Anti-Bribery and Corruption Policy

Metrisei Industrial Solutions LLP

Effective Date: 01-12-2024

1. Purpose

Metrisei Industrial Solutions LLP (hereinafter "the Company") is committed to conducting its business with the highest level of integrity, transparency, and compliance with all applicable laws and regulations. This Anti-Bribery and Corruption Policy (the "Policy") aims to set out the Company’s commitment to preventing bribery and corruption in all forms, both internally and externally.

2. Scope

This Policy applies to all employees, officers, directors, agents, consultants, contractors, and any third party acting on behalf of the Company (hereinafter referred to collectively as "Covered Persons").

3. Commitment to Compliance

The Company strictly prohibits bribery, corruption, and any other unethical business practices. All Covered Persons must comply with the following principles:

1. No Bribery: Covered Persons shall not offer, promise, give, request, or accept bribes or other illicit payments.
2. No Corruption: Covered Persons must not engage in any form of corrupt conduct, including improper influencing of business decisions, governmental actions, or individuals.
3. Compliance with Laws: Covered Persons are required to comply with all applicable anti-bribery and corruption laws in the jurisdictions where the Company operates.

4. Definition of Bribery and Corruption

1. Bribery: Offering, giving, receiving, or soliciting anything of value (money, gifts, services, or favors) with the intent to influence actions or decisions in favor of the giver.
2. Corruption: Abuse of power or influence for personal gain, whether direct or indirect, involving bribery or any form of unethical advantage.

5. Prohibited Conduct

The following activities are strictly prohibited under this Policy:

1. Offering or receiving bribes in any form, including cash, gifts, or other benefits intended to influence a business decision or governmental action.
2. Offering or accepting "facilitation payments" (small bribes to expedite routine actions).
3. Offering, giving, or receiving kickbacks or other illicit financial arrangements.
4. Engaging in improper political contributions or making any donations to political parties or candidates intended to influence business decisions.
5. Conducting business with third parties who engage in bribery or corruption.

6. Gifts and Hospitality

While legitimate business gifts and hospitality can be a normal part of business interactions, Covered Persons must ensure that:

1. Gifts or hospitality are modest, reasonable, and transparent.
2. Gifts or hospitality are not offered or accepted with the intent to influence a decision or obtain preferential treatment.
3. Gifts or hospitality must be disclosed to the Company, and approval must be obtained from a supervisor or relevant authority if there is any doubt regarding their propriety.

7. Due Diligence

The Company will conduct appropriate due diligence on potential partners, agents, contractors, and any third parties to ensure that they adhere to the same anti-bribery and corruption standards. This includes:

1. Assessing the reputation, financial standing, and history of compliance with anti-corruption laws of third-party entities.
2. Ensuring contracts with third parties include provisions that align with this Policy.

8. Reporting and Whistleblowing

Covered Persons have a responsibility to report any suspicions or knowledge of bribery, corruption, or unethical conduct. The Company provides various mechanisms for reporting concerns:

1. Whistleblower Hotline: Call to 6282853178
2. Email: info@metrisei.com
3. Direct Supervisor: Covered Persons may also report concerns to their direct supervisor or manager.

All reports will be treated with the utmost confidentiality, and the Company will not tolerate retaliation against anyone who reports misconduct in good faith.

9. Consequences of Violations

Failure to comply with this Policy may result in disciplinary action, including termination of employment or business relationships, as well as legal action. The Company will cooperate fully with law enforcement authorities in the investigation and prosecution of any criminal conduct related to bribery or corruption.

10. Training and Awareness

To ensure compliance with this Policy, the Company will provide regular training on anti-bribery and corruption practices. All Covered Persons are required to complete the training and demonstrate an understanding of the Policy’s contents.

11. Monitoring and Review

The Company will regularly review and update this Policy to ensure it remains compliant with applicable laws and continues to reflect best practices. The compliance team will monitor the effectiveness of the Policy and its implementation.

12. Questions

If you have any questions regarding this Policy or need guidance on how to proceed in specific situations, please contact [Vipin PR, Designated Partner].

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