+91 94054 57145

urdupraja@gmail.com

Pimpalgaon Raja, Dist. Buldhana, M.S., India

Anti-Bribery & Anti-Corruption Policy

1. Policy Overview & Scope

1.1 Objective

This anti-bribery and anti-corruption policy sets out the clear responsibilities of our organization and of those who work for us regarding observing and upholding our absolute zero-tolerance position on bribery and corruption. Raja Education & Bahuuddeshiya Society does not entertain, authorize, or tolerate any such acts across any tier of our operations. This document serves as a core source of information and guidance, helping our staff members recognize, confront, and deal with bribery and corruption issues, while fully understanding their personal responsibilities.

1.2 In-Scope Personnel & Jurisdictions

This policy applies uniformly to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, field workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties) no matter where they are located. The policy also strictly applies to all Institutional Officers, Trustees, Executive Board members, and Committee members at every level of the society.

1.3 Document Control

  • Policy Name: Anti-Bribery & Anti-Corruption Policy
  • Policy Code: REBS-ABCP-2026-V1
  • Effective Date: May 18, 2026
  • Review Cycle: Annual

2. Definition of Bribery

2.1 What Constitutes Bribery?

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to improperly induce or influence an action or administrative decision.

2.2 What is a Bribe?

A bribe refers to any inducement, reward, or item of value offered to another individual in order to gain a commercial, contractual, regulatory, institutional, or personal advantage.

2.3 Legal Implications

Bribery is not limited solely to the act of offering or paying a bribe. If an individual is on the receiving end of an illicit offer and accepts it, they are equally breaking the law. Bribery is entirely illegal under the Prevention of Corruption Act, 1988. Employees must not engage in any form of bribery, whether it be directly, passively, or through a third party. Personnel are strictly prohibited from bribing any public official, government representative, or independent inspector anywhere.

If any staff member is ever uncertain about whether an item or invitation constitutes a bribe, a gift, or an acceptable act of hospitality, they must immediately seek formal advice from the Society's Designated Compliance Officer.

3. Permissible vs. Impermissible Actions

This policy explicitly governs four specific operational areas:

  • Gifts and hospitality.
  • Facilitation payments and kickbacks.
  • Political contributions.
  • Charitable contributions.

3.1 Gifts and Hospitality

The society accepts normal and appropriate gestures of hospitality and goodwill (whether given to or received from third parties), provided that the exchange strictly meets the following institutional requirements:

  • It is not made with the underlying intention of influencing the party to whom it is given, or to obtain or reward the retention of an institutional or operational advantage, or as an explicit or implicit exchange for favors or benefits.
  • It is not made with any suggestion or undercurrent that a return favor is expected.
  • It is conducted openly in the formal name of the Society, never in an individual's private name.
  • It never includes cash or cash equivalents, such as digital gift cards, commercial vouchers, or certificates.
  • It is entirely appropriate for the specific circumstances (e.g., exchanging small token items around major cultural festivals like Diwali or Christmas, or offering a modest corporate thank-you upon completing a large welfare project).
  • It is of an appropriate type, modest financial value, and given at a suitable time, taking into account the verified justification for the gesture.
  • It is never offered to, or accepted from, a government official, inspector, politician, or political party representative without the explicit, documented prior approval of the Society’s Executive Management Committee.

Where it is culturally inappropriate or deeply offensive to decline an immediate offer of a gift (such as during specific traditional community welcomes), the gift may be politely accepted on behalf of the organization, provided it is immediately declared to the Compliance Officer, who will formally assess the circumstances. The society recognizes that customs regarding institutional gifts vary between regions, cultures, and contexts; therefore, definitions of what is acceptable must always align with transparency and the law.

3.2 Facilitation Payments and Kickbacks

  • Zero Tolerance: Raja Education & Bahuuddeshiya Society does not accept and will not make any form of facilitation payments of any nature. We recognize that facilitation payments constitute a form of bribery that involves expediting or facilitating the performance of a public official for a routine, mandatory governmental action. These typically tend to be demanded by low-level officials to secure or speed up the standard performance of a duty.
  • Kickbacks: The society strictly prohibits kickbacks from being made or accepted. We recognize that kickbacks are typically made in exchange for an improper business favor, allocation, or procurement advantage.
  • Personal Safety Exception: The society recognizes that despite our strict mandates, an employee or volunteer may face an extreme situation where avoiding an immediate facilitation payment or kickback could put their or their family’s personal security and physical safety at immediate risk. In such exceptional duress, the payment must be reported immediately to the Compliance Officer post-event for legal documentation.

3.3 Political Contributions

The society will not make donations, whether in cash, kind, or through any other means, to support any political parties, local factions, or individual political candidates. We recognize that such actions may be perceived as an improper attempt to gain an unfair institutional or regulatory advantage.

3.4 Charitable Contributions & Partnerships

The society accepts and actively encourages donating to genuine public causes—whether through services, knowledge sharing, volunteer time, or direct financial contributions—and agrees to maintain a transparent, public record of all such contributions. However, employees must exercise extreme care to ensure that charitable contributions are never used to facilitate, mask, or conceal acts of bribery. We ensure that all external donations are completely legal and ethical under local laws, and no donation may be executed without the prior approval of the Compliance Officer.

4. Employee & Volunteer Responsibilities

  • Compliance: As a representative of Raja Education & Bahuuddeshiya Society, you must ensure that you thoroughly read, understand, and comply with all the information contained within this policy, alongside any subsequent anti-corruption training you receive.
  • Collective Vigilance: All employees, teachers, and individuals under our control are equally responsible for the proactive prevention, detection, and reporting of bribery and other forms of systemic corruption. Personnel are required to completely avoid any activities that could lead to, or imply, a breach of this policy.
  • Reporting Obligation: If you have any reason to believe or suspect that an instance of bribery or corruption has occurred, or is likely to occur in the future, you must notify the Compliance Officer immediately.
  • Disciplinary Action: If any employee or volunteer breaches this policy, they will face immediate internal disciplinary action, which may include termination of employment or contract for gross misconduct, alongside potential external statutory prosecution.

5. Raising Concerns & Victim Protection

5.1 How to Raise a Concern

If you suspect or witness any instance of bribery or corrupt activities occurring in relation to any wing of the society, you are encouraged to raise your concerns at the earliest possible stage. If you are uncertain whether a specific action constitutes bribery, you should speak immediately to your line manager, the Designated Compliance Officer, the School Principal, or the Executive Management Board. The society will maintain clear whistleblowing channels to ensure these concerns can be voiced swiftly and confidentially.

5.2 What to Do if You Are Offered a Bribe

You must inform the Compliance Officer as soon as possible if you are offered an illicit bribe by anyone, if you are asked to make one, if you suspect you may be targeted for a bribe in the near future, or if you have clear reasons to believe you are the victim of another corrupt activity.

5.3 Absolute Non-Retaliation Protection

The society understands that individuals refusing to offer or accept bribes, or those reporting potential corruption, may worry about potential professional repercussions. The society guarantees that it will fully support anyone who raises concerns in good faith under this policy, even if a subsequent investigation finds that they were mistaken.

We strictly ensure that no one suffers any detrimental treatment as a direct result of refusing to accept or offer a bribe, or because they reported a potential corruption concern. Detrimental treatment refers to dismissal, unfair disciplinary action, threats, or any other unfavorable treatment regarding the concern the individual raised. If you believe you have been subjected to unjust treatment due to a refusal or report, you must inform the Compliance Officer or Executive Board immediately.

6. Training, Record Keeping, & Audits

6.1 Training and Communication

  • Induction: We will provide comprehensive training on this anti-bribery policy as part of the core induction process for all new employees, teachers, and long-term volunteers.
  • Annual Renewal: All personnel will receive regular, relevant updates on adhering to this policy and will be required annually to formally sign an acceptance declaration confirming full compliance.
  • External Stakeholders: Our zero-tolerance attitude toward bribery and corruption will be clearly communicated to all suppliers, vendors, contractors, and third-party partners at the absolute outset of our business relations.

6.2 Record Keeping & Gift Logs

  • Financial Integrity: The society will keep detailed, accurate, and completely transparent financial records, backed by stringent internal controls to act as clear evidence for all outward and inward payments made.
  • Written Disclosures: We will declare and maintain a central written record of the amount, nature, and justification for all hospitality or gifts accepted and given. All such exchanges are subject to regular managerial review.

6.3 Monitoring and Review

The Designated Compliance Officer is directly responsible for monitoring the overall effectiveness of this policy and will review its implementation on a regular basis to assess its ongoing suitability, adequacy, and operational effectiveness. All internal control systems and cash-flow procedures designed to prevent corruption will be subject to regular audits to ensure their real-world efficacy.

Appendix A: Primary Contact & Grievance Channels

For advice, double-checking gift boundaries, or lodging an immediate report regarding an anti-corruption violation, please contact the designated society representatives:

  • Central Society Address: Shakil Ahmad Urdu High School, Malvipura, Pimpalgaon Raja, District Buldhana, Maharashtra State, India.
  • Official Monitoring Email: urdupraja@gmail.com
  • Direct Compliance Helplines: +91 94054 57145 | +91 70207 34483

This policy serves as an official public declaration of Raja Education & Bahuuddeshiya Society’s commitment to transparency, honesty, and absolute compliance with the anti-corruption frameworks of India.