Anti-Bribery and Business Ethics Statement

1. Our position

BitsToBug Studios LLP conducts business honestly and with integrity. We have a zero tolerance approach to bribery and corruption in any form, whether in the private sector or in dealings with public officials, and in every country in which we operate.

2. Legal framework

We comply with the Prevention of Corruption Act, 1988 and other applicable Indian law, and we conduct ourselves in a manner consistent with international anti-corruption standards including the United Kingdom Bribery Act 2010 and the United States Foreign Corrupt Practices Act, where relevant to our engagements.

3. Prohibited conduct

• Offering, promising, giving, requesting or accepting any bribe, kickback or improper advantage, directly or through a third party.
• Facilitation payments of any kind, regardless of local custom or practice.
• Political contributions made on behalf of the firm to obtain or retain business.
• Gifts or hospitality that are lavish, given with the intention of influencing a decision, or offered during a live tender or procurement process.
• Any arrangement designed to conceal the true nature of a payment or relationship.

4. Public sector engagements

We participate in government and public sector procurement strictly on merit. We comply with all applicable tender rules, disclose conflicts of interest, and do not engage intermediaries to influence public officials. All engagements are documented, invoiced transparently and recorded accurately in our books of account.

5. Conflicts of interest

Personnel must disclose any personal, financial or family interest that could conflict, or appear to conflict, with the interests of the firm or a client. Disclosed conflicts are recorded and managed, including by removing the individual from the relevant engagement where appropriate.

6. Records and controls

All payments and receipts are recorded accurately and completely in our accounts. No undisclosed or unrecorded account is maintained for any purpose. Expenses are supported by documentation and reviewed before approval.

7. Third parties

We expect the same standards from suppliers, subcontractors, partners and agents acting on our behalf. Anti-bribery obligations are included in our contracts with third parties, and we reserve the right to terminate any relationship where these standards are breached.

8. Raising a concern

Any person, whether within or outside the firm, may raise a concern in confidence to Shreyansh Tiwari at shreyansh@bitstobug.com. Concerns are investigated promptly. We do not tolerate retaliation against anyone who raises a concern in good faith, whether or not the concern is ultimately substantiated.

9. Consequences

Breach of this Statement is treated as serious misconduct and may result in termination of employment or engagement, termination of a commercial relationship, and referral to law enforcement.