Anti-Corruption Policy

This policy is designed to:

• Set out the commitment of Meeram Technologies to conduct business ethically
• Ensure compliance with anti-corruption and anti-bribery laws
• Guide employees and business partners on handling potential corruption and bribery

The policy applies to:

• All representatives of Meeram Technologies worldwide, including board members and employees
• Joint ventures, contractors, suppliers, consultants, agents and other business partners
• Any entity or individual conducting business on behalf of Meeram Technologies

Meeram Technologies prohibits:

• Bribery, kickbacks, facilitation payments and corrupt hiring practices
• Soliciting, receiving, giving or offering anything of value to influence a decision or gain unfair advantage
• Offering or accepting gifts, hospitality or entertainment intended to influence business decisions or relationships

We recognise that modest hospitality and reasonable gifts can be a normal part of building business relationships. Where they occur, they must follow these guidelines:

• Gifts and hospitality — reasonable in both value and frequency, and never such that they could influence a business decision. Cash and cash equivalents, including gift cards, are strictly prohibited.
• Entertainment — in line with industry norms, never lavish or inappropriate. Extra caution applies when dealing with government officials.
• Sponsored travel — only for legitimate business purposes, and only with senior management approval.

Facilitation payments, typically made to expedite government action, are strictly prohibited even in countries where the practice is common. An exception applies only where an employee’s safety or security is at risk.

Every employee and third party representing the company is responsible for complying with this policy, and is obliged to:

• Keep accurate records of all transactions and maintain formal documentation
• Report any incident or suspicion of corruption or bribery promptly, through the appropriate channels
• Stay familiar with this policy and any changes to it

Employees and business partners are encouraged to report suspected violations through our “Speak Up” programme, which allows concerns to be raised in confidence. No retaliatory action will be taken against anyone who raises a concern.

Non-compliance will result in disciplinary action, up to and including termination of employment. Individuals involved in criminal conduct may also face fines or imprisonment under local law.

Meeram Technologies reviews and updates this policy periodically to keep pace with evolving law and best practice. Changes are communicated to employees promptly.