Anti-Bribery and Anti-Corruption Policy

Introduction

Asire Consulting LLP (“Asire”) is committed to the setting up, utmost standards for transparency and accountability in all its affairs. Asire strives in attaining it’s mission through compliance of high legal and ethical standards. Asire does not tolerate any form of bribery, embezzlements or corruption, and will uphold all laws countering bribery, fraud and corruption in all forms.

Purpose

The purpose of this policy is to set out the responsibilities of Asire and those individuals acting on its behalf in observing and upholding Asire’s position on bribery and corruption. Every individual or group of individuals, associated to Asire in any form, whether the staff members, the ad-hoc staff engaged in the program activities of the organization, the consultants, the contractors, the interns, the partner organisations and any other party with a financial or trustee-beneficiary relationship with Asire are expected to share this commitment. The basic objective of this statement is setting out the policy of Asire towards the prevention and identification of bribery and corruption and the certain procedures to be followed, if at all, any fraud is found or having an idea / impression of it’s existence.

Scope

This policy applies to the Staffs, ad-hoc staffs, Advisers, Consultants, Suppliers, Partners and Individuals acting on behalf of the Firm, irrespective of their location.

Statement

• Asire will not engage in bribery or any form of unethical inducement or payment including facilitation payments and “kickbacks.” All the Staff, Ad-hoc staff, Advisers, Consultants, Suppliers, Partners and Individuals acting on behalf of the Asire are required to avoid any activities that might lead to, or suggest, a conflict of interest with the activities of Asire.
• Asire expects its suppliers and partners to act with integrity and without thought or actions involving bribery and/or corruption and will, where appropriate, include clauses to this effect in relevant contracts.

Prohibited Activities

• It is prohibited, directly or indirectly, for any staff or individual acting on behalf of Asire to offer, give, request or accept any bribe (i.e. gifts with mala-fide intentions, loan, payment, reward or advantage, either in cash or any other form of inducement), to or from any person or company in order to gain commercial, contractual or regulatory advantage for Asire, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
• This policy requires employees and individuals acting on behalf of Asire :-

1. Not to offer, promise or make any bribe or unauthorised payment or inducement ofany kind to anyone;
2. Not to solicit business by offering, promising or making any bribe or unofficial payment to suppliers.
3. Not to request or accept any kind of bribe or unusual payment or inducement that would not be authorised by Asire in the ordinary course of business.
4. To refuse any bribe or unusual payment and to do so in a manner that is not open to misunderstanding or giving rise to false expectation and to report any such offers.
5. Not to make facilitation payments. These are payments used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has a legal or other entitlement. Asire will not tolerate or condone such payments being made.
6. To report any breaches of this policy’s principles or standards or of any associated

Criminal Offence (as defined in IPC)

• It is a criminal offence to:-

1. Offer a bribe.
2. Accept a bribe.
3. Fail to prevent a bribe (only applies to commercial organisations).

• Staffs, ad-hoc staff, advisers, consultants, suppliers, partners and any individuals acting on behalf of Asire should be made aware that if they are found guilty by a court of committing bribery, embezzlement or fraudulence an individual could face prosecution as per the norms of IPC (Indian Penal Code).

Gifts and Hospitality

Asire realises that giving and receiving of gifts and hospitality without any mala-fide intentions, or in other words, where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

Raising a Concern

• lf an employee or an individual acting on behalf of Asire is offered a bribe, or a bribe is solicited from them, they should not agree to it unless their immediate safety is in jeopardy. Should this be the case, the employee or individual should at first instance contact the Partner In-Charge as soon as they are able to do so. The employee or individual may be required to give a written account of the events to assist with any investigation. Likewise if the concerned Partner In-Charge is involved in such an act, the individual may directly contact the Director of Asire for reporting such case.
• Employees or individuals acting on behalf of Asire are encouraged to raise concerns about any instance of bribery or corruption at the earliest possible stage. The employee or individual raising a concern can do so in confidence and without fear of reprisals. All reports raised are taken seriously and, where appropriate, investigated. No employee or individual will be discriminated against in any way as a result of reporting a concern in good faith.
• lf any instance of bribery or corruption is identified; Asire management will take the remedial steps immediately. Asire has it’s own system of investigating it’s staff member for violation of service conduct including financial irregularities, corruption, fraud or embezzlement. If the charges are proved the delinquent may be awarded penalties depending on the gravity of misconduct.

These rules are based on the following principles:-

1. The right of Asire to take appropriate disciplinary steps against any delinquent staff member, who acts in a manner conflicting with the code of conduct and prescribed rules / regulations.
2. At the same time the rules also recognize the right of delinquent staff member to a fair hearing and applicable and just disciplinary action.
3. The emphasis of disciplinary action is on prevention, justice and rehabilitation.

Review of this Policy

In the interests of maintaining best practice, the contents of this Anti-Fraud Policy will be reviewed by the management every two years or any other appropriate time frame.