ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

• Prevention of Corruption Act, 1988 (as amended by the Prevention of Corruption (Amendment) Act, 2018)
• Indian Penal Code, 1860 / Bharatiya Nyaya Sanhita, 2023
• Prevention of Money Laundering Act, 2002 (PMLA)
• Companies Act, 2013 — provisions relating to corporate governance and ethics
• Foreign Contribution (Regulation) Act, 2010 (FCRA)
• Foreign Exchange Management Act, 1999 (FEMA)
• OECD Anti-Bribery Convention — as applicable to Indian business standards
• United Nations Convention Against Corruption (UNCAC)
• All applicable circulars, notifications, and directions issued by competent authorities

• All directors and officers of Arthvriksh Digital Solutions Pvt. Ltd.
• All permanent, temporary, part-time, and contract employees of Cashmo.
• All consultants, advisors, and freelancers engaged by Cashmo.
• All agents, representatives, and intermediaries acting on behalf of Cashmo.
• All API Partners, vendors, suppliers, and service providers in their dealings with Cashmo.
• All business partners and joint venture partners of Cashmo.
• All subsidiaries and affiliated entities of Arthvriksh Digital Solutions Pvt. Ltd.

• Cashmo will never offer, pay, promise, or authorize a bribe or corrupt payment to any person — public or private — for any purpose whatsoever, including to obtain business, retain business, gain a commercial advantage, or expedite any government process.
• Cashmo will never accept, solicit, or agree to receive a bribe or corrupt payment from any person for any purpose whatsoever.
• Cashmo will never make facilitation payments to public officials even where such payments may be customary or expected in a particular context.
• Cashmo will never use third parties, intermediaries, or agents as a conduit for bribery or corrupt payments.

• All business decisions at Cashmo shall be made on the basis of merit, quality, price, legal compliance, and legitimate business criteria — never on the basis of improper payments or corrupt inducements.
• Cashmo is committed to fair competition and shall not engage in any anti-competitive conduct involving corrupt payments or improper advantages.
• Cashmo shall conduct all interactions with public officials strictly in accordance with applicable law and without any improper inducement.

• Offering, promising, giving, or authorizing any financial or other advantage to a public official to:
  • Obtain or retain business for Cashmo.
  • Gain any regulatory approval, license, or permit improperly.
  • Influence any official decision in Cashmo's favor.
  • Expedite any routine government process through unofficial means.
• Accepting or soliciting any advantage from a public official in exchange for favorable treatment.

• Offering, promising, or giving any financial or other advantage to any private sector employee, director, or agent to:
  • Induce them to act improperly in the performance of their duties.
  • Secure a business advantage for Cashmo through improper means.
  • Influence a business decision in Cashmo's favor through corrupt means.
• Requesting or accepting any financial or other advantage from any private sector person in exchange for improperly favoring them in Cashmo's business decisions.

• Making any facilitation payment to any public official for any purpose, regardless of the amount or the perceived custom or practice in the relevant jurisdiction.
• Any demand for a facilitation payment received by a Cashmo employee or associate must be immediately reported to the Compliance Officer.

• Offering or giving gifts, hospitality, or entertainment to any person with the intent of improperly influencing a business or official decision.
• Accepting gifts, hospitality, or entertainment that could reasonably be perceived as intended to improperly influence Cashmo's business decisions.
• Offering or accepting cash or cash equivalents including gift cards, vouchers, or cryptocurrency as gifts under any circumstances.

• Making any political contribution — whether in cash or in kind — to any political party, political candidate, or political organization on behalf of Cashmo without prior written approval of the Board of Directors and in compliance with applicable Indian law.
• Using Cashmo's resources, facilities, or funds for the personal political activities of any employee or director.

• Making any charitable donation or sponsorship payment that is intended or could reasonably be perceived as a disguised bribe or corrupt payment.
• All charitable donations and sponsorships must be approved by the Compliance Officer and transparently recorded.

• Cashmo recognizes that reasonable and proportionate gifts and hospitality are a legitimate part of building business relationships. However, gifts and hospitality must never be used as a vehicle for bribery or corruption.
• All gifts and hospitality offered or received must be:
  • Reasonable and proportionate in value.
  • Consistent with normal and ethical business practice.
  • Transparent and properly recorded.
  • Not offered or received with any expectation of improper reciprocity.
  • Compliant with applicable law and the recipient's own organization's policies.

• Modest promotional gifts of nominal value bearing Cashmo's branding.
• Reasonable business meals and refreshments in the context of legitimate business meetings.
• Attendance at legitimate industry conferences, events, or seminars where the primary purpose is professional development or networking.

• Cash or cash equivalents including bank transfers, gift cards, vouchers, or cryptocurrency.
• Any gift to a public official regardless of value.
• Any gift during a tender, procurement, or regulatory review process involving the recipient.
• Any gift that the recipient's own organization's policy prohibits.
• Any gift offered with an expectation of reciprocal improper favor.

• All gifts and hospitality offered or received above ₹500 in value must be recorded in Cashmo's Gifts and Hospitality Register maintained by the Compliance Officer.
• The Register shall record:
  • Date of the gift or hospitality.
  • Description and estimated value.
  • Name and organization of the person giving or receiving.
  • Business justification.
  • Approval obtained (where required).
• The Gifts and Hospitality Register shall be reviewed by the Compliance Officer on a quarterly basis.

• Cashmo recognizes that it may be held liable for bribery or corruption committed by third parties acting on its behalf. Accordingly, Cashmo shall conduct appropriate due diligence on all third parties before entering into a business relationship.
• Due diligence shall be proportionate to the risk profile of the third party and the nature of the engagement.

• The third party's reputation, background, and track record.
• Whether the third party holds all required licenses, registrations, and regulatory approvals..
• Whether the third party has any known connections to public officials that could create a conflict of interest.
• Whether the proposed remuneration for the third party is reasonable and commensurate with the legitimate services to be provided.
• Whether the third party has its own anti-bribery and anti-corruption policies and controls in place.
• Whether the third party has been subject to any regulatory action, criminal investigation, or adverse media coverage related to bribery or corruption.

• All contracts with third parties shall include anti-bribery and anti-corruption representations and warranties requiring the third party to:
  • Comply with all applicable anti-bribery and anti-corruption laws.
  • Not engage in any bribery or corrupt conduct in connection with services rendered to Cashmo.
  • Maintain its own anti-bribery and anti-corruption policies and controls.
  • Immediately report to Cashmo any bribery or corruption concerns that arise in connection with Cashmo's business.
• Cashmo reserves the right to terminate any third-party contract immediately upon discovery of bribery or corruption by the third party in connection with Cashmo's business.

• All directors, officers, employees, and associated persons of Cashmo must promptly disclose any actual or potential conflict of interest to the Compliance Officer.
• Situations that must be disclosed include:
  • Financial interests in a vendor, supplier, or competitor of Cashmo.
  • Personal relationships with public officials who may influence Cashmo's regulatory matters.
  • Receipt of outside employment, consultancy, or business activities that conflict with duties to Cashmo.
  • Family or personal relationships with Cashmo's business counterparties.
  • Any situation where personal interests could influence a business decision at Cashmo

• Disclosed conflicts shall be reviewed by the Compliance Officer and appropriate measures taken including:
  • Recusal of the conflicted person from the relevant decision or process.
  • Additional oversight and review of decisions involving the conflicted person.
  • In serious cases, termination of the conflicting relationship.
• Failure to disclose a material conflict of interest shall be treated as a serious disciplinary matter.

• All directors, officers, employees, contractors, and associated persons of Cashmo have a positive obligation to report any actual or suspected bribery, corruption, or violation of this Policy.
• Reports should be made promptly upon becoming aware of a concern.

• Description of the suspected bribery or corrupt conduct.
• Names and roles of persons involved.
• Dates, amounts, and circumstances of the suspected conduct.
• Any supporting documents, communications, or evidence.
• Names of any witnesses.

• All reports made under this Policy shall be treated with strict confidentiality to the fullest extent permitted by law.
• The identity of the person making a report shall be protected and shall not be disclosed without their prior consent except where disclosure is required by law or a competent legal authority.
• Cashmo shall take all reasonable steps to protect the identity of the reporting person throughout the investigation process.
• Information contained in a report shall be disclosed only on a strict need-to-know basis to persons involved in the investigation.

• Cashmo is firmly committed to protecting all persons who report genuine concerns about bribery or corruption in good faith.
• No person shall suffer any adverse consequence for making a good faith report under this Policy including:
  • Dismissal or termination of employment or engagement.
  • Demotion, suspension, or reduction in remuneration.
  • Harassment, intimidation, or victimization.
  • Denial of promotion, training, or career advancement opportunities.
  • Any other form of retaliation or unfavorable treatment.
• Any person found to have subjected a reporting person to retaliation shall be subject to immediate disciplinary action up to and including termination of employment.
• Whistleblower protection applies equally to:
  • Employees reporting internally.
  • Contractors and agents reporting concerns.
  • Anonymous reporters to the extent their identity can be reasonably established.
• This protection does not extend to persons who make deliberately false, malicious, or vexatious reports. Such conduct shall itself be treated as a disciplinary matter.

• Upon receipt of a report of suspected bribery or corruption, the Compliance Officer shall:
  • Acknowledge receipt of the report within 48 working hours.
  • Assess the credibility and seriousness of the allegation.
  • Determine the appropriate level of investigation required.
  • Preserve all relevant documents, communications, and evidence.
• Where a report concerns the Compliance Officer personally, the matter shall be referred directly to the Board of Directors for independent investigation.

• All investigations shall be conducted:
  • Promptly and without unnecessary delay.
  • Impartially and objectively by persons with no conflict of interest in the matter.
  • With appropriate confidentiality throughout.
  • In compliance with applicable law including employment law obligations.
• The investigation may include:
  • Review of relevant documents, emails, financial records, and transaction logs.
  • Interviews with the reporting person, the subject of the allegation, and relevant witnesses.
  • Review of Gifts and Hospitality Register, expense claims, and financial records.
  • Engagement of external legal or forensic advisors where the complexity of the matter requires.
• The subject of an investigation shall be:
  • Informed of the allegation against them at an appropriate stage of the investigation.
  • Given a reasonable opportunity to respond to the allegation.
  • Treated fairly and with dignity throughout the process.
• During the pendency of an investigation, Cashmo may as a precautionary measure:
  • Suspend the subject with or without pay pending completion of the investigation.
  • Restrict the subject's access to systems, data, or business activities.
  • Place transactions or business dealings under enhanced review.

• Upon completion of the investigation, the Compliance Officer shall prepare a written investigation report containing:
  • Summary of the allegation.
  • Investigation methodology and steps taken.
  • Evidence reviewed and findings.
  • Conclusion as to whether a violation of this Policy or applicable law occurred.
  • Recommended actions and remediation measures.
• The investigation report shall be presented to senior management and the Board of Directors.
• All investigation records shall be maintained in strict confidence for a minimum period of 7 years.

• Formal written warning.
• Suspension with or without pay.
• Demotion or reduction in responsibilities.
• Termination of employment or engagement without notice or severance.
• Recovery of any improper benefit received.
• Civil legal action for recovery of damages suffered by Cashmo.
• Criminal referral to law enforcement authorities including the Central Bureau of Investigation (CBI), Anti-Corruption Bureau, or other competent agencies.

• Immediate termination of the business relationship and all associated contracts.
• Recovery of all payments made in connection with the corrupt conduct.
• Civil legal action for damages.
• Criminal referral to appropriate law enforcement authorities.
• Blacklisting from future engagement with Cashmo.

• The payment or advantage was small in value.
• The payment was customary or expected in the relevant industry or jurisdiction.
• The payment was necessary to secure or retain business.
• The person was instructed by a superior to make the payment.
• The violation was committed without Cashmo's knowledge but by a person acting on its behalf.
• Refusal to make the payment would have resulted in loss of business.

• Cashmo shall conduct mandatory anti-bribery and anti-corruption training for all persons covered by this Policy.
• Training shall be provided:
  • To all new employees, contractors, and relevant third parties at the time of onboarding.
  • Annually for all existing employees and directors.
  • Immediately upon any material change in applicable law or this Policy.
  • To higher-risk roles including procurement, sales, government relations, and finance on a more frequent basis.
• Training shall cover the following topics as a minimum:
  • Overview of applicable Indian anti-bribery and anti-corruption laws.
  • Cashmo's zero-tolerance Policy and its requirements.
  • Recognition of bribery and corruption risks in day-to-day activities.
  • Gifts and hospitality rules and thresholds.
  • Third-party due diligence obligations.
  • How to identify and report concerns.
  • Whistleblower protection.
  • Personal and corporate consequences of non-compliance.
• All training sessions shall be documented and attendance records maintained for a minimum period of 5 years.
• Completion of anti-bribery training shall be a mandatory condition of employment and engagement for all covered persons.

• Cashmo shall maintain accurate, complete, and transparent books of account and financial records that fairly reflect all transactions.
• No false, misleading, or incomplete entries shall be made in Cashmo's financial records for any purpose.
• No transaction shall be processed without appropriate authorization and documentation.
• Off-the-book accounts, secret funds, or unrecorded transactions are strictly prohibited.

• All expense claims must be supported by original receipts or invoices.
• Expense claims must accurately describe the nature and business purpose of the expenditure.
• Expense claims that appear disproportionate, vague, or lacking legitimate business justification shall be subject to enhanced review and may be rejected.
• False or inflated expense claims shall constitute a serious disciplinary offence.

• Dual authorization requirements for payments above prescribed thresholds.
• Segregation of duties between payment authorization and execution.
• Regular reconciliation of accounts and transaction records.
• Independent review of high-value or unusual transactions.
• Prohibition on cash payments above prescribed limits.

• Cashmo shall fully cooperate with any investigation, inquiry, or proceeding conducted by a competent law enforcement or regulatory authority in relation to bribery or corruption.
• Cashmo shall promptly disclose to competent authorities any instance of bribery or corruption that comes to its attention where disclosure is required by applicable law.
• No employee, officer, or director shall obstruct, mislead, or interfere with any lawful investigation into bribery or corruption involving Cashmo or its business.
• Cashmo shall take all reasonable steps to preserve relevant evidence upon becoming aware of any investigation or potential investigation.

• The Compliance Officer shall monitor compliance with this Policy on an ongoing basis through:
  • Regular review of the Gifts and Hospitality Register.
  • Review of expense claims and procurement decisions.
  • Periodic risk assessments of business activities and third-party relationships.
  • Review of investigation outcomes and disciplinary actions.
  • Analysis of reporting trends and policy breaches.
• The Compliance Officer shall conduct a formal annual review of this Policy to assess its adequacy and effectiveness in light of:
  • Changes in applicable law and regulatory guidance.
  • Changes in Cashmo's business activities, size, and risk profile.
  • Findings from investigations and audits.
  • Emerging bribery and corruption risks.
• The results of the annual review shall be presented to the Board of Directors with recommendations for any required updates to this Policy or Cashmo's anti-corruption controls.
• Cashmo shall conduct a bribery and corruption risk assessment at least once every 2 years to identify and evaluate risks across its operations, geographies, business lines, and third-party relationships.

• The Board of Directors of Arthvriksh Digital Solutions Pvt. Ltd. bears ultimate responsibility for ensuring that Cashmo maintains an effective anti-bribery and anti-corruption framework.
• The Board shall:
  • Approve and periodically review this Policy.
  • Receive regular reports from the Compliance Officer on the state of anti-corruption compliance.
  • Ensure adequate resources are allocated to anti-corruption compliance activities.
  • Set the tone from the top by demonstrating personal commitment to zero tolerance of bribery and corruption.
  • Review and approve any significant investigation findings and outcomes.
• The Board shall maintain oversight of Cashmo's anti-corruption program through the Compliance Officer's quarterly reporting.

• Cashmo reserves the right to amend, update, or revise this Policy at any time to reflect changes in applicable law, regulatory requirements, or business practices.
• All amendments to this Policy shall be approved by the Board of Directors prior to implementation.
• Material amendments shall be communicated to all covered persons via email or official notice with a minimum of 14 days' notice prior to the effective date.
• The updated Policy shall be published on the Platform and made available to all employees, contractors, and third parties with a revised effective date and version number.
• All covered persons are required to acknowledge receipt and understanding of this Policy and any material amendments.

• Prevention of Corruption Act, 1988 (as amended 2018)
• Indian Penal Code, 1860 / Bharatiya Nyaya Sanhita, 2023
• Prevention of Money Laundering Act, 2002
• Companies Act, 2013
• Foreign Contribution (Regulation) Act, 2010
• Foreign Exchange Management Act, 1999

• They have read and fully understood this Anti-Bribery and Anti-Corruption Policy.
• They agree to comply with all obligations and prohibitions set out in this Policy.
• They have not engaged in and will not engage in any bribery or corrupt conduct in connection with Cashmo's business.
• They understand their obligation to report any suspected bribery or corruption without delay.
• They acknowledge that violation of this Policy may result in termination, legal action, and criminal prosecution.
• They confirm that they have disclosed all actual and potential conflicts of interest to the Compliance Officer.