Attentions.ai

Anti-Bribery Policy

PURPOSE

ATTENTIONS AI LABS PRIVATE LIMITED (“Company”) is committed to conducting business ethically, transparently, and in compliance with all applicable laws and regulations relating to anti-bribery, anti-corruption, fraud prevention, sanctions compliance, and ethical business conduct.

This Policy establishes the Company's commitment to:

Prevent bribery and corruption in any form;
Ensure compliance with applicable sanctions and trade regulations;
Promote integrity, accountability, and ethical conduct across all business operations;
Maintain appropriate internal controls and reporting mechanisms.

The Company maintains governance, operational, and security controls aligned with internationally recognized standards, including ISO-aligned processes and SOC 2 Type II control frameworks.

POLICY STATEMENT

The Company adopts a zero-tolerance approach toward:

Bribery;
Corruption;
Fraudulent conduct;
Improper payments;
Facilitation payments;
Kickbacks;
Money laundering activities;
Dealings with sanctioned or prohibited entities.

The Company adopts a zero-tolerance approach toward:

Bribery;
Corruption;
Fraudulent conduct;
Improper payments;
Facilitation payments;
Kickbacks;
Money laundering activities;
Dealings with sanctioned or prohibited entities.

No employee or representative of the Company may directly or indirectly:

Offer, promise, give, request, or accept bribes or improper advantages;
Influence business decisions through unethical means;
Engage in transactions prohibited under applicable sanctions laws.

No employee or representative of the Company may directly or indirectly:

Offer, promise, give, request, or accept bribes or improper advantages;
Influence business decisions through unethical means;
Engage in transactions prohibited under applicable sanctions laws.

3. ANTI-BRIBERY & ANTI-CORRUPTION REQUIREMENTS

Employees and associated persons must:

Conduct business fairly and honestly;
Comply with all applicable anti-corruption laws;
Avoid conflicts of interest;
Maintain accurate books and records;
Obtain appropriate approvals for gifts, hospitality, or entertainment where applicable.

Employees and associated persons must:

Conduct business fairly and honestly;
Comply with all applicable anti-corruption laws;
Avoid conflicts of interest;
Maintain accurate books and records;
Obtain appropriate approvals for gifts, hospitality, or entertainment where applicable.

The following are strictly prohibited:

Cash payments intended to improperly influence decisions.
Unrecorded commissions or payments.
Facilitation payments;
Fraudulent reimbursements or invoices;
Improper benefits provided to public officials or private entities.

SANCTIONS COMPLIANCE

The Company shall not knowingly engage in business with:

Sanctioned individuals;
Restricted organizations;
Prohibited countries or jurisdictions;
Entities subject to trade restrictions under applicable laws.

The Company shall not knowingly engage in business with:

Sanctioned individuals;
Restricted organizations;
Prohibited countries or jurisdictions;
Entities subject to trade restrictions under applicable laws.

The Company reserves the right to:

Conduct due diligence on customers, vendors, and partners;
Refuse or terminate transactions that may expose the Company to sanctions- related risks;
Request compliance declarations from third parties.

5. THIRD-PARTY COMPLIANCE

All vendors, contractors, consultants, agents, distributors, and partners working with the Company are expected to:

Adhere to ethical business standards;
Comply with applicable anti-corruption and sanctions laws;
Avoid conflicts of interest;
Maintain truthful and transparent records.

All vendors, contractors, consultants, agents, distributors, and partners working with the Company are expected to:

Adhere to ethical business standards;
Comply with applicable anti-corruption and sanctions laws;
Avoid conflicts of interest;
Maintain truthful and transparent records.

The Company may discontinue engagement with any party found violating applicable compliance requirements

6. REPORTING & WHISTLEBLOWER PROTECTION

Any employee or stakeholder aware of:

unethical conduct,
bribery,
corruption,
fraud,
sanctions violations,
or suspicious activities

Any employee or stakeholder aware of:

unethical conduct,
bribery,
corruption,
fraud,
sanctions violations,
or suspicious activities

must report the matter to Company management or the designated compliance contact. The Company prohibits retaliation against individuals who report concerns in good faith.

7. RECORD KEEPING & INTERNAL CONTROLS

The Company shall maintain:

accurate accounting records;
transparent financial documentation;
appropriate approval mechanisms;
operational and security controls;
audit trails where applicable.

The Company shall maintain:

accurate accounting records;
transparent financial documentation;
appropriate approval mechanisms;
operational and security controls;
audit trails where applicable.

Internal controls and governance processes are periodically reviewed to support compliance and risk mitigation objectives.

8. TRAINING & AWARENESS

The Company may conduct periodic awareness and compliance communication programs for employees and relevant stakeholders to reinforce ethical business practices and regulatory compliance expectations.

9. VIOLATIONS

Any violation of this Policy may result in:

disciplinary action,
termination of employment or contract,
legal action,
reporting to regulatory authorities where required.

10. POLICY REVIEW

This Policy may be reviewed and updated periodically by the management of the Company to reflect changes in applicable laws, regulations, or business operations.