Anti-Bribery, Corruption & Money Laundering Policy

1. INTRODUCTION

1.1. tatapart.com (“tatapart”) is a web portal owned and operated by M/s Aman Motors (“Company/We/Us/Our”), , with its registered office at , India. Operating under the trademarked name “tatapart - spare parts expert,” it is an online marketplace for Tata Motors spare parts.

1.2. tatapart is committed to maintaining the highest standards of integrity and transparency in its business dealings. To reinforce our zero-tolerance approach towards bribery, corruption, and money laundering, this Anti-Bribery, Corruption, and Money Laundering (“Policy”) outlines the principles and guidelines for all individuals and entities associated with the Company.

2. DEFINITIONS

  • Associates: Includes all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, volunteers, service providers, seconded staff, casual workers, agency staff, agents, or any other person associated with tatapart, wherever located.

  • Business Partners: Refers to Consultants, Logistics Partners, Vendors, Contractors, Agents, Intermediaries, any other Service Providers, and associates of such third parties with whom tatapart enters into contracts.

  • Bribery: The offering, promising, giving, receiving, soliciting, or accepting of a financial or other advantage to influence the behavior of a person in a position of trust to gain a commercial advantage.

  • Cross-Border Transactions: Transactions involving a Government Official where the Associate or the transaction is in a country other than the home country of the Government Official.

  • Improper Payments: Payments made to influence any act or decision of a person improperly or to gain an improper benefit for the Company.

  • Extortion: The direct or indirect demand or acceptance of bribes, facilitation payments, or kickbacks.

  • Facilitation Payments: Unofficial payments made to expedite routine government actions.

  • Gift: Anything of value, including cash, discounts, services, loans, favors, and other benefits.

  • Kickbacks: Payments made in return for a business favor or advantage.

  • Money Laundering: The process of concealing the source of illegally gained funds and reintroducing them into the economy for legitimate purposes.

3. SCOPE AND APPLICABILITY

3.1. This Policy applies to all Associates and Business Partners of the Company. It is their responsibility to adhere to all elements described herein.

3.2. Associates must ensure that the Company’s procedures to combat bribery, corruption, and money laundering are upheld and strengthened.

3.3. This Policy provides guidance on recognizing and dealing with bribery, corruption, and money laundering issues, ensuring that tatapart operates with professionalism, fairness, and integrity.

4. COMPLIANCE OFFICER

4.1. The Company shall designate a Compliance Officer to oversee adherence to this Policy. The Compliance Officer is currently the Company Secretary.

4.2. Associates must report any concerns related to this Policy to the Compliance Officer. The Compliance Officer will investigate all reports and concerns.

4.3. Any significant breaches of this Policy will be escalated to the Board of Directors.

5. POLICY FRAMEWORK

5.1. The Company prohibits all forms of bribery and corruption, whether involving government officials or private sector individuals, directly or indirectly.

5.2. The Company expects everyone associated with it to conduct business with integrity, regardless of local customs or traditions.

5.3. Associates must not offer, pay, or authorize any payment or gift intended to influence a recipient’s job responsibilities or secure an improper advantage.

5.4. Associates must ensure that any payment made on behalf of the Company is appropriate for the goods or services provided and always request a detailed receipt.

5.5. Associates must comply with this Policy while engaging with Business Partners and report any suspicions of bribery or corruption according to the Whistle-Blower Policy.

5.6. Cross-border transactions must comply with local laws in the government official’s home country and the initiating Associate’s country. Consult the Legal Department if needed.

5.7. Associates cannot accept gifts, except those customary or religious, and must avoid frequent or material gifts to maintain integrity.

5.8. Charitable donations by the Company must be legal and ethical, and Associates may make personal donations that are documented with receipts.

6. RED FLAGS

Report any of the following red flags promptly using the Whistle-Blower Policy:

6.1. Awareness of a third party engaging in improper business practices.

6.2. A third party with a reputation for paying bribes or requiring bribes.

6.3. A third party requesting payment before signing a contract or completing a service.

6.4. Requests for cash payments or lack of formal agreements or receipts.

6.5. Payments requested to different countries from where the third party operates.

6.6. Requests for unexpected additional fees or commissions.

6.7. Demands for lavish gifts or entertainment.

6.8. Payments requested to overlook potential legal violations.

6.9. Requests to provide advantages to friends or relatives.

6.10. Non-standard invoices or custom payment requests.

6.11. Use of side letters or refusal to put terms in writing.

6.12. Use of agents or intermediaries not typically used.

6.13. Unusually generous gifts or lavish hospitality.

6.14. Contributions suggested to influence decision-making for licenses or approvals.

7. ANTI-MONEY LAUNDERING

7.1. The Company complies with all applicable anti-money laundering laws, including the Prevention of Money Laundering Act, 2002.

7.2. Associates and Business Partners must adhere to anti-money laundering laws and establish processes to prevent breaches.

8. REPORTING VIOLATIONS OF THIS POLICY – WHISTLE-BLOWER POLICY

8.1. Associates and Business Partners must conduct business in a lawful and ethical manner.

8.2. Any instance of Policy violation must be reported to the Legal Department at [Legal Department Email Address].

8.3. The Company will investigate reports and take appropriate action.

8.4. The Company will conduct due diligence to ensure Policy compliance.

9. DISCIPLINARY ACTION FOR NON-COMPLIANCE

9.1. Non-compliance with this Policy may result in disciplinary action, including termination of employment or contract.

9.2. Violations may also constitute criminal offenses under applicable laws, leading to civil or criminal penalties.

9.3. The Company may refer matters to regulatory authorities if necessary.

9.4. The Compliance Officer will oversee investigations and recommend corrective actions and penalties.

10. PERIODIC REVIEW AND EVALUATION

10.1. The Board of Directors will review and monitor the effectiveness of this Policy.

10.2. The Company reserves the right to amend this Policy as needed.