Anti-Bribery & Anti-Corruption Policy
Commitment to uncompromising ethical integrity, prohibition of facilitation payments, and strict compliance with the Prevention of Corruption Act 1988.
1Policy Statement & Zero-Tolerance Stance
FOGS Consultants maintains a strict, unconditional zero-tolerance policy towards bribery, extortion, kickbacks, and any corrupt practices in our business conduct across all 18 Indian operating platforms.
Strict Prohibition: No employee, partner, advocate, or representative of FOGS Consultants shall ever offer, promise, pay, demand, or accept any bribe, gift, or illegal gratification, directly or indirectly, to influence any official act or secure an improper business advantage.
2Prohibited Practices Under Indian Law
This policy enforces strict compliance with the Prevention of Corruption Act, 1988 (PCA), as amended by the Prevention of Corruption (Amendment) Act, 2018, and applicable international laws. The following actions are strictly banned:
- Bribes & Kickbacks: Giving or receiving money, gifts, loans, or services to influence procurement, audit approvals, or legal settlements.
- Facilitation Payments ("Speed Money"): Small unofficial payments to government officials to expedite routine, non-discretionary administrative actions (such as PF challan processing or license endorsements).
- Third-Party Conduits: Engaging subcontractors or agents with the knowledge or expectation that they will engage in bribery on our or our clients' behalf.
3Statutory Authority & Departmental Liaison
As compliance consultants representing clients before the EPFO, ESIC, Labour Welfare Fund boards, and Factories & Boilers Inspectorate:
- All official fees, scrutiny fees, and penalty remittances must be paid exclusively via official government challans, electronic bank transfers, or official government portals.
- Cash payments to any inspector, statutory officer, or administrative clerk are strictly forbidden under all circumstances.
- All meetings with regulatory authorities must be documented with formal attendance minutes and official case references.
4Gifts, Entertainment & Hospitality Limits
Promotional items of modest, token value (such as company stationery or calendars valued under โน1,000 INR) are permitted strictly if customary and transparent. Offering gifts or hospitality to public servants or statutory inspectors is strictly prohibited.
5Accounting Transparency & Record-Keeping
FOGS Consultants maintains complete and transparent accounting records under Indian accounting standards and GST laws. No secret, unrecorded, or "off-the-books" accounts or slush funds shall ever be created or utilized.
6Reporting Violations & Confidential Whistleblower Channel
Any employee, client, or vendor who witnesses or suspects bribery or corrupt solicitation must immediately report the matter to our designated Ethics & Compliance Officer. All reports are investigated with absolute confidentiality and statutory protection under our Whistleblower Policy.
Confidential Ethics & Anti-Corruption Desk
Reports are reviewed independently by Senior Management in Kochi, Kerala.
โ๏ธ File Confidential Report