Anti-Bribery and Anti-Corruption Policy

Eternal General Service Foundation ("Company") strictly prohibits bribery and corruption in any form. Employees must comply with all applicable laws relating to gifts, bribery, corruption, facilitation payments and other improper payments. Even in countries where the local law does not prohibit such conduct, it is strictly prohibited for Employees to make any payment to any person or persons, including public or private officials, customers, merchants or employees or consultants or any other third party dealing with the Company to obtain or retain business, influence business decisions or secure an unfair advantage.

This Policy along with the Code of Conduct and other Eternal Foundation policies forms the foundation of a resilient culture- "To always be ready for the sunshine test"

The Eternal Foundation will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it operates. It remains bound by local, national and international laws.

Regulatory references:

This Policy complies with the requirements, as envisaged by various laws and regulations, as below, to administer good governance practices:

This Policy shall apply to all Employees, Volunteers, and Third Parties who are working with or on behalf of Eternal General Service Foundation.

Employee

Includes all directors, officers, employees, and interns engaged directly or indirectly, wherever located regardless of grade and position, in terms of all dealings and transactions in all regions where Eternal General Service Foundation operates.

Third party

Means any individual or organization who has business dealings with Eternal General Service Foundation and includes actual and potential business associates, donors, Non-Governmental Organisations (NGO), contractors, subcontractors, business partners, service providers, suppliers, distributors, business contacts, agents, and government bodies and officials or any other person associated with or acting on behalf of Eternal General Service Foundation.

The purpose of this Policy is to:

a. Bribe:

Bribery is offering, promising, giving, or accepting any financial or other advantages, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

You must not engage in any form of bribery, in dealings with any foreign/ public official, private party or any third party (such as an agent or intermediary) either directly or indirectly, in order to improperly influence any act or decision of a person, or to otherwise gain an improper benefit for the Company.

Bribe can take many forms, for example any offer, promise, receipt or payment of:

b. Corruption:

Corruption is the abuse of entrusted power or position for private gain. Great care must be taken in dealing with government officials. No gift or payment may be given to government officials, directly or indirectly, for the purpose of, or that appears to be for the purpose of, seeking favourable arrangements or action by such officials. Please check with the legal team before giving any gift or payment to any government official.

c. Kickback:

You must not make or accept kickbacks. Kickbacks are typically payments made in return for a business favor or advantage. A kickback is a form of corruption that involves two parties agreeing that a portion of their sales or profits will be kicked back (given back) to the purchasing party, in exchange for making the deal.

d. Facilitation payment:

You must not make facilitation payments. Certain countries may have a practice of 'facilitation payments', which are payments to government officials to expedite or ensure routine actions, such as issuing visas, work permits, licenses etc. We do not partake in any of these, nor do we allow Third parties acting on our behalf, such as merchants, vendors, agents, customers, consultants, alliance partners, suppliers and contractors to make any such payments.

e. Anything of value:

Include any benefits, favors or advantage (with no minimum amount or threshold). It may be in any form, tangible (such as cash or cash equivalents, hospitality, cars, jewelry, home improvements, travel, loans, shares, etc.) or intangible (such as inside information, stock tips and improper assistance in arranging a business transaction).

The clauses set forth in this Policy are applicable to all employees and third parties. It is therefore your responsibility to follow and adhere to all clauses described in this Policy. In countries where there are more stringent applicable laws, regulations or industry codes, Eternal requires compliance with the most restrictive requirement and the principles set out in this Policy shall stand superseded in those specific countries.

a. Gifts

This Policy does not prohibit normal, reasonable, appropriate, modest and bona fide corporate/ customary gifts (given and received), if its purpose is to improve the Company's image, present products and services or establish cordial relations. Few considerations, as below, to be kept in mind prior to giving or accepting gift(s).

If all the above conditions are met, then the employee should disclose in line with this Policy prior to giving or accepting such gift.

In addition to the foregoing standards, Employees must observe local laws and regulations, as well as applicable internal rules and policies that may be set by Eternal General Service Foundation, from time to time, with respect to giving and receiving gifts, entertainment, and other benefits.

This clause is to be read in conjunction with the Eternal General Service Foundation Conflict of Interest policy.

b. Hospitality (meals, entertainment and travel)

Eternal General Service Foundation appreciates hospitality, however, hospitality in the form of meals, entertainment and travel may be provided to anyone (including yourself or third parties or foreign/ public officials) or may be taken but should be in connection with a legitimate business purpose only. Meals, entertainment and travel are prohibited to family members or close business associates of Third parties or foreign/ public officials.

Meals, entertainment and travel expenses incurred in an effort to sell products or services or to influence/promote business, labor or governmental decision-making are strictly prohibited.

c. Claims by employees for payments made for gift, and hospitality:

Employees need to take prior approval for making payments for gifts and hospitality of third parties or foreign/ public officials as per this Policy. Reimbursement for such expenses incurred will only be processed if cost approval is raised on Zoho prior to incurring the expense, as per Company's guidelines mentioning details, such as name of the party entertained, recipient of the gift and hospitality and the business reasons for the gift or hospitality etc. The duly sanctioned pre-approval, together with original receipts / invoices, must be attached with the reimbursement claim.

d. Political contributions:

Eternal is Apolitical. We respect our right to engage in political activities in personal capacity, provided we do not act, or give the impression of acting, as a representative of the Company and do it solely in personal capacity. The Company will not make donations or contributions, whether in cash or kind, in support of any political parties or candidates.

e. Charitable contributions

Eternal endeavors to be a positive contributor to the development of the community and in this endeavor, it sponsors various community development programs and makes charitable contributions. Few considerations, as below, to be kept in mind prior to making any contribution or agreeing to sponsor an event:

We understand that various applicable anti-bribery and anti-corruption laws make Eternal responsible for the acts of our third parties and others acting on our behalf. Therefore, no third party, acting on behalf of Eternal may engage in any act that could be construed as bribery or corruption, whether using Eternal funds or their own personal funds or whether acting directly or through a middleman. Eternal expects all those acting on our behalf to abide by our standards of ethics and integrity and, where necessary and appropriate, to follow our procedures. While engaging with third parties, employees should ensure that they comply with Eternal's Anti-Bribery and Anti-Corruption Policy.

If any employee becomes aware that the third party is engaged in bribery or corruption, he/ she should immediately report his/her concern by writing to compliance@eternal.com.

This clause is to be read in conjunction with the third party risk management framework.

An Intermediary is a third party service provider, merchant, agent, consultant, distributor, contractor, vendor, supplier, or other third party, whether an individual or an entity engaged on a contract basis, or retained, in any business function that requires or involves interaction with any foreign/ public officials.

Due care must be taken in onboarding/ dealing with intermediaries:

Employees must follow all applicable standards, principles, laws, regulations, and Company practices for accounting and financial reporting;

Employees are mandated to complete all required training, instructor-led, or web based, related to the Code of Conduct, and the Policy in a timely manner. The Governance Risk & Compliance team is responsible for dissemination of the Policy and arranges training for Employees at the time of joining the Company and on a periodic basis thereafter.

The Eternal General Service Foundation's zero-tolerance approach to bribery and corruption shall be communicated to all Third parties at the outset of the Eternal General Service Foundation's association with them and as appropriate thereafter. Wherever possible, all such Third parties shall also be sent a copy of this Policy at the outset of the said business relationship and periodically throughout the term of the relationship.

It is your responsibility to ensure compliance with the Policy. Employees are encouraged to consult with the Governance, Risk and Compliance ("GRC") team to seek clarifications on any queries they may have. Anyone who witnesses a breach of this Policy is obliged to promptly speak up and escalate/ highlight via reporting channels (informant@eternal.com), as specified in the Code of Conduct.

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. Eternal General Service Foundation encourages openness and supports anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. If a violation of the relevant laws or policies is proven, appropriate action shall be taken.

Eternal General Service Foundation shall not tolerate retaliation in any form against anyone for raising concerns in good faith or reporting what they genuinely believe to be improper, unethical, or inappropriate behaviour. All reports shall be treated confidentially.

Eternal General Service Foundation is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that actual or potential bribery or other corruption offense has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, inform us immediately.

The Board of Directors shall be responsible for supervision of this Policy. Further, the GRC team conducts regular risk assessments to identify risks as part of Internal Audits and implement corrective actions (if any).

Breach of this Policy can lead to investigation and subsequent disciplinary and other actions up to and including termination of employment in accordance with Code of Conduct or Vigil Mechanism and Whistleblower policy.

Any waiver of this Policy requires prior written approval of the Board.

Any change in the Policy shall be approved by the Board of Directors.

The Board of Directors shall have the right to withdraw and/or amend any part of this Policy or the entire Policy, at any time, as it deems fit, or from time to time, and the decision of the Board in this respect shall be final and binding.

In any circumstance where the terms of this Policy are inconsistent with any existing or newly enacted law, rule, regulation or standard governing the Company, the said law, rule, regulation or standard will take precedence over this Policy.