A Message from Our Managing Director

Rajesh Kumar Dora, Managing Director – OmniLink Technology Pvt. Ltd.

Dear Colleagues,

Corruption is not just a legal risk — it threatens trust, reputation, and long-term business sustainability. At OmniLink Technology, we have built over 28 years of client relationships, industry credibility, and operational excellence on one non-negotiable principle: we always do business the right way.

We strictly prohibit any direct or indirect involvement in bribery, including offering, accepting, or facilitating improper payments. We also forbid the misuse of company funds or assets for illegal or unethical purposes under any circumstances.

Violations of this policy will lead to disciplinary action, including termination of employment or contracts, and may result in legal proceedings.

I urge every employee, partner, agent, and associate to read this policy carefully, apply its principles, and uphold them consistently. Our reputation depends on the trust of our clients, communities, and colleagues—let us protect it.

Purpose and Scope of the ABAC Policy

OmniLink Technology Pvt. Ltd. has established this Anti-Bribery and Anti-Corruption (ABAC) Policy to ensure full compliance with applicable domestic and international laws. The policy prohibits improper payments, gifts, or inducements in any form.

Who This Policy Applies To

This policy applies to:

• All officers and directors
• All employees (permanent, contractual, and probationary)
• All agents, consultants, and advisors
• All third-party representatives, including vendors, partners, and subcontractors
• All subsidiaries, joint ventures, and associated entities

Geographic Scope

This policy governs all business activities across every location where OmniLink operates, including Bhubaneswar, Noida, Bangalore, and all international engagements. We enforce anti-bribery compliance across India and all global markets where we conduct business.

Zero-Tolerance Approach to Bribery and Corruption

OmniLink Technology enforces a strict zero-tolerance policy toward bribery and corruption.

• No employee or representative may offer, request, give, or accept bribes, kickbacks, or improper payments.
• No one may use company funds or assets for illegal or unethical purposes.
• We do not permit facilitation payments under any circumstances.
• Employees must not offer or accept gifts or hospitality that could influence business decisions.

This policy applies consistently across all operations, markets, and individuals associated with OmniLink.

Gifts, Hospitality, and Entertainment – Permitted and Prohibited

OmniLink Technology allows reasonable business hospitality but strictly prohibits any form of undue influence.

Permitted Gifts & Hospitality

Employees may accept or offer:

• Nominal promotional items with company branding
• Meals during legitimate business meetings
• Participation in industry events or training with valid business purposes
• Gifts below the value defined in the company’s Gift Register policy

Prohibited Gifts & Hospitality

The following are strictly prohibited:

• Cash or cash equivalents (gift cards, vouchers)
• Gifts or benefits offered to government officials for business influence
• Any benefit intended to influence procurement or regulatory decisions
• Gifts during active tenders or bidding processes
• Any item that could harm the company’s reputation if disclosed publicly

Employees must declare and record all non-nominal gifts with the Compliance Officer.

Interactions with Government Officials and Public Sector Bodies

OmniLink Technology maintains strict controls when engaging with government and public sector entities.

• Employees must not offer payments, gifts, or benefits to influence official decisions.
• All government fees and charges must go through official and documented channels.
• Employees must report any request for improper benefits immediately.
• Staff must complete mandatory ABAC training before engaging with public sector clients.

Third-Party Due Diligence and Vendor Compliance

OmniLink holds all third parties to the same ethical standards.

Third-Party Requirements

All third parties must:

• Comply with this ABAC Policy
• Complete due diligence checks before onboarding
• Provide records for compliance audits when required
• Report any suspected misconduct involving OmniLink

We will terminate engagements immediately if we identify policy violations or legal breaches.

Reporting Concerns – Speak Up Without Fear

OmniLink encourages prompt reporting of any suspected misconduct.

How to Report a Concern

You can report concerns:

• Directly to the Compliance Officer
• Through your manager or HR Business Partner
• Via the anonymous reporting mechanism

Whistleblower Protection

We protect all individuals who report concerns in good faith from retaliation or discrimination. However, we will take action against false or malicious reports.

Compliance Oversight, Training, and Consequences of Violations

The Compliance Officer

The Compliance Officer:

• Monitors policy implementation and compliance
• Maintains records such as the Gift Register
• Conducts risk assessments and audits
• Leads training and awareness programs
• Investigates violations and recommends actions

Mandatory Training

All employees must complete ABAC training during onboarding and at regular intervals. We design training programs to be practical and role-specific.

Consequences of Violations

Policy violations will result in:

• Immediate suspension during investigation
• Disciplinary action, including termination
• Legal action where required
• Personal civil or criminal liability

No business justification will excuse policy violations.

Policy Review and Amendments

OmniLink reviews this policy regularly and updates it based on legal or business changes. We communicate all significant updates to employees and stakeholders.

Continued association with OmniLink confirms acceptance of the latest version of this policy.

For the full ABAC Policy document, contact the Compliance Officer or HR Business Partner.