Code of Ethics &
Speak-Up Policy
Standards of integrity, client care and responsible conduct for Vestigo Insurance Brokers Pvt. Ltd.
Corporate Identity
CIN: U66220GJ2025PTC166605
Vestigo Insurance Brokers Pvt. Ltd.
Registered Office
SF 201, Status Complex, Opp. Amrapali Complex, Pani Tanki Road, Karelibaug, Vadodara - 390018, Gujarat, India
Ethics & Speak-Up Desk
enquiry@vestigoinsurance.com
www.vestigoinsurance.com
01. Purpose and Commitment
Insurance is built on trust, utmost good faith and responsible advice. Vestigo is committed to conducting business ethically, professionally and in the best interests of clients, while respecting insurers, regulators, employees, partners and the wider community. This Policy states the standards expected of Vestigo’s directors, employees, trainees, consultants, authorised representatives and business partners.
02. Core Ethical Principles
03. Responsible Insurance Advice and Distribution
Vestigo prohibits mis-selling and misleading conduct. No person acting for Vestigo may:
Where information is uncertain or incomplete, the limitation must be disclosed and reasonable steps taken to verify it. Policy documents issued by the insurer govern the contract of insurance.
04. Conflicts of Interest
Actual, potential or perceived conflicts must be disclosed promptly and managed fairly. Personnel must not use a Vestigo opportunity, client relationship, insurer relationship, confidential information or position for undisclosed personal benefit. Outside employment, financial interests, family relationships, referral arrangements and gifts that could influence or appear to influence judgment must be declared through the applicable internal process.
05. Gifts, Hospitality, Bribery & Improper Advantages
Vestigo has zero tolerance for bribery, facilitation payments, kickbacks, secret commissions and improper advantages. Cash and cash-equivalent gifts must not be offered or accepted. Modest and lawful hospitality or customary gifts may be accepted only where they are reasonable, infrequent, transparent, do not influence a decision and comply with internal approval requirements. Any demand or suspicion of bribery must be reported immediately.
06. Confidentiality, Data and Information Security
Confidential information may be accessed and used only for authorised duties. It must not be disclosed to family, friends, competitors, unauthorised colleagues or external persons. Personal email, unapproved messaging, personal cloud storage, removable media or unauthorised software must not be used for confidential information where prohibited. Suspected loss, leakage, phishing, credential compromise or unauthorised access must be reported immediately.
07. Accurate Records & Regulatory Cooperation
Business, financial, policy, claim, client, attendance, expense and compliance records must be accurate, complete, timely and capable of audit. No person may create a false record, backdate a document improperly, delete material evidence, conceal an error or obstruct an audit, inspection or investigation. Vestigo will cooperate lawfully and transparently with IRDAI, insurers, authorities, auditors and other competent bodies.
08. Fair Competition and External Communications
Vestigo competes on service, knowledge, innovation and trust. Personnel must not obtain competitor information unlawfully, make defamatory statements, misuse confidential market information or enter anti-competitive arrangements. Public statements, advertisements, website content, social-media posts and media interactions concerning Vestigo or client matters must be accurate, authorised and compliant with confidentiality and regulatory requirements.
09. Respectful Workplace and Professional Behaviour
Vestigo expects a workplace free from harassment, bullying, threats, discrimination, retaliation, substance misuse and violence. Professional disagreements must be addressed respectfully. Managers have a heightened duty to prevent misuse of authority, protect persons who raise concerns in good faith and act consistently.
10. Speak-Up and Reporting Concerns
A person may report suspected fraud, bribery, regulatory breach, mis-selling, conflict, data misuse, harassment, financial irregularity, document falsification, retaliation or other unethical conduct to enquiry@vestigoinsurance.com with the subject “Confidential Ethics Concern”. Reports should provide facts, dates, persons involved and available supporting material. Anonymous reports may be considered where sufficient information is provided, although anonymity may limit investigation or feedback.
11. Confidentiality and Protection Against Retaliation
Vestigo will handle a good-faith report as confidentially as reasonably possible, consistent with a fair investigation, legal obligations and the rights of persons involved. Retaliation against a person who raises a genuine concern, seeks guidance, preserves evidence or assists an investigation is prohibited. A deliberately false or malicious allegation, evidence fabrication or obstruction may itself result in action.
12. Investigation and Consequences
Concerns will be assessed objectively and may be investigated internally or with professional advisers. Persons involved are expected to cooperate and preserve relevant evidence. Findings may lead to corrective action, training, control improvement, disciplinary action, termination of employment or contract, recovery of loss, insurer or regulatory notification, or referral to law-enforcement. Action will be proportionate to the evidence and applicable law.
13. Guidance and External Rights
A person who is uncertain about an ethical issue should seek guidance before acting. This Policy does not prevent any person from approaching IRDAI, a lawful authority, ombudsman, court, tribunal or law-enforcement agency or from exercising a protected legal right. It does not create a contractual guarantee of any particular outcome or override applicable law or employment terms.
14. Policy Review
Vestigo may revise this Policy to reflect legal, regulatory, governance or operational changes. The current website version will state its effective or last-updated date.
Report an Ethical Concern
If you observe mis-selling, bribery, document falsification, conflict of interest, or unethical conduct, report it confidentially to our designated ethics team.
• Include "Confidential Ethics Concern" in the email subject line.
• State facts, dates, individuals involved, and attach available documentation.
• Protected against retaliation under our zero-tolerance Speak-Up Policy.