NVALIA GROUP

ABC Policy

Anti-Bribery and Corruption Policy

1. Introduction

1.1 Purpose The purpose of this Anti-Bribery and Corruption Policy (“Policy”) is to outline the commitment of NVALIAGROUP (“NVALIAGROUP” or the “Company”) to maintaining the highest standards of ethical behavior, transparency, and integrity in all our business operations. This Policy is designed to prevent bribery and corruption in any form within NVALIAGROUP and to comply with applicable anti-bribery and corruption laws and regulations, including but not limited to the Prevention of Corruption Act, 1988, and the Prevention of Money Laundering Act, 2002, of India.

1.2 Applicability This Policy applies to all employees, contractors, agents, consultants, suppliers, and any other individuals or entities acting on behalf of NVALIAGROUP (collectively referred to as “Covered Persons”).

2. Principles

2.1 Zero Tolerance NVALIAGROUP has a zero-tolerance approach to bribery and corruption. We prohibit all forms of bribery, whether direct or indirect, and expect all Covered Persons to adhere to this principle in all business dealings, both domestically and internationally.

2.2 Compliance with Applicable Laws NVALIAGROUP is committed to complying with all relevant anti-bribery and corruption laws and regulations applicable in India and any other jurisdictions where we conduct business. Covered Persons are expected to be aware of and comply with these laws.

2.3 Ethical Business Conduct All Covered Persons are expected to conduct themselves with the highest standards of ethics and integrity in all business transactions and interactions. This includes avoiding any behavior that could be perceived as corrupt or unethical.

2.4 Gifts, Entertainment, and Hospitality NVALIAGROUP recognizes that business relationships may involve giving or receiving gifts, entertainment, or hospitality. However, such gestures must be reasonable, transparent, and in accordance with local customs and laws. Any gifts or entertainment offered or received must not influence, or be perceived to influence, business decisions.

2.5 Reporting Suspected Violations NVALIAGROUP encourages all Covered Persons to promptly report any suspected violations of this Policy. Reporting can be done through established channels, such as the Company’s whistleblowing mechanisms, HR department, or directly to senior management.

3. Responsibilities

3.1 Senior Management Senior management is responsible for setting the tone at the top and ensuring that the principles of this Policy are communicated and enforced throughout the organization. They are also responsible for promptly addressing reported violations and taking appropriate action.

3.2 All Covered Persons All Covered Persons have a duty to familiarize themselves with this Policy and to act in accordance with its principles. This includes reporting any concerns they may have about bribery or corruption within the Company.

4. Training and Awareness

NVALIAGROUP will provide training and awareness programs to ensure that all Covered Persons understand the requirements of this Policy and can recognize potential bribery and corruption risks. Regular training and updates will be conducted as necessary.

5. Consequences of Violations

Violations of this Policy will not be tolerated, and appropriate disciplinary action will be taken against individuals found to have engaged in bribery or corruption, which may include termination of employment or contractual relationships. NVALIAGROUP may also report violations to the appropriate authorities.

6. Conclusion

NVALIAGROUP is committed to conducting its business with honesty, integrity, and transparency. This Anti-Bribery and Corruption Policy underscores our dedication to preventing bribery and corruption in all aspects of our operations. We expect all Covered Persons to actively support and adhere to this Policy in the pursuit of our business objectives.

This Policy is subject to periodic review and updates to ensure its continued relevance and effectiveness.

Date: 22nd September, 2023

Authorized by: Nandan Valia, Director, NVALIA GROUP