1. Purpose, Scope, and Responsibility

  1. This Anti-Bribery and Corruption Policy (“Policy”) establishes principles that must govern the conduct of the employees in order to: a) ensure that no employee of WebTiga (“Company”) indulges in and associate with any act of bribery, extortion or corruption with any government officials or any person for or on behalf of the Company; b) conform to the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and similar anti-corruption laws worldwide; and c) more broadly, reinforce our intention and obligation to act honestly and ethically in all of our business dealings.
  2. This Anti-Bribery and Corruption Policy is based on the law of Prevention of Corruption Act, 1988 of India and other similar applicable Anti Bribery and anti-corruption Laws of India and the World.
  3. The Director and General Counsel of the Company shall be the authorized authority for the purpose of this Policy.

2. Applicability

  1. This Policy shall be applicable to all officers, directors, managers, employees (“Employees”) of the Company (including employees temporarily transferred to affiliates and vendors), agents, representatives, and joint-venture partners, or anyone else doing business in the name of or
    with the Company, including the suppliers, contractors, or subcontractors (collectively referred
    to herein as “Covered Parties”).
  2. The Company has a zero-tolerance approach to acts of bribery and corruption, by Employees or anyone acting on behalf of the Company. Any breach of this Policy will be regarded as a serious matter by the Company of which is likely to result in disciplinary action.

3. Policy Statement

  1. Bribery and corruption are not only against our Company values; they are illegal and can expose both the employee and the Company to fines and penalties, including imprisonment and reputational damage.
  2. At WebTiga, bribery is never permitted. We will not seek to influence others, either directly or indirectly, by offering, paying or receiving bribes or kickbacks, or by any other means that is considered unethical, illegal or harmful to our reputation for honesty and integrity. Employees
    and Covered Parties of the Company are expected to decline any opportunity which would place our ethical principles and reputation at risk. While certain laws apply only to bribes to government officials (domestic and foreign); this Policy applies to non-government business
    partners as well.
  3. What is Bribery? Bribery is offering, giving or receiving anything of value with the intention of inducing a person to act or to reward a person for having acted. It is important to understand that a corrupt act has occurred even if:
    1. A bribe does not succeed.
    2. A person authorizes or provides direction for a bribe, but no bribe is ultimately offered or paid.                                                            “Anything of value” includes, but is not limited to:
      1. Cash, cash equivalents (such as gift certificates/cards), stock, personal property and
        assumption or forgiveness of a debt.
      2. Gifts, meals, entertainment and travel—Any corporate travel, gifts, entertainment and meals
        must be proportionate to the occasion and comply with the gift & entertainment
        policy/standards applicable to your location.
      3. Political contributions.
      4. Charitable contributions—if made to a charity at the direct request of a government official or
        private business partner, it could be considered an indirect bribe made in order to obtain or
        retain business or to secure other improper business advantage.
      5. Job offers or internship awards—offers to Government Officials (or their relatives) can present
        a risk of violating anti-bribery or anticorruption laws and regulations. Compliance must be
        consulted prior to making such offers.
  4. Corruption is dishonest or fraudulent conduct by those in power, typically involving bribery.

4. Prohibited Activities

  1. The Employees or the Covered Parties shall not offer and/or provide any pecuniary or other benefits to any Government Officials or Third party either directly or indirectly (i.e. through a third party). Furthermore, if there is a possibility that any activity could give rise to a misunderstanding
    that the Company has conducted the said activity with the intention of gaining an improper business advantage (irrespective of its genuine intention), the employee or the Covered parties should not conduct such activity in such situation.
  2. The Employees or the Covered Parties shall not offer any cash (including, but not limited to, bills/notes, Cheques, every kind of cash voucher, stock certificates and securities;
  3. The Employees or the Covered Parties shall not offer entertainment at hostess, strip or similar adult entertainment clubs; and
  4. The Employees or the Covered Parties shall not offer any business meal or gift if the expense is not properly recorded for in the appropriate accounting books and not as per the Code of Conduct Policy of the Company.

5. Third Parties

  1. Company cannot avoid liability by using a third party to give or receive a bribe. A third party shall include, but not be limited to consultants, agents, representatives, subcontractors and subadvisors. 
  2. Any third parties representing the Company shall during the term of this Agreement be bound by and shall at all times comply with Company’s Anti Bribery and Corruption Policy. In some jurisdictions, the Company may be convicted of a criminal offense if it fails to prevent bribery carried out on its behalf by a third party even if no one in the Company had actual knowledge of the bribe. Under any circumstances where the third party carrying out such bribery or corruption activity for or on behalf of the Company, such third party shall be liable.
  3. Whenever the Company seeks to engage a third party in which the third party may interact with a Government Official for or on behalf of the Company, the following guidelines apply: 
    1. Due diligence shall be performed to ensure that the third party is a bona fide and legitimate entity; and is qualified to perform services for which it will be retained; and maintains standards consistent with the legal, regulatory, ethical and reputational standards of the Company.
    2. Agreements with third parties must be in writing and should contain provisions related to the following, based on corruption risk present in the third-party relationship:
      1. A representation that the third party shall remain bound and shall be in compliance with all applicable anti-corruption laws in India, foreign laws including the FCPA and Company’s Anti Bribery and Corruption Policy.
      2. A provision that requires the third party to respond to reasonable requests for information from the Company regarding the work performed under the agreement and related expenditures by the third party.

6. Government Officials

  1. Laws and regulations are strict when dealing with Government Officials. Reasonable corporate hospitality that is acceptable with other business associates might not be allowable when Government Officials are involved. Before such expenses are incurred, obtain approval from your
    Compliance Director/legal contact.
  2. A Government Official is any:
    1. individual elected or appointed to a governmental entity,
    2. official or employee of a government,
    3. official or employee of a company wholly or partially controlled by a government (such as stateowned companies),
    4. candidate for political office,
    5. political party or official of a political party, or
    6. person acting in an official capacity for any of the above regardless of rank or position.

The definition of what could constitute a bribe to a Government Official is broad and can occur even when the benefit being offered is small, such as gifts, entertainment and even business meals.

Some laws allow expenses which relate to reasonable and bona fide travel, accommodation and meal expenses in connection with a contract between the Company and the third party, or the demonstration of Company capabilities relating to proposed business with the third party.

7. Facilitation Payments

“Facilitation or grease payments” are payments that facilitate a normal governmental function, such as to expedite processing paperwork. While these types of payments may be accepted as “a cost of doing business” in some cultures, they are illegal and counter to our values.

8. Reporting Violations

  1. Employees and representatives should seek clarification on any questions or concerns regarding activities under consideration or the interpretation of any law. If you are offered a bribe from a person or entity doing business with or seeking to do business with the Company, report it immediately to your business area’s Compliance Director/legal contact.
  2. If you are offered something of value and are uncertain whether you are allowed to accept it, refer to the gift & entertainment policy and standards applicable to your location, or check with your leader or your business area’s Compliance Director/legal contact.
  3. Violations can be reported anonymously by using the Ethics Hotline [●] or online reporting form [●] (available on the intranet or Internet). 
  4. Company’s Whistleblower Policy protects employees who report concerns in good faith.

9. Training & Communication:

  1. Company ensures that it has adequate procedures to combat threats relating to bribery and corruption. Accordingly, Company provides appropriate training for its Employees on prevalent anti- bribery & anti-corruption laws, their role and importance; in order to be in conformance with legal requirements and be in compliance thereof.
  2. A copy of this Policy is available on Company’s website [●].