Anti-Bribery & Anti-Corruption (ABAC) Policy

Policy Statement

The Company is committed to maintaining the highest standards of integrity, transparency, and accountability in all business dealings. This Anti-Bribery & Anti-Corruption (ABAC) Policy establishes the framework for preventing, detecting, and addressing bribery, corruption, and unethical practices within the organization. The Company maintains a zero-tolerance approach toward any form of bribery or corrupt conduct, whether direct or indirect.

Objective

• Ensure compliance with applicable anti-bribery and anti-corruption laws and regulations.
• Promote ethical conduct and integrity in all business activities and relationships.
• Provide clear guidance to employees and stakeholders on identifying and preventing bribery.
• Protect the Company's reputation and maintain stakeholder trust.

Regulatory Framework

• Prevention of Corruption Act, 1988 (India).
• UK Bribery Act, 2010 (where applicable).
• U.S. Foreign Corrupt Practices Act (FCPA), 1977 (for international dealings).
• United Nations Convention Against Corruption (UNCAC).
• Any other applicable local or international anti-corruption laws.

Scope and Applicability

This policy applies to all employees, directors, officers, contractors, vendors, consultants, agents, and third parties acting on behalf of the Company It covers all business transactions, including government and private sector interactions, both domestic and international.

Prohibited Conduct

• Offering, giving, soliciting, or accepting bribes, facilitation payments, or kickbacks.
• Providing gifts, hospitality, or entertainment to influence a business decision.
• Making political or charitable contributions intended to gain improper advantage.
• Using third parties or intermediaries to channel or conceal corrupt payments.
• Manipulating records or accounts to disguise bribery or illegal payments.

Gifts, Hospitality, and Entertainment

The Company recognizes that reasonable and proportionate gifts and hospitality may form part of legitimate business relationships. However, employees must ensure such exchanges are not intended to improperly influence a business outcome or create a conflict of interest.

All gifts or hospitality exceeding the approved monetary threshold must be disclosed and approved by the Compliance Department.

Third-Party Interactions

Third parties such as vendors, consultants, and agents acting on behalf of the Company must adhere to the principles of this policy. Due diligence shall be conducted before engaging any third party to assess their integrity, background, and compliance standing.

Political and Charitable Contributions

The Company does not make political contributions to influence decision-making. Charitable donations are permitted only if they are transparent, lawful, and do not create a conflict of interest or seek undue advantage.

Reporting of Violations

Employees and stakeholders are encouraged to report any suspected bribery or corruption through the Whistleblower Channel or directly to the Compliance Officer. Reports shall be treated confidentially, and retaliation against whistleblowers is strictly prohibited.

Roles and Responsibilities

• Board of Directors: Ensure oversight and promote a culture of ethical compliance.
• Compliance Officer: Oversee policy implementation, conduct investigations, and maintain records.
• Department Heads: Ensure adherence to ABAC guidelines within their teams.
• Employees: Comply with the policy and promptly report any suspected violations.

Training and Awareness

Regular training programs shall be conducted to educate employees and third parties on anti-bribery principles, red-flag indicators, and reporting mechanisms. Participation in ABAC training is mandatory for all employees and relevant stakeholders.

Consequences of Non-Compliance

Violations of this policy may lead to disciplinary action, termination of employment or contracts, and legal prosecution under applicable anti-corruption laws. The Company may also report serious violations to law enforcement or regulatory bodies.

Policy Review

This policy shall be reviewed annually by the Compliance Department and approved by the Board of Directors. Revisions will be made as necessary to reflect changes in laws, regulations, or business practices.

Employee Acknowledgment

I acknowledge that I have read and understood the Anti-Bribery & Anti-Corruption (ABAC) Policy of the Company I agree to comply with the provisions of this policy and uphold the principles of integrity and ethical business conduct in all dealings.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________