Anti-Bribery and Anti-Corruption Policy (ABAC)

Purpose
SAMOON FOUNDATION is committed to conducting all its activities with the highest standards of professionalism, fairness, and integrity. The Foundation adopts a ZERO TOLERANCE approach toward bribery and corruption. This policy has been developed in accordance with SAMOON FOUNDATION’s Code of Conduct, internal policies, and the applicable legal and statutory framework of anti-corruption legislation in India.

The purpose of this policy is to:

- Ensure compliance with all applicable anti-bribery and anti-corruption regulations.

- Promote transparent, ethical, and socially responsible dealings.

- Protect SAMOON FOUNDATION’s reputation by establishing clear controls and standards.

Applicability
This policy applies to all individuals associated with SAMOON FOUNDATION, including but not limited to:

- Directors, senior managers, officers, and employees

- Consultants, contractors, volunteers, interns, and agents

- Sponsors, partners, third-party representatives, or any other person acting on behalf of SAMOON FOUNDATION

Scope
All employees and representatives of SAMOON FOUNDATION are expected to remain vigilant and uphold ethical practices in the following areas:

1. Gifts & Hospitality

- Giving or receiving cash or cash equivalents on behalf of SAMOON FOUNDATION is strictly prohibited.

- Gifts or hospitality may be given or accepted if:

- They are proportionate, reasonable, and without any expectation of return.

- Properly documented.

Examples of permissible gifts or hospitality:

- Gifts from trainees or their families

- Distribution of free masks, nutritious products, or other community support items

- Gifts of products made by SAMOON FOUNDATION entrepreneurs to funders, GC members, or volunteers

- Diwali gifts from funders or other stakeholders

2. Bribery

- Employees and individuals acting on behalf of SAMOON FOUNDATION must not offer, give, request, or accept any bribe.

- A bribe is defined as anything intended to secure an unfair commercial, contractual, or regulatory advantage for the Foundation or personal gain for an individual or anyone connected to them.

Procedure for Reporting Suspected Bribery or Corruption

1. Complaints can be submitted in writing to the immediate supervisor.

2. The supervisor, in coordination with the CEO, will conduct a prompt investigation.

3. If the complaint is against the CEO, it may be escalated to the Vice-President for resolution.

4. Upon confirmation of unethical conduct, appropriate disciplinary or corrective action will be taken, which may include termination.

5. Investigations are normally completed within 15 days of receiving the complaint.

      6. Records of the investigation shall be maintained for a minimum of seven years.

Amendments
SAMOON FOUNDATION reserves the right to amend or modify this policy, in whole or in part, at any time. Any amendments will be communicated in writing to all employees and directors and will only be binding upon such notification.