risk of corruption are to be reviewed and implemented. Possible actions include the following:

• regular sensitisation of the employees assigned to areas susceptible to corruption,
• strict selection of personnel (technical, social and moral suitability of candidates),
• Staff rotations; rotations of susceptible employees at intervals suitable for the tasks to be performed; if necessary repeated changes (shuttles) between two organisational units; avoidance of single rooms for employees with contacts with outsiders; fluctuations while performing the same tasks (e.g. changing rooms and responsibilities of the employees in charge),
• separation of functions: Splitting complex task areas and process or decision- making processes; avoidance of the concentration of competencies in one person,
• standardisation of recurring work or case processes,
• maintenance of the four- or more-eye-principle in contacts with outsiders and in team-building,
• internal and external checks of files and invoices (superiors, internal auditing, General Accounting Office),
• assisting in the recognition of corruption; elaboration of a grid, which provides information about function-specific indicators.

It must be kept in mind that not all of the recommendations listed can actually be implemented in all of the organisational units and work areas susceptible to corruption. Some proposals, such as staff rotation, can not be implemented at all or only with great difficulty in some areas, due to the special circumstances and possible consequences (risk of the loss of expert knowledge).

4.9 Additional measures with respect to the awarding of employee orders

Purchase orders are issued by company, for example, with respect to
- procurements,
- construction and services,
- research and development projects, and
- the preparation of expert/consultant opinions.

Basically it must be kept in mind that larger orders requiring a public tender should not be split up, in order to enable the discretionary award of such orders due to the reduction of the order amount.

Attributes given contractors such as "reliable" or "reasonably priced" should not lead to competitors being ruled out or for preferring individual contractors over a long period of time without any plausible reason. This applies in particular to open-ended service agreements.

5. Prevention

Vee Gee Group have formulated a number of recommendations for adoption and implementation of codes of conduct and ethics for employee, obligations for officials to report suspicions, analyses of risks and improvements in administrative, financial and procurement procedures to reduce risks, transparency in decision making, enhanced management of personnel (including career planning, training, mobility and salaries), audit and control systems, setting up of systems of disciplinary sanctions, provisions for the financial disclosure of assets of officials, and creation of self-monitoring mechanisms within institutions at risk.

Corruption prevention comprises a wide range of actors and activities. Many of these are closely interrelated. Conceptually, however, the following types of prevention may be distinguished:

 Prevention A: integrity and cooperation
 Prevention B: transparency and accountability
 Prevention C: reducing risks and opportunities
 Prevention D: control

5.1 Prevention A: integrity and cooperation

The objective is to promote integrity and cooperation against corruption within society on the whole. Tools include awareness-raising, educational measures, information activities, surveys and publications on corruption, measures to strengthen independent media and investigative journalism as well as civil society institutions, implementation of integrity workshops, public/private partnerships, measures to encourage cooperation with the criminal justice system, the process of elaborating anti-corruption plans and codes of conduct or ethics.
Target groups are all sectors of society, including civil society in general, the media, educational institutions, NGOs, the business community, politicians and political parties, parliaments, governmental institutions, local governments, public administration, judicial and law enforcement institutions.

5.2 Prevention B: transparency and accountability

The objective is to strengthen transparency and accountability within public administration, the business sector and civil society institutions which could be vulnerable to corruption.

Tools include measures to strengthen good governance in public administration and corporate governance in the private sector, application of codes of conduct, regulations on the financing of political parties and on lobbying and pressure groups, monitoring of service delivery by citizens, involvement of civil society in decision-making, access to information, public procurement rules, compatibility and conflict of interest rules, registers/databases on public contracts, investigative journalism, clear rules on the acceptance of gifts.

Target groups include institutions and individuals who could be vulnerable to corruption from the business community, public administration, parliaments, politicians and political parties, parliaments, governmental institutions, local governments, public administration, judicial and law enforcement institutions, public notaries, interest and pressure groups and lobbyists.

5.3 Prevention C: reducing risks and opportunities

The objective is to reduce risks and opportunities for corruption within institutions and procedures vulnerable to corruption.

Tools include risk analyses, corruption prevention plans, anti-fraud mechanisms within companies, declaration of assets by public officials and politicians, rules on public procurement, rules on the documentation of decisions, blacklisting of companies, investigating journalism, four-eyes principle, and job rotation.

Target groups include institutions and individuals who are vulnerable to corruption, including police and other law enforcement services, customs, the judiciary and criminal justice institutions, public administration and officials involved in public procurement, institutions and officials providing services or licenses and permissions, politicians and political parties, local government, and public enterprises.

5.4 Prevention D: control

The objective is to control compliance with rules, in particular within institutions and procedures highly vulnerable to corruption.

Tools include supervisory accountability, systematic audits (for example, of public procurement), monitoring compliance with codes of conduct and other relevant guidelines and rules, monitoring conflicts of interest, internal compliance systems within companies, investigative journalism, obligation to report corruption-related problems, creation of internal affairs/investigation units or corruption commissioners or contact points within institutions, reporting of suspicious financial transactions (prevention of money laundering), control of tax evasion and fraud.

Target groups include, as in “prevention C”, institutions and individuals vulnerable to corruption, in particular those involved in processes and procedures particularly exposed to risks and offering opportunities for corruption.

6. Successful anti-corruption strategies

Experience shows that there is a need for the following components for a successful anti corruption concept:

6.1 Political commitment and leadership

Vee Gee Group and its surrounding political leaders need to exercise leadership in the anti-corruption effort, e.g. by pushing for the adoption of the necessary legislation and the ratification of international agreements, making the necessary resources available to law enforcement agencies and the criminal justice system, providing access to information and transparent governance, establishing control mechanisms within the Government, providing for transparent and accountable party financing, and, most importantly, living up themselves to the highest ethical standards. In democratic societies, the failure of governments to deal with corruption is increasingly reflected in election results. Where political leaders fail, prosecutors and judges or civil society organisations take the lead against corruption.

6.2 Legislation

Societies must have a common understanding as to what they want to control, prevent or fight. In the absence of a generally accepted definition of corruption, they need to clearly define offences which they consider corrupt behaviour in their criminal, civil and administrative law. Traditionally, these offences include bribery. However, European standards in this respect are becoming broader and more comprehensive.

6.3 Enforcement

Laws against corruption need to be enforced and those responsible for enforcement need to be given the necessary resources and authority to investigate and prosecute corruption-related offences. One could argue that a criminal law approach is very narrow as it only targets individual offenders and does not improve structures and reduce opportunities, and as it risks stigmatising and excluding rather than integrating institutions, individuals and the private sector.

On the other hand, corruption is a “control offence”: without investigation and prosecution, corruption may not become visible and societies may perceive themselves to be free of corruption. Also, and perhaps most importantly, justice and the rule of law in themselves are primary goals of any society. Finally, law enforcement has an important preventive effect: it may even be considered a prerequisite for prevention, in that it points at specific corruption problems, thus helping create the necessary awareness. Successful law enforcement can generate a momentum and mobilise society against corruption. Without the prosecution of high-level corruption, the chances of success of specific prevention measures may be fairly slim.

6.4 Prevention

The prevention of corruption is about preventing corrupt behaviour and corruption-related offences, including active and passive bribery, trading in influence and related accounting offences, fraud, embezzlement, breach of trust, abuses of office or function, or other offences either in the private or public sector. Stated positively, the prevention of corruption is about promoting integrity and ethics, good governance, justice and the rule of law. Prevention includes a large range of measures and seeks to involve a large number of actors.

There are of course many other elements which help contain corruption, including an independent and efficient judiciary, a fully functioning democracy, and economic and social development in general. The question is not what comes first; specific anti-corruption strategies and general reform measures go hand in hand and reinforce each other.

7. Role of training on anti-corruption measures

Officials need to be trained in the application of the codes of conduct and the prevention measures which are to be implemented in a given institution. Training events also serve the purpose of raising awareness and of promoting cooperation against corruption.

The elaboration of training concepts within institutions is recommended. Training should be target group-specific. Particular emphasis should be given to the training of senior managers to serve as an example and to exercise supervisory accountability. Corruption commissioners and members of internal audit units may also need specific training, for example in the implementation of risk analyses.

It may also be useful to accompany training and awareness activities with the preparation of publications and other materials.

Codes of conduct or guidelines and corruption prevention plans should be elaborated by those who are subsequently responsible for their implementation. This process, if carried out in a participatory manner, will also have a training effect.
Finally, training activities should be repeated regularly as a tool to maintain the momentum of the anti-corruption effort.

7.1 Training and interagency cooperation

Corruption is not a phenomenon limited to a particular administration or institution or sector. Successful approaches to the prevention of corruption thus require cooperation between agencies, services, institutions and administrations, in order to:
 exchange experience on the effectiveness of corruption prevention measures,
 exchange information on emerging corruption problems and trends, as well as on specific cases,
 reach agreement on concerted action against corruption, and
 share skills and resources required for example, for risk analyses, training, information materials and publications.

Cooperation could be institutionalised by establishing an interagency round table or working group.

7.2 Anti-corruption training at the Vee Gee Group

As a response to the subject of anti corruption, the Vee Gee Group, India, has been successfully delivering anti-corruption training in India and several others countries over the past few years. Within the framework of India projects and seminars, the Vee Gee Group has stressed the importance of awareness-raising and a concerted effort in the fight against corruption.

Each seminar is adapted to the particular needs and areas of concern of the administration in question. Generally, the participants will receive training in the following areas:

• the definitions of corruption
• areas at risk
• awareness-raising using the dilemma situation game
• the causes of corruption
• the consequences of corruption
• legal aspects of the fight against corruption
• corruption indicators
• prevention strategies, ways to curb corruption
• behaviour when corruption is suspected or identified
• repressive measures (administrative and labour law instruments)
• special areas of concern

7.2.1 Presentation of the training concept

The concept of the Vee Gee Group is to ensure that all the institutions involved in the training of officials providing services develop an understanding of the nature and sources of corruption as well as the competence to deal with them effectively.

Four modules were elaborated for all target groups in order to convey basic information on corruption as well as to build an appropriate attitude, i.e. a personal readiness to participate in the fight against corruption. Therefore, the training measures contain both cognitive and affective elements.
On a cognitive level, it is important for members of all target groups to become aware of the causes and phenomenology of corruption as well as of the harmful effects of corruption on the State and society as a whole, social status, the credibility of the administration, and the economy.

Therefore, the first module entitled "Definitions, causes and effects of corruption" includes such aspects as various definitions and types of corruption, causes of corruption as well as the effects and consequences for the government and society. The emphasis lies on an active dialogue with participants.

The second module, "Legal aspects of fighting corruption", focuses on the relevant legalmeasures to be followed in cases of corruption. This training module covers the applicable anti-corruption law, relevant norms on disciplinary violations and sanctions as well as relevant portions of the criminal code.

The third module, "Organisational aspects of fighting corruption", covers forms of detecting corruption, e.g. defining risk areas in public administrations and recognising "alarm signals", which indicate a high probability that a particular civil servant or a group of civil servants are corrupt, and generally applicable methods of preventing corruption through organisational, intra-administrative measures like job rotation in sensitive areas, and the introduction of the " four-eye principle" in all sensitive transactions.

On an affective level, it is important for members of all target groups to put into practice the overall accepted ethics and standards for civil servants in their daily work.

Therefore, the fourth module concentrates on how to deal with the possible "Conflicts of Interest" and the development and implementation of "CSR Codes of ethics" in employee administrations. A particular emphasis of this module is placed on developing problem-solving skills, especially on the basis of a game entitled "Dilemma Situations".

7.2.2 Pedagogical approach

The pedagogical approach of all the training activities follow the idea that learning can only happen, when the participants have an active role in the seminar. The idea is that someone will only learn if she or he can apply the information learned to their daily work. Thus, the participants should be involved in the training process.

The three-day compact course for all employees of the public administration is set up as follows:

Clear objectives: For each module specific objectives are formulated, which indicate clearly whether or not they deal with cognitive or affective objectives and the level of achievement at which they are aimed. (e.g. to become acquainted with different definitions of corruption = the lowest level; to be able to formulate a definition applicable to one's own area of work = highest level).

Topics of discussion: Specific questions are formulated for each module, which should aid the trainers in initiating a discussion. Possible results and analyses were also anticipated.

Background reading: Each of the four modules contains background reading adapted to the specific needs of the target group in question.

Participant exercises: Specific exercises have been prepared for each module that range from simple multiple-choice tests on analysis and problem-solving tasks for group work to more ambitious role plays. A key exercise is the “Dilemma Situations” game, which allows the participants to review possible areas of conflict and their solutions.

Transparencies: A complete set of transparencies is provided for each module, which facilitate the structuring of the trainer's information and presentation style as well as the visualisation of content.

7.2.3 Objectives of the four modules

The specific objectives of the four modules are listed below.

Module 1: Definitions, causes and effects of corruption

The participants should:

• become familiar with the various definitions of corruption from the political, economic and legal points of view;
• become familiar with and be able to discuss the current EU/international standard definition of corruption;
• be in a position to formulate their own definitions of corruption;
• be able to indicate causes and effects of corruption on the State and society as well as be able to analyse them;
• be able to name the particular causes of corruption and be able to debate;
• be able to name, analyse and debate the current effects of corruption.

Module 2: Legal aspects of fighting corruption

The participants should:

• be made aware of the role of law in everyday life and its meaning for the fight against corruption;
• be able to obtain an overview of the applicable legal norms (prevention norms, i.e. administrative law and guidelines, Anti-Corruption Law, sanctioning norms – criminal law and procedural issues) and their areas of application;
• be able to recognise that the occurrence of corruption is related to the risk of being caught and punished;
• become acquainted with the problems of different methods of investigation (e.g. hidden cameras, undercover agents);
• be able to describe the legal situation on the basis of various case study descriptions with the corresponding formulation of questions and (in individual cases) be able to apply the valid legal norms.

Module 3: Organisational aspects of fighting corruption

The participants should:

• be able to indicate and analyse the weak points and the risk areas in the public administration, which favour corruption;
• be able to describe the various kinds of indicators ("alarm signals"), that point to corruption in different areas of the public administration;
• be encouraged to develop guidelines for corruption risk assessment and risk management;
• become familiar with international examples of corruption prevention;
• be able to develop regulations and measures of corruption prevention for their own areas of work;
• become familiar with the organisational, intra-administrative measures of corruption prevention;
• be able to develop suggestions for the implementation of corruption prevention plans and measures for their own areas of work.

Module 4: Conflict of interests/CSR code of ethics

The participants should:

• become familiar with examples of conflicts of interest in the area of public administration;
• be encouraged to identify and explain possible conflicts of interest from their own areas of work;
• be in a position to recognise the relationship between conflicts of interest and (possible) corruption;
• be able to develop different ways/measures to deal with conflicts of interest;
• become familiar with international rules for the development and implementation of codes of conduct;
• be able to name the most important aspects, that need to be included in a CSR Code of ethics;
• be able to develop suggestions for promotion strategies for CSR Code of ethics;
• practice ethical behaviour in the role-play entitled "Dilemma Situations“.

7.2.4 Example of a group activity

The contents of these seminars focus not only on the legal and organisational aspects of the fight against corruption. The participants are also encouraged to take part in simulation games, in which they are confronted with dilemma situations and then asked to describe and substantiate their responses to delicate situations. The examples used stem directly from the administration, thereby making it easier to identify with possible situations which may very well arise as well as creating a conflict situation among the participants. Moreover, the participants are actively involved and learn that the fight against corruption is their individual duty and not just the duty of the administration as a whole.

Here is an example of a group exercise:

As an employee of an administrative unit, you learn by chance that the wife of the colleague responsible for placing orders is employed by a supplier that was awarded the last large contract. What will you undertake?
a. I will speak to this employee about this situation and ask for more background information.
b. I will not to take any actions and assume that this only happened by coincidence. Thus, I give the colleague the benefit of the doubt.
c. I will bring up this point with my immediate supervisor and leave the decision to him or her to take appropriate action.
d. I make an inquiry at the company if there is an employment possibility for my unemployed partner.

At the end of the small group discussions, the participants are asked to present their decisions to the entire group. In turn these decisions are judged by the other small groups. A certain type of “competition” emerges to see which group will have the best and most effective solution for fighting corruption. Thus, the participants are constantly encouraged to critically examine their own behaviour as well as the behaviour of the other groups.

8. Conclusion: the challenge

The prevention of corruption requires a continuous and long-term effort. One-time activities and a incoherent mix of activities will not produce the desired results. The challenge is to develop a coherent approach or strategy or plan. This could involve the following steps:

a. adoption of a general CSR code of ethics (or anti-corruption guidelines) for officials on the whole, or for specific categories of public officials, and the judiciary,
b. elaboration or adaptation of specific codes or guidelines by an individual administration or institution,
c. continuous training and integration in training policy,
d. risk analysis within the institution or administrations,
e. establishment of an internal control mechanism (e.g., an internal audit unit),
f. identification of specific measures to be undertaken on the basis of the code of conduct and the risk analysis,
g. identification of further training needs,
h. preparation and implementation of the prevention plan, and cooperation with other institutions.

2)Another topic is as follows:

POLICY ON AVOIDANCE OF BRIBERY AND CORRUPTION
Introduction
The reputation of company for lawful, ethical and honest business behaviour is one of our greatest assets.
Vee Gee Industrial Enterprises Pvt.Ltd. recognise that this requires us to:
• Comply with the spirit, as well as the letter of the applicable laws and regulations in all countries/states/cities/units ;where we operate/deals.
• Act with honesty, integrity and transparency at all times
• Conduct all our business relationships in an ethical and lawful manner.
Business corruption normally falls into two main categories – fraud perpetrated on an organisation by outsiders and fraud committed internally by company employees. Recent surveys confirm previous experience and show that the vast majority of frauds are internal.
The importance of deterrence of the range of actions that can be taken to minimise corruption, by far the most beneficial is deterrence. Reducing the likelihood of corruption occurring in the first place is infinitely preferable to reacting after the event. However, we recognise that preventing corruption is not simply a matter of internal controls: it must be based on a process that extends throughout the culture of an organisation.
It is therefore the policy of company to:
• Value personal and corporate integrity – not simply through words but by the demonstrable
actions of management in setting the tone from the top.
• Not tolerate corruption of any type.
• Encourage a climate where employees know that they will be supported if they report suspicious
or questionable activity provided they act in good faith
• Require all employees to bring forward any suspicions of questionable activity that they are aware

By Order

Factory Management
Precursors and other inputs to this policy
This policy draws on a number of sources, including:
• Company’s existing anti-corruption policies, issued in 2013. This cover related party
transactions; fraud and business gifts and entertaining (available on the company’s Intranet).
Specifically, the following are relevant, and should be referenced:
− Anti-fraud Policy
− Business Gifts and Entertaining;
• Business Principles for Countering Bribery, produced by the NGOs Transparency International and
Social Accountability International. This document provides guidance on best practice for
companies in tackling corruption issues.
• Company’s other companies face challenges similar to Vee Gee Industrial Enterprises. We have surveyed the policies on corruption and related issues of a number of our peers

POLICY STATEMENTS

Emerging markets
Vee Gee Industrial Enterprises recognises that there are a number of markets in which the legal system is internally contradictory and where bribery and corruption are wide-spread and endemic, and where ensuring full compliance with our policies is harder and will take longer. However, we recognise the importance of the rule of law and elimination of corruption as elements in the sustainable development of emerging markets.

Vee Gee Industrial Enterprises are therefore committed to:
• Work with relevant Organisation/NGO’s to develop processes and programmes for tackling corruption.
• Engage with governments to assist both in the development of coherent and workable legal
structures, and in the elimination of corruption.
• Co-operate with other companies in these markets, which are facing similar challenges.

Policy principles
Vee Gee Industrial Enterprises Pvt.Ltd. requires that all its operating units seek to abide by the following:
1)Conflicts of loyalty or interest:
All employees are expected to declare in writing if they find themselves in a situation where their
loyalty to the company comes into conflict with personal interests or loyalties. Such a declaration
should be made to their immediate manager who should then report it to the Sector Finance department. If appropriate, the group financial controller and Director should also be informed.
Further policy and guidance is contained in Policy - Related Party Transactions, available on the
Vee Gee Industrial Enterprises Pvt.Ltd.’s Intranet.
2)Gifts and entertaining:
We will only accept or give gifts or entertainment that are for business purposes and are not material or frequent. It is a key requirement that gifts or entertaining should not be given or received on such a scale that they form an inducement to do business which may not otherwise be undertaken.
What is considered appropriate will vary significantly from country to country. Therefore local business unit heads should put in place local rules to cover the giving and acceptance of gifts or entertainment that reflect local custom which are to be approved by sector management.
However, as Alpana Jewels is an international business, these local rules should always bear in mind how particular local practices may resonate elsewhere. Individuals should always ask themselves whether they would be comfortable to have specific gifts or entertainment highlighted in the press. Where any doubt exists, the advice should be sought of the Sector HR Director.
Further policy and guidance is available on the Vee Gee Industrial Enterprises Pvt.Ltd. Intranet see policy– Business Gifts and Entertaining.
3)Payments to officials:
It is strictly forbidden for Vee Gee Industrial Enterprises Pvt.Ltd., its businesses, their respective officers and employees, or anyone acting on their behalf to offer, promise, or pay anything of value to a public official to influence or reward any action by that official.
‘Anything of value’ might include, bribes, kickbacks or any other inducement.
Prohibited payments include ‘facilitation’ or ‘expediting’ payments to public officials in order to secure proper performance of routine government duties. The use of subcontracts, purchase orders or consultancy agreements, as a means of channelling payments to officials are also prohibited. If you have any doubts about what payments maybe prohibited, you should raise these with your manager.
A confidential whistle-blowing procedure is in place should an employee suspect his/ her manager of
involvement in bribery.
This procedure is described in the Policy on Whistleblowing.
4)Expenses
Expenses will only be paid in relation to costs incurred in the course of legitimate business. Expenses
should be claimed in accordance with the group-wide Travel and Expenses Policy and individual
5)Sector policies.
It is a minimum requirement of such policies that expenditure on business entertaining or for any
external payment be supported by receipts and be approved by the concern’s manager. The claimant should further declare why any business payment was made, or entertainment given.
6)Political donations
Neither Vee Gee Industrial Enterprises Pvt.Ltd., nor any of its subsidiary companies will make any political contributions or donations in cash or kind. Fees for services rendered by third parties, including agents, lobbyists and consultants must be for legitimate business purposes, and be demonstrably commensurate with the service provided. All fees paid for lobbying and other relevant services should be transparently accounted for.
We will, however, engage in relevant policy debates on subjects of legitimate concern to the Group,
its employees and the communities in which we operate.
Implementation
Responsibility
Responsibility for the compliance of Vee Gee Industrial Enterprises Pvt.Ltd. with this policy lies ultimately with the Board.
Performance will be reported to the Board by the Partners/Director and financial Auditor.
Responsibility for the implementation of the policy lies with the Partners/Directors who are
required to develop procedures relevant to their Sector. They will work with plant directors who are
responsible for the day-to-day implementation of the policy.

Monitoring and compliance
POLICY

Each Section/Sector will be responsible for ensuring that it has in place the necessary arrangements to monitor and report compliance against this policy on an annual basis. Each business unit will be required to report their performance against this policy in its Management Representation Letter.

By

By Order

Managing Director

Responsibility for the compliance of Vee Gee Industrial Enterprises Pvt.Ltd. with this policy lies ultimately with the Board.
Performance will be reported to the Board by the Partners/Director and financial Auditor.
Responsibility for the implementation of the policy lies with the Partners/Directors who are
required to develop procedures relevant to their Sector. They will work with plant directors who are
responsible for the day-to-day implementation of the policy.
Vee Gee Industrial Enterprises are therefore committed to:
• Work with relevant Organisation/NGO’s to develop processes and programmes for tackling corruption.
• Engage with governments to assist both in the development of coherent and workable legal
structures, and in the elimination of corruption.
• Co-operate with other companies in these markets, which are facing similar challenges.
General measures and recommendations to prevent corruption are independent of any particular task or department. They are directed towards the abstract threats and risks to which the entire organisation or the staff in general are exposed. They are aimed at the heads of the government agency, or the organisation as a whole, and at employees. During their implementation, managers have a special responsibility, due to their duties of administrative and work supervision as well as to their function as a role model.

Outside employment can not only have a negative impact on the deploy ability and motivation of employees, but also can represent possible "docking areas" and gateways to corruption. Here the need for information by businesses or by the media (e.g. prospects for access to data) can play a significant role.

Due to their basic importance in the prevention of corruption, taking stock of and auditing sidelines is a major prerequisite for a realistic assessment of the potential for risk. This measure is thus an important component of risk analysis.

We are dealt with these cases seriously and effective measures are taking for root causes and how to prevent such types of incident for future.Out effective monitoring system are based on international corruption and prevention principle basis.Personally top executive of the company involved in this cases and there is confidentiality maintained to identify the root causes and persons involved,after proper verification and collecting evidences ,we share with all employees the incident and take legal action against the persons who involved in this case.
Vee Gee Group have formulated a number of recommendations for adoption and implementation of codes of conduct and ethics for employee, obligations for officials to report suspicions, analyses of risks and improvements in administrative, financial and procurement procedures to reduce risks, transparency in decision making, enhanced management of personnel (including career planning, training, mobility and salaries), audit and control systems, setting up of systems of disciplinary sanctions, provisions for the financial disclosure of assets of officials, and creation of self-monitoring mechanisms within institutions at risk.

Corruption prevention comprises a wide range of actors and activities. Many of these are closely interrelated. Conceptually, however, the following types of prevention may be distinguished:

 Prevention A: integrity and cooperation
 Prevention B: transparency and accountability
 Prevention C: reducing risks and opportunities
 Prevention D: control
The purpose of a code of conduct for enployees is threefold:
 it is a statement of the ethical climate that prevails in the factory;
 it spells out the standards of ethical conduct expected of factory;
 it tells members of the public what to expect of official in conduct and attitude when dealing with them.

Furthermore, as a well-drafted code of conduct describes in a coherent way the main elements of a corruption prevention strategy, it could be used as the ‘charter’ or the starting point for the elaboration of a prevention strategy or plan.

The code of conduct or code of ethics for employee recommended by the Vee Gee Group essentially comprises standards which employees should also adopt.

Employees . . .
. . . must recognise without any reservations that their official function is a position of trust which obliges them to act in the interests of the general public.
Indicators are not evidence. Therefore, they mostly do not have any or only very little meaning, when considered alone. Only if they occur repeatedly, frequently or in certain combinations are they suitable for contributing towards the growth of a suspicion.

The handling of corruption-indicator grids assumes a particular sensitivity on the part of the user. If used excessively or thoughtlessly, they can lead to unjustified suspicions and inadmissible conclusions instead of making a positive contribution towards the fight against corruption. Under no circumstances should such a grid of indicators be used with the goal of initiating a "witch-hunt".