Anti Corruption Policy

Sharsid is committed to conducting its business with integrity, transparency, and accountability. We have zero tolerance for corruption in any form—whether in dealings with public officials or in private sector transactions.

This Policy aligns with the Prevention of Corruption Act, 1988 (as amended in 2018), the Companies Act, 2013, relevant provisions of the Indian Penal Code, and applicable international standards such as the United Nations Convention against Corruption (UNCAC) and OECD Guidelines.

Our objective is to prevent bribery, kickbacks, and all other corrupt practices, ensuring that our operations in India are compliant, ethical, and in line with global best practices.

  1. Purpose

This Policy aims to:

  • Prevent bribery, undue influence, and any form of corrupt conduct.
  • Promote a culture of integrity and ethical decision-making.
  • Ensure compliance with Indian anti-corruption laws and relevant international obligations.
  • Protect our employees, partners, and the Company from legal, financial, and reputational risks.
  1. Scope

This Policy applies to:

  • All employees, directors, and officers of sharsid
  • Consultants, agents, intermediaries, suppliers, contractors, and other third parties acting on behalf of the Company.
  • All business activities undertaken in India.
  1. Prohibited Conduct

The following actions are strictly prohibited:

  • Offering or accepting bribes: No employee or representative may offer, promise, give, request, or accept anything of value to influence business decisions.
  • Facilitation payments: Small, unofficial payments to speed up routine actions are strictly banned.
  • Improper gifts or hospitality: Only modest, reasonable, and lawful business courtesies are permitted.
  • Kickbacks and secret commissions: Any arrangement involving undisclosed or improper payments is prohibited.
  • Conflict of interest: Employees must avoid situations where personal interests conflict with the Company’s interests.
  1. Dealings with Government Officials

Special care must be taken in all interactions with government agencies and officials:

  • No gifts, payments, or favors may be offered to influence decisions on licenses, permits, inspections, or regulatory matters.
  • All interactions with public officials must be transparent, documented, and approved by authorized management.
  1. Gifts, Hospitality, and Entertainment
  • Permitted only if they are reasonable, infrequent, transparent, and not intended to gain an improper advantage.
  • Must be recorded in the Company’s gift register and pre-approved where required.
  1. Sponsorships and Donations
  • Charitable donations, sponsorships, or contributions to non-profit organizations are allowed only if:
    • They are lawful and transparent.
    • They are not used to improperly influence a business decision.
    • They are approved in accordance with the Company’s internal procedures.
  1. Third-Party Engagements
  • Due diligence must be conducted before engaging suppliers, contractors, consultants, or agents.
  • Contracts must include anti-corruption clauses allowing the Company to terminate agreements for violations.
  1. Record-Keeping and Transparency
  • All financial transactions must be accurately recorded in accordance with applicable accounting standards.
  • False, misleading, or incomplete records are strictly prohibited.
  1. Employee Responsibilities
  • Comply with this Policy and all applicable anti-corruption laws.
  • Report any suspicion or knowledge of corrupt activity immediately.
  • Complete mandatory anti-corruption training.
  1. Reporting and Whistleblowing
  • Concerns can be reported confidentially via the Company’s whistleblowing mechanism.
  • Reports will be investigated promptly, and whistleblowers will be protected from retaliation.
  1. Disciplinary Action
  • Violations of this Policy may result in disciplinary action, including termination, legal action, and reporting to authorities.
  • Third-party violations may result in immediate contract termination.
  1. Policy Review

This Policy will be reviewed annually and updated as required to reflect changes in law, business operations, or best practices.

Last Updated: 10/8/2025
Approved By: Board of Directors, sharsid