CODE OF CONDUCT
CODE OF CONDUCT
URL: vincoconsult.com/code-of-conduct
Last updated: May 2026
1. Purpose
This Code of Conduct (the “Code”) sets out the standards of behaviour that Vinco Consultancy & Advisory Services (“Vinco”) expects of itself and of every person who acts on its behalf. The Code reflects our values, the trust our clients and learners place in us, and our obligations under applicable Indian law.
2. Scope and Application
This Code applies to all Vinco personnel — founders, directors, employees, associates, trainers, contractors, interns, and volunteers — in every interaction conducted on behalf of Vinco, whether in person, online, in writing, or through any other medium. Suppliers, partners, and service providers are expected to act consistently with the principles of this Code in their dealings with Vinco. This Code supplements, and does not replace, applicable laws, contractual obligations, and other Vinco policies. Where any conflict arises, the more stringent requirement prevails.
3. Our Core Values
Our work is grounded in five values:
- Integrity — We do what we say we will do, we tell the truth, and we earn trust over time.
- Professional excellence — We bring rigour, preparation, and care to every engagement.
- Respect — We treat clients, learners, colleagues, and partners with dignity and consideration.
- Accountability — We own our outcomes, including our mistakes, and we work transparently to put things right.
- Service — We measure our success by the success of the people and organisations we work with.
4. Compliance with Laws and Regulations
All Vinco personnel must comply with the laws and regulations of India and of any other jurisdiction in which we operate. Where a law is unclear or where this Code sets a higher standard than the law, the higher standard applies. Any concerns about the legality of a proposed action must be raised before the action is taken.
5. Honesty and Professional Integrity
We commit to honest dealings in every aspect of our work:
- We do not misrepresent our qualifications, experience, capacity, or credentials.
- We do not misrepresent the credentials, accreditations, or outcomes associated with our training programmes or certificates.
- We are honest about the limits of our expertise and refer matters outside our competence to appropriate specialists.
- We give clients candid advice, even where it is not what they wish to hear.
- We do not falsify records, deliverables, or certificates.
6. Conflicts of Interest
A conflict of interest exists where personal interests, relationships, or activities could improperly influence — or appear to improperly influence — our professional judgement on behalf of Vinco or a client. Examples include outside employment that competes with Vinco, financial interests in a client or supplier, close personal relationships within reporting lines, and gifts or hospitality that could affect impartiality. All Vinco personnel must:
- Avoid actual, potential, and perceived conflicts of interest where possible.
- Disclose any actual, potential, or perceived conflict promptly to the Founder & Chief Executive.
- Recuse themselves from decisions in which they have a conflict, and follow any mitigation steps agreed in writing.
7. Confidentiality and Client Information
Confidential information — including client business information, learner information, financial data, strategy materials, and personal data — must be handled with care:
- Use confidential information only for the purpose for which it was provided.
- Do not disclose confidential information to anyone, inside or outside Vinco, who does not need it.
- Do not discuss confidential matters in public spaces, on personal devices, or on insecure channels.
- Continue to respect confidentiality after engagement with Vinco ends.
- Comply with the Privacy Policy and the Digital Personal Data Protection Act, 2023, when handling personal data.
8. Anti-Bribery and Anti-Corruption
Vinco does not tolerate bribery or corruption in any form, whether in the public or private sector. All Vinco personnel must comply with the Prevention of Corruption Act, 1988, and any other applicable anti-bribery laws.
- Do not offer, promise, give, request, or accept any bribe, kickback, or other improper advantage — directly or indirectly — to or from any person.
- Do not make facilitation payments to expedite routine government action.
- Do not use third parties (agents, consultants, or partners) to do anything that personnel are themselves prohibited from doing.
- Keep accurate records of all payments and ensure they are properly accounted for in our books.
9. Gifts and Hospitality
Modest, occasional, and customary business courtesies are acceptable. Gifts and hospitality must never:
- Influence, or appear to influence, a business decision.
- Be offered or accepted in cash or cash equivalents.
- Be offered to or received from a government official, except in circumstances expressly permitted by law.
- Exceed values or frequencies that would be unusual in a professional relationship of that kind.
Personnel who are unsure whether a gift or hospitality is appropriate should consult the Founder & Chief Executive before offering or accepting it.
10. Anti-Money Laundering and Sanctions
Vinco does business only with clients, partners, and suppliers whose activities are lawful and whose funds are derived from legitimate sources. Personnel must be alert to red flags suggesting money laundering, sanctions evasion, or terrorist financing, and must escalate any concerns promptly. We comply with applicable laws governing financial integrity, including the Prevention of Money Laundering Act, 2002.
11. Fair Competition and Fair Dealing
We compete on the merits — the quality of our work, our team, and our reputation. We:
- Do not enter into agreements with competitors to fix prices, allocate clients or markets, or rig bids.
- Do not obtain confidential information about competitors through improper means.
- Do not make false or misleading statements about competitors.
- Comply with the Competition Act, 2002, and other applicable competition laws.
12. Equal Opportunity and Non-Discrimination
Vinco is committed to providing equal opportunity in recruitment, training, compensation, advancement, and termination. We do not tolerate discrimination on the basis of gender, religion, caste, ethnicity, nationality, age, disability, marital status, sexual orientation, gender identity, or any other characteristic protected under applicable law.
13. Anti-Harassment and Respectful Workplace
Every person engaged with Vinco — whether employee, associate, contractor, learner, or visitor — has the right to a workplace free from harassment, intimidation, and bullying. We comply fully with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“PoSH Act”). Our PoSH framework includes:
- A constituted Internal Committee (IC) to receive and inquire into complaints of sexual harassment, in line with the requirements of the PoSH Act and Rules.
- Awareness sessions for all personnel on identifying, preventing, and reporting sexual harassment.
- Confidential complaint handling, time-bound inquiry, and protection against retaliation.
- Annual reporting to the appropriate authority as required by the PoSH Act.
Harassment of any kind — sexual or otherwise — is prohibited and will be treated as a serious breach of this Code.
14. Health, Safety, and Wellbeing
We are committed to the physical and mental wellbeing of our personnel and of those who attend our training and events. We comply with applicable workplace safety laws, take reasonable steps to identify and mitigate risks at our offices and event venues, and encourage personnel to raise safety concerns without fear of retaliation.
15. Data Protection and Privacy
All personnel must handle personal data in accordance with the Vinco Privacy Policy and the Digital Personal Data Protection Act, 2023. This includes:
- Collecting and using personal data only for legitimate, notified purposes.
- Limiting access to personal data on a need-to-know basis.
- Reporting suspected personal data breaches immediately to the Grievance Officer.
- Cooperating with rights requests from Data Principals.
16. Use of Vinco Assets and Resources
Vinco assets — including laptops, software licences, email accounts, data, intellectual property, and brand — must be used for legitimate Vinco business. Personnel must:
- Protect Vinco assets from loss, theft, damage, and misuse.
- Not use Vinco assets for personal gain or for any unlawful purpose.
- Use only properly licensed software and authorised services.
- Return all Vinco assets, including confidential information, on the end of engagement.
17. Intellectual Property
Personnel must respect the intellectual property of Vinco, of clients, and of third parties. Specifically:
- Work product created during a Vinco engagement belongs to Vinco or to the client, as governed by the relevant agreement.
- Do not use copyrighted materials, trademarks, software, or images without proper licence or permission.
- Do not bring confidential information or intellectual property from a previous employer or engagement into Vinco’s work.
18. External Communications, Media, and Social Media
Public statements made on behalf of Vinco — whether to media, regulators, clients, or the public — must be authorised by the Founder & Chief Executive or a designated spokesperson. In personal use of social media, personnel must:
- Make clear when they are speaking personally rather than on behalf of Vinco.
- Not disclose confidential information about Vinco, clients, or learners.
- Not post content that is defamatory, harassing, discriminatory, or otherwise inconsistent with this Code.
- Apply the same standards of professionalism online as they would in person.
19. Reporting Concerns and Whistleblower Protection
19.1 How to Raise a Concern
Any person — employee, associate, client, learner, supplier, or member of the public — who suspects a breach of this Code, of applicable law, or of Vinco’s policies may report the concern through any of the following channels:
- Email to the Founder & Chief Executive at Lakshman@vincoconsult.com.
- In writing, marked “Confidential”, to the Vinco office at Gurugram, Haryana, India.
- For sexual-harassment complaints, directly to the Internal Committee constituted under the PoSH Act.
Reports may be made openly or anonymously. Where the reporter’s identity is known, it will be treated as confidential and disclosed only on a need-to-know basis or where required by law.
19.2 Investigation
Reports will be assessed promptly, fairly, and proportionately. Where appropriate, an inquiry will be conducted by an individual or committee free from conflict of interest. The reporter and any affected person will, where possible, be kept informed of the outcome.
19.3 No Retaliation
Vinco will not tolerate retaliation — including dismissal, demotion, exclusion, harassment, or any other adverse action — against any person who, in good faith, raises a concern, participates in an inquiry, or refuses to participate in conduct they reasonably believe breaches this Code. Acts of retaliation are themselves a serious breach of this Code.
20. Consequences of Breach
Breaches of this Code may result in disciplinary action, up to and including termination of employment or engagement, in accordance with applicable law and contractual terms. Where a breach involves unlawful conduct, Vinco may also report the matter to the appropriate authorities and may pursue civil or criminal remedies.
21. Decision-Making Test
When a course of action is unclear, personnel are encouraged to ask:
- Is it lawful?
- Is it consistent with this Code and Vinco’s values?
- Would I be comfortable if the action were known to my colleagues, our clients, the regulator, and my family?
- Could it harm Vinco’s reputation, our clients, our learners, or any third party?
If the answer to any of the first three questions is “no,” or to the fourth is “yes,” the action should not be taken without first consulting the Founder & Chief Executive.
22. Acknowledgement, Training, and Review
All Vinco personnel are expected to read, understand, and acknowledge this Code at the commencement of their engagement and at least once a year thereafter. Vinco will provide periodic awareness sessions on the Code, including the PoSH framework and data-protection responsibilities. The Code will be reviewed at least annually and updated as required to reflect changes in law, in our practices, or in our business.
23. Governance
This Code is approved by the Founder & Chief Executive of Vinco, who is ultimately accountable for its implementation, oversight, and review. Day-to-day responsibility for the Code is shared across the leadership team.
24. Contact
Questions or concerns about this Code may be directed to:
| General Enquiries | vinco@vincoconsult.com |
| Training Enquiries | vinco@vincoconsult.com |
| Career Enquiries | vinco@vincoconsult.com |
| Grievance Officer | Lakshman@vincoconsult.com |
| Phone / WhatsApp (India) | +91 99711 70920 |
| Phone / WhatsApp (Nepal) | +977 97659 28158 |
| Office | Gurugram, Haryana, India |
| Office Hours | Monday – Friday, 09:30 – 18:30 IST |
