Anti Bribery & Anti Corruption Policy

Effective date: July 07, 2025

1. Purpose of This Policy
1.1 This anti-bribery policy outlines the responsibilities of Cloud in India and everyone associated with us to uphold our zero-tolerance approach to bribery and corruption.
1.2 It also serves as a guide for employees and affiliates, helping them identify, prevent, and address bribery or corruption issues, while understanding their obligations.

2. Policy Statement
2.1 Cloud in India is committed to conducting business ethically and transparently. We enforce systems to prevent bribery and corruption and maintain integrity in all business dealings, wherever we operate.
2.2 We comply with all applicable anti-bribery and corruption laws, including the UK Bribery Act 2010, both domestically and internationally.
2.3 We recognise that bribery and corruption carry severe penalties, including imprisonment and fines. Our company may face reputational damage, exclusion from public contracts, and unlimited fines if found complicit. Preventing bribery and corruption is therefore a critical legal and ethical responsibility.

3. Scope
3.1 This policy applies to all employees (permanent, temporary, fixed-term), contractors, consultants, trainees, interns, agency staff, volunteers, agents, sponsors, officers, trustees, board members, committee members, and third parties working with Cloud in India, both within the UK and internationally.
3.2 “Third party” includes clients, customers, suppliers, distributors, agents, advisers, government or public bodies, and their representatives or officials.
3.3 All third-party agreements include contractual provisions requiring compliance with minimum anti-bribery and corruption standards.

4. Definition of Bribery
4.1 Bribery involves offering, giving, receiving, or soliciting any item of value to influence a decision or action.
4.2 A bribe is any reward or advantage intended to secure a business, contractual, regulatory, or personal benefit.
4.3 Both giving and accepting a bribe is illegal. Employees must not engage in bribery directly, indirectly, or through third parties, including foreign public officials.

5. Acceptable vs. Unacceptable Practices
5.1 This section covers:
Gifts and hospitality
Facilitation payments
Political contributions
Charitable contributions

5.2 Gifts and Hospitality
Normal business gestures are permitted if they:
Do not intend to influence business decisions
Comply with local law
Are given in the company’s name
Are non-cash and of reasonable value
Are appropriate for the circumstances and disclosed to the compliance manager

5.3 If refusing a gift would cause cultural offense, it may be accepted but must be declared to the compliance manager.
5.4 Practices vary globally; disclosure to the compliance manager is always recommended.
5.5 Facilitation Payments and Kickbacks
Cloud in India prohibits facilitation payments and kickbacks, recognising them as forms of bribery.
5.6 In exceptional circumstances where refusal may threaten personal safety:
Keep payments minimal
Request a receipt
Record the payment
Report immediately to a line manager
5.7 Political Contributions
We do not make donations to political parties or candidates to gain business advantages.
5.8 Charitable Contributions
Charitable donations are encouraged but must be transparent, legal, and approved by the compliance manager, ensuring they are not used to conceal bribery.

6. Employee Responsibilities
6.1 Employees must read, understand, and comply with this policy and any training provided.
6.2 Everyone is responsible for preventing, detecting, and reporting bribery.
6.3 Suspected breaches must be reported to the compliance manager.
6.4 Breaches may result in disciplinary action or dismissal. Cloud in India may terminate contracts for non-compliance.

7. Raising Concerns
7.1 This section addresses:
How to report concerns
Actions if you are a bribery victim

Protections
7.2 Concerns should be raised promptly with a line manager, compliance manager, director, or Head of Governance and Legal.
7.3 Whistleblowing procedures allow employees to raise issues confidentially.
7.4 Victims of bribery must report incidents immediately.

7.5 Protections
Employees reporting concerns in good faith are protected from retaliation, including dismissal, disciplinary action, threats, or unfair treatment.

8. Training and Communication
8.1 Anti-bribery training is provided during induction and regularly thereafter. Employees are asked annually to confirm compliance with this policy.
8.2 The policy and zero-tolerance stance are communicated to all suppliers, contractors, and business partners.
8.3 Additional training is provided where employees may face bribery or corruption risks.

9. Record Keeping
9.1 Accurate financial records and internal controls are maintained. Gifts and hospitality are documented and subject to managerial review.

10. Monitoring and Review
10.1 The compliance manager monitors policy effectiveness and reviews its implementation regularly.
10.2 Internal controls are audited to ensure anti-bribery and corruption measures are effective.
10.3 Improvements are implemented promptly. Employee feedback is encouraged and directed to the compliance manager.
10.4 This policy is not part of an employee’s contract and may be updated at any time to enhance effectiveness.

Contact
For any questions about this policy, please contact us at info@cloudinindia.com