Anti-Bribery & Anti-Corruption Policy

Purpose & Scope

Aetherops Sentinel Technologies Pvt. Ltd. ("Aetherops," the "Company," "we," "our," or "us"), which operates the TheCloudbox brand and platform, has a zero-tolerance approach to bribery and corruption. This policy sets out our responsibilities, and those of everyone working for or on our behalf, in preventing corrupt conduct.

It applies to all directors, officers, employees, contractors, and interns, and to all third parties who act for or on behalf of the Company, including agents, intermediaries, distributors, and partners.

Policy Statement

We prohibit offering, promising, giving, requesting, agreeing to receive, or accepting any bribe or improper advantage — directly or through a third party — to or from anyone, whether a government official or a private party, for any purpose. We conduct business honestly and on merit.

Key Definitions

• Bribe — any financial or other advantage offered, given, or received to improperly influence a decision or secure a business advantage.
• Facilitation payment — a small unofficial payment to speed up a routine government action.
• Kickback — a return of a portion of a payment in exchange for favourable treatment.
• Public official — any officer, employee, or representative of a government, state-owned entity, public international organisation, political party, or candidate.

Prohibited Conduct

• Paying, offering, or authorising bribes or kickbacks to win, retain, or direct business.
• Accepting or soliciting bribes, kickbacks, or improper advantages.
• Using intermediaries to make or receive improper payments the Company could not make directly.
• Disguising improper payments as commissions, consulting fees, donations, or expenses.

Gifts & Hospitality

Reasonable and proportionate gifts and hospitality given openly for a legitimate business purpose are acceptable. They must never be intended to improperly influence a decision, must comply with the recipient’s own rules, and must be recorded. The following are not permitted:

• Cash or cash-equivalents (vouchers, gift cards) in any amount.
• Gifts or hospitality given during a tender, negotiation, or decision that could be influenced.
• Lavish, frequent, or secretive gifts or entertainment.
• Anything given to or received from a public official without prior approval.

Facilitation Payments

Facilitation payments and kickbacks are prohibited, regardless of local custom or size. If you are pressured to make such a payment, or a payment is demanded under duress where personal safety is at risk, make any unavoidable safety-related payment, remove yourself from the situation, and report it immediately.

Political & Charitable Contributions

The Company does not make political contributions to obtain a business advantage. Charitable donations and sponsorships must be to bona fide organisations, made transparently, properly recorded, and never used as a route for a bribe. Contributions on the Company’s behalf require prior approval from the Compliance function.

Third Parties, Agents & Intermediaries

Third parties acting for us can create liability for the Company. Before engaging an agent, intermediary, or partner, we conduct risk-based due diligence, include anti-corruption and audit terms in contracts, pay only reasonable fees for genuine services, and monitor the relationship. Red-flag concerns must be resolved before any engagement proceeds.

Books, Records & Internal Controls

All payments, gifts, hospitality, and expenses must be recorded accurately, fairly, and in reasonable detail. No off-book accounts, false or misleading entries, or undisclosed funds are permitted. Financial controls are designed to detect and prevent improper payments.

Applicable Laws

This policy is designed to meet the requirements of the anti-corruption laws that apply to us, including:

• The Prevention of Corruption Act, 1988 (India), as amended.
• The U.S. Foreign Corrupt Practices Act (FCPA), where applicable.
• The UK Bribery Act 2010, where applicable.
• All other anti-bribery and anti-corruption laws of the jurisdictions in which we operate.

Red Flags

Be alert to warning signs such as requests for cash or unusual payment routes, invoices for vague or inflated “consulting” services, a partner with a reputation for improper payments, requests for payments to third countries or accounts, or pressure to bypass due diligence. Report red flags before proceeding.

Reporting & Non-Retaliation

You must report any suspected bribery or corruption, or any request for an improper payment, as soon as possible. Reports may be made in confidence or anonymously through the channel below. The Company prohibits retaliation against anyone who reports in good faith or refuses to pay a bribe, even if it results in lost business.

Roles, Training & Enforcement

The Compliance function owns this policy, provides training, and investigates reports. Managers must ensure their teams understand and follow it. Breach of this policy is a serious matter that may lead to disciplinary action up to and including termination, and to civil or criminal liability for the individuals involved.

Contact & Reporting

Questions about this policy, or reports of a suspected violation, may be raised in confidence at: