Anti Corruption Policy

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Anti-corruption Policy Objective

Objective

The Persistent Group is committed to the prevention of corrupt business practices such as fraud and bribery. This is in alignment with Persistent Group’s principles to conduct its business activities with honesty, integrity and with highest ethical standards across its global locations. It also enforces its business practice, of not engaging/being part of or supporting corrupt business practices in any form.

This Policy is applicable to all stakeholders at global locations

Guidelines

Zero Tolerance

Persistent Group has a ‘Zero Tolerance’ approach to corruption and corrupt practices, including providing or accepting:

Cash payments or non-cash Payments

Cash/non-cash Payments

Kickback - Anti-corruption Policy

Kickback
Relates to payments provided for favourable business relations without official documentation.

Political or Social payments - Anti-corruption Policy

Political and/or Social payments
Under no circumstances shall the Company funds be used to make contributions to political parties or candidates in any country.

Gifts - Anti-corruption Policy

Gifts, travel, hospitality, and reimbursement of expenses
If the gifts given or received exceed the token gifts, prior written approval must be taken from the People & Org Development (P&OD) team.

Facilitation payments - Anti-corruption Policy

Facilitation payments

Facilitation payments, also called “grease payments” are illegal in most of the countries including India, the U.K. and Germany.

Bribing another person or associated person

Being bribed - Anti-corruption Policy

Being bribed (as the recipient of the bribe)
It will be an offence for any employee/affiliate to receive a bribe if that person requests, agrees to do or not to do something, or receives an ‘advantage’.

Bribing a foreign public official - Anti-corruption Policy

Bribing a foreign public official
It will be considered an offence to bribe a foreign public official.

Anti-corruption Policy - Failure to prevent bribery

Failure to prevent bribery
A company or partnership will be automatically liable for any bribe offered or given in connection with its business with Persistent Group.

Compliance

It is recommended to consult the People & Org Development (P&OD) team before offering or giving anything of value, even of nominal value.
You may write to ask_hr@persistent.com

Compliance with Laws, Rules and Regulations applicable to the US and the UK.

FCPA (Foreign Corrupt Practices Act, 1977)

General Prohibition and recruitments under the FCPA

The FCPA prohibits the offer, promise, authorization or payment of “anything of value”, directly or indirectly in order to obtain, retain, or direct business or to secure any improper advantage over official actions that may affect the Company. It covers cash payments; non-cash “payments”.

The prohibition under the FCPA extends to improper payment made by any intermediaries, subsidiaries or entities representing the Company, including: company employees; channel partners; resellers and other representatives of the Company, no matter by what name they are called; affiliates of the Company where the Company has majority ownership, including joint ventures; and other entities over which the Company possesses corporate control.

Key Concepts in the FCPA

The definition of “instrumentalities” includes state-owned or controlled companies. In many instances, employees or directors of such companies are not thought of as government officials in their home country.

The FCPA’s prohibition against improper payments to “obtain, retain, or direct business” or to “secure any other improper advantage” covers virtually any improper payment made in a business context.

UKBA (United Kingdom’s Bribery Act, 2010)

The UKBA goes beyond the requirements of the FCPA in that it prohibits bribery not only in the public sector, but also in the private sector, both domestic and foreign.

The UKBA is wider than the FCPA in three ways

It applies to private sector bribery as well as public sector bribery wherever such acts are committed;

There is no exemption for facilitating payments – even for U.S. companies -if they “do business” in the U.K.;

Both U.K. and non U.K. companies doing business in the U.K. will have corporate liability for offences committed by agents or others performing services on their behalf. It will be a defense for the organization to prove that it had “adequate procedures” in place designed to prevent persons who are associated with it (i.e., who perform services on its behalf) from undertaking such conduct.

Reporting a complaint

The Persistent Group is committed to the prevention of corrupt business practices such as fraud and bribery. This is in alignment with Persistent Group’s principles to conduct its business activities with honesty, integrity and with highest ethical standards across its global locations. It also enforces its business practice, of not engaging/being part of or supporting corrupt business practices in any form.

If you would like to raise any queries/ report any incidents with respect to the Anti-Corruption Policy,
You may write to anti-corruptioncommittee@persistent.com.

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