MITRA S. K....MSK/IFIA/CC/01 Mifta S.K. Private Limited REV. NO. 04 ISSUE NO. I REV. DATE 27tO8/2A19...

T E S T I t{ G r I}ISPECTIO}I

MITRA S. K.

PRIVATE LIMITEDShrachi Centre, (Sth Ftoor)

T4BrAcharya Jagadish Chandra Bose RoadKolkata-700016

West Bengal, IndiaPh: (033)2217 -7 4U 17 48s 12265-0007

Fax: +91 33 2265 0008

Email -info@mitrask comWebsite: www.mitrask com

COMPLIANCE MAI\IUALt

(As per IFIA/TIC Council Compliance Code)

TESTlilGrlilSPECTloil

DOC No. :

MSK/IFIA/CC/OI Mifra S.K. Private Limited REV. NO.04

ISSUE NO. I REV. DATE27n8D019

ISSUE DATE: l8/O7l20l3 Page 1 of 18

TITLE: Compliance & Ethics Code

MSK ha an established international reputation based on our core principles of integrity and trust.

These core values are enshrined in our Comfliance & Ethics code which is based on theguidelines and requirernents of our indushies profussional$ body the lntemational Federation oflnspection Agencies/Testing, lnspection,Certification Council (IF|A/TIC Council).

Our core principles are:

o lntegdty

. Conflict of interest

o Confidentiality and Data Protection

o Anti-bribery

. Fair Business Conduct

o Health and Safety

o Fair Labour )we shall implement and atide by the compliance code of lFlA / TIc couhcil.

This entails:

o ! approval of the Member's irnplementation by lFlA /TlC Council

o ! ? Compliance Prcgramme throughorit the Member's organization

o tr policies and proccdures in accordance with the Code

. tr training of staff globally, and

. ! regular monitorirg of corndiance with the Code.

To ensure the effectiveness of the implenrentation of Comfliance code , we shall submit ourCompliance Progranme to an annual indeperdent examination whose results are reported to lFlA/TlC Coundl.

This resuft shall be a sound and verified basis for trust.

All MSK E)irectors and empbyees must at all times perfurm their dulies in accordance with therequirernents of the Comp[ance & Ethics Code. Failure to comply will be consftlered to be aserious breach of company potcy and will result in immediate disciplinary action.

lssued By : Approved by :

MANAGING DIRECTOROfficer

TEgTllG.lilSPECTloil

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The Directors ard Managernent of MSK are charged with the respornitlifity of ensuring theeffedive implementation, undestandirg and adherence in support of the Gon4rliance & EthicsCode in thdr areas of respomitifity; anO through induclion and ongcing hdnir4g programme forensuring that the requirernents of the Code are explained to, and understood by all employees.

Each and every employee must sign a declaration that they have read and understood theCompliance & Ethics Code at the commencement of their ergynent, and mnfirm thisdeclaration on an annual bmis thereafter.

Group Compliance OfFrcer

. 9qt&(v4 l'^,--{-'Saial Kurnar Mitra

Hanaging Dircctor

Approved by:

MANAGING DIRECTOR

TESTIilG rlilSPECTl0il

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Gompliance & Ethics Principles

1. lntegrityOur work shall be carried out in a professional, independent and impartial rnnner in all ofour activities.

We comnit to carryirq out our work honestly and shall not tolerate any daniation from theapproved methods and procedures. Data, test resutb and other nraterial facts shall bereported in good fuith and shall not be impoperly changed. Where approved test methodsmake provision for tolerances in resufts, we will ensure that sucfr tolerances are not abusedby us to of the test findirgs.

We shall report data, test resuJ'b ard other material facts in good faith ard shall notimproperly change them, and shall only issue reports and certificates that conecdy presentthe actualfindings, professional opinions or results obtained.

We will ensure the imflementation of the above through our Quality System prsoesses.

2. Conflicts of lntercst ' '

All of our employees undertake to avoid conflicts of interest with any related entity in whichthe company hm a financial or commercial interest and to rl'hich it is rquired to provideservioes.

We shall avoid confliG of interest between Group companies ancUor divisions engaged indifferent aclivities but which may be prwidirg services to either the same client oi eachother.

We shall ensure that our employees avoid conflicts of interest with the adivilies of thecompany.

3. Gonfidentiality and Data ProtectionWe will beat all infonnation received in the oouse of the provision of our services asconfidential to the extent that such infornation is not already published, generally availableto third parties or otherwise in the public domain.

MSK's intellectual property rghts, including technical information, inventions, systerns etcdeveloped or acquired by the company, together with information govemed by non-disclcu re agreernents must remain confi dential.

Such inforrnation should be given to authorized persons only, and in the case of any doubtadvice shouH be sought from the Group Compliande Officer.



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5.

AntiiriberyWe categodcally prohibit the ofier or acceSance of a bribe in any brm, indudirg kickbackson any poilion of a contract paynent.

We prohibit the use of any routes or channels for provision of inproper benefits to, orreceipt of improper benefits from, custoners, agents, mntractors, suppses, or employeesof any such party, or govemment officials.

The above policies are not intended to prohitrit nonnal and appropdate hosp*tality and giftsthat are custornary in a given rnarket, poviding that they are proportionate ard properlyrecorded ard documented. In the case of any douH advice and pem*ssion must beobtained from the Group Complance Officer.

Fair Business ConductWe are commited to competing fairly. We shall only present oursefues and conductmarketing, including any compadsons with or references to compelitos or their services, ina manner that is truthful and not deceptive or misleading,-or likely to nislead. We arecomrdtted to rnaintain business ethics and integdty, and shall notdo anylfrirg which wouldbring our rep.rtation, or the reputation of lFlA/TlC Council orthe TIC industry, into disrepute.

Heatth and SafutyWe shall implement adequate training and procedures to protect the hgalth and safety ofemployees, customes, ard third pailies and shall rnonitor incidents with the view ofnt'nimiZng risks in the couse of business operations.

Fair l-abourWe are aware of our social responsibility for our employees and the people, comrnunitiesand environments in whic{r it works ard we shall respect hurnan dghts.

7.

Approved by:

MANAGING DIRECTOR

TE ST ltl G .ltlSPECTloil

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Through the implementation and application of our Compliance & Ethics Code; MSK and allof its Group companies undertakes to:

1. Comnft itself at board level to implement the Gomfliance Prindples throughout itsorganization through operation of a Compliance Programme which has been approved bylFlA/TlC Council.

2. Appoint a Compliance comnittee and Comdiance officer to overcee and manage thePrograrnrne.

3. Train staff, ensure their continuing underctarding of the Compliance Programme andconsult them on its development.

4. Provide help lines for staff and encourage the reporting of violations on a confidential basisand free from reprisal except in malicious cases.

5. Publicly disclose our Compliance Principles and facilitate enquiries, complaints andfeedback.

6. lnvestigate and record all reported violations and apply conective and disciplinaryrleasures.

7. Protect the security of confidential business infornntion.

L Minimize heatth and safety risks in the workplace, rnonitor incidents, and Brt in place anynecessary correc-tive measures.

9. Maintain accurate books and records which properly ard fairly document all financialtransactions.

10. Ensure that our Compliance Progranrne is applied to the extent approfiate to its businesspartners.

11. Monitor the effec'tiveness of the Compliance Progranrne through the use of annualmanagerpnt declarations and i nternal auditi ng.Managers are to make their intemal reports in the format of Annex A of the lFlACompliance Code: Guidelines on lmplementation

12.. Arrange for the effectiveness of the implementation of the Programrne to be examined atleast annually by a competent independent extemal ar.rdit firm and we shall meet thedocument subnfssion requirements of lFlA/'llC Council (ncluding the submission of theAgreed Upon Procedures report).

Approved by:

MANAGING DIRECTOR

TESIIilG flilSPECTloil

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The audit firm will report in accordance with the requirements of Annex B or C of the lFlA/TlCCouncil Compliance Code: Guidelines on lmplementation.We shall submit copies of theindependent assurance report, including any reportable corditions, annually to lFlA/TlC Councilwithin six npnths of the end of our financial year.

1. Application of Gompliance Principles

1. lntegrity

1.1 MSK will provide guidance to its employees for dealing with clients who expect the MSK toabuse tolerances to obtain acceptable resufts.

1.2 ln respect of those business sectors in which MSK is active, MSK will comp[ with any sectorspecific lntegnty Rules published by the applicable lFlA/Tlc council commiftee.

2. Conflicts of interest

2.1 ln order to avoid conflids of interest, or the appearance of conflicts of interest, in MSK'sbusiness transactions and services, MSK will maintain a policy regarding conflicts of interest.

2.2 MSK's policy will provide guidelines to employees in order to avcrid conflicts of interestsbetween

D MSK and related entities in which MSK has a fnancial or comnerdal interest andto which it is required to provide services, and

ii) MSKs companies andlor divisions engaged in different ac{ivities but which maybe providing services to either the sarne client or each other.

2.3 MSK's policy will provide, as a ninimum, that MSKs Employees do not:

a) directly or through relatives, friends or intermediaries, acquire an interest in asupplier, a client or a competitor of MSK, except for the acquisition of shares of aclient, supplier or cornpetitor on a public stock exchange, and then only to an extentwhich does not grant significant influence over the affairs of the client, supplier orcompetitor and whicfr does not make the employee unduly dependent on itsfinancial fortunes;

b) hold any position with a competitor or client;

c) conduct any company business with any member of their fanily or with an

, individual or organization with which they or their fanrily is associated;

d) employ a member of their family without approval of MSKs management.

Approved by:

MANAGING DIRECTOR

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3. Gonfidentiality

3.1 MSK will require each enrployee to sign a Non{isclosure Agreement which prohibrits thedisclosure of any confidential business information, obtained during the course of his/heremployment, to other parties.

3.2 MSK will ensure that all intermediaries, joint venture partners, agents, subcontractors,franchisees, contractos and suppliers are made aware of the confidential nature of businessinformation that they may handle through their dealings with MSK, and that they should notdisclose confidential information to other parlies,

4. Anti{ribery

4.1 Gompliance with laws

MSK will ensure that the Principles and Rules of its Progmmme rneet the requirements of thisCode and local laws relevant to countering bribery in all the jurisdictbns in which it operates.

ln the event that the local lavrrs speciff additional or different requirernents, whic*r are not coveredby their Progranrne, MSK will rmdiff its Programrne for the country Qes) concemed. Recordsshould be kept of epuntries where their Programrne has been modified.

4.2 Analysis of risks

MSK'S Compliance Committee and/or the senior executive, or his delegate, in each country ofoperation should olganize periodic revieus to assess bribery risks and detemfne appropriatecontrol measures. Such reviews should be systematically conducted:-

0 Prior to the cammencement of a new service or the start up of operations in anew country and

(ii) Whenever a significant breach of MSKs Prograrnne which warrants a review ofthe existing control measures occurs.

4.3 Business Principbs for Gountering Bribery

MSK will employ good business practices and risk r-ranagement strategies in accordance with theBusiness Principles for Countering Bribery as pnrblished by Transparency lntemational and SocialAciountabili$ lntemational (see www.transparency.org). These should addres at least thefollorruing areas:

lssued By: Approved by:


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4.3.1 Political contributions

MSK, its emfloyees or agents should not make direct or indirect contdbutions to political parties,organizations or individuals eng4ed in politics, as a way of obtaining advantage in businesstransactions.

MSK will amunt for all its political contdbutions in a separate ledger and consolidate all suchpayments made by any of the operations that form part of its organization.

4.3.2 Charitable contributions and sponsorships

MSK will ensure that charitable contributions and sponsorchips are not being used as a subterfugefor bribery.

MSK will account for all its chadtable contlitxrtions or sponsorships in a separate ledger andconsolidate all such payments made by any of the operations that form part of its organization.

4. 3.3 Facilitation payments

Facilitation payments are defined as small payments made to "*ui"

orexpedite the performanceof a routine or nece$sary action to which the payer of the fadlitation payment has legal or otherentitlement.

Recognilrg that facilitation payments are a form of bribery, MSK will work to identiff and eliminatethem.

4.3.4 Gifts, hospitality and expenses

MSK will prohibit the offer or receipt of gifts, hospitality or expenss whenever sucfi arrangementscouH affecf the outcome of business transactions and are not reasonable and bona fideexpenditures.

5. Fair business conduct

5-1 MSK will provide guidelines to employees, agents and intennediaries to ensure that theyunderstand and adhere to the Pdnciple goveming fair business conduct.

5.2 MSK will maintain a Fair Business Conduct policy prohibiting:i) making untrue statements about competitorc, their operations, services or service ofiedngsii) aclivities contrary to rules for fuir competition, anti-trust or tenderingiii) inciting, inducing or encouraging any person to b'reach its conhactual obligations (includingobligations of confdentiality)iv) commerdal esfonage and/or data theft

5.3 MSI('s presentations and puHications will accunately and unamtiguously reflect ttre Member,snetwod< and affiliations, resouroes I capabilities, experi6nce and services prbviOeO.

Approved by:

MANAGING DIRECTOR

TESTIIGODISPECTIOil

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6. Health and Safiety

6.1 MSK wil! rnaintain a policy on Health & Safety to meets all legal requirenrents.

6.2 MSK will provide Health & Safety training to their employees, appropiate for the adivities theyare engaged in.

6.3 MSK will encourage employees to report Heafth & Safety related inci&nts, record theseincidents, investigate these incidents and if required, take corrective measures.

7. Fair labour

MSK will rmintain a policy on fair labour.

MSK's policy willstate the MSKs mmnftnent to the following:

i) Compliance with at least with n*nimum wage legislation and other applicable urage and workingtime laws.

ii) Prohitftion of cf$b labour * strictty prohibit the use of chiH labour.'-

iii) Prohibition of forced and ompulsory labour - prohibit all fonns of fored labour, ufrether in theform of pnson labour, indentured labour, boded labour, slarre labour or any kind of non-voluntarylabour.

iv) Respect of equal opportunities in the workphce

v) Zero tobrance of abuse, hlllyrng or harassment in the wokplace.

Approved by :

MANAGING DIRECTOR

TESTlNG.lilSPECTlotl

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2. Compliance Proqramme

lmpbmentation

MSK is required to implement a Compliance Prqramne, based on this Code, throughout itsorganization. MSK may choose to do this by integration of the Code's requirements into its qualitymanagement system.

Members' Compliance Programmes

MSK's Group Board, or equivalent body, will confirm its comnitrnent to implementing this Code bypublishing and adopting its Pdnciples and the key elements of implementation which will, at least:

o address all the lFlA/TlC Council Conpliance Principles and Requirements forlmplementation

. follow these Guidelines as specified in paragraph 2 of the lntroduction to thee Guidelines

r apply them throughout the whole of the organization.

MSK is required to send, within one month of publication, a copy of its Compliance Programme,and any subsequent updates, to the Director General for verification of comdiance with thelFlA/TlC CouncilCode.

The Director General will respond within two npnths of receipt.

Gompliance Ofiicer

MSK's Group Board, or equivalent boch/, will nont'nate a Compliance Officer, who, irrespective ofhis or her other responsibilities shouh have responsibilig and authority under the Board for the co-ordination of the implementation of the Com$iance Programme throughout MSK's organization.The Compliance Officer may nominate delegates to perform some or all of his/her functions withinspecified parts of the organization. Additionally, senior managers throughout the organizationshould have responsibility for implernentation of the Programme in their areas of responsitility,

Compliance Committee

MSK's Group Boad, or equivalent body, will estaHish a Comf,iance Comnittee to carry outperiodic reviews of the progress of the Compliance Programme and provide policy guidance. TheCompliance Comnfttee shall have atleast three members including the Chief Executive Officer(or equivalent), the Compliance Officer, representation from Legal (for Legal function) andrepresentation from HR (for HR tunction).

Approved by:

MANAGING DIRECTOR

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Recruitnent

Prior to a job offer, prospective employees will be informed of the Compliance Programme.

Employee commitrrent

MSK will ensure that:

(a) each employee is provided with a copy of the Compliance Programnre and requested to sign adeclaration that it has been re@ived, read and understood. A record shouH be kept in theemployee's file;

(b) each Senior Manager is required to sign an annual declaration (see Annex A) that theProgramme has been implemented in his/her area of responsibility.

MSK's Programrne will include prwision that it be made clear that emfloyees will not sufferdemotion, penalty or any other aderse consequences adsing from strict implementation of theProgramnre even if it may resuft in a loss of business.

Training ' .

All employees, incltding Managers, of MSK will be required to undergo a Conplance TrainingCourse. For the purpose of guidance in the preparation of coulse matedal, MSK will refer to thelFlA/TlC Council Compliance Training Guide. A Record of couse mmpletion should be kept ineach employee's file,

Employee "Help lines"

MSK will make provision for *help lines" where its emfloyees rnay o$ain guidance on any questionor matter of concem relating to the impbmentation or interpretation of the Programme. At theemployee's request, any such question should be dealt with confdentially and the anonymity of theemployee should be protected to the extent reasonably practicaHe. Such help lines may utilizeMSK's intemal resour@s and/or an extemalthird party organization.

Securtty Measures

MSK will implement adequate security measures in its organization's prenises containingconfidential business inforrnation to ensure that access is restricted to authorized personnel onlyand that documentVdata are stored in designated secure areas ard disposed of in a securemanner.

External Comrnunications:

MSK will make public its Gompliance Principles and provide facilities to receive enquiries,comphints or feedback from interested parties.

Approved by:

MANAGING DIRECTOR

TESTIilG flISPECTloil

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Reporting of Violations:

MSK's enployees will be encouraged to report details of violations or suspected violations eitherdirect to the Compliance Officer, or to the employee's superior, a member of senior managementor an intemal auditor. The repoiling employee will be fully protected against any form of reprisalunless he/she acted rnaliciously or in bad faith. lf requested, the emfloyee's anonynity will beprotected to the extent reasonably practicable.

Employees will be required to report any solicitation for, or offer of, an improper payment oradvantage coming to their knowledge.

lnvesti gations and Sanctions:

The Compliance Officer will initiate, where appropdate, an investigation into any violation of theProgramme reported to him/her or coming to his/her knovledge.

MSK will maintain a documented procedure for the handling of investigations and sanctions whichwill include requirernents for:-

(a) the maintenance of records of all reported violations and subsequent bctions taken;

(b) the alleged perpetrator of such violation to have the dght to be heard;

(c) MSK's management or Compliance Comnitee to decide on the appropriate conective anddisciplinary measures to be implenented if a violation has been estaHished. These measures mayinclude a repdmand, demotion, suspension or dismissal;

(d) the Compliance Offcer to receive progress reports from his/her noninated delegates and/or themanagement in the locations concemed and prepare periodic sumnary reporb for the ComplianceCommittee on investigations, violations established and the impbmentation of corrective actionsand disciplinary measures.

Business Relationships:

To ensure that MSK's Compliance Programme is applied to the extent appropriate in its businessrelations with parties extemal to MSKs organization and that improper paynents are notchannelled through them,

MSK will ensure that such Frties abide by MSK's Conpliance Programme to the extent that isappropdate. Such parlies include:

o lntermediaries, (entities or individuals external tq MSK who are required to promote theservices of MSK as part of their responsibilities, includirg consultants and advisers)

o , joint venture partners

o agents

lssued By : Approved by:


IESIlilG.ltlSPECTl0I

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o subcontractors

. contractors

r Suppliers

o ftanchisees (wheneverapplicable).

MSK will do this by at least

r conducting due difigence before entering into or renewing any contract with the party

. making known its Compliance Principles to the party and seeking assuranoe that the partywill comply with the Principles in so far as these apply to activities perforrned on behalf ofMSK

r requidng all our business partners including intermediaries except in the case of subcontractors, in addition to, contractually comply with the Compliance Prindples themselvesand to allon MSK to veriff this periodically.

o monitoring the party's continual compliance with the P{nciples (and in the event ofdiscovering a breach taking remedial ac{ion)

o rot dealing with any parties knourn to be involved in bribery.

Due diligence includes

o A risk analysis

. An interview with the party

. An investigation of the party's baclqgrourd which, for intenrediaries, should be reviewedand approved by MSK's compliance Comnfttee

. Vedfication through a renuneration analysis, which shouH be reviewed and approved byMSK's Comfliance Comnfttee, that the remuneration patd to each internrediary isappropdate and justifable for legitimate services rendered, and does not facilitate improperFyrnents by the intermediary.

MSK will monitor compliance with their due diligence procedures.

ln addition, for intermediaries and other parties as may be appropriate, MSK prwide training andsupport.

MSK will account for all interrnediaries' remuneration in q separate general ledger account in itsaccounting records and con'so$date all such payments made by any of its operations and prepareannuqlly a consolidated management staternent of all internrediaries' rernrneration.



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Complaints and Disciplinary Procedures

Complaints concerning alleged non-conpliance with this Code by other lFlA/TlC Council Membensshould be lodged with lFlA/TlC Council in accordance with the lFlA/TlC Councit Complaints andDisciplinary Procedures. lFlA/TlC Council Members should refrain from submitting such complaintsto other parties unless it is necessary to do so to proteci their reputation.

(Breaches of this Code rnay lead to sanctions imposed by the lFlAlTlC Council subject to the rules,including rights of appeal, set out in the lFlA/TlC Council Complaints and Dsciplinary Procedures.)

Accounting and book keeping

MSK will maintain accurate books and records which properly and fairly document all financialtransac{ions. Otr-the-books accou nts shou H be prohibited.

Health and Safety

MSK will record and investigate all reported Health & Safety incftl+ihts and undertake correctivemeasures where appropdate.

Compliance sumnnry report

MSK's Compliance Officer shall prepare, a summary report covering statistics or confirmations

to show compliance with the Member's pnocedures and policies, on an annual basis for the

following areas:

A)Molations - number of violations / suspected violations shall be reported; number of violations

substantiated; and confirmation that remedial actions shall be determined and action shall be

taken for each substantiated violation / non-compliance.

B)New or renewed intermediaries, joint venfures partners and franchisees-

i)number of new or renewed intermediaries, joint ventures partners and franchisees in the

financialyear;

ii)cbnfirmation that each shallgone through the Member's due diligence procedures as required;

iii)eonfirmation that an appropriate contract / terns of buiiness shall be put in place with each.


MANAG]NG DIRECTORGroup Compliance Officer

lESTlilG f|ISPECT|0{

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C) Expenses - confirmation the expenses are in line with the Member's Compliancc Programmeand related policies for:

tr Po[tical contributions

! Charitable contdbutions and sponsor ships

I Expenditures relating to gifts, hospitality and expenses

! I ntermediaries' remuneration

D) Health & Safety - number of Health & Safety incidents shall be reported; and confirmationthat remedial actions shall be determined and action urdertaken / beirrg undertaken for eachincident.

lssued By: Approved by :


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3. Verification

Ma nagement declarations

MSK will require its Senior Man4ers throughout its organization to prepare and sign, on an annualbasis, a Compliance Declaration which, as a ndnimum, shouH be based on the template containedin Annex A. These Compliance Declarations shouH be sent to the Cornpliance Officer who shouldsubmit an annual summary reportto the Compliance Comnjttee.

lnternal audits

MSK will require its nominated intemal auditors, as part of their internal audit plan, to veriff that theCompliance Programme has been implemented within its organization aM in particular that theManagement Declarations have been completed in conformance with Annex A and reflectcompliance with the Programme and, in respect of those locations selected for site auldits, correcilyreflect the actual situation. Such site audits should review the processes in flace and includetesting, on a sampling basis, to ensure the effective application and implementation of theProgramme. The lFlA/TlC Council Guidance Check List for Members' lntemal Compfance Auditsmay be used for reference. This Check List is directly ap$icable if the Member's implernentation ofthe Code follows the July 2005 version of the lFlA Gompliance Code in detail. Othenrvise it acts asa general check list for areas that the intemal audit is likely to need to cover when applied to auditof any lFlAlTlC Council Member company's implementation of the lFlA/TlC Council Code.

The compliance findings resufting from such audi,ts should be reported to the Compliance Officerwho shouH subnit a summary report to the Compliance Commiftee. The Compliance Officerand/or compliance comnittee should take follow-up actions where appropriate.

External examinations

1 Frequency

The effecttveness of the implementation of the Programme will be examined at least annually byMSK's appointed independent extemal audit firm.

2 Appointment of audit firm

MSK's appointed recognized independent external audit firm to carry out the vedfcation by agreed

upon procedures shall be the firm engaged for the statutory audit of the MSKs (consolidated)

financial statements. The appointed audit firm shall be a reputable organization that is a member ofa recognized national professional accounta ncy org anization.

rssuedBy,Wr' Approved by:

MANAGING DIRECTORCompliance officer

TESTlilG.ltlSPECTloff

DOC No. :


ISSUE NO I REV, DATE27108/2019

ISSIJE DATE: l8l}7 /2013 Page 17 of 18


3 Notification to lFlA of Member's appointed extemal audit fim(s)

Prior to the appointrnent of the external audit firm(s), or any subsequent proposed changes thereof,MSK will submit details to the Director General for confirmation of compliance with lFlA/TlCCouncil requirements.

4 Scope of examination

4.1 Submit documents for verification to lFlA I TIG Gouncil

MSK will subnit the following documents:

1) MSK's Compliance Programme, as well as policies in relation to each Princifle.

2) The Tenns of Reference for the Compliance Cornmittee (or equivalent) including thespecification that the Compliance Committee (or equivalent) is responsible for overseeing theCompliance Programme.

3) List of members of the Compliance Committee (induding job tifle),..

4) Compliance Programme training course rnaterial.

5) Material helpfrq the awareness of the Employee Help Line (or equivalent - e.g. designatedemail).

6) Material encouraging employees to report'details of violations or suspec*ed violations and towhom they can report.

7) Screen print of Member's website where:

- the Compliance Pdnciples are explained.

- an interested party can make inquiries, conplaints or feedback.

8) Documented procedure for the handling of investigations and sanctions

9) Policies relating to confidential business information (nfornntion security policy, confidentialitypolicy).

10) Procedures for due diligence for initiating or renewirg relationships with intennediaries, jointventures partners and franchisees.

11) Procedure for contracting with interrnediaries, joint venture partners and franchisees andrelated template(s) of contract / terms & conditions with a new / renewed intermediary, jointventure partner or franchisee.

,12) Template of the annual managernent declaration based on the tenplate in Annex A.



TgSTlilgrllSPECTloil

DOC No. :

MSK/IFIA/CC/OIREV. NO. 04

ISSUE NO. I REV. DATE27/08/2019



13) Scope of lnternal Audit plan that includes the review of the imphmentation of the ComplianceCode.

14) Annual sumrary reporb prepared by the Compliance Officer covering statistics orconlirmations to show comfliance with Member's procedures and policies, as specified in Annex B.

15) Annual report of the resutts of the agreed upon procedures.

When submitting the documents, the MSK will self-assess whether the evidence being subnittedmeets all the evidence requirernents. MSK shall explain the reasons for any deviations to theevidence requi rernents.

Documents will be be re-submitted, if they have been updated. All documents shall be reviewedand u@ated at least every three years or whenever there is an updated version of the ComplianceCode andlor guidelines issued by lFlA I TIC Council.

4.2 Request audit firm to carry out agreed upon procedures

MSK shall request audit firm to cany out agreed upon procedures ,-

lndependent audit firm, appointed by MSK will carry out audit annually agreedthe following areas:

l) Understanding of compliance code by each new employee

ll) Attendance of Compliance Programme training course(s) by employees

upon procedures for

lll) Employee Help Line (or equivalent - e.g. designated email) to raise queries and / or issuesrelating to the Compliance Programme

lV) Reviewing and taking actions on enquiries, complaints and feedback fiom interested parties

V) Understanding of the confidentiality requirenrents by each new employee

Vl) Schedules prepared for political contdbutions; charitable contdbutions and sponsorships;expenditures relating to gifts, hospitality and expenses; and lntermediaries' remuneration

Vll)Monitoring of annual compliance declaration subnissions by Senior Managers

The specific agr,eed upon pocedures shall be detailed in Annex C.

5 Audil firm's Report

Audit firm shall produce a Report showing the results of the agreed upon procedures using thetemplate contained in Annex C,and will submit to MSK.

MSK will subnrit its audit firm's Report to lFlA / TIC Council within six months of the end of theMSK's financialyear.

Approved by :

MANAGING DIRECTOR

ANNEX AMana gement Declaration Template

Confidential

. . . ..(nane of ltember/s Gompliance programmeManagementDeclarationforthe yearending... ..........20....

To:...... .....-..._(name of lvlemfc/s Comrtia:e- Atrter q mrnirnted&legd.e)

Name of Manager: ..Job Tite:Localions and/or activities covered by this Declaration:

I -.-.......-.... ......(rrpmeof tt/einryer)do herebydeclarethatininPlencntation of

:: :: :: .; ;; ffi""i',ffi;"":ffi:?:ffi[HTH*5'"'h::4fiff'lL*nry area of responsibility:-

1.To the besJ of my knovrrledge l, and the members of stafi reporting to me, have complied in all respects with theCompliance Programme,2.1 have verified that the Compliance Prognamme has been distributed to eacfi Empoyee wtro had not previouslyreceivedthem;3.1 have fully and completely reported to the Comfliance O'fficer any violation or suspected violation of theProgramme, induding any solicitation or offer of any improper payment or a&antage, vrltrictr has come to myknowledge;4.1 have fully and completely imflemented all correc{ive and disciflinary actions required by theCompliance Commiftee in respect of any violation of the programme.

Signature

Apprwed by:I

Managing Director

Annex BDetailed requiremenG for evidence to be submitted

fuldcneto bcsobr*cd Eltidcncc RcqrlorlFnts1) Membe/s Conpliame hotran ne as rell as policies in retationtoeach prirriple (if separatel

The proBramme should coner the corrpliance code prirriples:

- lntegrity- Conflicts of interest- Confidentdity and Data Protection-Anti-kib€ry- Fair business mrduct- Fair labour- lbalth & Safety

The programme and policies require to be in line with tlr details prwided in the?pdbatim of Cofipliarre principles' in the Ccnfliara Code gui;delinecThe programme should irrlude:- reference to the Help [ine.- provisions for protection of confidentiality for reportirE vidatiorE.- a provisicr nrtere erpq/ees can report knwr or suspeced violations to tlFCornpliance Offrcer, the enployee's superbr, a rvrenrber of scnric managennn! or aninterml auditd"

- requirementfsemployeestoreportarrysolic.itationof, orofferof, an improperpayment or ad\rantage comir€ to their attentlJrl- provision that it be made clear that employees will not suffer denotim, penalty or anyother adverse ccxequerrces arising from strict implernentation of the ftogramrle evenif it may result in a loss of business-

2) The Terms of Rebrence fa the Corrpliame Committee (orequinlentf irrcluding the speclficatbn ttut the C_ornplianceCornmittee (or equiwlent! is responsiHe for mseeing ttnCompliance Programme

The Terms of Reference should specify that ttE ccnrx'ttee is respomible for overseeingthe Cornpliance Programme.

The Terms of Reference should sp€cify.thlrequencl of the Cornpliance Convnitteemeetings. The Ccnpliance Cornmittee should mCet regularly {at least on an annualb6is).

3) List of menbers of the ComSiarr:e Cornmittee 0ncludirg jobtitle)

There should beat le6t 3 rnert€rs in the Corpliarre ComnfRee.The members of the Cornrnittee should include:

- Compliance Officer (or reports intoas atterdee)- CEO (orequivalentf- bpresentative frorn Legal (if nrember has a legal furrtion)- bpresentati\re frorn HR lif member has a HR f urEtion)

4) Cmpliance Programrne train'ng coUrse material Th€ material should include sections on:

- lntegity- Conflicts of interest- C-onfidentiality ard data protection- Anti-bdbery- Fairbusiness corduct- Fair labour- l-lealth & SafetyAny trainir€ relevant to the financial year shouH be submitted.

5) Material helpir€ the arwrerrss of the Emplolree l-lelp Une (orequivBlent - e.g- designated ernail)

The material should e4plain:

- that emdoyee can obtain guidance qt anyquestlon or matterof cmcem relating tothe imdernentation or interpretation of tk Conrpliarre prqrannne.- at ttF enployee's request, any such questixr shorld be dealt with confdentially andthe anfiymity of ttle enployee should be prdected to the extent reasonablypractlcable.

6l Material encouraging enployees to report delails of vidatixror susp€cted vt-olatiorrs ard to whdn they en report

t

The material should e)plain that the:

- emdoiree is fully protected agairst any form of reprisal unless he/she actedmalbiously or in bad faith.- employee is required to report anv solicitatian fc, orofferof, an improper payrnent oradvantage confng to their knowledge-May be the sanr as submission 5.

7l Screen print of Membcr! rhrite wtEre:- the Cornpliance Prirriples are elplairrd.- an interested party can make inquiries, cornplaints orfeedback

N/A

lssuedby: \\Wcrorpcornpi),/omcer /Rl

Approved by:

Manalng Director

eQ'9i'Y!ti 67

Evld:nca to bc submittcd Evidcnca Rcouircnrcnts8l Documented procedure for the hardling of invetigatbns ardsarrtims

The prcedures should irrclude requirements for:(a) the maintenance of recsds of all reported violaticns and sub.equent actiors taken;{b} the alleged perperator of such vidation to hare the right to be heard;(clthe Membs's management or Compliance Cornmittee todecide on the appropriatecorrective ard disciplinary measures to be imple.nented if a vidation has beenestablished- These measures may include a reprimand, demotion, suspmsim ordismissal; and(d) the Corrpliance Officer to receii/e progress repsts frqn his/tpr nsninateddehgates and/or the managenFnt in the locatiors concerred and prepare periodicsummary reports forthe Conpliance Cornmittee on in\estiBations, vidatiatsestablisbd ard the implementatim of corrective acti:ns and discinlimrv reasurc<

9l Policies relating to confidcntial business infarnation{inforrnation security policy, confidentiality pdicy)

TtE pdky should cover the need fs the business to implennr* adequate securitymeasures to ensure that access is restricted to authorised persomel only and thatdocuments/data are storcd in designated secure areas and dispoeed of in a seuremnmr-

10) Procedures fc health & safety incident reporting andin\restigatiorB

The procedures stnuld:- define wtrat a health & safety incldent is.- explain how the emdolEe can report health & safety incidents-- encourage erpblrees to report health & saftty irridentr- explain how health & safety incidents will be inEstigated and rernedial actims will bedetemired-

11) Procedures fc due diligerre fa initiatir€ or rerewir€ therelationships with intermediaries, lbint venture partrers andframhi*s

For interrnediaries, ioint venture partnem ard franchisees, the Member requires to havea written procedure in terms ofwhat due diligence step6 they require tocarry out ands,hat appml/al is required for initiating or renewing the intermediary, joint venturepartner or frarchisee.

12) Prcdure ftr cmtmting with interrnediaris, jointrenturepartners and fanchisees and related template(s) of cmtract /terms & conditiorE with a new/ re-rcwed internediary lcintventure partner or franclfsee

Th€ cmt€ct/ tsm of bwines should imlude:- A requirernent that the Business partrcr cornplies with the Compliance programrne

- A prodsim allowingthe Mernber toverirythe RjsirEss partne/scompliance with tlECornpliance Proeramme-

For internEdiary, iint renture partrEr ard franchisee, tlc lvbnrber requires to havewitten procedures in terms of what contracts/ tems of b6ine6s requires to be put inplace coverirE tlle intermediary loint venture partner or frarrchisee,s acknowledgementof cdnpliance with lvtembe/s compliancifrogramme.Wttere the Member does not hare a standard teFplatq wlember shqjld submitexamdes of cmtracts which irnlude abore.

13) Template ofthe annual mamgement declaration based on thetemplate in Annex A

Cornpliance declaration should include the attributes in Anrpx A induding locatiorsand/or activities cowred by the dedaration as vFll as dedaration of implernentation oft}E Cornpliance Programme

14) Scope of lnternal Audit plan that includes the review oftheimplementation of tte Ccnpliance Code

The Scope of the lnternal Audit plan slpuld cwer the Membeds organisatidt.

15|Annual summaryreports prepared by the Canpliance Officercovering statisti€s or confirmatiqE to show comdiarre withlvlembe/s praedures and pdicies ard policies, as specified inAnrcx B

On an arnual basis (in line with financial year-end!, the Membershould prepare anannual summary reports detailing:1| Molatians:- Number of violatiors / suspected violatiqE reported- Number of violations subgtantiated- Confirmation that rernedial actims have been determirnd and actim undertaken /being undertaken for each substantiated vidatim / non-cornpliance.

ffhe above statistics are required to corEr those vidations / suspected vidationsreported throl.lgh Help Line as well as fa.rnd durirg lnternal AJdits.)

2| For new or re-newed inbrmediaries. joint venture partners ard franchisees:- Numberof newor re-neyed intermediaries, ilintventure partlers ard franchisees inthe finarrcial year-

- Confirmatio that each has gone through the Mernbefs due diligence procedures asrequird.- Confirmatim that an appropriate contract/ terms of business has been put in plaewith each.

3) Cmfirrnation the e)eerEes are in line wfth the Membe/s Compliance programrne andrelated pdicies for:- Politbal contributiors.- Chantable cmtributiors ard spcrsorshipo.- Expenditures relating to gifts, hospitality and expeces-- lntermed iaries' remuneratim.

4l Health &Safety: "

- Number of health & safety incidents reptrted- Confirmatim that remedial actims have been determircd ard acticr undertaken /being undertaken for each incident.

16) Annual report of tlE results of the agreed uocr orcedure N/e

lssued

Group

Approved by:

Manahng ll{rector

KOLKAIA

ANNEX C

Template Report for Agreed Upon Procedures results

"Report on Mitra S. K. Private Limited's Compliance programme"

We have performed the agreed upon procedures enumerated below, which were agreed to by the Member and thelFlA / TIC Council, solely to assist you the Member in reviadng your Compliance Programme in connection Wth yourmembership in lFlA / TIC Council. The Member is responsible for implementing a Comfliance programme thatconforms to lFlA / TIC Council guidance. The sufficiency of these procedures is solely the responsiblity of thoseparties specified in this repoil. Consequenty, we make no representation regarding the sufficiency of the froceduresdescribed below either for the purpose for which this report has been requested or for any other prrpose.

Arditarca Agrced upon Frcdtrcs Rqdts and Ftctrnl ftidtlr$cbceorryFled bVeudtfirml

l) Understanding ofcompliance code by each newemployee

1. Obtain a list of new employees during the 12months to financial year-end.

For Members who operate in multipleoffices/locatiom, the sample should be selectedacross the offi cedlocations.Albrnatire: Wlplrc the Member hc more than70 ofrics, dte l,tlerntrlr con provide a iist of AIIoIfu6- The ardlbr lhen sekts 7O ofica- Forlhe offie, lhe Menber prcvldes a lbt of ne*pinets in the audit ptiod. lf tlrelrc is no rwjoinu anodter olfice k selechd.2. Select a sample of 1O new employees3. For each selected sample, obtain the signeddeclaration that they have read and understoodthe Compliance Programme and signed within 3Odays ofioining.

1. Obtained fiom rnanagement a list of all newemployees of the Mernber for the financialaccounting perbd of ldatelto fcJar.e j. {We make nocornment with respect to the completeness oraccuray of the list.)Ntanotive: Ab&ritlrld lrom matugement a tist ofNL offies and sr/etul 10 olfic. Obtoind a listof oll nw enpbyes ftom the gfu sel*td lorthcS'g,mful xcourfiirrg pqid of tdatel to {tiate}.2. Norstatistically selected lxxi employees from thelist.

3. Confirmedqach employee selected in 2. hadsigned declarbtion t{rat they have read andunderstood the Compliance Programme and signedwithin ir:la';s for iongesi p*ri.::til days of joining.

ll) Attendance of ComplianceProgramme training course(s)by employees

1. Obtain a list of all employees.Etebnolion:This is a list ol ALL et rybyeq otrd,bt just o frst olthosethatatlp,rdd tllEcourse-2. Select a sample of 1O employees who haveattended the course in the 12 month period tofinancial year-end.

Nhnptlve: For Menbas *ho optatc inmuftipb $ficefucotions, the sr,npb shouU tuselec&d acrcss the office/loadons.3. For the sample selected, obtain trainingrecords showing their attendance of theCompliance Programme training course.

Etqhnotion: For any rr:w a np@e (tf sanples&cE,dt,itis nod thotthq mayyetto futaircd dqending on thelr date ol joining otdtaining schcdti/c / tinptoble.AII enpb'yesshouu have C.ompfranehogmmme toining ot last on a lwo yarYbosb.

1. Obtained fiom management a list of allemployees of the Member {or the finarrcialaccounting period of [dat *1 to ldi'.e]. (We make nocomment with respect to the completeness oraccuracy ofthe list.)2. Non-statistically selected lxxl employees from thelist covering different offices and locations.3. Confirmed each employee selected in 2. hadattended the follnwing Compliance Programmetrainint courses within the last 2 years fromfinancial year-end:

- [n:m* cf crurr,"i- | nanre r;f rour re I

- !n.tttre *f roursei

lssuedby: \VGroup cornplialofficer

Approved by:

Manaling Director

Arditarce Agrccrd upon FocdLres RCsrA rnd Ftrtnl fere|r FanG.drrFlGBd lylrrdtknr!.

lll) Employee Help Une (orequivalent - e.6 designated email)to raise queries and / or issuesrelating to the CornplianceProgramme

1. Obtain the Employee Help Line number oremail address.

2. Call / send email to confirm the Help Uneis in operation.3. Discuss with Management how queriesand / or issues reported on Help Line arebeing investigated / looked into andresolved.

4. Obtain / impect evid€flce showing thatthe queries and / or issues are being handledas explained in step 3.

Explanation: l{ed to obtdn / inspcrt ortlrralaideneshwing gp,ervtion - totiusttemp,ofE,-

1. Conllrmed with managemera the followngEmpkcyee Help Une details: [!{elp iine nunrber l rrrli.ieip ii*e ernaill2. contacted the Help Une on l<iatel to confirm theHelp Line in operation.3. Discussed with Managementthe queries and / orissues reported on Help Line are being investigated /looked into and resolved by ltlre team 1 pe,rson

r*ponsrble] and tracked using lqueries ,1 i;siir:st r.:.kirlFi m echaft ise i.4. lnspected the leuerier / rseues trackingmer hanisn.rl and confumed that queries / issuesstatus is being tracked and queries f issues are beingresolned.

lV) Reviewing and taking actions onenquiries, complaints and feedbackfrom interested parties

1. Obtain the Third Party Help line numberor email address.

2. Call / send email to confirm the Help Lineis in operation.3. Discuss with Management how queriesand / or issues reported on Help Line arebeing investigated / looked into andresolved.

4. Obtain / inspect evidence showing thatthe queries and / or issues are being handledas explained in step 3.

Expbnalion: l{ed to obtain / inspe &t tale.videne sho*lng q*ation - ,Dt justtempb'€,.

Explaattion: lt lhe mahanism lor thirdporli€s to ?qise qu€}li€s ard / or hsucs is themme os enpbps cova os portof lll.

1. Confirmed with managemera the following ThirdParty Help Line dstails: lHelp t,ine nunrl;eri iir ilieicl.int ernarl;

2. Contacted the Third Party llelp Line on [d;t* i toconfirm the Help Line in operation.3. Discussed with Management the queries and / orissues reported on Help Une are being investigated /looked into and resolved by {tire tearn ,/ persr.rrresponsrblei and tracked using lqr.reries / issuestrdcking rrerhanieej.4, lnspected the lqueries I issu€s trackingrlleciranrsm j and confirmed that queries / issuesstatus is b€int tracked and queries / issues are beingresolved. )

V) Understandingoftheconfi dentiality requirements byeach new employee

1. Obtain a list of new employees during the12 months to financial year-end. (same listas agreed upon procedures l)For Members who operate in multipleoffices/locatbns, the sample should beselected across the offices/locations.Ntamtive: Whae the Menfur hc morclllc,n 7O offw, lhe Menier con protldle aliJ;t of a11 611i*. The auditor then se/€r's7O offfca. For tlrc otfice, ttrc Mefl,bepmyi.lesa frsto, ncfr joiners in thc auditp6id. t rre nev, joinetar'r,fir€,.ofrceisseraetd.2. Select a sample of 1O new emplcyees(same sample as agreed upon procedures l)3. For each selected sample, obtain thesigned confidentiality agreemeflt (or obtainthe signed declaration that they have readand understood the confidential bsinessinformation policy).

1. Obtained from manatement a list of all newempbyees of the Memberfor the financialaccounting perbd of Idate] to [d.:tei. (We make nocomment with respect to the completeness oraccuracy ofthe list)Ntanative: o6r&litrcd lrom matngement a list o,Allolfuand sdectd 10 a1fi6. Obtllind o listof all nct ett plops fion th $fes selqted fordtefitnncial ecouttirlg pe*lftld ot{datel to {datef .

2. Non-statistically selected [xx] employees from thelist.

3. C-onfirmed each employee selected in 2. hadsigned confidentiality agreement within Idays fi:rlongest perioell days ofjoining

Approved by:

Uanjgng Director

Auditarca Agrecd upon proccdrrcs eddB-*rd'&trl fh&gr (u tr tor@ tvau&firml

Vl) Schedules prepared for politicalcontributions; charitaHecontributions and sponsorships;expenditures relating to gifts,hospitality and expenses; andlntermediaries' remuneration,

1. Obtain the year-end schedule prepared byManagement for:- Political contributions- Charitable contributions and sponsorships- Expenditures relating to tifts, hospitalityand elpenses- lntermediaries' remuneration2. Discuss with management how they arecomfortable each schedule is complete andaccurate.

3. Obtain the review and approrral oftheschedules by the Audit Committee and/orCompliance Officer. (Thb can be part oftheannual summary report - submissbndocument 15).

1. Obtain the year-end schedule prepared by lic,btit-ie cf persc.n preparingj for:- Polltical conlributions- Charitable contributions and spomorships- Expenditures relating to gifts, hospitality andexpenses

- lntermediaries' remuneratiron2. Discussed with fjob titl€ o{ prrson preparingi howthey are comfortable each schedule is complete andaccurate.

3. Obtained the review and approval of the scheduleby In.-rnre of conlmittoe or Job ti!le of personrevi ewi n g; confirming that the transactions are inadhererrce whh the Member's polhies,

Vll) Monitoring of annualcompliance declarafpn submissionsby Senior Managers

1. Obtain evidence of monitoring ofcompleteness of annual submissions bySenior Manager,Etplanalion: ft is tlrn rcsponsibility of theMeflfu to d$rv ord identity the SeniorM a tnge rc oaos l{.r o rga nisotio n.2. lf the mechanism is not in place, rabe a

finding and obtain a list of Senior Managers.Explanotbn: k is tfu responsibifity ol theMen&rto d$ne and idantllythe SeniorMa m gerc acm ss tllc orga n isatio n.3. C-onfirm the list of Senior Managers ftom1. or 2. has at least one Senior Manageridentified for each 'Group Member'specifiedby the Member within the Mernber's GroupMembership (if applicable).4. Select a sample of 1O employees frorn list.5. For the selected samples obtain theannual signed management declaration.

1. Obtained Inrechanlsm of manitcricgconrpieieness r:{ annuat suhmission by S*nicrfulanager ; for the finarlcial accounting period ofiriatel to lriaret.2. T;as requiri:ti / \nJ:s not requ:red to obtain a list ofSenior Managers.3. Confirme{with ii}b tirtei the list of SeniorManagersfrbm Isperi{./ 1. cr 2.1 has at least oneSenior Manager identified for each Group Member'specified by the Member within the Member'sGroup Membership.4. Non-statistically selected [xx] employees from thelist.

5. Confirmed each Senior Manager selected in 4. hadsigned the annual manatement declaratbn for thefinancial accounting period ldatel to idarel.

Factual Findings: our findings with respect to the above procedures are as follovus:Please list any non-cornpliance / paftiai ccmpliance findrngs lrom the agreed upon procedures performed clr type 'NlA'

The agreed upon procedures that we have performed do not constitute an audit or a rwiew made in accordance withlnternational Standards on Auditing or lnternational Standards on Revie\rv Engagemenb and, consequenfly noassurance will be expressed on the adherence to lFlA / TIC Council's Comfliance Code. Had we performed additionalprocedures or had lre performed an audit or revie\ /, other matters might have come to our attention that would havebeen reported to you.

This report is intended solely for the information and use of Member and the Director General of the lFlA / TIC Council,and is not intended to be and should not be rsed by anyone other than these specified parties. This repoft relates onlyto the accounts and iGms specified above and does not extend to any consolidated financial statements of theMember, taken as a whole.

Name of External Audit FirmDate

frrr"aUV,\@ Approved by:

UanJgng Director

ffi

MITRA S. K....MSK/IFIA/CC/01 Mifta S.K. Private Limited REV. NO. 04 ISSUE NO. I REV. DATE 27tO8/2A19...

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Transcript of MITRA S. K....MSK/IFIA/CC/01 Mifta S.K. Private Limited REV. NO. 04 ISSUE NO. I REV. DATE 27tO8/2A19...