Definitions

“FCPA” means U.S. Department of Justice’s Foreign Corrupt Practices Act

“Human Rights” means universal rights of every person to be treated with dignity and equality, in particular with regards to freedom of speech, privacy, health, life, liberty, security, and an adequate standard of living.

“NCT” means NeuroCog Trials

“NCTL” means NCT Linguistics

“NCT Holdings, Inc.” is the parent company of NCT and NCTL

“NCT Senior Management” means NCT President, CEO, COO, Senior Directors, Directors, and Managers

“NCT Staff” includes regular employees, contractors, and interns

“PO” means policy

References

United Nations Global Compact

www.unglobalcompact.org

United Nations Universal Declaration of Human Rights (and subsequent iterations) –

http://www.ohchr.org/EN/UDHR/Documents/UDHR_Translations/eng.pdf

International Covenant on Economic, Social and Cultural Rights

http://www.ohchr.org/EN/ProfessionalInterest/Pages/CESCR.aspx

International Covenant on Civil and Political Rights

http://www.ohchr.org/en/professionalinterest/pages/ccpr.aspx

OECD Guidelines for Multinational Entreprises

http://www.oecd.org/daf/inv/mne/48004323.pdf

The Basic Labor Standards as defined by the International Labor Organization

http://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang–en/index.htm

U.S. Department of Justice, Foreign Corrupt Practices Act

https://www.justice.gov/criminal-fraud/foreign-corrupt-practices-act

UK Bribery Act

http://www.legislation.gov.uk/ukpga/2010/23/contents

 

Policy

NCT HOLDINGS, INC. HUMAN RIGHTS COMMITMENT

NCT is committed to every individual’s basic human right to dignity, equality, and respect, both within our own work environment as well as for individuals impacted by our extended business dealings globally. Endeavoring to foster a corporate philosophy of shared values for all employees, NCT believes in creating a receptive workplace environment which bolsters inclusive, free discussion and enables merit-based opportunity in order to promote growth. As part of our philosophy, NCT subscribes to the principles of the United Nations Global Compact, the United Nations Universal Declaration of Human Rights (and subsequent iterations), the International Covenant on Economic, Social and Cultural Rights, the International Covenant on Civil and Political Rights, the OECD Guidelines for Multinational Entreprises, and the Basic Labor Standards defined by the International Labor Organization.

Every NCT staff member, in all aspects of business operations, will responsibly uphold the following principles to ensure these rigorous standards are met:

  • NCT condemns forced labor – NCT will only employ individuals of legal working age for a given country and we denounce exploited child labor, human trafficking, and slavery of any kind.
  • NCT respects lawful freedom of association – NCT recognizes the right of all persons to participate in collective bargaining for the promotion or defence of their occupational interests.
  • NCT will provide fair compensation – For any contracted work to be done on behalf of the company, NCT will ensure a reasonable living wage is provided, basic needs are able to be met, and a safe, healthy working environment is offered to all staff members.
  • NCT does not discriminate – No form of discrimination on the basis of race, gender, age, or any other legally protected characteristic will be tolerated.

NCT will not be complicit in any human rights abuses and commits to swiftly address any potential non-compliance with these basic principles which we discover within our business activities.

ANTI-CORRUPTION & ANTI-BRIBERY

NCT operates globally with a focus on ethics and integrity, setting the expectation that all of its business operations shall be performed in good faith. As such, we comply with all relevant anti-corruption and anti-bribery laws, including but not limited to the U.S. FCPA and the U.K. Bribery Act, in all countries where NCT or any of our contracted third parties operate on our behalf. Specifically, NCT will not tolerate the following behavior from any of its employees or third parties:

  • Improper payments or offers of value given, offered, or promised to anyone (not only to government officials), directly or indirectly, as inducement or reward, in particular for the purpose of securing undue favor or advantage in business dealings or to obtain/retain business; nor will any NCT employee or anyone on behalf of the company accept improper payment of like kind, directly or indirectly.
  • Knowing inaccurate or misleading maintenance of books, records, and accounts of completed business transactions

NCT Senior Management should be notified immediately of any indication of potential violation, on the part of NCT or a contracted third party, of this policy.

COMPLIANCE AND MONITORING OF THIRD PARTIES

NCT demands ethical and transparent behavior in every area of its business practices and requires the same of any party with which it conducts business. NCT takes a precautionary approach in carefully evaluating third parties with which it has working agreements to determine risk, as well as towards compliance with any applicable laws or regulations for the country of location. Third parties under contract with NCT shall be obligated to adhere to NCT’s ethics policies and guidelines, with any appropriate training to be provided or made available by NCT.

An environment of trust and openness is considered essential to allow for continual improvement of all NCT working relationships. NCT will ensure that all commitments made by the company under agreement are met, and insists on the same in return from contracted third parties. Open monitoring of third parties by NCT will occur to ensure adherence and to highlight potential areas of improvement. Any concern regarding non-compliance will be addressed promptly and collaboratively by NCT. However, any ongoing or egregious performance or compliance concerns will likely result in termination of continued association.

 

Version 1, Dated 22 Nov 2016