Globose Technology Solutions Private Limited Anti-Corruption and Anti-Bribery Policy

Globose Technology Solutions Private Limited and its subsidiaries (the "Company") operate in a diverse range of legal and business environments, many of which pose challenges to our ability to conduct our business operations with integrity. As a company, we are committed to conducting ourselves according to the highest standards of ethical conduct, including a zero tolerance for bribery and corruption. Throughout its operations, the Company seeks to avoid even the appearance of impropriety in the actions of its directors, officers, employees, and agents.

Many countries have ratified the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Convention). This Anti-Corruption Policy ("Policy") sets out our commitment to integrity, and explains the specific requirements and prohibitions applicable to our operations under the anti-corruption provisions of the relevant local and international laws (collectively, “Anti-Corruption Laws”). The Policy contains information and guidance intended to prohibit and prevent corruption and bribery from occurring in the Company's activities. The Company strictly prohibits all forms of bribery and corruption and will take all necessary steps to ensure that it does not occur in its business activities.

Under the Anti-Corruption Laws, it is an offence to provide, offer or promise to provide a benefit not legitimately due to another person, with the intention of influencing the exercise of a public official’s duties in order to obtain a business advantage. A bribe is any advantage or anything of value that might induce or reward a person to perform or for performing their functions or activities in a way that is improper in the circumstances. The concept of prohibiting bribery is simple. However, understanding the full scope of the Anti-Corruption Laws is essential as these laws directly affect everyday business interactions between the Company and its customers and governments and government-owned or government-controlled entities.

Violations of Anti-Corruption Laws can also result in violations of other laws, including anti-money laundering laws, mail and wire fraud, and conspiracy. The penalties for violating the Anti-Corruption Laws are severe. In addition to being subject to Company disciplinary policies (including termination of their employment), individuals who violate Anti-Corruption Laws may also be subject to imprisonment, fines, and confiscation and related orders.

This Policy is applicable to all of the Company's operations worldwide. This Policy applies to all the Company's executives, directors, officers, and employees (for ease of reference, they are referred to as “Employees” in this Policy).