Anti-bribery and

Anti-corruption Policy

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Table of Contents
1. Object.................................................................................................................................................. 3
2. Scope and Applicability ….................................................................................................................... 3
3. Policy details ................................................................................................................................... 3
4. Gifts and hospitality ......................................................................................................................... 3
5. What is not acceptable? .................................................................................................................... 4
6. Willful blindness ................................................................................................................................. 5
7. Facilitation payments and kickbacks ...................................................................................................5
8. Blackmail/ extortions .......................................................................................................................... 6
9. Charitable donations ............................................................................................................................ 6
10. Political activities ............................................................................................................................... 6
11. Business relationships ........................................................................................................................ 6
12. What we expect of you .................................................................................................................... ..7
13. Record-keeping ..................................................................................................................................7
14. How to raise a concern …………............................................................................................................ 7
15. What to do if you are a victim of bribery and corruption? …..............................................................8
16. Protection ………..................................................................................................................................8
17. Who is responsible for the Policy? …………..........................................................................................8
18. Waiver and Amendment of the Policy………………………………………………………………………………………………8

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 Policy Details
1. Objective

MEC (“MEC “or the “Company”) is committed to the prevention, deterrence and detection of
fraud, bribery and all other corrupt business practices. It is MEC’s policy to conduct all of its
business activities with honesty, integrity and the highest possible ethical standards and
vigorously enforce its business practice, wherever it operates throughout the world, of not
engaging in bribery or corruption.

2. Scope and applicability

This Anti-bribery and Anti-corruption Policy (this “Policy”) applies to all individuals worldwide
working for all affiliates of MEC at all levels and grades, including directors, senior executives,
officers, employees (whether permanent, fixed-term or temporary), consultants, contractors,
trainees, workers, interns, agents, customers, clients or any other person associated or dealing
with MEC (collectively referred to as “You” or “you” in this Policy).

In this Policy, “Third Party(ies)” means any individual or organization, who / which come into
contact with MEC or transact with MEC and also includes actual and potential clients, suppliers,
business contacts, consultants, intermediaries, representatives, subcontractors, agents, advisers,
joint ventures and government & public bodies (including their advisers, representatives and
officials, politicians and political parties).

3. Policy details

A bribe is an inducement, payment, reward or advantage offered, promised or provided to any

person or demanded by any third party in order to gain any commercial, contractual, regulatory or
personal advantage. It is illegal to directly or indirectly offer a bribe or receive a bribe. It is also an
offence to bribe a government / public official. “Government / public official” includes officials,
whether elected or appointed, who hold a legislative, administrative or judicial position of any kind
in a country or territory. A bribe may be anything of value and not just money , inside information,
sexual or other favors, inordinate corporate hospitality or entertainment, offering employment to a
relative, payment or reimbursement of travel expenses, charitable donation or social contribution,
abuse of function -- and can pass directly or through a third party. Corruption includes
wrongdoing on the part of an authority or those in power through means that are illegitimate,
immoral or incompatible with ethical standards. Corruption often results from patronage and is
associated with bribery.

4. Gifts and hospitality

Employees or members of their immediate families (spouse, mother, father, son, daughter,
brother, sister or any of these step- or in-law relationships, whether established by blood or
marriage including common law marriage) should not provide, solicit or accept cash or its
equivalent, entertainment, favors, gifts or anything of substance to or from competitors, vendors,
suppliers, customers or others that do business or are trying to do business with MEC. Loans
from any persons or companies having or seeking business with MEC, except recognized financial
institutions, should not be accepted. All relationships with those who MEC deals with should be
cordial, but must be on an arm’s length basis. Nothing should be accepted, nor should the
employee have any outside involvement, that could impair, or give the appearance of impairing,
an employee's ability to perform his/her duties or to exercise business judgment in a fair and
unbiased manner.

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 This Policy does not prohibit normal and appropriate gifts, hospitality, entertainment and
promotional or other similar business expenditure, such as calendars, diaries, pens, meals and
invitations to theatre and sporting events (given and received), to or from Third Parties. However,
the key determining factor for appropriateness of the gift or hospitality and/or its value would be
based on facts and circumstances under which such gift or hospitality is provided.
The practice of giving gifts and hospitality in the normal course of business is recognized as an
established and important part of doing business. However, it is prohibited when they are used as
bribes. Giving gifts and hospitality varies between countries and sectors and what may be normal
and acceptable in one country may not be so in another. To avoid committing a bribery offence,
the gift or hospitality must be:

a. Reasonable and justifiable in all the circumstances.

b. Intended to improve the image of MEC, better present its products and services or establish
cordial relations.

The giving or receiving gifts or hospitality is acceptable under this Policy, if all the following
requirements are met:

a. It is not made with the intention of influencing a Third Party to obtain/ retain business or a
business advantage or to reward the provision or retention of business or a business advantage
or in explicit or implicit exchange for favors/ benefits or for any other corrupt purpose.

b. It complies with local laws and customs.

c. It is appropriate in the circumstances. For example, during festivals or otherwise it is customary

for small gifts to be given at Diwali, New Year, etc.

d. Taking into account the reason for the gift or hospitality, it is of an appropriate type and value
and given at an appropriate time.

e. It is given openly, not secretly and in a manner that avoids the appearance of impropriety.

Examples of Token Gifts: Corporate calendar, pens, mugs, books, T-shirts, wine bottles, bouquet
of flowers or a pack of sweets or dry fruits.
If the gifts or hospitality given or received is more than a token gift or modest meal/ entertainment
in the ordinary course of business, you must obtain prior written approval from the management.

5. What is not acceptable?

It is not acceptable for any employee of MEC (or someone on his / her behalf) to:

a. Accept an offer of a gift of any size from any Third Party which is in negotiation with, or is
submitting a proposal with MEC.

b. Give, promise to give or offer, any payment, gift, hospitality or advantage with the expectation
or hope that a business advantage will be given or received or to reward a business advantage
already given.

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 c. Give, promise to give or offer, any payment, gift or hospitality to any third party or a
government official, agent or representative to “facilitate” or expedite a routine procedure.

d. Accept or solicit any payment, advantage, gift or hospitality from a Third Party that you know or
suspect is being offered with the expectation that it will obtain a business advantage for them.

e. Threaten or retaliate against, another employee who has refused to commit a bribery offence
or who has raised concerns under this Policy.

f. Engage in any activity that might lead to a breach of this Policy.

The points stated above are illustrative in nature and in no way intend to limit the applicability of
this Policy.

6. Willful blindness

If an employee willfully ignores or turns a blind eye to any evidence of corruption or bribery within
his / her department and /or around him / her, disciplinary action it will also be taken against the
employee. Although such conduct may be “passive”, i.e. the employee may not have directly
participated in or may not have directly benefited from the corruption or bribery concerned, the
willful blindness to the same can, depending upon the circumstances, carry the same disciplinary
action as an intentional act.

7. Facilitation payments and kickbacks

Neither an employee of MEC nor any person acting on behalf of MEC shall make and shall not
accept facilitation payments or “kickbacks” of any kind. “Facilitation Payments” are typically small,
unofficial payments (sometimes known as “grease payments”) made to secure or expedite a
routine government action by a government official. “Kickbacks” are typically payments made to
commercial organizations in return for a business favor/ advantage, such as a payment made to
secure the award of a contract. You must avoid any activity that might lead to or suggest that a
Facilitation Payment or Kickback will be made or accepted by MEC.
Facilitation Payments are known to be prevalent in many countries and industry sectors. There It
may be of concern, that the inability to make such payments may cause difficulties in doing
business in some jurisdictions and that this may result in loss of income or contract. The guidance
set out below is intended to help support you in circumstances when you are asked to make
Facilitation Payments.

7.A. Guidance on how to avoid making Facilitation Payments

Corrupt government officials demanding payments to perform routine government actions may
often put people acting on behalf of MEC in very difficult positions. Therefore, there is no easy
solution to the problem. However, the following steps may help:

Insist on official receipts for any payments.

Report suspicions, concerns, queries and demands for Facilitation Payments to the higher ups
and to local enforcement authorities with prior consent of the management and refuse to make
such payments.
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 8. Blackmail / extortions

MEC remains committed to its policy of not making Facilitation Payments. The only limited
exception to this is in circumstances where you or the Third Parties are left with no alternative but
to make payments in order to protect against loss of life, limb or liberty. In such circumstances,

Make the payment and it is your immediate responsibility to contact the Management as soon as
possible after the event, so that the incident can be properly recorded, reviewed and accounted
for with the authorities.

9. Charitable donations

As part of its corporate citizenship activities, MEC may support local charities or provide
sponsorship, for example, to sporting or cultural events. MEC only make, charitable donations
that are legal and ethical under local laws and practices and also within the corporate governance
framework of the organization.

10. Political activities

MEC is apolitical, advocate government policies on sustainability and does not contribute
financial or in-kind to political parties, politicians and related institutions in any of the countries
except as permitted by law. MEC does not make contributions to political parties, political party
officials or candidates for political office except as permitted by Law.
Payment or use of corporate assets of any type as payment, directly or indirectly to any person,
business, political organization or public official for any unlawful or unauthorized purpose is
prohibited. No political contribution on behalf of MEC, use any MEC resources to assist a
candidate or elected official in any campaign or coerce or direct another employee to vote a
certain way. Never attempt to offer any incentives to public officials in the hopes of influencing the
decision of that individual.

11. Business relationships

MEC expects all Third Parties doing business with MEC to approach issues of bribery and
corruption in a manner that is consistent with the principles set out in this Policy. MEC requires all
Third Parties to cooperate and ensure compliance with these standards, to continue the business
relationship. In order to maintain the highest standards of integrity, with respect to any dealings
with a Third Party, you must ensure that:

a) Employees and associates shall conduct due diligence enquiries to review the integrity records
of any Third Party before entering a commercial relationship with them.

b) Employees and associates shall fully document the engagement process and the final
approval of the selection of any Third Party.

c) Employees and associates shall implement a program to provide appropriate information on

this Policy to all Third Parties engaged in business relationship with MEC.

d) Employees and associates shall ensure that:

Each Third Party within your work area are fully briefed on this Policy and may make a formal
commitment in writing to abide by it.

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 Fees and commissions agreed will be appropriate and justifiable remuneration for legitimate
services rendered in accordance with applicable Laws.

Contractual agreements will include appropriate wording making it possible to withdraw from
the relationship if any of the Third Parties fail to abide by this Policy.

In the event of any doubt on the integrity of a Third Party, it is the employee’s responsibility to
contact the Committee / Management as soon as possible.

12. What we expect of an “MECians”?

MECians, are the pillars of this organization and are behind each MEC success story. Every
employee must ensure that he / she shall read, understand and comply with this Policy. If any
employee has doubts or concerns, he / she should contact his / her Manager.
The prevention, detection and reporting of bribery and other forms of corruption are the
responsibility of all those working for MEC or under MEC’s control. Employees are required to
avoid any activity that might lead to or suggest a breach of this Policy.

Employees must notify his / her Manager as soon as possible if he or she believes or suspects
that a breach of or conflict with this Policy has occurred or may occur in the future.
Any employee who breaches this Policy will face disciplinary action, which could result in
dismissal. We reserve our right to terminate our contractual relationship with the employee if the
employee breaches this Policy. Any breach of this Policy would also result in imposition of large
fines/termination of the individual/ disciplinary action by the Company as the case may be or even
termination of contract with a Third Party.

13. Record-keeping

Employees must ensure all expenses claims relating to hospitality, valid gifts or expenses
incurred on Third Parties are submitted in accordance with our expenses policy and specifically
record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with
third parties, such as clients, suppliers and business contacts, should be prepared and
maintained with strict confidence, accuracy and completeness. No accounts will be kept “off-
book” to facilitate or conceal improper payments and the same is ensured through effective
monitoring and auditing mechanisms in place.
Employees must follow all the procedures laid out in other policies which help in anti-bribery and
corruption due diligence on suppliers, potential joint venture parties, clients and other Third
Parties.

14. How to raise a concern

Every person, to whom this policy applies too, is encouraged to raise their concerns about any
bribery issue or suspicion of malpractice at the earliest possible stage. If he / she is unsure
whether a particular act constitutes bribery or corruption or if he / she has any other queries,
these should be raised with their respective Manager and/or the Committee.
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 15. What to do if you are a victim of bribery and corruption?

It is his / her responsibility to inform / report it to their respective Dept. Head or Management as
soon as possible if you are offered a bribe by a third party, you are asked to make one, suspect
that this may happen in the future or believe that you are a victim of another form of corruption
or other unlawful activity. You must refuse to accept or make the payment from or to a third
party, explain our policy against accepting or making such payment and make it clear that the
refusal is final and non-negotiable because of this Policy. If you encounter any difficulty making
this refusal, you should seek assistance from the Dept. Head or Management.

16. Protection

Those who refuse to accept or offer a bribe or those who raise concerns or report another’s
wrong-doing, are sometimes worried about possible repercussions. We encourage openness and
support anyone who raises genuine concerns in good faith under this Policy, even if they turn out
to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as
a result of refusing to take part in bribery or corrupt activities or because of reporting their
suspicion in good faith that an actual or potential bribery or other corruption offence has taken
place or may take place in the future. If any employee believes that he / she has suffered any
such treatment, he / she should inform the Dept. Head or Management.

17. Who is responsible for the Policy?

The Management and Department Heads has overall responsibility for ensuring that this Policy
complies with our legal and ethical obligations and that all those under their control comply with it.
Managers at all levels are responsible for ensuring that those reporting to them are made aware
of and understand this Policy, undertake training on how to implement and adhere to it and also
monitor compliance of it.
The Management and Department Heads are responsible for this Policy and for monitoring its
use and effectiveness (and dealing with any queries on its interpretation). Management at all
levels is responsible for ensuring that those reporting to them are made aware of and understand
this Policy and attend regular training on how to implement and adhere to it.
Every person to whom this policy applies is responsible for the success of this Policy and should
ensure that he / she should use it to disclose any suspected activity or wrong-doing without loss
of time or any misconception to facilitate timely corrective action by those responsible for
compliance of this policy.

18. Waiver and amendment of the policy

MEC is committed to continuously reviewing and updating our policies and procedures based on
the learning. This is so even when MEC enters new market/ sector/ country which may pose a
risk under this Policy. The Management shall monitor the effectiveness and review the
implementation of this Policy, regularly considering its suitability, adequacy and effectiveness.
Any improvements identified will be made as soon as possible. Therefore, this document is
subject to modification. Any amendment or waiver of any provision of this Policy must be
approved in writing by the Company’s Board of Directors. The Policy will be reviewed and audited
from time to time which requires cooperation from all concerned.

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