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iTechWorks Technology Solutions Private Limited

Anti-Corruption Policy Statement

Why Do We Have This Statement?

This Statement confirms that iTechWorks is committed to doing business ethically and complying with all anti-corruption laws that may apply to the Company, including local anti-corruption laws. No one — neither iTechWorks employees nor others acting on iTechWorks’s behalf — is permitted to offer, make, promise, request, or accept a bribe, or to otherwise make any improper payment in connection with iTechWorks’s business.

Scope of Statement

This Statement applies to all iTechWorks Directors, officers, and employees worldwide as well as all iTechWorks business units and subsidiaries, joint ventures over which iTechWorks has operational control, and business partners (collectively “Associates”).

If local law or a business unit imposes stricter requirements than those described in this Statement, Associates must comply with those rules.

Requirements

Prohibition Against Bribery & Corruption Generally

iTechWorks’s rule about corruption is simple: we never pay bribes or act corruptly.

  • A bribe is any payment or Anything of Value offered or provided to improperly influence a decision-maker or to obtain an unfair business advantage.
  • An act is corrupt if it is performed to secure an improper advantage, either by paying a bribe or through other means (for example, by paying a kickback or a payoff, or by laundering money).
  • Anything of Value includes items such as cash, bonuses, gifts, favors, charitable donations, political contributions, offers of employment, offers of hospitality/entertainment, kickbacks, or any other type of preferential benefit.
  • This Policy prohibits bribery of Government Officials and private persons, or making payments to relatives, friends, or colleagues of a private person or of a Government Official to obtain an unfair business advantage. This includes the hiring of relatives of a Government Official for the purpose of influencing the official’s decision making.

Dealings with Government Officials

All iTechWorks Associates, no matter where they are located, must pay close attention to interactions with Government Entities and Officials.

A Government Entity refers to any:

  • Government or government division;
  • Department, agency, or instrumentality of such a government or organization;
  • Political party;
  • Company or entity owned or controlled (partially or wholly) by or acting on behalf of any of the above.

Examples of Government Entities include, but are not limited to: governments of countries, states, provinces or cities; the United Nations; the International Monetary Fund; a customs or patent office; and state-owned businesses, banks, hospitals, utilities, and universities.

A Government Official is any individual acting in an official capacity for or on behalf of a Government Entity. Examples include, but are not limited to: a customs official; an inspector from a tax, health, or environmental agency; an employee of a state-owned bank; a journalist employed by a state-owned media company; the Chief Technology Officer of a government agency or ministry; a legislator such as a Technology Subcommittee Chairperson of a House of Parliament; a businessperson who is a consultant acting for and on behalf of such Government entity; and a professor or researcher at a state-owned university.

Facilitation Payments

A facilitation payment is generally a small payment made to a low-level Government Official for the purpose of securing or expediting the performance of a routine, nondiscretionary government action. iTechWorks does not permit facilitation payments absent prior approval in exceptional cases from the Chief Legal Officer/General Counsel/ Authorised Personnel.

Gifts and Entertainment for Government Officials

Please be aware that iTechWorks prohibits providing gifts to Government Officials.

Any entertainment of a Government Official, if required, would require prior approval from the concerned authorised personnel of the company.

Political and Charitable Contributions

Political contributions made by or on behalf of the Company are not permitted unless approved in advance from the concerned authorised personnel. If you plan on engaging in any political activities on behalf of the Company or making a political contribution on behalf of the Company, you must contact the Legal Department prior to taking any action.

A charitable contribution is any payment or other support given to a charitable organization or to an entity organized to provide a public benefit. iTechWorks only works with charities that have been vetted to ensure that they are legitimate, reputable and will not be used as a conduit for an improper payment.

All of iTechWorks’s charitable contributions must be:

  • Reasonable in nature and amount;
  • Permissible under all applicable laws and regulations;
  • Provided in a manner that would not embarrass iTechWorks if publicly disclosed;
  • Given openly with no appearance of an improper purpose;
  • Given without expecting anything in return;
  • Accurately recorded in iTechWorks’s books and records.

Third Parties

All third parties with whom iTechWorks works must comply with the Code, including its prohibitions on bribery and corruption. Retention of certain third parties can expose iTechWorks to corruption risks, particularly when those third parties are likely to interact with Government Entities or Officials on iTechWorks’s behalf. Examples include: accountants, customs brokers, real estate vendors, logistics providers, visa processors, customs brokers, lawyers, lobbyists, and public relations representatives. iTechWorks has developed a reasonable, risk-based due diligence program for third parties that iTechWorks proposes to enter into a relationship with. Please see iTechWorks’s Anti-Corruption Compliance Procedures for the Selection & Retention of Third Parties.

Joint Venture Transactions, Mergers, Acquisitions & New Market Entry

iTechWorks sometimes expands its business by launching new products, competing for new business, or entering a new geographic market. iTechWorks may conduct these activities through joint ventures, mergers, acquisitions, or new market entries. Joint ventures, mergers, acquisitions, and new market entries can present corruption risks. Before entering into a joint venture, initiating a merger or acquisition, or entering a new market, Associates must contact the Legal Department, who will provide guidance about how to address anti-corruption aspects of the proposed transaction, including conducting any required due diligence or drafting relevant contractual language.

Books, Records & Internal Controls

iTechWorks is required to maintain records that accurately reflect its business transactions. Associates who conduct business on iTechWorks’s behalf must ensure that all transactions (no matter how small) are recorded promptly and accurately, contain sufficient detail, and are supported by accessible documentation. Never misconstrue or mislabel a transaction in our books and records.

Violations A violation of anti-corruption laws, the Code, this Statement, or its related procedures is a serious matter and can result in criminal or civil penalties against iTechWorks and the individual involved in the violation, as well as harm to iTechWorks’s reputation. Associates involved in a violation will be subject to appropriate discipline, up to and including termination. Any violation of law, the Code, or this Statement may result in a loss of incentive compensation, bonuses, or other awards, to the extent permitted by law.

Mandatory Reporting of Violations & Guidance on Compliance

Associates have a responsibility to report suspected violations of this Statement, the Code, or of any applicable law. iTechWorks is committed to ensuring that an individual does not face retaliation for reporting such concerns. To report concerns or ask questions Associates may contact:

Any member of the iTechWorks Legal Department

By email: Contact Us Portal at https://inettechworks.com

By mail: Address specified at https://inettechworks.com

Our iTechWorks Helpline

Reports of violations or concerns may be made anonymously, where local laws allow. However, you are encouraged to identify yourself when making a report, so that additional information can be obtained if needed. Whenever possible and permitted by law, your identity will be kept strictly confidential.

To access the Helpline via the internet, go to the Contact Us Portal at https://inettechworks.com and follow the instructions for submitting a report.

To make a report by telephone, please use the listed contact number at https://inettechworks.com

Use the appropriate access code for your country.

Who Should I Contact with Questions?

Questions regarding this Statement should be directed to the concerned personnel or your local authorized resource.

Effective date: September 2018