Ethics & Compliance
QCG is committed to high standards of professional and ethical conduct. Below you will find our policies, reporting channels, and the governance framework we follow. If you have concerns or proposals, contact legal@quarkconsultant.com.
Principles that guide professional behaviour, client interactions and internal conduct.
Scope: Applies to all QCG directors, employees, contractors and consultants engaged on QCG matters.
Key expectations: honesty, integrity, client confidentiality, professional competence, non-discrimination and anti-retaliation. Employees must treat conflicts of interest, gifts and outside activities transparently.
Practical steps: Report any suspected breaches to compliance@qcg-global.com. QCG will investigate and apply proportionate disciplinary measures where breaches are substantiated.
Zero tolerance for bribery, facilitation payments or improper advantages in any jurisdiction.
QCG maintains a policy of zero tolerance towards bribery and corruption. This applies to direct and indirect payments, gifts, facilitation of government approvals, procurement, and partner relationships.
Requirements: Any gift, hospitality or business courtesy must be recorded and approved in accordance with the Gifts & Hospitality guidance. Third-party vendor due diligence is required for high-risk suppliers.
Actions: Suspected bribery must be reported immediately to compliance@qcg-global.com or via the whistleblower channel. QCG will cooperate with lawful investigations by competent authorities.
Identification, disclosure and management of personal and firm-level conflicts.
Policy: All potential conflicts must be disclosed promptly to the Compliance Officer. Conflicts include financial interests, board roles, family relationships with clients, or concurrent advisory roles.
Management: Where conflicts exist, QCG will either decline the engagement, implement safeguards (Chinese walls, restricted access) or obtain informed consent from the affected parties.
Mechanisms to report concerns safely, with protections against retaliation.
How to report: You may report concerns to compliance@qcg-global.com. QCG is designing an anonymous reporting mechanism and will share details once operational. If you prefer, use the following indicative address: whistleblower@qcg-global.com (check our published procedure before using).
Scope: Reports may include fraud, bribery, gross negligence, harassment, discrimination or serious ethical breaches.
Protection: QCG prohibits retaliation against good-faith reporters. All reports will be treated as confidential to the extent reasonably possible and investigated by designated staff or an independent investigator.
How QCG handles personal data (clients, employees, partners).
QCG treats personal data with care. Processing is limited to stated purposes (service delivery, legal obligations, HR), secured with role-based access controls, and retained only as necessary. Our full Privacy Policy is provided in the Legal & Policy section.
If you have a data request or concern, contact privacy@qcg-global.com.
Rules for acceptance, approval and recording of gifts and hospitality.
Nominal gifts of modest value may be accepted if lawful and not intended to influence business decisions. Anything above a modest threshold must be pre-approved and recorded centrally. Sponsorships and charitable donations require senior approval and due diligence.
Planned training for staff and monitoring of compliance effectiveness.
QCG plans regular training on ethics, anti-bribery, data protection and conflicts for employees and partners. Monitoring will include periodic reviews, compliance checklists and executive oversight. Where necessary, QCG will engage external auditors to review policy implementation.
Fair, timely investigations and proportionate disciplinary measures.
All reports will be triaged and investigated by appointed investigators. Investigations will respect confidentiality and provide the subject with an opportunity to respond. Sanctions may range from retraining to termination depending on severity and facts.
Retention periods for compliance records and audit logs.
Compliance records, investigations and training logs are retained in accordance with applicable law and internal retention schedules. Audit trails are maintained for key approvals, disclosures and vendor due diligence.
QCG appoints a senior Compliance Officer responsible for policy maintenance, triage of reports and coordination of training. Significant issues are reported to senior leadership and the Board (or designated oversight committee) for review and appropriate action.
QCG intends to engage independent reviewers for material compliance programs when appropriate. Statements about independent assurance or audit will be published only where such engagement has occurred.
Email legal@quarkconsultant.com or use the whistleblower address whistleblower@quarkconsultant.com (check policy for anonymity options).
Legal jurisdiction for disputes concerning employment or compliance processes: courts of Delhi, India. QCG will handle personal data in compliance with its published Privacy Policy and applicable Indian law.Q: Will whistleblowers be anonymous?
A: QCG intends to support anonymous reporting where technically feasible while balancing the need for a fair investigation. Specific procedures will be published in the Whistleblower Procedure document.
Q: Who reviews conflicts?
A: The Compliance Officer reviews disclosures and recommends safeguards or recusals; material conflicts are escalated to senior leadership.
Q: How are vendors screened?
A: High-risk vendors require due diligence checks; the Compliance Officer maintains vendor risk criteria and documentation.
