Anti Bribery Policy

1. POLICY STATEMENT

1.1 Globoprime Documents Clearing Services LL.C, its Branches and Operation Partners (collectively, the “Company”) is committed to conduct the business on the bases of Enhanced Transparency, Accountability and Business Productivity with utmost importance to the honesty and Fairness. Legal and Regulatory Compliance are the essential components of doing the business in line with its fundamental business principles. Zero Tolerance to Corruption is the moto of the company. Therefore, it is important that the Company complies with and conducts its business in accordance with applicable anti-bribery and anti-corruption laws of the countries of its operation. The present policy is an extension of its commitments detailed in the corporate manual of the company.

1.2 The Company will abide by all the concerned UAE laws and laws countering bribery and corruption in all of the jurisdictions in which the Company operates or conducts its business directly or through its operation partners.

1.3 in cases where there is no law to punish the bribery or corruption in the country of its occurrence, Indian/UAE Penal code and other penal laws to Combat the bribery and corruption shall have Extra Territorial Application subject to the laws of such country.

1.4 The Company is committed to

1. comply to all the Anti- bribery and Anti-Corruption Legislation
2. not offering bribes or condoning the offering of bribes on the Company’s behalf.
3. not accepting bribes, or agreeing to them being accepted on the Company’s behalf
4. maintaining accurate books and records.
5. making sure that the Company’s Representatives are aware of and abide by the Company’s values and policies;
6. avoiding doing business with or affiliating the Company with others who do not accept the Company’s values and policies and who may harm the Company’s reputation
7. ongoing monitoring of and auditing compliance with these principles.

1.5 this policy intend to set-out the responsibilities of the company, Responsibility of those who are working for the company in the capacity of employee, Agent, Affiliate or Operating Partner to observe and uphold the company’s position of zero tolerance to Bribery and Corruption. It also ensures that the company’s guidelines to prevent and detect the bribery and corruption,

2 TO WHOM DOES THIS POLICY APPLY?

2.1 This policy applies to the Mangers, officers, employees (whether permanent, or temporary), technical and other consultants, agents, Operation partners or any other person associated with or acting on behalf of the Company, wherever located (collectively referred to as “Representatives” in this policy).

3 WHO IS RESPONSIBLE FOR THE POLICY?

3.1 The Managing partner is responsible of this policy and its compliance and implementation. The members of the management team at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it. The Managing partner may delegate administrative tasks to subordinates or other employees or officers, as may be necessary for the purposes of this policy.

4 WHAT IS BRIBERY?

Bribe or Bribery includes and not limited to,

1. gift, financial or other advantage offered or received, directly or indirectly, to induce or reward the improper performance of a relevant function or activity.
2. request or acceptance, the offer or making of any promise or gift (or other advantage) to a public official or a person who manages or is employed by a legal entity, either directly or indirectly, in order to abet that public officer or person to abuse his power, whether actual or presumed, in order to obtain, from a public department of authority or a legal entity, an unlawful benefit.
3. Promise, offer, promising, giving, accepting or soliciting of an advantage as an inducement or reward for an action which is illegal or Unethical.
4. direct or indirect promise, offering or authorization of anything of value or the offer or receipt of any kickback fee, reward or other advantage.
5. misuse of public office or power for private gain or misuse of private power in relation to business outside the realm of government.
6. Any other definition of bribery and corruption under the laws, regulations, degrees and judicial pronouncements of concerned jurisdiction.

5 WHAT IS NOT PERMITTED?

5.1 to give, promise to give, or offer, a payment, loan, reward, gift or entertainment, to a Public Official, or any Third Party with the expectation or hope that a business advantage will be received, or to reward a business advantage already given (i.e. securing a permit, securing or renewing a contract with favorable terms, influencing a Public Official to take or omit an action in violation of his or her lawful duty etc.)

5.2 to give, promise to give, or offer, a payment, loan, reward, gift or entertainment to a Public Official, or any Third Party to “facilitate” or expedite a routine procedure;

5.3 to threaten or retaliate against any person who has refused to commit a bribery offence or who has raised concerns under this policy; or engage in any activity that might lead to a breach of this policy.

5.4 to falsify the Company’s books and records for the purpose of bribery or of hiding bribery. 5.5 inaccurately identify liabilities;

5.6 knowingly use false documents or destroy accounting books and records.

6 FACILITATION PAYMENTS AND KICKBACKS

6.1 Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government-officials whereas Kickbacks are typically payments made in return for a business favor or advantage and can include discounts or other types of cash incentives.

6.2 All Representatives must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made by or on behalf of the Company.

6.3 the company shall keep the records of all the payments to its Affiliates, Agents and Operation partners all the time.

7 GIFTS, ENTERTAINMENT AND HOSPITALITY

7.1 Giving business gifts and taking part in corporate entertainment or undertaking speaking engagements to be tested whether these are justifiable and reasonable and does not carry any obligation on the part of receiver or construe others to allege favoritism, discrimination or other unacceptable practices.

7.2. Giving of gifts and corporate hospitality or entertainment is not prohibited if it is not violation of law of applicable country and does not at any way intends to influence a Third Party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favors or benefits.

8 CHARITABLE CONTRIBUTIONS AND SPONSORSHIPS

8.1 The company shall not relate Any charitable contributions or sponsorship to win or influence the business model or decision.

8.2 the company shall assure any such payments are of legitimate and shall comply with required registration and filings in compliance to respective local laws and accounting standards.

9 POLITICAL DONATIONS

The Company shall not make contribution to political party or public international organization without the prior written approval of Managing Partner. In undertaking any such unauthorized activity, all Agents, Affiliates or Operation partner will be deemed to be acting in their personal capacity or that of their own corporate organization and not on behalf of the Company.

10. OPERATION PARTNERS

The Company is committed to appoint and affiliate the operation Partners across the globe on doing the required due diligence about their Integrity, Honesty and business productivity. The appointment and engagement of operation partners shall be in accordance with the Service Level Agreement (SLA) and other applicable laws of the country concerned.

The Service Agreement with operation partner shall include the minimum standard provisions and undertaking of Operation partners to comply with the Relevant Anti-Bribery and Anti-Corruption laws and Anti-bribery and Corruption policy of the Company.

All the payments to the Operation partners or Agent shall be in accordance with the invoice, receipt and other service level assignments generated in the name the business partner and such payments shall be honored through wire-transfer or cheque only.

11 YOUR RESPONSIBILITIES

11.1 All the representatives, Affiliates, Agents and operation partners shall adhere to this policy and shall take precautionary measures to prevent bribery and corruption in their respective operation zone.

11.2 All the representatives, Affiliates, Agents and operation partners shall avoid any actions which shall lead to the Bribery and corruption

11.3. Any Corrupt practices on the part of employee shall lead to appropriate disciplinary and penal action.

11.4. Reporting of Any Corrupt practices on the part of Agent, Affiliates or Operation partner shall attract the immediate termination of Contract along with the appropriate civil and criminal action for the losses of any nature.

12 RECORD-KEEPING AND COMPLIANCE

11.1 the Company shall comply to the applicable laws of record keeping of respective jurisdiction.

11.2 the company shall follow the standard accounting methods of issuing and receiving payments.

11.3 the company shall not involve in any forms of Money laundering Transactions or suspected money laundering transactions.

11.4 the company shall all the time comply with Anti- Money Laundering Legislation of respective jurisdictions.

11.5 the company is committed to comply with the National and international Mandates of Anti-Money Laundering legislations and policies.

11.6 the Managing Partner of the company shall be responsible to assure the AML Commitment.

13 HOW TO RAISE A CONCERN

All Representatives are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with the Managing Partner

14 PROTECTION

14.1 If you come across with any kind of bribe or corrupt Practices or suspected such practices, you shall report the matter to the Managing partner immediately through confidential mail.

14.2 The company is committed to secure anyone who raise the genuine concerns in good faith from the detrimental repercussions.

15 TRAINING AND COMMUNICATION

the company shall render the awareness and training about the Zero tolerance policy of the company to the employees, Agents, Affiliates and operational partners

16 MONITORING AND REVIEW

16.1 the Globoprime is committed to monitor the effective performance of this policy

16.2 the company shall carry out timely review to this policy to cop up with the changing circumstances and legislative changes in the respective jurisdictions.

16.3 Any Changes in this policy shall be communicated to All the Agents, Affiliates and Operation Partners.