I. PURPOSE

The anti-corruption laws in India, including The Prevention of Corruption Act, 1988, make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime. It subjects all concerned to fines and/or imprisonment. The purpose of this Policy is to ensure compliance by all employees, officers and office bearers of DVS, and its authorised representatives, with the related anti-corruption laws in India and elsewhere with which the organisation associates.

II. SCOPE

This Policy applies to all employees, officers and office bearers of DVS in India and elsewhere or any other person so authorised by DVS. This policy should be read in conjunction with DVS Code of Conduct and all other relevant policies in force.

III. POLICY

1. Bribes, Kickbacks or Other Corrupt Payments

1.1 It is the policy of DVS that, in working anywhere, all employees, officers and office bearers or any of its affiliates, must comply fully with applicable anti-corruption laws, especially The Prevention of Corruption Act, 1988.
1.2 DVS employees are prohibited from directly or indirectly offering, giving, soliciting or receiving any form of bribe, kickback or other corrupt payment, or anything of value, to or from any person or organisation, including government agencies, individual government officials, private companies and employees of those private companies.
1.3 No employee will be penalised on his or her refusal to pay a bribe.

2. Gifts and Hospitality

2.1 This policy does not prohibit gifts, entertainment, hospitality or other promotional expenditures (given and received) to or from third parties which are proportionate, transparent, reasonable and for bona fide purposes related to the aims and objectives of the DVS provided:
(a) it does not include cash or a cash equivalent (such as gift certificates or vouchers);
(b) it is appropriate in the circumstances. For example, it is given as a ceremonial gift on a festival or at another special time (e.g. Deepawali or New Year);
(c) taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
(d) it is given openly, not secretly.

2.4 It is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope or that this will influence the decisionmaking of the DVS or that a business advantage will be received, or to reward a business advantage already given.

3. Responsibilities

3.1 All employees, officers and office bearers must ensure that they read, understand and comply with this policy. All are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.2 Any employee, officer and office bearer who breaches this policy will face disciplinary action. for gross misconduct.
3.3 DVS reserve its right to terminate its contractual relationship with its partners, grant recipients, and associates if they breach this policy