Anti-Bribery And Anti-Corruption Policy
Anti-Bribery & Anti-Corruption Policy - Table of Contents
Last Updated: December 17, 2025
This ABAC Policy applies to WebEngage, its subsidiaries, associates, and joint ventures. It outlines our zero-tolerance stance on bribery and corruption, ensuring compliance with laws such as India’s Prevention of Corruption Act, 1988 (as amended in 2018), the UK Bribery Act 2010, and the US FCPA.
Purpose: To prevent bribery, facilitation payments, or corruption through adequate procedures, risk assessments, and training. All WebEngage Personnel must identify and report suspicious conduct.
1. Policy Statement
- WebEngage conducts ethical business with robust systems to detect and prevent fraud, bribery, and corruption.
- Zero tolerance for bribery or corrupt activities.
- We act with integrity in all dealings and comply with ABAC laws in every jurisdiction.
2. Scope and Applicability
This Policy applies to all WebEngage Personnel: directors, executives, employees (including all types), consultants, contractors, interns, agents, business partners, and third parties.
In doubt? Consult the Grievance Officer
- Covers interactions with public/private officials, customers, suppliers, and governments.
- Bribery includes direct/indirect offers of money, gifts, or favours to improperly influence actions.
- Test for Doubt:
| Question | Guidance |
| Is the intent relational or influential? | Must be purely relational. |
| How would this look publicly (e.g., on social media)? | Avoid any negative perception. |
| Would you accept it if roles were reversed? | No double standards. |
- Red Flags (report immediately):
| Red Flag | Example |
| Unusual payments | Cash to unnamed parties or off-books. |
| Sham contracts | Consultants for government deals with vague services. |
| Success guarantees | Promises without due process. |
| Record refusal | Third parties reject ABAC clauses. |
3. Grievance Officer
- Designated: Director-Legal (or person appointed by the Board).
- Report all concerns here; serious issues should be escalated to the Board/Designated Director.
- Email:
4. Key Definitions
- Bribery: Offering, promising, giving, requesting, or accepting undue advantage to influence improper performance.
- Corruption: Abuse of power for private gain.
- Public Official: Government employees, judges, politicians, or their agents (includes foreign officials).
- Third Party: Vendors, agents, consultants, suppliers.
- Facilitation Payment: Small payments to expedite routine government actions (prohibited except under duress—see 7).
5. High-Risk Areas
Gifts/hospitality, procurement, political donations, recruitment, M&A, government interactions.
6. Gifts, Entertainment, and Hospitality
- Definition: Items/services of value (e.g., cash, meals, travel > INR 5,000).
- Rules:
| Item | Threshold | Approval | Notes |
| Gifts | Business only | Pre-approval from Department Head | No cash equivalents. |
| Hospitality/Entertainment | Business only | Pre-approval from Department Head | Pro-rata for groups. |
| Travel/Lodging | Business-only | Pre-approval from Department Head | No family/spouse. |
- Public officials: Strictly nominal (≤ INR 2,500); comply with the law.
- Annual gift register audited by Internal Audit and retained for 5 years
7. Compelled Undue Advantage
- Report threats to safety within 24 hours to the Grievance Officer.
- Legal Head notifies law enforcement within 15 days.
- Facilitation payments are strictly prohibited, except under duress. Any existing arrangements must be reported immediately for cessation.
8. Procurement
- Follow the Procurement Manual.
- No gifts influencing selection; document all bids/decisions.
- Due diligence on vendors > INR 10 lakhs.
9. Customers and Third Parties
- Transparent discounts/rebates only; no hidden bribes.
- Third-Party Due Diligence:
- Risk assessment (high/medium/low.
- Standard ABAC clauses in contracts.
- Annual re-certification for high-risk.
- Retain records for 7 years
10. Government Interactions
- Reasonable, documented hospitality.
- No political donations without Board approval + legal review.
11. Mergers & Acquisitions
- ABAC due diligence pre-close.
- Post-close: Train staff, audit units, and re-vet third parties.
12. Training and Communication
- All employees: Annual training + onboarding.
- High-risk third parties: Contractual training requirement and obligation.
- Communications via town halls, intranet.
13. Raising Concerns
- Report via department head, Grievance Officer, or Whistleblower Policy.
- Protections: No retaliation for good-faith reports.
14. Violations and Penalties
- Disciplinary action (up to termination); criminal referral.
- Personal liability: Fines up to 3x the bribe (PCA), imprisonment.
- Investigations: Fair process, natural justice.
15. Review
- Annual Internal Audit review.
- Amendments by the Board as needed.
16. Contact Information
For questions, violations reports, or requests regarding this ABACP:
Email:
WebEngage reserves all rights to interpret, enforce, and amend this policy consistent with evolving legal and ethical standards
