Anti-Corruption & Anti-Bribery Policy

MaquishTech Venture® Pvt Ltd ("we", "us", or "our") is a technology company based in India that works with clients worldwide. We are committed to conducting business honestly, ethically, and in compliance with all applicable anti-corruption laws. This policy sets out our standards and the responsibilities of everyone who works for or on behalf of us.

1. Zero Tolerance

We take a zero-tolerance approach to bribery and corruption in any form. No one acting for MaquishTech Venture® Pvt Ltd may offer, promise, give, request, agree to receive, or accept any bribe, kickback, or other improper advantage, directly or indirectly, to obtain or retain business or to influence any decision. This applies regardless of local custom, and no business opportunity justifies a breach of this policy.

2. Legal Framework

We comply with all anti-corruption, anti-money-laundering, and related laws that apply to our operations in India and to our cross-border work. These include, as applicable:

India

• The Prevention of Corruption Act, 1988, as amended by the Prevention of Corruption (Amendment) Act, 2018, including Section 8 (offence of giving a bribe to a public servant) and Section 9 (offence by a commercial organisation, against which having adequate procedures in place to prevent bribery is a defence);
• The Bharatiya Nyaya Sanhita, 2023, which replaced the Indian Penal Code, including its provisions on cheating, criminal breach of trust, and forgery;
• The Prevention of Money-laundering Act, 2002;
• The Companies Act, 2013, including Section 128 (books of account), Section 134 (Board's report, including details of frauds reported by auditors), Section 143(12) (reporting of fraud by auditors), and Section 177 (vigil mechanism), to the extent applicable to us;
• The Foreign Exchange Management Act, 1999;
• The Lokpal and Lokayuktas Act, 2013;
• The Foreign Contribution (Regulation) Act, 2010;
• The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015;
• The Prohibition of Benami Property Transactions Act, 1988; and
• For public procurement and tenders, the guidelines of the Central Vigilance Commission (including Integrity Pacts where required) and the code of integrity under the General Financial Rules, 2017.

Cross-border

• The UK Bribery Act 2010, including Section 7 (failure of commercial organisations to prevent bribery), where it applies to our work;
• The US Foreign Corrupt Practices Act of 1977, including its anti-bribery and books-and-records provisions, where it applies to our work;
• The principles of the United Nations Convention against Corruption (UNCAC), which India has ratified;
• The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, as implemented by the laws of states that are party to it, when we work with partners or clients there; and
• The local laws of the countries where we serve clients, for example the UAE Federal Decree-Law No. 31 of 2021 (the Crimes and Penalties Law), Singapore's Prevention of Corruption Act 1960, Australia's Criminal Code Act 1995 (including the foreign bribery offences as amended in 2024 to add a failure-to-prevent offence), and Canada's Corruption of Foreign Public Officials Act.

Where more than one law applies, or where local law and this policy differ, we follow the strictest applicable standard. This policy is a statement of our internal standards; it is not legal advice and does not represent any external certification.

Sanctions, export controls, and anti-money-laundering

We screen clients, partners, agents, and suppliers, in proportion to risk, against applicable sanctions and export-control restrictions, including United Nations Security Council sanctions and, where relevant to a transaction, those of India, the United States, the United Kingdom, and the European Union. We do not knowingly deal with sanctioned persons or facilitate prohibited exports, and we do not accept or make payments that we suspect relate to money laundering, terrorist financing, or tax evasion. Unusual payment requests are escalated and reviewed before proceeding.

3. Scope

This policy applies to all directors, officers, employees (permanent, temporary, or part-time), interns, contractors, consultants, partners, agents, and any other person or organisation acting on our behalf, wherever they are located.

4. Facilitation Payments

We do not make or permit facilitation payments ("grease payments") — small unofficial payments made to speed up or secure routine government actions. The only exception is where a person faces an imminent threat to their health, safety, or liberty; any such payment must be reported to management immediately and recorded accurately.

5. Gifts and Hospitality

Reasonable and proportionate gifts and hospitality can be a normal part of building business relationships, but they must never be used to influence a decision improperly. Any gift or hospitality given or received must be:

• modest in value and appropriate to the occasion;
• infrequent, and not given or received during a tender, negotiation, or pending decision involving the other party;
• given openly, never in cash or cash equivalents (such as vouchers or gift cards);
• permitted under the recipient's own rules and local law; and
• recorded and disclosed to management.

If in doubt, decline the gift or hospitality and seek guidance before proceeding.

6. Conflicts of Interest

Everyone covered by this policy must avoid situations where personal, financial, or family interests conflict, or appear to conflict, with the interests of MaquishTech Venture® Pvt Ltd or our clients. Any actual or potential conflict must be disclosed promptly so that it can be managed appropriately.

7. Public Officials and Tenders

Extra care is required when dealing with public officials, government bodies, state-owned enterprises, and public tenders. We do not offer anything of value to a public official to influence an official act or decision. We participate in tenders honestly, submit accurate information, and do not seek or use confidential tender information improperly, collude with other bidders, or engage in bid rigging.

8. Third-Party Due Diligence

We may be held responsible for the actions of those who act on our behalf. Before engaging agents, resellers, consultants, subcontractors, or partners, we carry out due diligence proportionate to the risk, expect them to adhere to standards consistent with this policy, and include appropriate anti-corruption terms in our agreements where relevant. Any red flags — such as requests for unusual payments, commissions, or payments to third parties or offshore accounts — must be reported and resolved before proceeding.

9. Accurate Books and Records

We keep complete and accurate books, records, and accounts that fairly reflect all transactions. No undisclosed or unrecorded accounts, false invoices, or misleading entries are permitted. All payments, gifts, hospitality, and expenses must be properly documented and approved.

10. Political and Charitable Contributions

We do not make political contributions on behalf of the company to obtain a business advantage. Any charitable donation or sponsorship must be lawful, transparent, approved by management, recorded accurately, and never used as a disguised bribe.

11. Training and Awareness

We communicate this policy to everyone it covers and provide anti-corruption guidance and training appropriate to their role, including at onboarding and when the policy is updated.

12. Reporting Concerns

Anyone who suspects or becomes aware of a breach of this policy, or who is asked to make or accept an improper payment, should report it as soon as possible. Concerns can be raised in confidence by email to business@maquishtechventure.com with the subject line "Anti-Corruption Concern". Reports will be reviewed promptly, confidentially, and fairly.

13. Non-Retaliation

We will not tolerate retaliation, victimisation, or any detrimental treatment against anyone who raises a concern in good faith or refuses to take part in bribery or corruption, even if this results in a loss of business. We protect the identity of whistleblowers to the extent permitted by law, in line with applicable whistleblower and vigil-mechanism requirements.

14. Consequences of Breach

Any breach of this policy is a serious matter. For employees, it may lead to disciplinary action up to and including dismissal. For contractors, partners, and agents, it may lead to termination of the relationship. Breaches may also be reported to the relevant authorities and may result in civil or criminal penalties for the individuals involved.

15. Company Safeguards and Enforcement

This policy applies equally to everyone within its scope, including the directors and founders of MaquishTech Venture® Pvt Ltd. No person is exempt.

• Adequate procedures. MaquishTech Venture® Pvt Ltd maintains this policy and the associated procedures as adequate procedures designed to prevent bribery by persons associated with it. Any act of bribery or corruption by any individual is that individual's own act, done outside the scope of their authority and contrary to the company's express instructions.
• No authority to bribe. No director, employee, contractor, partner, agent, or other person is authorised to offer, pay, solicit, or receive a bribe or any improper advantage on behalf of MaquishTech Venture® Pvt Ltd, and any such act will not be ratified by the company.
• Enforcement. The company may suspend, investigate, discipline, or terminate the engagement or employment of any person who breaches this policy, recover any losses, costs, or damages caused by the breach, and report the matter to the appropriate law enforcement or regulatory authorities.
• Third-party commitments. Partners, agents, contractors, consultants, and vendors are required, where appropriate, to give written anti-bribery and anti-corruption warranties and to indemnify MaquishTech Venture® Pvt Ltd against losses arising from their breach. The company may audit their compliance and may terminate their contracts with immediate effect in the event of a breach or a reasonable suspicion of one.
• No third-party rights. This policy is an internal statement of standards. It does not create any contractual rights for any third party, and it does not form part of any employee's contract of employment unless expressly stated.
• Investigations. All investigations are conducted confidentially and are overseen by the Board of Directors, or by persons appointed by it. The Board of Directors has final authority over the interpretation and application of this policy and discretion over the outcome of any investigation, subject always to applicable law.
• Good-faith reporting. Concerns raised honestly and in good faith are protected, even if they turn out to be mistaken. However, allegations against the company, its directors, or its staff that are knowingly false, malicious, or made for personal gain will result in disciplinary and/or legal action.
• Amendments. MaquishTech Venture® Pvt Ltd reserves the right to amend, update, or replace this policy at any time. The version published on this website is the current version.
• No admission. Nothing in this policy constitutes an admission of liability by MaquishTech Venture® Pvt Ltd or any of its directors, employees, or associated persons.

16. Governing Law and Jurisdiction

This policy is governed by the laws of India. Subject to any mandatory law to the contrary, the courts at Gorakhpur, Uttar Pradesh, India shall have exclusive jurisdiction over any matter arising from it.

17. Review

This policy is effective from 20 October 2026. It is reviewed at least annually, and updated as needed to reflect changes in law and in our business. This policy is reviewed periodically; if you have any questions about it, please contact us at business@maquishtechventure.com.