Anti-Bribery & Anti-Corruption Policy

1. Purpose

The purpose of this policy is to set out the responsibilities of SODES and those individuals acting on its behalf in observing and upholding SODES’s position on issues and concern regarding bribery and corruption.

Every individual or group of individuals, associated with SODES in any form, whether the staff members, the ad-hoc staff engaged in the program activities of the organization, the consultants, the contractors, the interns, the partner organizations and any other party with a financial or franchisee -beneficiary relationship with SODES are expected to share this commitment. The basic objective of this statement is setting out the policy of SODES towards the prevention and identification of bribery and corruption and the certain procedures to be followed, if at all, any fraud is found or having an idea / impression of its existence.

2. Scope

This policy applies to all individuals working at all levels and grades, including officers, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual workers and agency staff, volunteers, interns, agents, sponsors, business partners, and third-party representatives, or any other person associated with us, wherever located who may be acting on behalf of SODES.

3. Policy Statement

Corruption is the abuse of public or private office for personal gain. Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust.

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner.

We follow a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implement and enforce effective systems to counter bribery.

4. Objective

Anti-Bribery & Anti -Corruption policy objectives are:

• To encourage all employees to be vigilant and to act diligently in good faith.
• To initiate the steps to reduce the bribery and corruption risks to the business of the Organization by setting out clear guidelines.
• To monitor and investigate instances of alleged corruption.
• To minimize the risk of involvement of all employees and Directors in corruption related activities.
• To take firm and vigorous action against any individual(s) involved in corruption.
• To form a common understanding for all stakeholders that SODES prevents the corruption in any form
• To set responsibility for the employees to know and adhere with the principles and requirements of the Policy, the key rules of the applicable anti-corruption laws, as well as adequate procedures to prevent corruption.

5. Principals

• SODES expresses its zero tolerance to corruption.
• SODES welcomes and encourages compliance with the principles and requirements of the Policy by all grantees and sub grantees, contractors, employees, associated parties/companies, its managerial bodies and other person.
• The President, the Board members and Senior Managerial Personnel of SODES should form the ethical standard of uncompromising attitude to all forms and demonstration of anti corruption at all levels setting the example by their own behavior.
• In this policy, third party means any individual or organization as associate comes into contact with SODES and includes any potential clients, customers, distributors, business contacts, government and public bodies including their respective representatives.

6. Coverage

Anti-Bribery & Anti -Corruption policy covers

• Bribes
• Gifts and hospitality
• Facilitation payments
• Political contributions
• Charitable contributions.

*Exceptions

SODES realizes that giving and receiving of gifts and hospitality without any mala-fide intentions, or in other words, where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

• The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
• As far as possible, it is strongly recommended that receipts of gifts are reported to your superior / admin department and have it formally recorded in organization records.

7. Restricted Practices

List of acts /practices which are restricted / prohibited under the policy framework are as given below:

• Dishonest misappropriation of property/money as defined under Indian Penal Code (IPC)
• Criminal breach of trust as defined under IPC
• Cheating as defined under IPC
• Receiving or giving bribe
• Acceptance /giving of Gifts over and above the extent and the manner as allowed hereunder
  • Gifts and representative expenses including the hospitality business expenses which the employee may provide on behalf of the Organization to the individuals or organizations, or which the employees may receive in connection with their work in the Organization from other persons and organizations, must meet a set of five criteria mentioned below: (a) to be directly related to the legitimate activity of the Organization, for example, a presentation or completion of business project(s), or the successful execution of contracts, or conducting an official event (which may include delegate kits, publications, etc.), or on festivals such as the Christmas, Diwali, New Year, International Women’s Day, anniversaries, birthdays; (b) to be reasonable, proportionate and not be a luxury; (c) to be not a hidden fee for the service, act, omission, conniving, protection, provision of rights, making of certain decision on transaction, agreement, license, permit, etc. or attempt to influence the recipient to indulge in any illegal or unethical activity; (d) not to create a reputational risk for the Organization, employees, and other persons, in case of disclosure of information on gifts or representative expenses;
  • Gifts on behalf of the Organization, its employees and representatives to third parties in the form of cash or non-cash in any currency, are not allowed.
• Charity in order to obtain commercial advantages.
• Participation/Contribution in/to Political Activities.
• Payment of any costs for government officers and their relatives (or in their interests) in order to obtain commercial advantages, and
• Any other unethical act or omission.
• To use partners, agents, joint ventures, intermediaries, or other persons for any actions that are contrary to the principles and requirements of the Policy or the rules of the applicable anti-corruption laws.

8. Compliance Monitoring

• Compliance to the organizations policy is verified through various methods, including but not limited to, internal and external audits, reports from available business tools, self-assessment, and/or feedback to the policy owner.
• It is the Organization’s policy to maintain accurate, reasonably detailed records that fairly reflect its transactions and disposition of assets, therefore, Organization’s Personnel are prohibited from making any false or misleading statements in Organization’s books and records for any reason.
• Regular audits which include a review of the Organization’s books and records maintained by the Finance Department pertaining to the entertainment, gift, and travel expenditures by Personnel on behalf of the organization.
• Exceptions: Any exceptions to the Anti-Corruption and Bribery policy must be approved by the President & Secretary of the organization.
• Non-Compliance: Deviations or non-compliance with this policy, including attempts to circumvent the stated policy/process by bypassing or knowingly manipulating the process, system, or data may result in disciplinary actions, up to and including termination, as allowed by local laws

9. Complaint process and procedures

A person wishing to make a complaint on any suspected case of bribery can consult and file a complaint with the Anti-Corruption Committee. The complaint should be made in writing and addressed to Chairperson of committee within 5 working days of any such incident.

The constitution of the Committee shall be:

• Chair of the Anti-Bribery & Anti-Corruption Committee.
• Two members from middle level, (one male and one female).
• HR Department, Head.

Once the complaint has been filed an investigation will be undertaken immediately by Anti-Bribery & Anti-Corruption Committee and work towards the prompt resolution ,the matter should be resolved within 10 working days.