-------------------------------------------------- DRAFT FOR ATTORNEY REVIEW ONLY — NOT LEGAL ADVICE This Anti-Bribery Policy is a preparation draft only. Obligations and penalties under Indian anti-corruption law must be confirmed with a qualified Indian attorney. Adopting a policy does not by itself prevent or excuse bribery. Senior management of Bharat Infra Projects Pvt Ltd remain responsible for compliance. -------------------------------------------------- 1. DOCUMENT HEADER ANTI-BRIBERY AND CORRUPTION POLICY — DRAFT FOR ATTORNEY REVIEW Organization: Bharat Infra Projects Pvt Ltd Version: 1.0 Effective Date: to be confirmed by the organization Policy Owner: Chief Compliance Officer Approved by: the Board 2. PURPOSE AND SCOPE This policy protects the company from bribery and corruption in its road and bridge contract work. It applies to all directors, officers, employees, contractors, and agents acting for the company. 3. POLICY STATEMENT The company has zero tolerance for bribery. No one may give, offer, promise, request, or accept a bribe, directly or through another person, for any reason. 4. KEY DEFINITIONS Bribe: anything of value offered to influence a decision improperly. Public official: anyone working for or acting for a government body. Facilitation payment: a small payment to speed up a routine government action. Associated person: anyone who acts for the company, such as an agent. Gift and hospitality: items or entertainment given or received. Conflict of interest: a personal interest that may affect a business decision. 5. LEGAL FRAMEWORK This policy refers to the Prevention of Corruption Act 1988 as amended in 2018, the Bharatiya Nyaya Sanhita 2023, and the Companies Act 2013. The Central Vigilance Commission is named as a relevant body. Breach may lead to criminal penalties, fines, imprisonment, debarment, and reputational harm. Law and penalties must be confirmed by a qualified attorney. 6. PROHIBITED CONDUCT You must not bribe a public official, pay or take kickbacks, pay a bribe through an agent, or accept a bribe from a supplier. 7. GIFTS AND HOSPITALITY Gifts above INR 5,000 need Compliance approval. No gifts or hospitality may be given to public officials. All gifts must be entered in the gift register. Cash and cash equivalents are never allowed. 8. FACILITATION PAYMENTS The company does not allow facilitation payments. If asked to pay one, refuse and tell Compliance. If your safety is at risk, protect yourself first and report as soon as possible. Legal treatment of these payments varies and must be confirmed. 9. POLITICAL AND CHARITABLE CONTRIBUTIONS Political donations need Board approval. Charitable gifts and sponsorships to be confirmed by the organization. 10. THIRD PARTIES AND DUE DILIGENCE Agents used for permits must pass due diligence before appointment. Each agent contract must include an anti-bribery clause. Payments to agents must match the contract. 11. RECORDS AND FINANCIAL CONTROLS All transactions must be accurately recorded. False or hidden entries are not allowed. Records are kept for 8 years. 12. RISK ASSESSMENT Risk is assessed for each project and government body. The review is repeated every year. 13. REPORTING CONCERNS AND NON-RETALIATION Report concerns to the ethics hotline or ethics@bharatinfra.example. Anonymous reports are allowed. No one will face retaliation for a good faith report. 14. INVESTIGATION AND DISCIPLINE Reports will be investigated promptly and fairly. Breaches may lead to dismissal and referral to authorities. 15. TRAINING AND COMMUNICATION All staff and agents receive training every year. The policy is shared on joining and after each update. 16. MONITORING AND REVIEW Compliance monitors this policy and the policy is reviewed every year. Next review: to be confirmed by the organization. 17. SENIOR MANAGEMENT RESPONSIBILITY The Board and senior management set the tone, provide resources, and oversee compliance. 18. GOVERNING LAW AND APPROVAL Maharashtra, India law applies. Approved by the Board: ________________ Date: ________________ PLAIN ENGLISH SUMMARY This policy says the company never uses bribes to win work. You must never offer or take anything to influence a decision, and you may not give gifts to public officials. Gifts above INR 5,000 need approval and must be recorded. Agents must pass checks and sign anti-bribery terms. Report concerns to the hotline. You may report anonymously and you will be protected from retaliation. An attorney must confirm the legal points before the policy is adopted. ANTI-BRIBERY CHECKLIST (planning aid only) - Board approval recorded - Risk assessment completed - Gift register started - Agent due diligence process set - Contract clauses added - Hotline live - Training done and recorded - Review date set WHAT TO CONFIRM BEFORE ADOPTING 1. The current anti-corruption laws and penalties that apply. 2. The treatment of facilitation payments. 3. Corporate liability for agents and other associated persons. 4. Gift limits and any local rules. 5. Whistleblower protection law. 6. Attorney review of the full policy. -------------------------------------------------- This Anti-Bribery Policy draft was generated by an AI drafting tool as a structured preparation and documentation aid only. It does not constitute legal advice, does not guarantee compliance with any law, and does not by itself prevent or excuse bribery. Always have it reviewed by a qualified attorney before adoption. --------------------------------------------------