While using Teravent and its associated services, you must read and understand Teravent's applicable policies, including this Anti-Bribery and Corruption (ABC) Policy and the Teravent Privacy Policy.
Effective on April 19, 2025.
Teravent establishes a zero-tolerance approach to bribery and corruption. It strictly prohibits offering, giving, soliciting, or receiving any form of bribe or improper payment in the course of business.
Teravent Limited is committed to conducting business with the highest standards of integrity and in full compliance with all applicable anti-bribery and anti-corruption laws. This includes, but is not limited to, the UK Bribery Act (UKBA), the U.S. Foreign Corrupt Practices Act (FCPA), the Prevention of Corruption Act, 1988 (India), and other relevant international regulations.
This Policy applies to all employees, officers, agents, consultants, and any intermediaries acting on Teravent's behalf.
Improper payments include bribes, kickbacks, excessive gifts, entertainment, or any benefit intended to gain an undue business advantage. Any gift or hospitality exceeding USD 50 must be recorded in the Company's internal gift log, and prior written approval from the reporting manager is required.
- Prohibition on Bribery: Teravent strictly prohibits bribery or any other form of improper payment in its business activities worldwide, including dealings with government officials, commercial partners, suppliers, or any third party.
- Facilitation Payments: Small unofficial payments to expedite routine government actions are strictly prohibited.
- Government Officials: Extra caution must be exercised in dealings with public officials under the Prevention of Corruption Act, 1988 (India) and equivalent international laws.
- Willful Ignorance: Teravent and its employees may be held liable for improper payments made by agents or intermediaries if there is actual knowledge or reason to suspect a bribe. Willful ignorance is not a defence.
- Bribery: Offering or receiving anything of value to influence a decision or secure an improper advantage.
- Corruption: Abuse of entrusted power for private gain, including fraud, embezzlement, or misuse of position.
- Facilitation Payments: Small unofficial payments to expedite routine government actions - strictly prohibited.
- Foreign Public Official: Any officer or employee of a government or government-controlled entity, including public sector units and international organizations.
- Prohibited Payments: Includes cash, gifts, entertainment, employment offers to relatives, political contributions, or other benefits intended to influence decisions.
Accurate and complete financial records are essential to prevent corruption, ensure compliance with legal requirements, and safeguard the Company's reputation. Employees are required to ensure that all financial transactions are properly documented and recorded.
- No Off-the-Books Accounts: All transactions must be captured in official records; creating hidden or unrecorded accounts is strictly prohibited.
- Transparent Recording: Any payments to officials or third parties must be accurately documented, clearly stating the purpose, recipient, and amount.
- Reject Irregular Documentation: False, incomplete, or unclear invoices and expense reports must be immediately reported and not processed.
- Integrity in Financial Entries: All accounting records must truthfully and fully reflect the underlying business activity.
Interactions with third parties such as agents, consultants, and other intermediaries can present heightened risks of bribery or corruption. Teravent applies rigorous standards for the selection, appointment, and ongoing oversight of all third parties.
- Due Diligence: Before engaging any third party, employees must perform comprehensive background checks to verify their reputation, legal standing, and ethical conduct.
- Identify Red Flags: Employees must remain vigilant for warning signs such as unusual payment requests, opaque business structures, or pressure to bypass standard procedures.
- Enhanced Scrutiny: If red flags are detected, employees must escalate the matter and apply additional review measures.
- Prior Approval and Documentation: All engagements with third parties must receive prior approval from a senior manager and be properly documented.
- Be familiar with this Policy and ensure subordinates are informed.
- Seek guidance when unsure about specific situations.
- Monitor business activities conducted via third parties.
- Remain alert to indications of wrongdoing.
- Promptly report actual or suspected violations to supervisors, the next level of management, or the CEO.
Retaliation against employees who report concerns in good faith is strictly prohibited.
Employees found to have engaged in bribery, corruption, or any conduct contrary to this Policy may face disciplinary measures proportionate to the severity of the violation - ranging from formal warnings and mandatory retraining to suspension or termination of employment. Violations may also necessitate reporting to law enforcement or regulatory authorities and may result in criminal prosecution.
The CEO is responsible for the implementation, oversight, and continuous improvement of this Policy. The Policy will be reviewed annually, or as required due to regulatory or organizational changes.
Board of Directors, Teravent Limited. Effective Date: 19 April 2025. Next Review: 19 April 2026.