Anti-Bribery & Anti-Corruption Policy

01. Executive Mandate & Scope

ABT Info Cloud (the technology division of the historic ABT Group) considers integrity non-negotiable. Bribery undermines fair markets, distorts commerce, and compromises corporate trust.

This Policy applies universally to all directors, executive officers, full-time and contractual employees, channel resellers, sales agents, consultants, joint-venture partners, and third-party vendors acting on behalf of ABT.

02. Applicable Statutory Framework

Our operations comply with all relevant anti-corruption statutes across the jurisdictions in which we conduct business, including but not limited to:

• India: The Prevention of Corruption Act, 1988 (as amended by the Prevention of Corruption (Amendment) Act, 2018), which criminalizes both the giving and taking of bribes, as well as commercial organizations failing to prevent bribery.
• United States: The Foreign Corrupt Practices Act of 1977 (FCPA), prohibiting corrupt payments to non-US public officials to obtain or retain business.
• United Kingdom: The UK Bribery Act 2010, which penalizes commercial bribery, bribery of foreign public officials, and failure of corporate entities to prevent bribery worldwide.

03. Prohibited Corrupt Practices

The following activities are strictly prohibited:

• Commercial Bribery: Offering or accepting money, gifts, services, loans, or employment opportunities to or from private sector clients, procurement executives, or competitors to gain an unfair business advantage.
• Public Official Bribery: Direct or indirect transfers of value to any domestic or foreign public official, political party, candidate, or state-owned enterprise representative to influence official action.
• Kickbacks & Secret Commissions: Returning a portion of contract payments or offering unrecorded financial kickbacks to individuals who facilitate procurement awards.
• Extortion: Demanding or yielding to extortion demands. In extreme cases where life or physical safety is immediately threatened, payments must be reported immediately to the Compliance Officer.

04. Facilitation Payments ("Grease Money")

Facilitation payments are small, unofficial payments made to low-level government officials to expedite or secure routine, non-discretionary governmental actions (such as customs clearance, visa processing, or utility connections).

05. Gifts, Meals & Business Hospitality

Modest business courtesies are acceptable only when transparent, proportional, and compliant with explicit parameters:

• Nominal Value: Promotional items of nominal value bearing corporate logos (calendars, pens, technical event swag) are permissible.
• No Quid Pro Quo: Gifts, meals, or entertainment must never be provided during active competitive tender processes or contract negotiations.
• Cash Prohibition: Gifts in the form of cash, gift cards, prepaid credit cards, securities, or convertible instruments are strictly forbidden.
• Pre-Approval & Registry: Any corporate hospitality exceeding designated company thresholds requires prior written approval from the Chief Compliance Officer and formal logging in the Gifts & Hospitality Registry.

06. Third-Party Intermediaries & Due Diligence

ABT can be held legally liable for corrupt acts committed by third-party intermediaries acting on our behalf. Consequently:

• All commercial agents, distributors, lobbyists, and subcontractors must undergo documented pre-engagement anti-corruption due diligence.
• Contracts must incorporate mandatory anti-bribery covenants, right-to-audit clauses, and immediate termination provisions upon breach.
• Compensation paid to intermediaries must be commercially reasonable and commensurate with actual, legitimate services performed.

07. Accurate Books, Records & Internal Controls

ABT maintains financial integrity through meticulous recordkeeping:

• All disbursements, invoices, contracts, expense reimbursements, and asset transfers must be accurately and truthfully recorded in company ledgers.
• No off-the-books funds, slush funds, or unrecorded bank accounts may be established or maintained for any reason.
• No false, misleading, artificial, or deceptive entries may be made in corporate books and records.

08. Whistleblower Hotline & Non-Retaliation

Employees, contractors, partners, and the public are urged to report any suspected breach of this Policy immediately. ABT enforces a strict Non-Retaliation Policy: no individual who raises a good-faith concern will suffer demotion, penalty, discharge, or any form of harassment.