Anti-Bribery & Anti-Corruption Policy

1. Purpose

SSMTB Software Services Pvt Ltd is committed to conducting its business with honesty, integrity,
and transparency. This Anti-Bribery & Anti-Corruption Policy establishes the company’s
commitment to preventing bribery, corruption, and unethical practices in all business dealings.
The policy ensures that all employees, representatives, and business partners comply with
applicable anti-corruption laws and maintain the highest standards of ethical conduct.

2. Scope

This policy applies to:
• All employees of SSMTB Software Services Pvt Ltd
• Directors and management personnel
• Contract consultants and recruiters
• Business partners and vendors
• Any third party acting on behalf of the company
All individuals associated with the company must comply with the standards outlined in this policy.

3. Definition of Bribery and Corruption

Bribery refers to offering, giving, receiving, or soliciting anything of value in order to improperly
influence a business decision or gain an unfair advantage.
Corruption refers to misuse of authority or position for personal or business gain through unethical
or illegal means.
Examples may include:
• offering payments or gifts to secure contracts
• accepting benefits to favor a vendor or candidate
• facilitating improper business advantages

4. Zero-Tolerance Policy

SSMTB Software Services Pvt Ltd maintains a strict zero-tolerance approach towards bribery and
corruption.
Employees and representatives must not:
• offer bribes or improper payments
• accept gifts or benefits that influence business decisions
• engage in fraudulent or corrupt activities
• misuse company resources for personal gain
All business activities must be conducted transparently and ethically.

5. Gifts, Hospitality and Business Courtesies

Reasonable business hospitality and professional courtesies may be acceptable when they are
modest, transparent, and do not influence business decisions.
However, employees must not:
• offer or accept excessive gifts
• provide financial benefits to influence contracts or hiring decisions
• accept gifts that may create a conflict of interest
Any gifts or hospitality that may raise ethical concerns must be disclosed to company management.

6. Conflict of Interest

Employees must avoid situations where personal interests conflict with the interests of the
company.
Examples of conflicts of interest include:
• personal financial relationships with vendors or clients
• favoritism toward candidates or partners
• using company position for personal advantage
All potential conflicts of interest must be disclosed to management immediately.

7. Third-Party Compliance

SSMTB Software Services Pvt Ltd expects all third-party partners, vendors, and contractors to
operate with the same ethical standards as the company.
Before engaging with external partners, the company may evaluate their ethical practices and
ensure they do not engage in corrupt activities.
Third-party partners acting on behalf of the company must comply with this policy.

8. Reporting Concerns

Employees and partners are encouraged to report any suspected bribery, corruption, or unethical
activities.
• Reports may include:
• suspected bribery attempts
• unethical vendor practices
• conflicts of interest
• misuse of company funds or authority
All reports will be reviewed confidentially and investigated appropriately.
The company is committed to protecting individuals who report concerns in good faith.

9. Record Keeping and Transparency

SSMTB Software Services Pvt Ltd maintains accurate and transparent financial records and
documentation for all business transactions.
Employees must ensure that:
• all payments are properly documented
• Financial Records accurately reflect transactions
• company resources are used responsibly
Misrepresentation of financial records is strictly prohibited.

10. Training and Awareness

SSMTB Software Services Pvt Ltd encourages employees to maintain awareness of ethical
business practices and compliance standards.
Management will promote ethical conduct and ensure that employees understand their
responsibilities under this policy.

11. Policy Violations

Any violation of this Anti-Bribery & Anti-Corruption Policy may result in disciplinary action,
termination of employment or association, and legal consequences where applicable.
SSMTB Software Services Pvt Ltd takes all allegations of bribery or corruption seriously and will
investigate any reported concerns.

12. Policy Review

This policy will be reviewed periodically to ensure it remains aligned with legal requirements,
international standards, and best business practices.
Updates may be made to strengthen the company’s commitment to ethical conduct.
Declaration
SSMTB Software Services Pvt Ltd is committed to maintaining the highest standards of integrity,
transparency, and ethical conduct in all business activities.
The company strictly prohibits bribery, corruption, and unethical practices and expects all
employees and partners to uphold these principles.