TVS Industrial & Logistics Parks Private Limited
CIN: U45200MH2005PTC154628

ANTI BRIBERY & CORRUPTION

TVSILP is fully committed to complying with the relevant anti-bribery and corruption laws
in India including the Prevention of Corruption Act, 1988, and international best practice.
The Company prohibits offering, giving or promising bribes directly or indirectly either to
a government official or to any other stakeholder to obtain or retain business, influence
business decisions or to secure an unfair advantage.

Bribery
Bribery involves offering, promising or giving an advantage (financial or otherwise) to an
individual to induce that individual to perform an improper action. It also occurs when
such an inducement is demanded, or when there is agreement to receive such an
inducement, whether or not it is received.
A corporate entity may be criminally liable for its failure to prevent bribery, including by
anyone providing services for or on its behalf. This may include employees, agents, joint
ventures, representatives and subsidiaries, amongst others.

Corruption
Corruption may be described as any abuse of position for personal gain by a person in
public office. The risk of exposure to corruption increases when dealing with politically
exposed persons (“PEPs”). PEPs are defined as persons serving in public office as well as
their associates. Such associates could be family members, friends or business persons
who can use their position with the respective persons serving in public office, to
influence their position.

Facilitation payments
A facilitation payment is a payment made in order to facilitate or expedite the provision
of a routine government service. This is also commonly referred to as grease payment,
speed money or routine payments. TVS ILP does not draw a distinction between
facilitation payments and other forms of bribery and corruption.

Inducement
An inducement is a pledge or promise that causes an individual to enter into a particular
agreement.

Giving A Bribe
It is illegal to offer, promise or give an advantage to someone: (i) with the intention that
the advantage will induce or reward that person for behaving improperly, or (ii) knowing
or believing that the recipient’s acceptance of the advantage would constitute improper
behaviour. A person behaves improperly if they act in breach of an expectation that they
will perform a function in good faith or impartially, or in breach of an expectation arising
from the fact that they occupy a position of trust.

Receiving A Bribe
If an employee accepts an improper gift, payment, or offer of hospitality, they may
commit an offence of requesting, agreeing to receive or accepting a bribe.
The question of whether a person has behaved improperly is judged by reference to
whether they have acted in breach of an expectation of good faith or impartiality, or an
expectation arising from a position of trust.

Bribing a Public Official
TVS ILP employees must never pay an unofficial gratuity to government officials or
government employees in order to facilitate or expedite administrative actions, such as
customs clearances, visas, permits, licenses, etc. Employees are prohibited from
discussing business terms with people who demand or offer bribes.

Bribing through a third party
TVS ILP must never pay an unofficial gratuity to government officials or government
employees, through the use of third parties. The Code of Conduct forbids paying, offering,
asking for, proposing terms for, or accepting bribes with the assistance of any
organization or individual. TVS ILP will never authorize third parties to engage in bribery
or corruption on its behalf. The Company may be held responsible for the conduct of third
parties if they violate the law while working on TVS ILP’s behalf.

Corruption Register
All reports of corruption including where favours are demanded must be reported to the
Chief Compliance Officer, who will maintain these records in the Fraud and Corruption
register.

Duties of employees
• Comply with all relevant anti-bribery and anti-corruption laws.
• Never offer or accept anything of value meant to improperly influence business
decisions.
• Report incidents of bribery or corruption, including situations in which a bribe was
requested but not paid, immediately to the reporting manager or the Chief
Compliance Officer.
• Accurately record and fully disclose transactions in which a bribe has occurred.
• When in doubt, consult the Chief Compliance Officer or the legal team.