Anti Corruption Policy

JFS Holdings Private Limited, including its affiliates and its subsidiaries, value honesty, transparency, integrity, and professionalism in dealings with suppliers, competitors, clients, government officials, and all other parties JFS Holdings Private Limited is involved in business dealings with.

JFS Holdings Private Limited including its affiliates and its subsidiaries value honesty, transparency, integrity, and professionalism in dealings with suppliers, competitors, clients, government officials, and all other parties JFS Holdings Private Limited is involved in business dealings with.

This Policy applies to all employees, officers, directors, and independent contractors of the Company. This document gives specific details on JFS Holdings Private Limited’s Policy prohibiting corruption in the performance of JFS Holdings Private Limited’s business operations and individual employee responsibilities for ensuring adherence to the Policy.

The goal is to inform Personnel of their anti-corruption obligations and to ensure compliance by Personnel with the JFS Holdings Private Limited’s Policy. It also provides information on how to identify

What is bribery? What is Corruption?

Bribery: Bribery refers to the act of offering, giving, receiving, or soliciting something of value with the intention of influencing the actions or decisions of an individual in a position of power or authority. It typically involves offering money, gifts, favors, or other benefits as a means to gain an unfair advantage or to manipulate outcomes.

Corruption: Corruption is a broader term that encompasses various dishonest or unethical practices, including bribery. Corruption involves the abuse of entrusted power for personal gain or to benefit others in exchange for illicit favors, kickbacks, or other advantages. It can manifest in different forms, such as embezzlement, fraud, nepotism, or abuse of public office, and undermines the fairness and integrity of institutions and systems

Policy

The Company’s Policy is to engage in business practices in full compliance with the anti corruption regulations with all other anti-corruption and anti-bribery laws and regulations applicable to the Company’s business anywhere in the world.

The Company has zero tolerance for any corruption in business activities. Bribes or other improper or unauthorized payments that directly or indirectly make, offer or promise to make, kickbacks, benefits, or advantages to any person, individual, organization, or entity, are prohibited by this Policy. A violation of this Policy can occur even if a bribe or other corrupt practice fails to achieve the desired outcome.

Personnel is expected to adhere to both the spirit and the letter of this Policy concerning all aspects of the Company’s business anywhere in the world. It is the responsibility of Personnel to be aware of how each situation may violate or lead to a violation of this Policy and Anti-Corruption Laws.

Gifts

Gifts are commonly offered as gestures of gratitude or tokens of appreciation, but in some situations, they can also be construed as bribes. The Company does allow gifts made in good faith, but they must comply with this Policy.

Personnel must ensure that any gifts are of value in proportion to the situation at hand, and any gifts should be infrequent to avoid being perceived as an attempt to influence an act or a decision. When offering or accepting a gift, Personnel should specifically consider the following:

The intended outcome: Gifts can have many purposes, such as expressing appreciation and building a relationship, but they can also be viewed as an attempt to influence a direct result, e.g., to win a bid or affect the negotiation process.
The Company’s reputation: The gift may be a private act, but if it were to come to the public’s attention, Personnel should consider how it would affect the reputation of the Company.
Competition: A general rule of thumb is to think about how the Company would perceive a similar gift made by a competitor.

Charitable donation policy

Our company supports charitable causes aligned with our values, such as education, healthcare, and social welfare. We evaluate donation requests based on criteria such as impact, transparency, and compliance. A designated committee reviews and approves donations, and we maintain records for transparency and accountability. We comply with all applicable laws and regulations and periodically review and update our policy.

Disciplinary Action

If Personnel should fail to comply with this Policy or Anti-Corruption Laws, they will be subject to disciplinary action up to and including termination of employment or other relationship with the Company. Restitution could also be required, and civil or criminal action against individual Personnel could be warranted.

If Personnel is involved in or aware of a situation they believe may violate or lead to a violation of this Policy, they must ask for guidance from their manager or other personnel in a superior position.

How do I raise concerns and seek out help or guidance?

If you have any questions or require further clarification regarding our Policy, please reach out to the Human Resources department of our organization.

Questions about the Policy or its applicability to particular circumstances should be directed to Madhushan Raigamage- Director/CEO of JFS Holdings Private Limited

Anti Corruption Policy