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Home › Legal › Anti Bribery Policy
Governance · Board-Signed · Effective 1 July 2026

Anti-Bribery & Anti-Corruption Policy.

VB Engineering conducts business honestly, transparently, and with zero tolerance for bribery and corruption in any form. This Policy sets our standard for every employee, contractor, agent, and vendor in every country where we operate.

Effective: 1 July 2026 · Version: 1.0 · Signed by the Board of Directors, VB Engineering India Private Limited · Reviewed annually.

01Zero tolerance.

VB Engineering has zero tolerance for bribery and corruption. This applies to every VB employee, contractor, agent, consultant, joint-venture partner, subcontractor, and any third party acting on our behalf, in every country where we operate, without exception. Any breach is grounds for termination of employment or contract, forfeiture of pending compensation, and referral to regulatory or law-enforcement authorities.

02Applicable law.

We comply with all anti-bribery and anti-corruption laws applicable to our operations, including without limitation:

  • India · Prevention of Corruption Act 1988 (as amended in 2018) · Prevention of Money Laundering Act 2002 · Companies Act 2013 §447 fraud provisions.
  • United States · Foreign Corrupt Practices Act (FCPA) 15 U.S.C. §78dd-1 et seq. Applies to our US subsidiary and to any activity touching US commerce.
  • United Kingdom · UK Bribery Act 2010. Extraterritorial reach captures our UK activity and any activity by UK persons within VB.
  • Gulf Cooperation Council · anti-bribery frameworks of Saudi Arabia, UAE, Qatar, Kuwait, Oman, Bahrain · including alignment with UNCAC standards.
  • OECD Anti-Bribery Convention · principles of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

03What is prohibited.

Bribery

Offering, promising, giving, requesting, or receiving anything of value (cash, gift, entertainment, favour, employment offer, or benefit of any kind) with the intent to influence or reward the improper performance of a function or activity by any person, whether public official or private party.

Facilitation payments

Even small "grease" payments to expedite routine government action · customs clearance, permit issue, utility connection · are prohibited under UK Bribery Act and FCPA (for public-integrity offences). VB does not authorise facilitation payments.

Kickbacks

Any arrangement where a portion of a contract price is returned, formally or informally, to a decision-maker on the buyer side, in cash or in kind.

Improper hospitality

Gifts or hospitality that are not reasonable, proportionate, transparent, or aligned with business purpose. See §05 for the permitted-hospitality framework.

Political contributions

VB does not make political contributions in cash or in kind, in any country, in any name, without prior written Board approval.

Charitable contributions used as cover

Charitable giving is permitted through governance-reviewed channels, but never as a means to secure or reward improper action by any person or entity.

04Who is a "public official."

A public official includes: (a) any officer or employee of any government, state-owned enterprise, or public international organisation; (b) any officer or employee of a national oil company (Saudi Aramco, ADNOC, QatarEnergy, KOC, PDO, BAPCO, ONGC, IOCL, BPCL, HPCL, and equivalents); (c) any officer or employee of a state-owned utility or infrastructure operator; (d) any political party, candidate, or officeholder; (e) any judge, arbitrator, or regulator. VB imposes heightened diligence on interactions with any person meeting this definition.

05Permitted hospitality.

Reasonable, proportionate, transparent business hospitality is permitted, subject to pre-approval for any item above USD 100 in value or any interaction with a public official. Meals, standard conference invitations, and small promotional gifts within monetary thresholds are permitted. Cash gifts, gift cards, personal-benefit vouchers, and any hospitality provided during an active competitive procurement are prohibited without exception.

06Books, records, and internal controls.

Every transaction is recorded accurately, in reasonable detail, and in the correct account. No "off-the-books" accounts, no false invoices, no misclassified expenses, no unrecorded assets. Financial controls include separation of duties, dual signature above thresholds, and periodic internal audit review.

07Third-party diligence.

Before engaging any agent, intermediary, commercial representative, joint-venture partner, subcontractor, or reseller who will interact with public officials or a client procurement function on our behalf, we conduct risk-based due diligence including: (a) beneficial-ownership review, (b) sanctions screening, (c) reputation check, (d) prior-conduct check, (e) contractual anti-corruption representations and warranties, (f) audit rights, (g) termination-for-cause on breach.

08Reporting concerns.

Any employee, contractor, agent, vendor, or third party may report a suspected bribery or corruption concern through:

  • Email: [email protected]
  • Direct: any member of the Board or the Chairman
  • Anonymous submission via our whistleblower channel

VB does not tolerate retaliation of any kind against any person who reports a concern in good faith. Reports are handled confidentially and investigated promptly.

09Accountability.

The Board of Directors of VB Engineering India Private Limited holds ultimate accountability for this Policy. Day-to-day implementation is delegated to the Chairman and to designated Compliance Officers in each geography. Annual training is mandatory for all VB personnel.

Signed for the Board of Directors:
Peri Sastry Peri, Founder & Chairman
VB Engineering India Private Limited · 1 July 2026

Original signature on file at the Registered Office. This public statement reflects the position adopted by the Board.

Ethics & Compliance

Reports of suspected bribery, corruption, or ethics violations may be submitted to [email protected] or to any member of the Board.

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