Anti-Bribery and Corruption Compliance Policy

1. Introduction

At GH2 India, we are committed to conducting all aspects of our business in an ethical,transparent, and responsible manner. This document outlines our Anti-Bribery and Corruption ABC) policy, procedures, and programs to ensure compliance with all applicable laws, regulations, and international standards.


2. Scope and Applicability

This policy applies to all employees, contractors, consultants, and any third parties representing or acting on behalf of GH2 India. The policy covers activities globally, regardless of location.


3. Policy Statement

GH2 India has a zero-tolerance approach to bribery and corruption. Employees and representatives are prohibited from offering, giving, soliciting, or accepting any form of bribe, whether monetary or non-monetary, directly or indirectly.


4. Compliance Framework

4.1 Governance

  • The Board of Directors oversees compliance with anti-bribery laws and regulations.
  • The Compliance Officer is responsible for implementing and monitoring the ABC program.

4.2 Training and Awareness

  • Regular training programs for employees and contractors on anti-bribery policies and procedures.
  • Distribution of the policy during onboarding and annual updates to all employees.

4.3 Due Diligence

  • Rigorous due diligence is conducted on all business partners, contractors, and suppliers to identify and mitigate bribery risks.

4.4 Reporting Mechanisms

  • Employees and third parties are encouraged to report concerns or violations through the whistleblowing hotline or email.
  • All reports are handled confidentially and without fear of retaliation.

4.5 Gifts, Hospitality, and Entertainment

  • Clear guidelines are provided on acceptable practices for gifts, hospitality, andentertainment.
  • All gifts or hospitality over a specific value must be pre-approved and recorded in the Gift Register.

4.6 Risk Assessments

  • Regular risk assessments are conducted to identify areas vulnerable to bribery and corruption.
  • Appropriate controls and measures are implemented to mitigate identified risks.


5. Procedures

5.1 Preventive Measures

  • Contracts with third parties include anti-bribery clauses.
  • Monitoring of financial transactions to detect irregularities.

5.2 Investigations

  • All reported concerns are promptly investigated by the Compliance Officer.
  • Appropriate actions, including disciplinary measures or legal proceedings, are taken against violators.


6. Penalties for Non-Compliance

  • Employees violating the anti-bribery policy face disciplinary action, including termination.
  • GH2 India will cooperate with authorities and support prosecution for bribery offenses.


7. Continuous Improvement

  • Regular review and updates of the policy to ensure alignment with evolving laws and best practices.
  • Independent audits to evaluate the effectiveness of the ABC program.


8. Contact Information

For questions or to report concerns related to this policy, please contact:

Email: team@gh2.org.in | Phone: +91-9894273991