Gifts and Hospitality Policy

Table of Contents
1.

Definitions .......................................................................................................................................... 3

2.

Objective ............................................................................................................................................ 4

3.

Scope and Applicability .................................................................................................................... 4

4.

Acceptable Gifts ................................................................................................................................ 55.

Non- Acceptable Gifts ...................................................................................................................... 6

6.

Offering Gifts ..................................................................................................................................... 77.

Disclosure in the Gifts Register ...................................................................................................... 88.

Communication and Training .......................................................................................................... 8

9.

Raising a concern or complaint ...................................................................................................... 910.

Zero Retaliation ................................................................................................................................. 911.

Monitoring and Review .................................................................................................................... 912.

Disciplinary Action .......................................................................................................................... 10

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1.

Definitions“Associates” shall mean all directors, officers, managers, employees(whether full-time, temporary, or part- time), trainees, interns, etc. ofCACTUS or its affiliates, wherever located.
“Gifts” shall mean gifts and hospitality given to another person including
but not limited to cash or its equivalent, entertainment vouchers, favors,gifts, accommodation, invitation to a meal, or an event or any item having
any cost or financial value.
“Conflict of Interest” means a situation when a person’s personal,financial, or other interests could potentially interfere with their ability tomake unbiased and objective decisions in their professional role. Thissituation can lead to actions that are not in the best interest of anotherperson or organization to which that individual owes loyalty.
“Business Partners” shall mean any individual or organization,
who/which come into contact with CACTUS or transact with CACTUS
including but not limited to all past, current, and potential clients,
consultants, vendors, suppliers, business contacts, intermediaries,advisors, agents, freelancers, contractors, including their associates,
freelancers, and contractors.
“Government Official” shall mean officials, associates, employees,agents, representatives, and advisors of a federal, national, state,provincial, local, or municipal government, public bodies, and politicalparties and also includes Politicians and their family members.
“Politician” refers to a person who has political power in the governmentof a state, a person active in party politics, or a person holding or seeking
an elected office in government. This doesn’t extend to people who haveretired from the political power.
“Stakeholders” shall mean collectively all Associates and BusinessPartners.

© 2002—2024 Cactus Communications. All Rights Reserved32.

ObjectiveThis Gifts and Hospitality policy (“Policy”) of Cactus Communications
Private Limited including all its global affiliates and group companies(“CACTUS” / “Company” / “we” / “us” / “our”) is designed to ensure that all
gifts and hospitality offered or received by our employees, andrepresentatives are appropriate, transparent, and compliant withapplicable laws and our internal standards.
The objective of this Policy is to:
1. Prevent Conflicts of Interest: Ensure that Gifts do not influence,or appear to influence, business decisions or create any conflict ofinterest.
2. Maintain Transparency: Promote transparency in the giving andreceiving of Gifts to avoid any appearance of impropriety or undue
influence.
3. Ensure Compliance: Comply with all relevant laws, regulations,and industry standards regarding Gifts in the countries where weoperate.
4. Protect Our Reputation: Safeguard the reputation of CACTUS byupholding our commitment to ethical business practices.
5. Foster Fair Business Practices: Encourage fair and unbiased
business relationships by setting clear guidelines for acceptable
Gifts.
By adhering to these principles, we aim to foster an environment of trustand integrity, both within our organization and in our dealings withBusiness Partners. This Policy complements and is to be read in
conjunction with our Anti-Bribery and Anti-Corruption (ABAC) Policy,reinforcing our dedication to ethical business conduct in all aspects of ouroperations.

3.

Scope and Applicability

This Policy applies to all Stakeholders (referred to as “you” and “your” inthis Policy) working for or on behalf of CACTUS.

© 2002—2024 Cactus Communications. All Rights Reserved44. Acceptable Gifts
The Company recognizes that it is customary for some of its Associatesto occasionally accept or give small Gifts to those with whom they dobusiness or have transactional dealings.
This Policy does not prohibit normal and appropriate Gifts, entertainment
and promotional or other similar business expenditure. However, the key
determining factor for appropriateness of the Gifts and/or its value would
be based on facts and circumstances under which such Gifts areprovided. As a general rule, an Associate of the Company may accept aGift from another Associate or a Business Partner, provided such a Gift:• is not made with the intention of influencing a Business Partner toobtain/retain business or a business advantage or to reward a businessadvantage or for any other corrupt purpose;• it complies with updated local laws and regulation;• it is appropriate in the circumstances, for example, it is customary forsmall Gifts to be given during festivals, such as Christmas time in theU.S., during Diwali festival in India, and during Spring Festival in China;• it is given openly, not secretly and in a manner that avoids theappearance of impropriety;• does not create the appearance (or an implied obligation) that the gift
giver is entitled to preferential treatment, an award of business, better
prices, or improved terms of sale or service;• would not influence, or appear to influence, the associates’ ability to act
in the best interest of the Company;• would not embarrass the Company or the Gift giver, if disclosed
publicly;• would not in any manner prevent or impede business of the Company
being awarded or conducted through the Gift giver’s competitors;• is exchanged during festivals or other ceremonial occasions and iscommensurate with the culture and occasion; and• presented as honorariums while delivering lectures or taking sessions
in educational or professional or industry institutions/associations orinvitations to become panel members in various bodies of publicinterest.

© 2002—2024 Cactus Communications. All Rights Reserved5

The cumulative value of all Gifts an Associate of the Company may
receive or provide to a Stakeholder should be reasonable and appropriate
within the business context and should not influence Company’s businessdecisions or actions.
If any gesture is intended to improve the image of CACTUS, better present
its services or establish cordial relations, we may accept an invitation to ameal, entertainment or a sports event which is within the scope of social
formality and not excessively extravagant, expensive, or frequent. Such
invitations should ideally be pre-cleared by the reporting manager (whoshould ensure that such an invitation meets the above criteria and isunlikely to create a conflict of interest).

5.

Non- Acceptable Gifts

Under any circumstances, any Associates of the Company shall not
accept the following items, and if deemed necessary shall apprise theGrievance Committee regarding the matter.
• Airline travel, whether domestic or international.
• Daily allowances, cash advances, or cash payments of any nature.
• Tickets for family members or persons not directly related to therelevant business project to join any official trips/events or any
personnel trips.
• Gifts of cash or gold or other precious metals, gems, or stones.
• Gifts that are prohibited under applicable law.
• Gifts given as a bribe, payoff, kickback, or facilitation payments (e.g.,in order to obtain or retain business or to secure an improper
advantage, such as securing a favorable tax treatment).
• Gifts the recipient knows are prohibited by the Gift giver’s or recipient’sorganization.
• Gifts given in the form of services or other non-cash benefits (e.g., apromise of employment).
• Acceptance of an offer of any Gifts of any size from any Stakeholder
or Government Official. Example: An agent gives your nephew a job© 2002—2024 Cactus Communications. All Rights Reserved6

but makes it clear that in return they expect you to use your influence
in CACTUS to ensure we continue to do business through them. It isan offence for an agent to make such an agreement. It would also be
an offence for any Associate to accept the offer to gain a personaladvantage.
•6.

Indulging in corrupt practices to gain or provide a business. Example:
You commit an income-revenue-generating contract for an
acquaintance without adequate assessment of other similar vendors
and/or continue to work with an acquaintance despite complaints ofpoor-quality work/harassment from the acquaintance. This would betreated as an offence as it will be treated as giving a businessadvantage to your acquaintance over other potential and deserving
vendors.

Offering Gifts

The act of offering Gifts assists in establishing or enhancing all types ofrelationships. This is also true for the corporate world and government
agencies. It is also a way to recognize talent and achievements. TheCompany should have bona fide reasons for offering Gifts, such as
thanking long-standing Business Partners and recognizing dedicated
Associates. The primary intent should be to affirm the relationship in themost professional manner. An Associate should not offer the following on
behalf of the Company:• Gifts or hospitality if there is a likelihood that it could be seen as‘bribery’,• Gifts in the form of cash,• Gifts if these do not comply with CACTUS’ ethical belief or with relevantlaws,• Gifts to family members of a Business Partner,• Gifts to Government Officials, unless they are customary gifts provided
during festivities, are modest in value, and do no impact Company’sbusiness decisions,• Give, promise to give or offer, any Gifts or advantage with theexpectation or hope that a business advantage will be given or received© 2002—2024 Cactus Communications. All Rights Reserved

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or to reward a business advantage already given, (Example: You offer
tickets to a potential client for a major sporting event, but only if theyagree to do business with us. This would be an offence as you aremaking the offer to gain a business and commercial advantage. It may
also be an offence for the potential client to accept our gifts.), and•7.

Give, promise to give or offer, any payment, Gifts to a Government
Official, agent or representative to “facilitate” or expedite a routine(Example: A Government Official suggests a contribution should bemade to his favorite charitable organization and in return he would be
able to influence the decision-making process for license approvals.).

Disclosure in the Gifts RegisterTo ensure transparency and compliance with this Policy, the following
procedure must be followed:
a. Reporting Gifts - Associates who receive / provide any Gifts arerequired to declare such Gifts to the Human Resource Operations
team by completing and submitting the Gift Reporting Form within
7 business days of receiving the Gift.
b. Maintaining Gifts Register – All reported gifts shall be disclosed in
the Gifts Register maintained by HR Operations

8.

Communication and Training
It is our commitment to ensure that this Policy is available andunderstood
throughout
ourorganization
throughpropercommunication to equip Stakeholders to make informed decisions anduphold the Company’s ethical standards while dealing with Gifts.
To meet this objective, the following will be executed:
a. Dissemination of this Policy for new Associates shall be carriedout at the time of induction.
b. This Policy will be shared with all existing Associates andBusiness Partners. If you have any query about this Policy, you
should contact your HRBP.
c. CACTUS’ zero-tolerance approach to unethical standards while© 2002—2024 Cactus Communications. All Rights Reserved

8dealing in Gifts should be communicated to all Business Partners,
wherever possible, at the outset of CACTUS’ business
relationship with them or as appropriate thereafter.
Appropriate and periodical training on this Policy will be provided toAssociates to educate them about the principles and requirements ofthis Policy.

9.

Raising a concern or complaint

Any person who has reason to believe that a violation of this Policy hasoccurred, or may occur, must promptly report this information to theGrievance Committee (GC) by writing to grievance@cactusglobal.com.
CACTUS requests all Stakeholders to approach issues under this Policy
in a manner that is consistent with the principles set out in this Policy.

10. Zero Retaliation
CACTUS is committed towards no retaliation provisions towards
Stakeholders who file reports or complaints under this Policy. CACTUS
aims to prevent victimization and other retaliatory behavior towards theStakeholders, so they aren’t afraid to speak up about any issues. Toensure that this Policy is adhered to and to assure that the concerns orgrievances will be acted upon seriously, CACTUS shall ensure that
the Stakeholder reporting under this Policy is not victimized andadequate safeguards against such victimization are provided;b. complete confidentiality of the reporting Stakeholder is maintained;c. suitable action is taken against any person violating this Policy.
a.

11. Monitoring and Review
CACTUS will establish appropriate measures to ensure compliance withthe relevant policies, procedures, and controls. CACTUS will monitor theeffectiveness and review the implementation of this Policy regularly,
considering its suitability, adequacy, and relevance. Any improvements
identified will be made as soon as possible. CACTUS reserves the right© 2002—2024 Cactus Communications. All Rights Reserved

9to amend, suspend or terminate this Policy at any time, at its sole
discretion, with or without notice.

12. Disciplinary Action
Non-compliance with the Policy by a Stakeholder may result in criminalor civil penalties which will vary based on the offence. An Associate
acting in contravention of the Policy will also face disciplinary action up toand including summary dismissal. A Business Partner acting in thecontravention of the Policy will also result in suspension of payment andtermination of all contracts and association with them.
Additionally, disciplinary procedure as per the Disciplinary Policy shall bereferred if any violation is noticed in regard to this Policy.

© 2002—2024 Cactus Communications. All Rights Reserved© 2002—2024 Cactus Communications. All Rights Reserved

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