SASF Anti Corruption Anti Brib…

Policy Statement

SAS Foundation is committed to the highest standards of integrity, transparency, and accountability. We operate a zero-tolerance policy towards all forms of corruption and bribery. This policy is designed to comply with the Prevention of Corruption Act, 1988 (as amended), the Indian Penal Code, and global best practices on anti-bribery and anti-corruption (ABAC) standards.

Purpose

The purpose of this policy is to:

• Prevent bribery and corruption in all forms.
• Establish procedures and responsibilities to detect, report, and address violations.
• Protect the reputation and operational integrity of SAS Foundation.
• Comply with legal and ethical obligations in India and globally.

Scope

This policy applies to:

• All trustees, employees, interns, and volunteers.
• All contractors, consultants, vendors, suppliers, and partners.
• Any third parties acting on behalf of or in partnership with SAS Foundation.

Definitions

• Bribery: Offering, giving, receiving, or soliciting anything of value to influence a decision or action.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payments: Small, unofficial payments made to expedite routine actions are strictly prohibited.

Prohibited Practices

SAS Foundation strictly prohibits:

• Offering or accepting bribes, kickbacks, or gifts in exchange for favorable treatment or services.
• Making facilitation payments to public officials or others.
• Engaging in corrupt practices with vendors, government officials, or donors.
• Misrepresentation of facts or concealment of information to obtain funds or approvals.

Gifts and Hospitality

• Modest, occasional gifts or hospitality may be accepted only if:
  • They are customary and reasonable in value.
  • They are not intended to influence decision-making.
• All gifts or hospitality above INR 2,000 must be declared and approved by the Ethics Officer or Secretary.

Due Diligence

• All third parties, including vendors and partners, must be screened for past ethical conduct.
• MOU and agreements must include anti-corruption clauses.

Reporting Mechanism

Suspected bribery or corruption must be reported to the Ethics Officer or via the Whistleblower Policy.

Reports can be made anonymously and will be handled with strict confidentiality.

Investigation and Disciplinary Action

• All reported concerns will be promptly and impartially investigated.
• Any individual found in violation may face disciplinary action, including termination, legal prosecution, and disqualification from future engagements with the Foundation.

Training and Awareness

• Mandatory training will be provided to all employees and volunteers.
• Awareness sessions will be held annually and during onboarding.

Record-Keeping

• Accurate financial records must be maintained to reflect all transactions.
• No off-the-books accounts or false documentation is permitted.

Monitoring and Review

• The policy shall be reviewed annually by the Board of Trustees.
• Compliance audits shall be conducted periodically.

Policy Governance

• The Managing Trustee & Treasurer shall act as the Ethics Officer and oversee compliance.
• Contact for reporting: contact@sas-foundation.in | +91 9654709935