Gifts & Entertainment Policy

Policy Statement

The Company is committed to conducting its business with the highest standards of integrity, transparency, and fairness. This Gifts and Entertainment Policy establishes clear guidelines for offering and receiving gifts, entertainment, or hospitality to avoid any conflict of interest, bribery, or unethical behavior in the workplace.

Objectives

• Promote ethical business practices by preventing undue influence in decision-making.
• Provide clear guidance on acceptable and prohibited gifts, entertainment, and hospitality.
• Ensure compliance with applicable anti-bribery and anti-corruption laws, including the Prevention of Corruption Act and the Company's ABAC Policy.
• Protect employees and the Company from reputational and legal risks.

Scope and Applicability

This policy applies to all employees, directors, officers, contractors, consultants, vendors, and third parties acting on behalf of the Company It applies to both the giving and receiving of gifts, hospitality, and entertainment in the course of business activities.

Definition of Gifts and Entertainment

• Gift: Any item of value, service, favor, or benefit offered or received without payment, including but not limited to cash, vouchers, tickets, discounts, or merchandise.
• Entertainment: Meals, hospitality events, travel, or recreational activities offered as part of a business relationship.
• Facilitation Payment: Any small payment made to expedite routine government actions; such payments are strictly prohibited.

General Principles

• Gifts or entertainment must never influence, or appear to influence, business decisions.
• All gifts and entertainment must be reasonable, proportionate, and provided in good faith.
• Cash or cash-equivalent gifts (such as gift cards) are strictly prohibited.
• Employees must disclose and seek prior approval before accepting gifts above the approved monetary threshold.
• Gifts or hospitality must not create a conflict of interest or violate applicable laws or regulations.

Approval and Disclosure Requirements

Employees must seek written approval from their Department Head or the Compliance Department before offering or accepting any gift or entertainment exceeding the Company's monetary threshold (e.g., INR 5,000). All approved gifts and entertainment must be recorded in the Company's Gifts and Hospitality Register.

Prohibited Gifts and Activities

• Gifts or entertainment that could be perceived as a bribe or an attempt to gain favorable treatment.
• Gifts in the form of cash, vouchers, or other monetary equivalents.
• Lavish or extravagant hospitality or travel arrangements.
• Gifts or entertainment offered during bidding, contract negotiation, or approval processes.
• Any activity that violates the Company's ABAC Policy or local anti-corruption laws.

Acceptable Gifts and Entertainment

• Modest business meals, refreshments, or small promotional items bearing the Company logo.
• Gifts or hospitality given as a courtesy or token of appreciation on customary occasions (e.g., festivals).
• Attendance at industry conferences or business events, provided such attendance is reasonable and in the Company's interest.
• Gifts or entertainment approved and recorded in the Gifts and Hospitality Register.

Record Keeping and Transparency

All gifts, hospitality, and entertainment provided or received must be documented accurately in the Gifts and Hospitality Register. Records should include details such as the date, nature, value, purpose, and parties involved. The Compliance Department shall periodically review the register for accuracy and compliance.

Responsibilities

• Employees: Comply with this policy, seek approvals, and report any policy violations.
• Department Heads: Review and approve gift or entertainment requests as per guidelines.
• Compliance Officer: Maintain the Gifts and Hospitality Register, conduct reviews, and provide training.
• Vendors and Partners: Adhere to this policy when interacting with Company representatives.

Reporting and Violations

Employees must promptly report any suspected policy violations or inappropriate gift-related activities to the Compliance Department or through the Whistleblower Channel. Violations may result in disciplinary action, including termination, and may also attract legal consequences.

Policy Review

This policy shall be reviewed annually or as required by changes in regulatory or business environments. Updates shall be approved by the Board of Directors and communicated to all employees.

Employee Acknowledgment

I acknowledge that I have read and understood the Gifts and Entertainment Policy of the Company I agree to comply with the provisions and to conduct myself in a manner consistent with the Company's ethical and compliance standards.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________