Last Update: 15/03/2024

cagda & CO LLP-(hereinafter referred to as the “Firm”

is committed to the highest standards of ethic and integrity in all our activities, doing open and fair business, follow best practices of governance and support the business reputation at the appropriate level.

It is worth noting that, the Firm has a zero‐tolerance approach to bribery and corruption and will not engage in any bribery
or corrupt activities in any form. This policy prohibits all forms of bribery and corruption in all business dealings in every
country around the world in which we operate, in relation to either private individuals and companies or public officials.

Purpose: This Ethics, Anti‐Corruption & Anti‐Bribery Policy (the “Policy”), is set forth for the Firm including their partners,
executive directors, officers and employees, (whether regular, fixed term or temporary) consultants, independent
contractors, vendors, assigns, trainees, secondment staff, casual workers, contingent workers, interns, and others acting on
Firm’s behalf and working on any Firm’s premises at all locations or working remotely on behalf of the Firm (hereinafter
referred to as the “Firm Individuals”) for their commitment to ensure that the Firm Individuals, affiliates, and other acting
on Firm’s behalf abide by Anti‐Bribery and Anti‐Corruption laws (International and domestic as the case may be) published
and notified by the relevant authority of their respective jurisdiction and place of transaction implemented or facilitated by
them on Firm’s behalf.

The Firm Individuals must take all reasonable steps to ensure that any person or companies acting for or on behalf of the
Firm do not, directly, or indirectly offer, promise, give, receive, or request bribes as part of their activities on behalf of Firm.

The Firm Individuals shall not, directly, or indirectly offer, promise, or give a financial or other benefit or anything of value to
any individual or company and public official with whom the Firm does business or may potentially do business, with the
intent of influencing such official, company or person to obtain or retain a business or other undue advantage in the conduct
of business activities. For avoidance of doubt, public official could include, among others, government officials, employees
of government agencies, employees of government‐owned companies, and any person who holds a legislative,
administrative, or judicial position of any kind and in any country or territory.

Anti‐Corruption Laws: Our global business is subject to domestic anti‐bribery and corruption laws which have global reach.
These laws, as well as local anti‐bribery and corruption laws in the relevant country, apply to all Firm’s businesses and
people wherever they may be located and where a transaction is facilitated on behalf of the Firm undertaken by Firm
Individuals.

The following list of statutes, rules, and convention, as amended from time to time, amongst other statutory legislations,
rules and notifications duly published by the relevant authority, may be attracted (without limitation) to Firm’s business at a
global level:

• Prevention of Corruption Act, 1988 (“PCA”)
• U.S. Foreign Corrupt Practices Act of 1977 (“FCPA”);
• UK Bribery Act, 2010;
• U.S. Currency and Foreign Transaction Reporting Act of 1970;
• U.S. Money Laundering Control Act of 1986;
• Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015;
• All India Service Conduct Rules, 1968;
• UN Convention on Corruption; and
• Prevention of Money Laundering Act, 2002.

Bribery and corruption create serious legal and reputational risks which can damage the Firm’s reputation. Violations of anti‐
bribery and corruption laws can lead to substantial civil and criminal penalties for the Firm and individuals which may
include imposition of unlimited fines, blacklisting from tendering process by respective Public Sector Undertakings/
government authorities, disgorgement of profits, prosecution and, in the case of Firm’s individuals, imprisonment. amongst
other proceedings and punishments as per the relevant law in force.

Applicability: This Policy shall be applicable to all Firm Individuals at any location and at all levels and grades, in the course
of their engagement for or on behalf of the Firm.

Corrupt Practices: A bribe is generally defined as conferring of benefit by one upon another, in cash or in kind, to procure
an illegal or dishonest action in favour of the giver. A bribe involves offering, promising, giving, receiving, requesting a
financial or intermediation of financial bribe or other inducements bribes or anything of value, for the purpose of
influencing or rewarding someone to do something that is illegal, unethical and / or a breach of trust. A financial or other
benefit or anything of value could be a gift, prize, business opportunity, favour, commission, loan, cash, hospitality, service,
discount, the award of a contract, political contribution, sharing confidential information, exchange of information with
competitors or anything else of value.
Corruption is the abuse of power or authority, often for personal or corporate gain. Bribery is a form of corruption. Other
form of corrupt practices include fraud, tax evasion and money laundering.

Violations, Responsibilities and Punitive Action: If any Global Individual have concerns against potential bribery or
corruption as prescribed in this Policy, the same must be raised immediately with the immediate superior. If the immediate
superior is not the appropriate person, then the Firm Individual concerns must be brought directly to the attention of the
Managing Partner.

Violations of Firm’s anti‐bribery and corruption policies by the Firm Individuals shall be treated as an offence against the
Firm and shall be subject to investigation conducted by the investigation committee constituted by the Managing Partner. If
any Firm Individual is found guilty of such corruption and malpractices, then it may result in disciplinary action up to and
including termination of their employment. Firm Individuals, subject to this policy may be subject to civil and criminal
proceedings being brought against them, and may also be reported to relevant authorities, as appropriate.