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Anti-Corruption and Anti-Bribery Policy Policy Statement

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

Scope and Applicability

This policy applies to all Employees of NetConnect and Third Parties performing duties for or on behalf of NetConnect. This policy extends to all NetConnect employees regardless of geographical location and type of work. “Anti-Corruption Laws” shall mean any applicable anti-corruption laws, including but not limited to;

The (Indian) Prevention of Corruption Act, Money Laundering Control Act of 1986, as amended, the (Indian) Prevention of Money Laundering Act, 2002, and any other anti-money laundering or anticorruption laws in effect in India. Definitions of Terms Used in this Policy Bribe: A bribe is an inducement, payment, reward or advantage offered, promised or provided to any employee 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 a separate 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 Gifts, Hospitality, Entertainment and Travel Expenses 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. Business Relationships NetConnect expects all Third Parties doing business with NetConnect to approach issues of bribery and corruption in a manner that is consistent with the principles set out in this Policy.

NetConnect requires all Third Parties to cooperate and ensure compliance with these standards, to continue the business relationship. Recordkeeping Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to Third Parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

Obligations to Report Breaches of Anti-Corruption Laws NetConnect Confidential Anti Bribery Policy Page – 2 Employees and Third Parties are required to draw attention to circumstances where they believe that there may have been breaches of this Policy or related improper behaviour by other Employees or Third Parties and can use NetConnect’s Whistleblowing Policy.

Consequences for Breaches of Anti-Corruption laws Consequences may include unlimited fines for corporations and/or individuals, imprisonment for terms as prescribed under applicable laws which may extend to 10 years for individuals and/or directors, disqualification from acting as a director and significant monetary fines against you as an individual. You would also be subject to disciplinary action, up to and including dismissal from the company. Enforcement and Discipline NetConnect views corruption and bribery very seriously.

NetConnect will investigate all allegations of corruption and take legal and/or disciplinary action in all cases where it is considered appropriate. Responsibilities and Review It is the responsibility of senior management to act as Anti-Corruption Officer for NetConnect.

It shall be the responsibility of the Anti-Corruption Officer to review this policy and its implementation on an annual basis to ensure it continues to comply with relevant bribery and anti-corruption laws. Reporting and Process Company Personnel who are or become aware of, suspect, or have reason to suspect a violation of the AntiCorruption Laws is under an obligation to report the same to the Anti-Corruption Officer immediately.

Under certain Anti-Corruption laws, “turning a blind eye” to a suspected violation can result in criminal penalties and civil liability both for the Company and for individuals. For those who wish to remain anonymous, you should make your report in accordance with the procedures set out in the Company’s Whistle-blower Policy.

The Company will not take any adverse action against anyone for providing truthful information relating to a violation of law or this Policy, and the Company will not tolerate any retaliation against Company Personnel asking questions or making good faith reports of possible violations of this Policy. Questions and Information If you want to ask a question about the requirements in this policy or are concerned that an anti-bribery breach is occurring or has occurred, you should report it immediately to one of the following:

 Anti-Corruption Officer

 The whistleblowing system set out in the Whistleblowing policy.