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Quadrafort Technologies Limited (the 'Company' or 'Quadrafort') practices a zero-tolerance approach to bribery and corruption and is committed to act professionally and fairly in all its business dealings and relationships and in implementing and enforcing effective systems to counter bribery and corruption in any form. Company mandates compliance with all applicable an -bribery and an - on laws in all markets and jurisdictions in which it operates.
Bribery is a serious criminal offence in in India (Preven on of Corruption Act, 1988, Indian Penal Code, 1860) and other applicable laws where offences can result in the imposi on of severe fines and/or custodial sentences, exclusion from tendering for public contracts and severe reputa onal damage. Whoever we, as a Company or as individuals, may deal with, and wherever we may operate, we are committed to doing so lawfully, and with integrity.
This An -Bribery and An - Corruption Policy (the 'Policy' or 'ABAC Policy') has been formulated and designed to provide a framework for ensuring compliance with various legisla ons governing bribery and corrup on globally and provides guidance on the standards of behavior to which we must all adhere. The Company's commitment is to always act with integrity to ensure that we are trusted by our customers, colleagues, business partners, and the communi es in which we operate. As part of this commitment, any form of bribery and corrup on is not acceptable. We prefer foregoing business opportuni es rather than paying bribes.
Quadrafort expects all contracted par es seeking to sell goods or services to conduct their business in accordance with the highest ethical standards. Suppliers or potential Suppliers must strictly comply with all rules and regula ons on bribery, corrup on and avoid unacceptable business practices. Hence Suppliers and those acting on their behalf are expected to observe the following:
Gifts, Hospitality and Entertainment given to or received from any Third Party who have a business rela onship with the company are generally acceptable, if the gift is modest in value, appropriate to the business rela onship, and does not create an appearance of impropriety. No cash or cash equivalent payments should be given or received.
In case of Public Officials, giving gifts is prohibited except for gifts during fes ve seasons such as Diwali, Christmas. Hospitality provided to Public Officials should be reasonable and should not influence or appear to influence any business decision. Further, any form of entertainment to Public Officials is not permissible.
Prior to offering a permissible gifts, hospitality or entertainment to any Third Party including Public Officials, Employee should be in compliance with respect to the approval guidelines and value limits set by the company.
Donation and Sponsorship to political parties, individual candidates and Public Officials is prohibited.
Quadrafort does not offer donations or provide sponsorship to Public Officials.
Quadrafort is politically neutral, i.e., not directly or indirectly affiliated with any political party and does not provide services linked to any political messages. Quadrafort does not associate itself with any poli cal party or independent candidate, and does not campaign for, support and offer donation to political parties to influence any decision or gain business advantage. Accordingly, Quadrafort does not make political contributions, donations and sponsorships of any kind to political parties and individual candidates.
Anti-Bribery and Corruption laws impose liability on companies that become involved in the direct or indirect acts of Bribery. The Company may therefore incur criminal and/or civil liability where Third Parties indulge in any act of Bribery in the course of their work on the Company's behalf, or otherwise for the Company's benefit. This exposure can arise even where the Company Employees ensured to take preven ve steps that improper payments or advantages are not offered or accepted on behalf of the Company by Third Party or their representa ves.
To maintain the highest standards of integrity, with respect to any dealings with a Third Party, the Company will ensure that:
All the Third-Party contracts include An -Bribery and An -Corrup on compliance clauses to ensure compliance with terms of this Policy.
Include appropriate wording/clauses in the Third-Party contracts to make it possible to withdraw from the rela onship and take the appropriate disciplinary ac on, on the Third Par es who fail to abide by this Policy.
At the me of onboarding a Third Party and later on Annual basis, the Company must obtain an An -Bribery and An -Corrup on undertaking or declara on from every Third Party to this effect. Every Third Party appointed for represen ng Quadrafort or carrying out any ac vity for Quadrafort must be hired/appointed in accordance with the guidelines, protocols and procedures around Third-Party iden fica on, due diligence, on- boarding and approvals as set forth in Quadrafort's Third Party Management Policy.
Money laundering occurs when individuals or organiza ons try to conceal illicit funds or make those funds look legi mate. Money laundering is illegal and strictly prohibited by Quadrafort.
Quadrafort is strongly committed to prevent the use of its opera ons for money laundering, financing of terrorism, or any other criminal activities, and will take appropriate ac ons to comply with all the applicable anti-money laundering and anti-terrorism laws throughout the world.
Quadrafort conducts business only with reputable customers involved in legitimate business activities, with funds derived from legitimate sources. Jurisdictions in which Quadrafort and its Team operate may publish lists of individuals and organizations that any company is prohibited from accepting funds from or distribu ng funds to, under applicable An -Money Laundering laws. Employees are expected to use reasonable care to verify that counterpar es are not owned or controlled by, or ac ng on behalf of, sanctioned governments, groups, individuals, organizations and other enties.
If an employee deal directly with customers or Third Parties, the following examples may signal potential money laundering:
This shall include, but will not be limited to, instances where an Quadrafort employee or director may have an interest of any kind in the Supplier's business, whether through personal relationships, investments, directorships or any kind of economicties with the Supplier or any such rela onship whereby the Supplier is in a posi on to directly/ indirectly influence the concerned employee.
Suppliers must disclose all actual or poten al Conflicts of Interest with Quadrafort at the me of empanelment.
Supplier must immediately report if any of the Supplier's staff and/or officers had or have any relative employed with Quadrafort at the me of empanelment.
Where such Supplier is already in service of Quadrafort at the me of the rela ve becoming an employee of Quadrafort, the Supplier must immediately no fy Quadrafort of such employment once he/she is made aware about the same.
Failure to make such declara on shall be construed as a conflict of interest and might result in the exclusion of the Supplier from present and future procurement activities and/or other legal action as deemed fit by the Organization. For the purpose of this clause, the term “relative” shall include immediate family and shall include children, parents, spouse, partner and sibling.
political contributions shall be made on behalf of the Company either directly or indirectly to any political party or for any political purpose without the prior approval of the Board Members. No employee shall use his job tle or Company affiliton in connection with political activities.
The Company shall ensure that charitable contributions and sponsorships are not used as a vehicle for bribery. We shall publicly disclose all our charitable contributions and sponsorships and ensure that all such transactions are legal and ethical under local laws and practices.
The Company prohibits facilitation or grease payments or kickbacks of any kind, regardless of whether such payments are permitied under applicable law. It is also our policy that we work to ensure that our employees, business associates and business partners do not make facilita on payments or kickbacks on our behalf. If you have doubts about a payment and suspect that it might be considered a facilitation payment, check with the Board Member for expertise and guidance. Any suspicions, concerns or queries regarding a payment should be raised with the HR Head.
It is important that you tell your Department Head or the HR as soon as possible if you are offered a bribe by a third party or are asked to give a bribe or suspect that this may happen in the future.
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are some mes worried about possible repercussions. The Company encourages openness and supports anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. If a viola on of the relevant laws or policies is proven, appropriate action shall be taken. Company shall not tolerate retaliation in any form against anyone for raising concerns or reporting what they genuinely believe to be improper, unethical or inappropriate behavior. All reports shall be treated confiden ally. The Company is commi ed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corrup on offense has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary ac on, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, inform one of the Board Member immediately.
The Company's ABAC Policy shall be promoted and enforced consistently throughout the Company with clear and consistent disciplinary consequences to anyone who violates the Policy. All employees are expected to comply with the ABAC Policy.
