IT Quality Policy

Anti-Bribery & Corruption Policy

1. Policy Statement

• OLAK Technologies Private Limited (“OLAK”) supports the national anti-bribery and anti-corruption effort by establishing and upholding good corporate governance and continuously inculcating good ethical business practices among its directors, employees, service provider and other business partners.
• In line with this commitment, OLAK has developed its Anti-Bribery & Anti-Corruption Policy.
• All members of the Board of Directors, staff and related parties must uphold the highest standard of integrity and accountability in discharging their duties and to ensure that all activities, offer, or services are conducted in compliance with this Policy and all other applicable legal and regulatory requirement on anti-bribery and anti-corruption.
• Normally Annual Maintenance Contract (AMC) is singed by the Customer

2. Definitions

• The following definitions are included in this Policy.
• Bribery: Bribery is defined as any action which would be considered as an offence of giving or receiving ‘gratification’. In practice, this means offering, giving, receiving, or soliciting something of value to illicitly influence the decisions or actions of a person, in a position of trust within an organisation.
• Gratification: Means
  (a) money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;
  (b) any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
  (c) any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;
  (d) any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;
  (e) any forbearance to demand any money or money’s worth or valuable thing;
  (f) any other service or favour of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and
  (g) any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f).
• Board: Board Means the Board of directors of the Company and which shall include all independent and non- independent directors, executive and non-executive directors of OLAK.
• The areas covered under this Policy are as follows:

3. Conflict of interest

• OLAK conducts its business according to the principle that it must manage conflicts of interest fairly.
• OLAK may face actual and potential conflicts of interest from time to time.
• OLAK policy is to take all reasonable steps to maintain and operate effective organizational and administrative arrangements to identify and manage relevant conflicts.
• It is stated in the OLAK Employee Agreement that employees should exercise caution in their personal relationships with customers, suppliers, competitors, or businesses introduced or affiliated with a customer or supplier.
• This is to ensure there is no involvement of obligations that may prejudice or influence the business relationship or result in any conflict with their duties.
• If a conflict of interest arises between employees and a third party, the employees or the relevant department head should be made aware of the conflict, where appropriate, and inform the Senior Management.
• Should a conflict of interest arise, it must be managed promptly and fairly
• OLAK has in place arrangements and/or procedures designed to ensure that:
  • There is control of the flow of information where, otherwise, the risk of a conflict may harm the interests of a customer.
  • There is prevention of trading activities that harm the interests of a customer.
  • Appropriate and adequate disclosures to customers to enable the customer to make an informed decision.
  • Staff declares the gifts and entertainment received, their external engagements and appointments.
  • Where necessary, exclusion of certain persons from working on a specific transaction, business activity or participating in the management of a potential conflict of interest.

4. Gifts and Entertainment

• Care should be exercised in the giving and receiving of business-related gifts/entertainment from customers, business partners and third-party suppliers.
• The act of giving or receiving these gifts must not carry any intention or obligation or expectation of favors
• The Company’s aim is to deter givers of gifts from seeking or receiving special favors from OLAK employees.
• Accepting any gift of more than nominal value or entertainment that is more than a routine social amenity can appear to be an attempt to influence the recipient into favoring a particular customer or vendor.
Gift
• The acceptance of gifts under inappropriate circumstances may also amount to Bribery and/or a criminal act. Accepting gifts shall be guilty of an offence if he corruptly receives or gives a Gratification (whether in the form of cash, employment, business opportunities, favours or otherwise) as an inducement or reward to a person to do or not to do any act.
• To avoid the reality, the appearance that business judgement may be improperly influenced or compromised and to protect the staff from any perception of improper conduct or conflicts of interest, employees should observe the following guidelines when deciding whether to accept gifts.
  • Where circumstances make it impossible, difficult, or impractical to reject gift or where the rejection of the gift may affect the relationship with the customers or business associates (other than cash or cash equivalent) or rejecting them is deemed as offensive given the local custom, you may accept the gift(s). If accepted, it is deemed to have been accepted on behalf of the Company and become the property of the Company. The use of the gift is to be determined by the OLAK Management team.
  • Consumables like food gifts and hampers at nominal value will not need to be declared but instead be shared within the company staff.
  Entertainment
• The employee should obtain approval from his or her supervisor for business entertainment extended to the employee. As a guide, business meals are acceptable.
• The following need not be declared:
• Annual dinner/ gala dinner/ cocktail events which are also attended by employees or other companies / organizations.
• Working lunches and other meals including those following / preceding official meetings
• Invitations to official opening ceremonies / seminars
• Business entertainment that might compromise the employee’s ability to or appear to hinder his or her duties in a professional manner should not be accepted. The following deemed inappropriate
• Overseas trips in the form of paid holidays or holiday incentives.
• Accepting invites or tickets by the employee when the prospective host will not be present at the event with the employee.
• If there are doubts as to whether business entertainment might create the appearance of any conflict or impropriety, these situations can be referred to Senior Management or Chief Executive Officer (CEO)

5. Donations and Sponsorships

• OLAK is permitted to provide donation or sponsorship provided it comply with following:
  • Ensure such contribution is allowed by applicable laws.
  • Obtain all necessary authorization (where required)
  • Be made to well established entities having an adequate organizational structure to guarantee proper administration of the funds;
  • Not to be used to cover up an illegal payment or bribery.
• OLAK ensure that such contribution is recorded in the Company’s books and/or records properly.
• OLAK shall not make political contribution from the Company’s resources to any political party, political candidate, or political campaign.

6. Facilitation Payments

• OLAK adopts a strict stance that disallows facilitation payments or other provision made personally to an individual in control or a process or decision.
• Employees are expected to notify their immediate superior when encountered with any requests for a facilitation payment.
• In addition, if a payment has been made and employees are unsure of the nature, their immediate superior must be immediately notified and consulted.
• They must also ensure that the payment has been recorded transparently.

7. Financial Controls

• OLAK has established proper approval process to disburse any payment to any party.
• The Company’s internal operational manual illustrated clear responsibilities and approval matrix of authorised officer in the Company to approve its purchase or payment or other expenditure.

8. Non-financial Controls

• Due diligence shall be undertaken with regards to any service provider intending to act on OLAK behalf/ act for OLAK.
• The extent of the due diligence will be risk-based and shall include a bribery risk assessment.
• Due diligence may include a search through relevant databases, checking for relationships with public officials, and documenting the reasons for choosing one service provider over another.
• OLAK expects all service providers acting on behalf of the Company to contractually agree to refrain from bribery and corruption practices, and to adhere to the Policy.
• Due diligence, and background checks during staff recruitment and on an ongoing basis, to be satisfied that they are fit and proper persons who have the necessary

9. Record Keeping

• OLAK shall maintain documentation related to the adequate procedure for 7 years
• As a measure to satisfy the requirement of document retention, any disposal of relevant documents will require consent and approval from OLAK Chief Executive Officer CEO.
• Each department should inform CEO and obtain his prior approval for any disposal of relevant documents.

10. Awareness and Training

• OLAK will conduct a training session for all new staff within the first month of their employment.
• For all existing staff, refresher training on anti-Bribery and anti-corruption measures will be held once a year.

11. Whistleblowing policy and Reporting Channel

• OLAK is committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements and any legislation relating thereto.
• Whistleblowing Policy is created to encourage employees to raise concerns, in confidence about possible irregularities while being protected from reprisals or victimization for whistleblowing in good faith.
• The key objectives of the Whistleblowing Policy are to:
  • Discourage wrongdoing and to promote standards of good corporate practices.
  • Provide proper avenues for employees to raise concerns about actual or suspected improprieties in matters of financial reporting or other matters and receive feedback on any action taken.
  • Give employees the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
• A whistle blower may also report on any suspected and/or real corruption incidents or inadequacies to CEO via secured reporting channels: email or SMS or WhatsApp or voice call
• Each Employee has a responsibility to ensure that suspected bribery and corruption incidents are reported promptly.
• Reports made in good faith, either anonymously or otherwise, shall be addressed in a timely manner and without incurring fear of reprisal or victimization regardless of the outcome of any investigation.

12. Disciplinary action for non-compliance

• Cases of misconduct or gross misconduct will be dealt with according to internal procedure.
• The procedure is designed to ensure that all staff are dealt with fairly.
• It does not form part of the contract of employment or otherwise have contractual effect.
• OLAK regards bribery and corruption as a serious matter. Non-compliance may lead to disciplinary action, up to and including termination of employment depending on the seriousness of the situation, the Company may decide at its sole discretion.
• OLAK shall notify the relevant regulatory authority if any identified bribery or corruption incidents have been proven beyond reasonable doubt.
• Further legal action may also be taken if the OLAK’s interests have been harmed because of non-compliance.
• OLAK is committed to continually improving its Policy and to develop further integrity measures and enhance its anti-Bribery and anti-corruption procedures.
• Any deviation or waiver from this Policy must be approved by the Board.
• OLAK shall make this Policy available to both internal and relevant external parties.

- End of 21: Anti-Bribery & Anti-Corruption Policy –

1. General

• OLAK is committed to the prevention of pollution and the protection of the environment and recognizes that this is in the best interests of the organization, it’s employees and stakeholders, and that it contributes to a better quality of life, now and for future generations including helping our customers use information technology to meet environmental challenges.
• OLAK activities, even though within the professional services industry, have an environmental impact at local, national and global levels, so it acknowledges that even small contributions to the preservation of the environment are important to pursue. It endeavours to conduct all business activities and operations in line with best environmental practice and seeks continual improvement in all activities.
• Taking account of our business needs, customer requirements and the desire to minimize adverse impacts on the environment, we maintain our products, run our business operations and develop products in a responsible manner.
• OLAK’s primary environmental impacts relate to: the company’s own energy consumption as well as the energy consumption of its hardware products; the disposition of its hardware products at the end of their useful life; vendor and supply chain management; business travel; and the consumption of natural resources through its own activities and its procurement processes.
• Striving to reduce business travel and promote alternatives wherever practicable;
• Committing to comply with applicable environmental laws and regulations, as well as other standards
• Educating OLAK employees about the steps OLAK is taking to help protect the environment and providing channels for employees to contribute to our efforts;
• Requesting that employees report any instances of noncompliance with applicable environmental laws and regulations and conducting appropriate follow-up.

2. The Process to achieve goals

• Save Energy - Our aim to be efficient in our use of energy and natural resources and to reduce consumption within our offices.
  • Advising staff to switch off lights and appliances when not in use.
  • Phase out energy inefficient Air conditions and replace with energy-efficient versions
  • Shutdown the Software Development servers and move to Cloud
• Minimise Travels - We have a policy to use video and telephone conferencing as an alternative to travel where this is feasible, to reduce carbon dioxide emissions.
• Minimize printing -Our policy to minimize the printing or using hard copies and always use digital copies. Even the contracts use digital signature so it minimizes the printing papers, printer cartridges etc.
• E-waste policy - Our recognition of our responsibility to manage redundant and obsolete equipment properly, by disposing of such to third party organizations wherever possible
• Reuse paper - Our encouragement of the use of previously used paper within the internal operation and reuse envelops tool.
• Digital documentation - Generate employee letters digitally. Even project proposals, invoices etc are submitted digitally with digital signature.
• Digital payments - Encourage supplier payments using digital channels instead of physical cheques. Encourages customers to make payments using bank transfers instead of issuing of cheques.
• Scanned documents - Reduce paper movements and use scanned copies of documents and transfer them using workflows or email.
• Digital marketing - Not use any printed marketing materials and use eFlyers and social media. All the promotional campaign done using social medial to reduce paper usage.

- End of 22 : Environment Policy –