Anti-Corruption and Bribery Policy

1. Purpose

The purpose of this policy is to maintain the highest standards of integrity, accountability and transparency in all business dealings and to ensure that corruption and bribery are strictly prohibited within UGC Supply Chain Solutions Pvt. Ltd.

2. Scope

This policy applies to all employees, officers, directors, consultants, agents, contractors, vendors, suppliers and any third party representing or acting on behalf of UGC across all locations.

3. Policy Statement

UGC has a zero-tolerance approach to corruption and bribery. Offering, soliciting, giving or receiving bribes or improper benefits in any form is strictly prohibited.

4. Definitions

Bribery: Offering, promising, giving, accepting or soliciting of an undue advantage as an inducement for an action.

Corruption: Abuse of entrusted power for private gain.

Facilitation Payments: Small unofficial payments made to secure or expedite routine government actions strictly prohibited under this policy.

5. Prohibited Conduct

Employees and associated persons shall not:

• Offer or accept bribes in any form.
• Make facilitation payments to secure or accelerate business services.
• Use Company funds for unlawful or unethical payments.
• Engage in corrupt practices in public or private sector dealings.
• Conceal or misrepresent the nature of transactions in financial records.

6. No Gifts and Hospitality

Employees, officers, directors, contractors, suppliers and business partners of UGC shall not give, offer, request or accept any gifts, hospitality, entertainment or other benefits of any kind, regardless of value, from any individual, customer, supplier, government official or third party.

This prohibition applies in all circumstances, without exception, to ensure absolute integrity, transparency and avoidance of any actual or perceived conflict of interest.

7. Donations and Sponsorships

All charitable donations and sponsorships must:

• Be made transparently and with documented approval.
• Not be used as a vehicle to conceal bribery or corruption.

8. Roles and Responsibilities

• Employees must report any suspected instances of corruption or bribery.
• Supervisors and Managers must enforce this policy and promote awareness within their teams.
• Compliance Officer will oversee policy implementation, investigate reports and ensure compliance.

9. Implementation Steps

To ensure the effective implementation of this policy, UGC will:

1. Awareness & Training

• Conduct regular training sessions on anti-corruption for all employees.
• Include anti-bribery clauses in employee contracts and third-party agreements.

2. Due Diligence

• Conduct risk-based due diligence on vendors, suppliers and agents.
• Assess background, ownership and compliance history before engagement.

3. Monitoring & Auditing

• Periodically review and audit financial records and procurement processes.
• Implement internal controls to detect and prevent illicit payments.

4. Whistleblower Mechanism

• Establish a confidential reporting system for employees and third parties.
• Ensure non-retaliation for whistleblowers.

5. Disciplinary Action

• Take strict disciplinary measures, including termination and legal action, against individuals involved in bribery or corruption.

10. Reporting Violations

All suspected violations must be reported immediately through the internal reporting channels or to the Compliance Officer. Anonymous reporting is permitted and all reports will be handled confidentially.

11. Review and Updates

This policy will be reviewed annually and updated as necessary to reflect changes in law, business operations or compliance standards.