Ethics & Compliance
Compliance Declaration
- Compliance with Anti-Corruption Laws. In connection with its agreements with different Enterprise Solution Companies(Partner as used hereafter), CSA Consultants Pvt. Ltd.(Company as used hereafter), and all employees, officers, and directors, and any other third parties working for, Company or performing activities on Company’s behalf, (a) have complied with and shall comply with all applicable laws and regulations, including without limitation the Indian Corruption Act 1988 and other applicable anti-corruption laws and regulations (collectively, the “Anti-Corruption Laws”); and (b) have kept and shall keep accurate books, accounts, and records. It is the intent of the parties that no payments or transfers of anything of value shall be made in connection with any agreements between Company and Partner that have the purpose or effect of public, commercial or other bribery, or acceptance of or acquiescence in extortion, kickbacks, or other unlawful or improper means of obtaining business or any improper advantage.
- Conviction, Debarment, Suspension. Company has not been convicted of or pleaded guilty to (or otherwise been adjudicated as culpable for) an offense involving fraud, corruption, or similar offense, and has not been listed by any government agency as debarred, suspended, proposed for the foregoing actions, or otherwise ineligible for government procurement programs. Company will notify Partner promptly in the event of a change in status that causes the foregoing statement to no longer be true.
- Consequences of Violation. Company acknowledge that Partners will materially rely on this declaration. In the event that any statements made herein are determined to be materially false, such statements shall be considered a material breach by Company of Company’s agreements with Partner and Partner shall have the right to immediately terminate all agreements with Company.
- Training. Company has provided or will provide training and information to its officers, directors, employees, and any third parties utilized by Company in connection with performance of the agreements between Company and Partner as necessary to ensure full compliance with the Anti- Corruption Laws and any other applicable laws.
- Certification. Company, by and through an authorized officer, will periodically, at Partner’s request, complete Partner’s Due Diligence Questionnaire and Compliance Certification and/or otherwise certify compliance in writing with Company’s obligations set forth in this certification. Company may be subject to additional due diligence, questions and training, as determined by Partner in its sole discretion.
- Reporting Potential Violations. Company shall promptly inform Partner’s Legal Department in writing should it or any of its officers, directors, or employees learn of, or suspect, any act or circumstance that may violate applicable laws in connection with its agreements with Partner.
- No Affiliation with Government Officials – Disclosure Obligation. Company affirms that (1) none of its owners, directors, employees and, to its knowledge, third parties involved in the performance of its agreements with Partner is a Government Official or a Close Family Member of a Government Official with the ability, or appearance of ability, to influence the performance of its agreements with Partner; or that (2) it has fully described any such relationship in writing to Partner’s Legal Department and received acknowledgement by Partner’s Legal Department of such disclosure. For purposes of this certification (A) “Government Official” means an officer or employee of any government; officer or employee of any public international organization; officer or employee of any department, agency, or instrumentality of any government or of any public international organization; officer or employee of any government-owned or government-controlled company; political party; political party official; or anyone, whether a private person or otherwise, acting in an official capacity on behalf of any of the above or of any government entity and (B) “Close Family Member of a Government Officials” means the Government Official’s spouse, the Government Official’s or the spouse’s grandparents, parents, siblings, children, nieces, nephews, aunts, uncles, and first cousins; the spouse of any of the above; or any other person who shares the same household with the Government Official. In the event there is a change in the information described in this paragraph during the term of its agreements with Partner, Company shall promptly disclose such change to Partner’s Legal Department in writing.
- Disclosure of Third Parties. Company shall not utilize or employ any Affiliate, third-party subcontractor, consultant, agent, or other intermediary, in connection with the performance of lead generation or government-controlled entity procurement activities under its agreements with Partner without express prior written consent from Partner’s Legal Department. Partner will have the authority to accept or reject any proposed third party.
