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Compliance & Business Ethics Policy

1. Purpose

At GIT Software Technologies Ltd, we are committed to conducting business with integrity, transparency, and in full compliance with all applicable laws and regulations. This Compliance & Business Ethics Policy establishes our zero-tolerance approach to corruption, unethical practices, and improper payments.

This policy applies to all directors, employees, contractors, consultants, partners, and third parties acting on behalf of the company.

2. Anti-Corruption & Anti-Bribery Commitment

We strictly prohibit:

  • Bribery in any form, whether direct or indirect
  • Offering, promising, giving, requesting, or accepting anything of value to improperly influence a business decision
  • Facilitation payments or unofficial payments to secure routine governmental actions
  • Any corrupt practice involving private or public sector entities

We comply with applicable anti-corruption laws including:

  • UK Bribery Act 2010
  • Prevention of Corruption Act (India)
  • Other applicable international anti-corruption regulations

3. Business Ethics & Professional Conduct

We are committed to:

  • Fair competition and ethical market practices
  • Transparent contracting and procurement processes
  • Accurate financial reporting and record keeping
  • Avoidance of conflicts of interest
  • Respect for confidentiality and data protection

All employees are required to act honestly, fairly, and in the best interests of clients and stakeholders.

4. Commissions, Fees & Third-Party Payments

To prevent improper conduct:

  • All commissions, referral fees, and third-party payments must be legitimate, contractually documented, and approved by authorized management
  • No commission or fee may be paid to influence a government decision or procurement outcome
  • All payments must be supported by written agreements and proper invoices
  • Payments must be made through official banking channels — no cash or unofficial transfers

We conduct due diligence before engaging agents, consultants, or intermediaries.

5. Gifts, Hospitality & Entertainment

We recognize that reasonable business hospitality may occur in normal commercial relationships. However:

  • Gifts or entertainment must be modest, reasonable, and proportionate
  • Must not influence or appear to influence business decisions
  • Must comply with local laws and client policies
  • Must never be offered to Government Officials to secure improper advantage

Cash or cash equivalents are strictly prohibited.

Any gift or hospitality exceeding internal thresholds requires prior written approval from senior management.

6. Government Officials

Special care is taken when dealing with Government Officials. We strictly prohibit:

  • Offering gifts, hospitality, or anything of value to influence official decisions
  • Indirect payments through third parties
  • Political contributions intended to gain business advantage

All interactions with public authorities must be lawful, transparent, and properly documented.

7. Record Keeping & Financial Transparency

We maintain:

  • Accurate books and records
  • Proper internal controls
  • Transparent accounting practices
  • Audit-ready documentation

No undisclosed or unrecorded accounts are permitted.

8. Reporting & Whistleblower Protection

Employees and partners are encouraged to report any suspected misconduct, unethical behavior, or violation of this policy.

We provide:

  • Confidential reporting channels
  • Protection against retaliation
  • Prompt and impartial investigation of concerns

9. Training & Enforcement

We ensure:

  • Periodic awareness communication to employees
  • Policy acknowledgement by relevant personnel
  • Disciplinary action for violations, up to and including termination

10. Policy Governance

This policy is reviewed periodically and updated as necessary to ensure compliance with evolving legal and regulatory requirements.

For compliance-related inquiries, please contact:

Compliance Officer
GIT Software Technologies Ltd
Email: finance@gitsoftwaretech.com