Effective Date: May 27, 2025
Applies to: All employees, officers, directors, agents, contractors, consultants, and business partners globally.
Srinsoft Inc. commits to integrity, transparency, and zero-tolerance for corruption. This Policy enforces compliance with:
Applies globally to all Srinsoft personnel—including third parties. It represents a minimum standard: where stricter laws apply, they take precedence.
Bribery: Offering, promising, giving, soliciting, or receiving anything of value to influence business improperly—covering both public and private sector officials.
Facilitation Payments: Prohibited, even if customary in some jurisdictions, to expedite routine government tasks.
Red Flags: Examples include unusual payment practices, resistance to disclosures, unclear dealings.
A senior Compliance Officer (e.g., CFO or GC level) is appointed with direct reporting to the Board/a designated Director.
Must be modest, transparent, pre-approved above threshold, and never intended to influence decisions. Prohibit all political contributions unless Board-approved. Charitable donations must be vetted for legitimacy.
Enhanced due diligence for agents, consultants, suppliers—especially those interfacing with government or requesting introductions. Contracts must explicitly require anti-bribery compliance. Monitor activities and beware of red flags.
Accurate bookkeeping with no off-books transactions. Regular internal audits especially in high-risk areas.
Encourage timely reporting via secure, anonymous channels. No retaliation for good-faith reporting. Investigations overseen by Compliance Officer/Ethics Counsellor, with escalations to Board as appropriate.
Annual training on anti-corruption laws, corporate policies, red-flag detection. Communicated to employees and third parties.
Periodic risk assessments, audits, and compliance reviews by Ethics team or Internal Audit. Annual compliance reports submitted to Board/Directors.
Violations lead to disciplinary actions up to termination and possible criminal penalties. Facilitators, intermediaries, and company may be held strictly liable.
To be read together with the Code of Conduct, Whistleblower Policy, Gifts & Hospitality Policy, Third-Party Code, and any local compliance documents.