Anti-Corruption & Anti-Bribery Policy

Version 1.0 | Effective: March 1, 2026 | Last updated: March 1, 2026  |  Nimaxiom Service Private Limited

1. Policy Statement

Nimaxiom Service Private Limited, operating as NimeDocs ("the Company," "we," "us," or "our"), maintains a zero-tolerance policy toward bribery and corruption in all forms. We are committed to conducting our business ethically, transparently, and in full compliance with all applicable anti-corruption and anti-bribery laws worldwide.

This policy reflects our belief that ethical conduct is not merely a legal obligation but a fundamental component of sustainable business practice. Every individual acting on behalf of the Company is personally responsible for maintaining the highest standards of integrity and for ensuring that no act of bribery or corruption is committed, facilitated, or condoned.

This Anti-Corruption & Anti-Bribery Policy (the "Policy") supplements, and does not replace, any other policies, procedures, or codes of conduct adopted by the Company.

2. Scope

This Policy applies to:

• All directors and officers of Nimaxiom Service Private Limited;
• All employees, whether full-time, part-time, probationary, or temporary;
• All independent contractors, consultants, and freelancers engaged by the Company;
• All agents, representatives, intermediaries, and channel partners acting on behalf of or for the benefit of the Company;
• All resellers, distributors, and AppExchange partners who market, sell, or distribute NimeDocs products or services;
• All joint venture partners and subcontractors involved in Company operations.

The Policy applies to all business dealings and transactions in every country and territory in which the Company operates, directly or indirectly, regardless of local customs, practices, or competitive pressures.

3. Applicable Laws

The Company is subject to, and this Policy is designed to comply with, the following anti-corruption and anti-bribery legislation (among others):

Jurisdiction	Legislation	Key Provisions
United States	Foreign Corrupt Practices Act (FCPA), 15 U.S.C. §§ 78dd-1 et seq.	Prohibits payments to foreign government officials to obtain or retain business; requires accurate books, records, and internal controls.
United Kingdom	Bribery Act 2010 (c. 23)	Criminalises active and passive bribery, bribery of foreign public officials, and failure by a commercial organisation to prevent bribery. Extra-territorial reach.
India	Prevention of Corruption Act, 1988 (as amended 2018)	Criminalises taking and giving of gratification other than legal remuneration to public servants; Section 8 addresses giving undue advantage to a public servant; Section 9 addresses the liability of commercial organisations for failure to prevent such offences.
India	Companies Act, 2013 — Section 177	While Section 177 of the Companies Act, 2013 mandates vigil mechanisms for listed and prescribed companies, Nimaxiom voluntarily adopts these standards as a matter of good governance.

Where local laws impose stricter standards than this Policy, the stricter standard shall prevail. Where this Policy imposes a standard stricter than local law, this Policy shall prevail to the extent permitted by law.

4. Prohibited Conduct

The following activities are strictly prohibited, whether conducted directly or through any third party:

• Bribery — Offering, promising, giving, soliciting, or accepting any financial or other advantage (including cash, gifts, services, employment, loans, travel expenses, entertainment, or other benefits) to or from any person with the intent to induce or reward improper performance of a function or activity, or to influence a public official in the exercise of their duties.
• Kickbacks — Making or receiving payments, rebates, or returns of a portion of a sum already paid or to be paid as a reward for making or fostering business arrangements.
• Facilitation payments — Small, unofficial payments or gifts made to government officials or employees to expedite or secure the performance of routine governmental actions (e.g., permit processing, customs clearance, utility connections). Facilitation payments are prohibited under this Policy regardless of local custom or practice.
• Improper gifts and entertainment — Providing or accepting gifts, meals, entertainment, or hospitality that are lavish, disproportionate, or intended to improperly influence business decisions.
• Political contributions for commercial advantage — Making contributions to political parties, political campaigns, or politically exposed persons with the expectation of receiving business advantages, preferential treatment, or government contracts in return.
• Charitable donations used as a subterfuge — Making charitable donations that are, in substance, indirect bribes or payments made at the request of a government official to influence an official act or decision.

5. Gifts & Hospitality

The Company recognises that the exchange of reasonable business courtesies is a normal part of commercial relationships. However, all gifts and hospitality must comply with the following requirements:

5.1 Permissible Gifts

• The gift or hospitality must be made in good faith, be of modest value, and be appropriate to the business relationship.
• The aggregate value of any gift or series of related gifts to or from a single individual or organisation must not exceed INR 5,000 (or the equivalent in local currency) in any twelve-month period.
• Gifts exceeding this threshold require prior written approval from the Founder or designated compliance officer.
• All gifts, regardless of value, must be properly recorded in the Company's gift register.

5.2 Prohibited Gifts

• Cash or cash equivalents (gift cards, prepaid debit cards, vouchers redeemable for cash) are never permissible.
• Gifts to government officials, public servants, or their family members intended to influence or that could reasonably be perceived as influencing any official act, decision, or omission are strictly prohibited.
• Gifts provided during an active procurement process, tender, or regulatory decision involving the Company are prohibited.
• Lavish entertainment, luxury travel, or hospitality disproportionate to the business relationship is not permitted.

5.3 Disclosure

All gifts and hospitality — whether given or received — must be disclosed promptly to the Company's compliance function by email to legal@nimaxiom.com. The disclosure must include the recipient, provider, date, description, value, and business purpose.

6. Political Contributions

The Company does not make corporate political contributions of any kind, whether in cash, in kind, through the provision of services, or by any other means. This prohibition includes:

• Direct or indirect donations to political parties, political action committees (PACs), or political candidates;
• Sponsorship of political events, fundraisers, or campaign activities;
• Use of Company resources (including employee time, office facilities, or intellectual property) for political purposes;
• Payments to organisations known to channel funds to political parties or candidates.

Employees retain their right to participate in the democratic process in a personal capacity, using their own resources and time, provided they do not purport to act on behalf of, or create any association with, the Company.

7. Third-Party Due Diligence

Under the UK Bribery Act 2010, Section 7, a commercial organisation may be held liable for bribery committed by associated persons unless it can demonstrate "adequate procedures" to prevent bribery. Similarly, the FCPA prohibits corrupt payments made through intermediaries. Accordingly, the Company undertakes risk-proportionate due diligence on all third parties, including:

• Partners and resellers — AppExchange partners, referral partners, and channel resellers;
• Agents and consultants — Any individual or entity retained to act on behalf of the Company in dealings with government bodies or commercial counterparties;
• Vendors and suppliers — Providers of services, technology, or goods that interact with or represent the Company.

7.1 Due Diligence Process

The due diligence process includes, as appropriate to the level of risk:

1. Background verification of the third party's identity, reputation, and business track record;
2. Assessment of corruption risk factors, including the country of operation, industry sector, and nature of the engagement;
3. Screening against applicable sanctions lists, debarment registers, and politically exposed persons (PEP) databases;
4. Contractual obligations requiring the third party to comply with this Policy, applicable anti-corruption laws, and to permit audit rights;
5. Ongoing monitoring and periodic reassessment of the relationship.

8. Record Keeping

Consistent with the standards established by the FCPA books-and-records provisions, Nimaxiom maintains accurate books, records, and accounts that fairly reflect all transactions.

• All transactions must be recorded accurately and promptly in the Company's books and financial records.
• No off-books accounts, undisclosed funds, or unrecorded transactions are permitted under any circumstances.
• All entries must reflect the true nature, amount, and purpose of each transaction.
• Expense claims must be supported by original receipts, invoices, or other appropriate documentation.
• Internal controls are maintained to provide reasonable assurance that transactions are executed in accordance with management's authorisation.
• Financial records are subject to internal review and external audit as required by the Companies Act, 2013.

9. Reporting & Whistleblower Protection

9.1 Duty to Report

All individuals subject to this Policy have an obligation to report, promptly and in good faith, any known or suspected violation of this Policy, any applicable anti-corruption law, or any conduct that could give rise to a corruption risk. Reports may be made through any of the following channels:

• Email: legal@nimaxiom.com
• Direct report: To the Founder, Neha Singhal, or any member of the leadership team;
• Written correspondence: Marked "Confidential — Anti-Corruption Compliance" and addressed to the Founder at the registered office address.

9.2 Non-Retaliation

The Company is committed to protecting individuals who report concerns in good faith. No person who makes a bona fide report of a known or suspected violation shall be subjected to retaliation, including dismissal, demotion, suspension, harassment, discrimination, or any other adverse employment or contractual action.

This protection extends to individuals who participate in or cooperate with any investigation of a reported concern. Any act of retaliation against a reporter or witness is itself a violation of this Policy and will be treated as serious misconduct.

Consistent with the vigil mechanism standards under Section 177 of the Companies Act, 2013 (which Nimaxiom voluntarily adopts), and the whistleblower protections under the Prevention of Corruption (Amendment) Act, 2018, the Company shall protect the identity of the reporter to the maximum extent permitted by law.

9.3 Investigation

All reports shall be investigated promptly, thoroughly, and impartially. The Company reserves the right to engage external legal counsel or forensic auditors to assist with investigations. Individuals subject to investigation are expected to cooperate fully and are reminded that failure to cooperate is itself a disciplinary matter.

10. Training

The Company shall ensure that all individuals subject to this Policy receive adequate training on anti-corruption and anti-bribery compliance:

• Onboarding training: All new employees, directors, and relevant contractors receive anti-corruption training as part of their induction within 30 days of commencement.
• Annual refresher training: All employees receive mandatory anti-corruption and anti-bribery training at least once per calendar year.
• Role-specific training: Individuals in higher-risk roles (e.g., sales, business development, procurement, finance, and those interacting with government entities) receive enhanced, role-specific training.
• Third-party training: Key agents, partners, and resellers are provided with appropriate guidance on the Company's anti-corruption expectations and their contractual obligations.

Training records, including attendance and completion, are maintained by the Company. Failure to complete mandatory training without reasonable justification may result in disciplinary action.

11. Consequences of Violation

Violations of this Policy are regarded as serious misconduct. Depending on the nature and severity of the violation, consequences may include:

• Disciplinary action — Verbal or written warning, mandatory retraining, suspension, demotion, or reassignment of duties;
• Termination — Termination of employment or contractual relationship with immediate effect and without compensation;
• Civil and criminal prosecution — Referral to relevant law enforcement authorities. Under applicable legislation:
  • The FCPA provides for fines of up to US $250,000 (or twice the pecuniary gain or loss, whichever is greater) and imprisonment for up to five years for individuals. For organisations, fines can reach US $2,000,000 per violation;
  • The UK Bribery Act provides for imprisonment for up to ten years and unlimited fines;
  • The Prevention of Corruption Act (India) provides for imprisonment of three to seven years and fines.
• Recovery of losses — The Company reserves the right to seek recovery of any financial loss suffered as a result of a violation, including through civil proceedings.

12. Review & Amendment

This Policy shall be reviewed at least annually by the Founder and any appointed compliance officer to ensure its continued effectiveness, relevance, and compliance with applicable laws. Amendments may be made at any time to reflect changes in legislation, business operations, or best practice.

13. Governing Law

This Policy is governed by and construed in accordance with the laws of India. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts in Jaipur, Rajasthan, India.