Anti-Corruption
Policy
Purpose &
Objective
This overview of ORANGE RETAIL
FINANCE INDIA PRIVATE LIMITED (ORFIL). Anti-Corruption Policy outlines the principles that ORANGE RETAIL FINANCE
INDIA PRIVATE LIMITED and its affiliates (collectively "ORFIL" or "we") follow to achieve
zero-tolerance against bribery and corruption. The objective of our anti-corruption policy is to ensure that
appropriate anti-corruption and bribery procedures are in place.
This policy applies to all officers,
directors, shareholders, employees, and appointed third-party representatives of ORFIL (including but not
limited to agents, intermediaries, consultants, and introducers) in all locations. Violation of this policy will
be severely sanctioned, including where appropriate disciplinary procedures, up to and including termination of
employment and possible referral to the appropriate criminal or regulatory authorities. ORFIL intends to review
doing business with others who do not commit to the same standard of zero-tolerance of corruption, including
joint ventures partners and distributors.
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Policy
Requirements
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ORFIL has embedded
within its business the following principles and controls to achieve zero-tolerance against
bribery and corruption: No acceptance or offering of bribes and facilitating
payments
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Strictly prohibited
from giving or receiving bribes (i.e. personal benefit for any improper advantage) as well as
facilitating payments (regardless of whether these are common practices in a particular country)
which involve anything of value to government officials in order to expedite or facilitate
routine, non-discretionary government actions.
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Charitable and
political donations
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Prohibited from
payment of donations that are linked to obtaining any improper advantage, including facilitating
payments.
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Gifts and
Entertainment
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Prohibited from
providing gifts or entertainment to clients, prospects, government officials, or their family
members when such expenses are not incurred while conducting company business and/or do not
satisfy this policy and our related policies.
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Payment &
Recordkeeping
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All relevant
expenditures must be properly documented, approved, and maintained for a minimum of 6
years.
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Government
officials
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Required to adhere
to our additional recordkeeping requirements regarding all expenditures related to government
officials. Written prior approval is required when a certain threshold is exceeded.
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Due Diligence on
Third-Party Representatives
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Required to conduct
an appropriate due diligence review on background, reputation, and business capability before
engaging or contracting with any third-party representatives and to include anti-corruption
provisions in any such contract.
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Periodic
training
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Required to carry
out appropriate training to employees regarding the Anti-Corruption Policy and their role to
ensure compliance.
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Monitoring and
Reporting
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We shall monitor compliance with our
Anti-Corruption Policy.
Further, all persons covered by this
policy must promptly report any violation or suspected violation of this policy to the VP–Internal Audit
& Compliance email ID at meeran.msn@orangeretailfinance.com.
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