1. Statement of the Policy

Convergent strictly prohibits any corrupt practice and has zero tolerance for any violation of relevant laws and regulations relating to anti-corruption and bribery.

Convergent and its subsidiaries, affiliates, and associates, their directors, officers, employees, and consultants, while working on behalf of Convergent, strictly comply with this Anti-Bribery Policy (also referred referred to as “Policy”). Employees are prohibited from giving or receiving Bribes to any Government Officials or any other person or entity, including any person or entity in the private or commercial sector (hereafter referred to as “Private Parties”). Such prohibition is provided that the payment is for inducing the recipient to misuse their position giving an unfair advantage to Convergent.

Exceptions to this are small gifts of negligible value deemed ordinary in relevant standard business practice, such as promotional gifts, occasional courtesy, or invitations. The value of such benefits has to remain reasonable, and in all cases, local laws and customs must be respected.

2. Compliance with the Policy

Bribes to any government officials, persons, or companies are strictly prohibited. Any direct or indirect benefit granted to employees (or their family members) or Convergent by a third party is also prohibited because it may result in dependency and affect the individual’s decision-making process while performing their duty.

All dealings with Government Officials and Private Parties should be anti-bribery Policy compliant. It is the personal responsibility of each employee to acquaint themselves with the standards and restrictions applicable to their assigned duties and to conduct themselves following these standards and regulations in all respects. Any questions should be directed to the Compliance Officer, as the Board of Convergent may nominate from time to time. No employee has the authority to make decisions that violate the anti-bribery Policy. This Policy is subject to no waivers or exceptions despite competitive or commercial demands, industry customs, or other exigencies. Any employee not complying with this Policy shall be subject to disciplinary action, as determined by the company, up to and including termination from employment.

3. Books, Records, and Controls

Its Convergent Policy that its records must be fair and accurately reflect the facts of a transaction and give sufficient information for understanding the transaction. No transaction shall be entered into with the intention of it being documented or recorded deceptively. All the transactions should be properly authorized, executed, and recorded.

4. Compliance Officer

The Board of Convergent may nominate Official(s) to act as a Compliance Officer (hereafter referred to as “Compliance Officer”) and their alternate in their absence. The Compliance Officer is responsible for all the processes and procedures to ensure compliance with the anti-bribery Policy. If a potential policy violation allegation is made against any employee, the Compliance Officer’s responsibility is to investigate the allegation and bring it to a reasonable conclusion.

5. What is a Bribe or Corrupt Practice

Under the anti-bribery Policy, Bribe is anything of value, therefore not necessarily limited to money regardless of the quantum, if given to induce the recipient to misuse their position and thereby provide an unfair advantage to the company.

It is recommended that the gifting Policy be applied uniformly across levels and gifts must be within the limits specified in the gifting Policy. Special consideration may be given to cultural expectations and customs, for example, receiving and giving Diwali gifts. Likewise, acceptance of reasonable hospitality from the Private Parties and Government Officials is permitted if the same is in the natural course of dealings and is not meant to serve the purpose of Bribe.

6. Intermediaries (Third parties dealing directly or indirectly with the client on behalf of Convergent)

Intermediaries mean and include any agent, service provider, consultant, contractor, or other third party hired on a contractual basis (hereafter referred to as “Intermediaries”) to assist the company in any business function. The anti-bribery Policy prohibits employees from engaging the Intermediaries to give or offer a Bribe on behalf of the company.

7. Contracts with consultants Intermediaries

Contracts with the Intermediaries must be in writing and include appropriate anti-corruption verbiage.

8. Expenditure requiring intimation/approval

Certain gifts and expenditures may be made within Policy prescribed limits. Any gift or expense exceeding the prescribed limit has to be approved by the compliance officer.

9. Whistle-blowing Mechanism

Every employee is responsible for reporting any incident involving bribery and corruption. Therefore, it is crucial to understand the content of the Policy and what may be considered a Bribe. Employees are encouraged to seek the Compliance Officer’s or CEOs guidance in this regard. No manager or individual has the authority to permit any exceptions to this Policy. All employees are encouraged to report any activity they believe might violate laws/regulations or the anti-bribery Policy. All allegations will be appropriately investigated and dealt with utmost caution. Subject to potential legal requirements, the identity of an employee reporting alleged violations will be kept confidential. It is reiterated that employees will not be subject to retaliation or penalties of any kind for reporting in good faith a suspected breach of this Policy to the company.