Meeram Technologies ensures 100% compliance with all the applicable anti-corruption laws of the countries in which we operate to demonstrate our commitment to eliminate unethical business practices like corruption and bribery. We consider both fairness and honesty to be of paramount importance in building long-term business relationships; therefore, this particular policy is applicable to all the directors, officers, employees, and third parties who represent the company.

Purpose

This policy is designed to:

• Outline the commitment of Meeram Technologies to conduct business in an ethical manner.
• Ensure compliance with both anti-corruption and anti-bribery laws.
• Serve as a guideline on as to how situations like potential corruption and bribery can be catered to by both business partners and employees.

Scope

The policy is applicable to:

• All representatives of Meeram Technologies operating around the world including board members, and employees.
• Joint Ventures, contractors, suppliers, consultants, agents, and other potential business partners.
• Any entity or individual who conducts business on behalf of Meeram Technologies.

Prohibited Actions

Meeram Technologies prohibits:

• Engagement in activities like corrupt hiring practices, facilitation payments, kickbacks, and bribery.
• Soliciting, receiving, giving, or even offering something of value in order to influence any decision or action for gaining unfair advantage.
• Both offering or accepting hospitality, entertainment, or gifts that are aimed to influence relationships or business decisions.

Guidelines for Gifts and Hospitality

It is acknowledged by the company that offering hospitality, or even small and reasonable gifts can occasionally be considered a norm when fostering stronger business relationships, but such acts need to be in compliance with the following guidelines:

• Gifts and Hospitality: Both frequency and value need to be reasonable, as they shouldn’t influence or impact a business decision, so acceptance of cash or any equivalents like gift cards is strongly prohibited.
• EntertainmentIt needs to be in alignment with the industry standards so it can neither be inappropriate nor lavish. Furthermore, extra caution is advised to individuals when it comes to dealing with government individuals.
• Sponsored TravelIt could only be for the business purposes of legitimate nature, and the approval of senior management is mandatory in this regard.

Facilitation Payments

Considering the fact that facilitation payments are normally made to expedite actions from the government’s side, these payments are strictly prohibited even when operating in countries where such acts are considered normal. However, exception can be applied in cases when an employee’s security or safety is at increased risk.

Responsibilities

Every individual including third parties and employees representing the company is responsible for ensuring compliance with this policy, and they are also under obligation to:

• Avoid inaccuracies by ensuring record-keeping for all transactions and maintaining formal documentation.
• Use appropriate reporting channels to report any incident or suspicion of corruption or bribery as soon as possible.
• Make themselves familiarized with anti-corruption policy and keep themselves up to date on any changes.

Reporting Violations

Both business partners and employees are encouraged to report suspicion or violation of policy through our “Speak Up” program if they want to maintain confidentiality, and the company will ensure that no retaliatory action is taken against the individual who has raised the concern.

Consequences for Non-Compliance

Strong disciplinary action will be taken against the individuals in case of non-compliance with this policy, which may even result in the termination of employment contracts; moreover, the individuals involved in criminal activities may also have to face imprisonment or pay fines depending on the local laws.

Policy Review and Updates

The policy will be reviewed and updated periodically by Meeram Technologies in order to ensure compliance with both best practices and the evolving laws; moreover, any new changes will be communicated to the employees promptly.