ANTI-CORRUPTION
AND
ANTI-BRIBERY POLICY

Part 1: Anti-Corruption and Anti-Bribery Policy for Employees of RightMatch HR Services Private Limited

1. Introduction

• RightMatch HR Services Private Limited (hereinafter referred to as "RightMatch") is dedicated to conducting its business with integrity, honesty, and transparency. This Anti-Corruption and Anti-Bribery Policy has been established to ensure compliance with all applicable laws and regulations in counties we provide our services. It applies to all directors, officers, employees, contractors, consultants, and other individuals associated with RightMatch.

2. Scope

• This policy governs the conduct of all employees of RightMatch, regardless of their position or role within the organization, and applies to all activities undertaken by them, both domestically and internationally.

3. Core Principles

• a. Zero Tolerance: RightMatch maintains a zero-tolerance policy towards corruption, bribery, and unethical behavior in any form.

• b. Compliance with Laws: All employees must adhere to applicable anti-corruption and anti-bribery laws and regulations in the jurisdictions where RightMatch operates.

• c. Transparency and Accountability: Transparency and accountability are fundamental principles of RightMatch. All financial transactions, agreements, and relationships must be accurately recorded and documented.

• d. Prohibition of Bribery and Corruption: Employees are strictly prohibited from offering, giving, receiving, or soliciting bribes, kickbacks, or any other improper payments or benefits to gain an improper advantage or influence business decisions.

• e. Due Diligence: RightMatch will conduct due diligence on third parties and outside customers to ensure they comply with anti-corruption and anti-bribery standards.

4. Responsibilities

• a. Senior Management: Senior management is responsible for setting the tone at the top and fostering a culture of integrity, compliance, and ethics.

• b. Employees: All employees must familiarize themselves with this policy, adhere to its principles, and report any suspected instances of corruption or bribery.

• c. Compliance Officer: The Compliance Officer is responsible for overseeing the implementation of this policy, conducting risk assessments, providing training, and investigating reported incidents of corruption or bribery.

5. Prohibited Conduct

• a. Offering, giving, receiving, or soliciting bribes, kickbacks, or any other improper payments or benefits.

• b. Engaging in fraudulent activities, including falsifying records or financial statements.

• c. Misusing company assets or resources for personal gain.

• d. Participating in conflicts of interest without disclosure.

• e. Retaliating against whistleblowers who report suspected instances of corruption or bribery.

• f. Any receipt or payment of compensation in cash or kind, exceeding what is receivable or payable as per the agreement, shall be construed as bribery, leading to legal proceedings.

6. Reporting Procedures

• a. Employees must report suspected instances of corruption or bribery to their supervisor, the Compliance Officer, or through the designated reporting channel.

• b. Reports will be treated confidentially, and whistleblowers will be protected from retaliation.

• c. Investigations into reported incidents will be conducted promptly, thoroughly, and impartially.

7. Disciplinary Actions

• a. Individuals found guilty of corruption or bribery may face disciplinary action, including termination of employment, suspension, or legal consequences.

• b. Failure to comply with this policy may result in severe consequences, including legal action, reputational damage, and loss of employment.

8. Training and Awareness

• a. RightMatch provides regular training on anti-corruption and anti-bribery principles to all employees.

• b. Employees must certify their understanding and compliance with this policy on an annual basis.

9. Review and Revision

• a. This policy will be reviewed periodically to ensure its effectiveness and relevance.

• b. Revisions will be made as necessary to address changes in laws, regulations, or emerging risks related to corruption and bribery.

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Part 2: Anti-Corruption and Anti-Bribery Policy for Dealing with Third Parties and Outside Customers

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1. Introduction

• RightMatch HR Services Private Limited (hereinafter referred to as "RightMatch") recognizes the importance of maintaining integrity, honesty, and transparency when interacting with third parties and outside customers. This Anti-Corruption and Anti-Bribery Policy has been developed to ensure compliance with all applicable laws and regulations in countries we provide our services.

2. Scope

• This policy applies to all interactions and transactions with third parties and outside customers, including but not limited to vendors, suppliers, clients, contractors, consultants, and agents.

3. Core Principles

• a. Transparency and Accountability: All business dealings with third parties and outside customers must be transparent, accurately documented, and conducted in accordance with applicable laws and regulations.

• b. Due Diligence: RightMatch will conduct due diligence on third parties and outside customers to ensure they comply with anti-corruption and anti-bribery standards.

• c. Prohibition of Bribery and Corruption: RightMatch prohibits the offering, giving, receiving, or soliciting of bribes, kickbacks, or any other improper payments or benefits in connection with business transactions involving third parties and outside customers.

4. Responsibilities

• a. Procurement and Legal Teams: Responsible for conducting due diligence on third parties and outside customers, drafting contracts with anti-corruption and anti-bribery provisions, and monitoring their activities.

• b. Business Units: Responsible for ensuring that interactions and transactions with third parties and outside customers comply with this policy and reporting any suspected instances of corruption or bribery.

• c. Compliance Officer: Oversees compliance with this policy and investigates reported incidents of corruption or bribery involving third parties and outside customers.

5. Prohibited Conduct

• a. RightMatch shall not: i. Make any offer, payment, or promise of payment, including kickbacks, to gain an improper advantage or influence business decisions involving third parties and outside customers. ii. Permit any action that would cause RightMatch to violate applicable anti-corruption and anti-bribery laws and regulations.

• b. Engaging in agreements or transactions involving corrupt practices or unethical behavior.

6. Reporting Procedures

• a. Employees must report suspected instances of corruption or bribery involving third parties and outside customers to their supervisor, the Compliance Officer, or through the designated reporting channel.

• b. Reports will be treated confidentially, and whistleblowers will be protected from retaliation.

• c. Investigations into reported incidents will be conducted promptly, thoroughly, and impartially.

7. Disciplinary Actions

• a. Individuals found guilty of engaging in corrupt or unethical activities involving third parties and outside customers may face disciplinary action, including termination of employment, suspension, or legal consequences.

• b. RightMatch may terminate contracts with third parties and outside customers found to be involved in corrupt practices.

8. Training and Awareness

• a. RightMatch provides training to employees involved in interactions and transactions with third parties and outside customers on the principles outlined in this policy.

• b. Employees must certify their understanding and compliance with this policy on an annual basis.

9. Additional Policy Clarifications

• a. Any receipt or payment of compensation, exceeding what is receivable or payable as per the agreement signed between RightMatch and its customer, shall be construed as bribery, leading to legal proceedings.

• b. This policy is binding and applicable to all employees of RightMatch, including but not limited to directors and all appointed representatives, irrespective of their location, function, or grade.

• c. Definitions: i. Bribery: Giving or receiving an unearned reward to influence someone's behavior, including "kickbacks" following favorable treatment. ii. Corruption: Any unlawful or improper behavior seeking to gain an advantage through illegitimate means, involving the abuse of entrusted power for private gain. iii. Bribe: Money or a present given to someone to do something dishonest.

10. Infringements and Consequences

• Infringements of this policy shall result in disciplinary action by RightMatch, including dismissal, and may involve criminal or regulatory proceedings for individuals.

• RightMatch remains committed to upholding the highest standards of integrity and ethics in all its interactions, ensuring a business environment that is free from corruption and bribery.