Policy on Anti-Fraud, AntiMoney Laundering, Anticompetitive practices© 2002—2024 Cactus Communications. All Rights Reserved1

Table of Contents
1. Definition ......................................................................................... 3
2. Objective ......................................................................................... 4
3. Scope and Applicability ................................................................... 4
4. Third-Party Due Diligence ............................................................... 5
5. Implement Internal Controls ............................................................ 5
7. Awareness and Training.................................................................. 6
8. Raising a concern or complaint ....................................................... 7
9. Zero Retaliation ............................................................................... 7
10. Monitoring and Review .................................................................. 8© 2002—2024 Cactus Communications. All Rights Reserved2

1. Definitions“Associates” shall mean all directors, officers, managers, employees(whether full-time, temporary, or part- time), trainees, interns, etc. ofCACTUS.
“Fraud” can be defined as an abuse of knowledge or financial position
that is executed intentionally to create a financial gain for the person
committing the fraud or for a related person or entity and/or to cause aloss to another person or entity. Examples of fraud are●

Any dishonest or fraudulent act.

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Manipulation, forgery, falsification, or alteration of accounting records.

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Misappropriation of funds, supplies, or other assets.

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Disclosure of official activities or information for advantage.

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Theft or misuse of property, assets, facilities or services.

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Use of subcontractors because of personal relationship or profit froman official position.

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Impropriety in the handling or reporting of money or financialtransactions.

“Anti-Competitive Practices” refers to actions taken by a company orgroup of companies that harm competition in the market typically to gain
unfair advantage over competitors. This can be done througha. price fixing – i.e. agreements between competitors to set prices at acertain level, rather than allowing market forces to determine prices.
b. market division – i.e. agreements between competitors to divide
markets among themselves, either by geographic area, type ofproduct, or customer segment, to avoid competition with each other.
c. bid rigging – i.e. Collusion between competitors to manipulate thebidding process to ensure a predetermined outcome.
d. predatory pricing i.e. - setting prices extremely low with the intent todrive competitors out of the market, after which prices are raised tohigher levels.
e. vertical restraints (i.e., restriction in competition at different levels offirm’s operations),© 2002—2024 Cactus Communications. All Rights Reserved3

f. false or misleading advertising etc.
“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 current, and potential clients, consultants, vendors,suppliers, business contacts, intermediaries, advisors, agents,freelancers, contractors, including their associates, freelancers, andcontractors.
“Money laundering” is defined as the process to cover up illegallyobtained money. The original source of the money or asset, usually acriminal action, is hidden and exchanged to appear legitimate.
“Stakeholders” shall mean collectively all Associates and BusinessPartners.

2. Objective
Cactus Communications Private Limited, including all its global affiliates
and group companies (“CACTUS”/“Company”/ “we”/ “us”/ “our”) has along-standing commitment to govern and conduct its business withintegrity, honesty, fair dealing, and full compliance with all applicable laws
and regulations. As part of our guiding principles, we emphasize ethicalbehavior, accountability, and transparency in all our operations.
We do not participate in or endorse any corrupt practices and within ourbusiness, there is zero-tolerance for any types of fraud, money laundering,anti-competitive practices or any other improper benefits contrary to thispolicy, local laws and regulations, industry standards or ethical codes in
the countries in which we operate. This policy is to be read in conjunction
with our Anti-Bribery and Corruption Policy.

3. Scope and Applicability
This policy on Anti-Fraud, Anti- Money Laundering and Anti-Competitive
Practices (hereinafter, “Policy”) applies to all Stakeholders working for oron behalf of CACTUS (referred to as “you” or “your” in this Policy).

© 2002—2024 Cactus Communications. All Rights Reserved4

4. Third-Party Due Diligence
Due Diligence is a process of gathering sufficient information about apotential or existing business partner, to assess the risk associated with
their activities, and ensure compliance with regulatory requirements,
particularly in the context of anti-money laundering (AML) and counterterrorism financing (CTF) measures. CACTUS is committed toimplementing a due diligence process for its key business partners in thefuture. We will develop and introduce measures to systematically evaluate
potential risks related to fraud, money laundering, and anti-competitivepractices. Our goal is to ensure the integrity and compliance of ourBusiness Partners with applicable laws and regulations. We are dedicatedto maintaining the highest standards of ethical conduct in our operations
and will take appropriate actions to prevent any involvement in illicitactivities.

5. Implement Internal Controls
We shall implement the following internal control so as to timely identify
any misconduct and address it in a timely and appropriate manner.
• For financial control, we shall segregate duties, conduct regularreconciliation, and implement rigorous approval processes to preventand detect fraudulent activities.
• For transaction monitoring, we shall study the patterns of transaction
regularly and report any unusual patterns or red flags to management
to indicate potential money laundering. All transactions involving ourStakeholders must be recorded accurately and in reasonable detail inour books and records. A failure to do so may constitute an offence,and if any violation is made under applicable laws, then it shallconstitute a criminal offence.
•We have an internal auditor, an external party, who conducts internal
audits to check compliance with our internal policies and regulatory
requirements to ensure adherence and effectiveness.

6. Monitoring and Reporting on Suspicious
Activities© 2002—2024 Cactus Communications. All Rights Reserved

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The following kinds of activities are to be treated as red flags and reported
as per the procedure mentioned in this Policy:• Business Partners whose identity verification seems difficult or if they
appear not to cooperate.
• Where the source of the funds is not clear or not in keeping withbusiness partner apparent standing/business activity.
• Transactions with Business Partners, including their affiliates, banks
and financial institutions in high-risk jurisdictions (such as countries
with low corruption perception index (CPI), i.e., a score given to a
country basis their perceived levels of public sector corruption.
Countries with low CPI are often associated to be tax havens, subject
to sanctions, known to provide support to terrorist organizations).
• Substantial increases in business with suspicious cause.
• Unusually large cash deposits made by an individual or business.
• Business Partners doing payment in cash for the services rendered byCACTUS.
• Transfer of investment proceeds to apparently unrelated third parties.
The above-mentioned list is only illustrative and whether a particulartransaction is suspicious or not will depend upon the background, detailsof the transactions, and other facts and circumstances.

7. Awareness and Training
It is our commitment to ensure that this Policy is available and understood
throughout our organization through proper communication and theStakeholders are educated on recognizing the signs of frauds, money
laundering, and anti-competitive practices; To meet this objective, thefollowing will be executed:o Dissemination of this Policy for new Associates shall be carried out at
the time of induction.
o This Policy will be communicated to all existing Associates via
Company’s Intranet.
o This Policy will be communicated to all Business Partners, wherever
possible, at the outset of CACTUS’ business relationship with them or
as appropriate thereafter.

© 2002—2024 Cactus Communications. All Rights Reserved

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Appropriate and periodical training on this Policy will be provided toAssociates to educate them about the principles and requirements of thisPolicy.

8. Raising a concern or complaint
We foster a corporate culture that values ethics and integrity, encouragingStakeholders to uphold ethical standards and report any misconduct.
Additionally, we ensure the confidentiality of our Stakeholders ismaintained.
The prevention, detection, and reporting fraud and anti-competitive
practices is the responsibility of all those working for or with CACTUS. You
are required to avoid any activity that might lead to or suggest a breach ofthis Policy.
If any Stakeholder of the Company wants to raise a concern regarding
any exchange of fraud, money-laundering and anti-competitive behavior
which violates the requirements of this Policy, they can do so by raising
the concern through Protected Disclosure under Whistle Blower Policy.

9. 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.

© 2002—2024 Cactus Communications. All Rights Reserved

710. Monitoring and Review
CACTUS will establish appropriate measures to ensure compliance with therelevant 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 toamend, suspend or terminate this Policy at any time, at its sole discretion,with or without notice.

© 2002—2024 Cactus Communications.
All RightsReserved© 2002—2024 Cactus
Communications.
All Rights Reserved18