Policy Overview

Company Name *

Effective Date *

Compliance Officer Name *

Compliance Officer Email

Compliance Officer Phone

Scope and Applicability

Scope of Policy *

Prohibited Acts *

Gifts and Entertainment

Gifts/Entertainment Threshold (INR) *

Policy on Gifts and Entertainment *

Business Hospitality Guidelines

Reporting and Whistleblowing

Reporting Mechanism *

Reporting Channels (detailed) *

Whistleblower Protection *

Investigation Process

Consequences and Review

Consequences of Violation *

Mandatory Training *

Policy Review Period *

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ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Effective Date: [Date]

Policy Owner: ()

PURPOSE AND COMMITMENT: is committed to conducting business with integrity and transparency in full compliance with all applicable anti-corruption and anti-bribery laws, including the Prevention of Corruption Act, 1988, and all applicable regulations.

SCOPE: This policy applies to: . All covered persons are expected to comply with this policy.

PROHIBITED CONDUCT: The following conduct is strictly prohibited:

BRIBERY: No employee shall, directly or indirectly, offer, promise, give, or authorize the giving of anything of value to any government official, customer, or third party to obtain any improper advantage or business benefit.

FACILITATION PAYMENTS: Facilitation or 'speed money' payments to government officials or others are strictly prohibited.

GIFTS, ENTERTAINMENT, AND HOSPITALITY: Gifts and entertainment offered to or received from customers, suppliers, or government officials must not exceed INR in value and must conform to the following guidelines:

BUSINESS HOSPITALITY:

RECORD-KEEPING: All transactions shall be accurately recorded in the company's books of accounts and shall be subject to audit and review.

REPORTING VIOLATIONS: Employees must report any suspected violations through the following channels:

WHISTLEBLOWER PROTECTION: No employee shall face retaliation for making a good faith report of suspected violations.

INVESTIGATION: All reports of suspected violations will be investigated promptly and confidentially.

CONSEQUENCES: Violations of this policy may result in:

TRAINING: All employees must undergo anti-corruption training at onboarding.

POLICY REVIEW: This policy will be reviewed and updated as necessary to reflect changes in law and organizational needs.