#Anti-Bribery and Anti-Corruption Declaration

STM-GL-030 | Version 1.0.0 | Last Modified On 31 July 2026

#Purpose

Edsol Edtech Pvt. Ltd.'s standing position on bribery, corruption and improper payments, and the commitments it gives to a hospital that asks. It is written to be signed as it stands and to satisfy the supplier anti-bribery clause in a chain's code of conduct.

It is published openly rather than released on request. A supplier that will only state its position on corruption behind a login has said something about its position.

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#The declaration

#1. Laws Edsol Edtech Pvt. Ltd. complies with

Edsol Edtech Pvt. Ltd. complies with all anti-bribery and anti-corruption laws applicable to it and to its dealings with Customer legal name, including:

1. the Prevention of Corruption Act, 1988, including the offence of giving an undue advantage to a public servant, and the liability of a commercial organisation and of the persons in charge of it;
2. the Bharatiya Nyaya Sanhita, 2023, in respect of criminal breach of trust, cheating, forgery and related offences;
3. the Prevention of Money-Laundering Act, 2002;
4. the Companies Act, 2013, in respect of fraud, related-party transactions and vigil mechanisms;
5. the Foreign Contribution (Regulation) Act, 2010, where a counterparty receives foreign contribution; and
6. in the markets where Edsol Edtech Pvt. Ltd. supplies outside India, the equivalent local law, and any extraterritorial legislation to which it becomes subject.

#2. What Edsol Edtech Pvt. Ltd. will not do

Edsol Edtech Pvt. Ltd., and its directors, officers, employees and any person acting on its behalf, will not, directly or indirectly:

1. offer, promise, give, request, agree to receive or accept any bribe, kickback, secret commission or undue advantage, whether of money, goods, services, employment, hospitality, or anything else of value, to or from any person, in order to obtain or retain business or any improper advantage;
2. make any facilitation payment, a small payment to secure or expedite a routine action to which the payer is already entitled. Edsol Edtech Pvt. Ltd. does not treat facilitation payments as permissible in any jurisdiction, irrespective of local practice or of any exception available under another country's law;
3. offer, give or accept a gift or hospitality that is intended to, or could reasonably be seen to, influence a decision. Modest and infrequent hospitality in the ordinary course of business is permitted only where it is transparent, proportionate, properly recorded and lawful, and never where it is offered while a procurement decision is open;
4. make any political contribution or donation on behalf of, or in connection with, business with Customer legal name;
5. make any charitable donation that is, in substance, a payment for business, including a donation to a trust, foundation or society connected with Customer legal name or with any of its decision-makers;
6. engage any agent, consultant, intermediary or referral partner on terms that are not commercially justified, or whose remuneration is contingent on the outcome of a procurement decision; or
7. use Customer legal name's procurement process, or information obtained through it, to obtain an improper advantage over another supplier.

Referral and channel arrangements are disclosed, not concealed. Where Edsol Edtech Pvt. Ltd. pays a lawful, arm's-length referral fee to a channel partner in respect of an introduction to Customer legal name, it will disclose that fact to Customer legal name before contract, in the Schedule to STM-IN-017.

#3. What Edsol Edtech Pvt. Ltd. does to make this real

Edsol Edtech Pvt. Ltd. is a small company. Its controls are proportionate to that, and are stated as they are rather than described as a programme that does not exist.

Candour note. Where a control in the table above is not yet in place, the correct entry is a statement of what exists today and by when the gap closes, not a description of a policy that has not been written. A declaration that overstates the programme is itself a misrepresentation, and it is the kind that gets found.

#4. Undertakings to Customer legal name

1. Edsol Edtech Pvt. Ltd. will not do anything that would cause Customer legal name to be in breach of any anti-bribery or anti-corruption law.
2. Edsol Edtech Pvt. Ltd. will notify Customer legal name promptly on becoming aware of any breach, or credible allegation of a breach, of this declaration in connection with the engagement.
3. Edsol Edtech Pvt. Ltd. will, on reasonable written request and at reasonable intervals, provide information reasonably necessary to demonstrate compliance with this declaration.
4. Edsol Edtech Pvt. Ltd. accepts that a material breach of this declaration is a breach of MSA-IN-001 and that the consequences are those set out in that agreement. This declaration does not create a separate remedy, a separate indemnity or a separate termination right; where the agreement and this declaration differ, the agreement governs.
5. Edsol Edtech Pvt. Ltd. gives the same undertakings in respect of any subcontractor or partner it engages in connection with the engagement, and will not engage any person who declines to give them.

#5. Reciprocity

Edsol Edtech Pvt. Ltd. asks Customer legal name to apply the same standard. No employee of Customer legal name should ask any person at Edsol Edtech Pvt. Ltd. for a payment, benefit or personal advantage in connection with the engagement. Any such request will be reported to Customer legal name's designated compliance contact, in writing and without delay, and Edsol Edtech Pvt. Ltd. will decline it in the meantime. This paragraph is included deliberately. It is a supplier's most useful protection, and a hospital that objects to it has told Edsol Edtech Pvt. Ltd. something worth knowing before contract.

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#Internal note: before signing a hospital's own anti-bribery clause

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#Related documents

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#Change history

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STM-GL-030 v1.0.0 | Last Modified On 31 July 2026 | Edsol Edtech Pvt. Ltd. | CIN [TO BE SUPPLIED]