1) INTRODUCTION:
Luthra Industrial Corp. is committed to setting up, utmost standards for transparency and accountability in all its affairs. Luthra Industrial Corp. strives in attaining it’s mission through compliance of high legal and ethical standards. Luthra Industrial Corp. does not tolerate any form of bribery, embezzlements or corruption, and will uphold all laws countering bribery, fraud and corruption in all forms.

2) PURPOSE:
The purpose of this policy is to set out the responsibilities of Luthra Industrial Corp. and those individuals acting on its behalf in observing and upholding Luthra Industrial Corp’s position on bribery and corruption and to provide guidance on business ethics. This policy supplements the principles set out in the code of conduct to show that Luthra Industrial Corp. operates fairly, transparently and with integrity. Every individual or group of individuals, associated with Luthra Industrial Corp.in any form, whether the staff members, the ad-hoc staff engaged in the program activities of the organization, the consultants, the contractors, the interns, the partner organisations and any other party with a financial or trustee-beneficiary relationship with Luthra Industrial Corp.are expected to share this commitment. The basic objective of this statement is setting out the policy of Luthra Industrial Corp.towards the prevention and identification of bribery and corruption and the certain procedures to be followed, if at all, any fraud is found or having an idea / impression of its existence.

3) SCOPE
Everyone at Luthra Industrial Corp. must show that all business is performed to the highest ethical standards and complies both with these guidelines and all applicable laws. This policy applies to all the staffs, ad-hoc staffs, advisers, consultants, suppliers, partners and individuals acting on behalf of the society, irrespective of their location associated with Luthra Industrial Corp. in any proportion

4) STATEMENT:
A "bribe" is the promise of money, reward, favour or a benefit to a person in order to influence the conduct or judgment of that person.
i. Luthra Industrial Corp. or any of its employee will not engage in accepting or offering bribery or any form of unethical inducement or payment including facilitation payments and "kickbacks". All the staff, ad-hoc staff, advisers, consultants, suppliers, partners and individuals acting on behalf of the Luthra Industrial Corp. are required to avoid any activities that might lead to, or suggest, a conflict of interest with the activities of Luthra Industrial Corp.
ii. Luthra Industrial Corp.expects its suppliers to act with integrity and without thought or actions involving bribery and/or corruption and will, where appropriate, include clauses to this effect in relevant contracts. In particular, no Luthra Industrial Corp. employee will accept , offer and/or engage in any form of bribe to/from any person or public official directly or indirectly through a 3rd party.

5) PROHIBITED ACTIVITIES:
It is prohibited, directly or indirectly, for any staff or individual acting on behalf of Luthra Industrial Corp.to offer, give, request or accept any bribe (i.e. gifts with mala-fide intentions, loan, payment, reward or advantage, either in cash or any other form of inducement), to or from any person or company in order to gain commercial, contractual or regulatory advantage for Luthra Industrial Corp., or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

i. This policy requires employees and individuals acting on behalf of Luthra Industrial Corp.
a. Not to offer, promise or make any bribe or unauthorised payment or inducement of any kind to anyone.
b. Not to solicit business by offering, promising or making any bribe or unofficial payment to suppliers.
c. Not to request or accept any kind of bribe or unusual payment or inducement that would not be authorised by Luthra Industrial Corp.in the ordinary course of business.
d. To refuse any bribe or unusual payment and to do so in a manner that is not open to misunderstanding or giving rise to false expectation; and to report any such offers.
e. Not to make facilitation payments. These are payments used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has a legal or other entitlement. Luthra Industrial Corp. will not tolerate or condone such payments being made.
f. To report any breaches of this policy's principles or standards or of any associated.

6) CRIMINAL OFFENCE (AS DEFINED IN IPC)
i. It is a criminal offence to:
• Offer a Bribe
• Accept a Bribe
• Fail to prevent a Bribe

ii. Staffs, ad-hoc staff, advisers, consultants, suppliers, partners and any individuals acting on behalf of Luthra Industrial Corp. should be made aware that if they are found guilty of committing bribery, embezzlement or fraudulence an individual could face prosecution as per the norms of IPC (Indian Penal Code).

7) COMPLIANCE AND OVERSIGHT
Luthra Industrial Corp. realises that giving and receiving of gifts and hospitality without any mala-fide intentions, or in other words, where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

8) THIRD PARTIES
Luthra Industrial Corp. could be held responsible for acts of bribery by its intermediaries such as distributors, agents, advisers, consultants and other 3rd parties. All agents and third parties acting for or on behalf of Luthra Industrial Corp. must comply with all applicable laws. In addition they, and everyone we do business with, must be made aware of these guidelines, to promote better business conduct generally. Third parties must not be used to perform acts that violate these guidelines or applicable local laws.

9) GIFTS AND ENTERTAINMENT
Gifts and entertainment must only be offered and accepted for conventional social and business purposes at a level appropriate to the status and seniority of those involved. The test when considering gifts and entertainment (whether giving or receiving them) is whether they could be intended, or even be reasonably interpreted, as a reward or encouragement for a favour or for preferential treatment - if they could be, then they are not permitted under these guidelines. Gifts must be given openly, unconditionally, must be of modest value and must comply with the expenses policy. Gifts and entertainment must never be offered or accepted to obtain or retain business or for reward or inducement. Any deviations from the guidelines or the expenses policy of the business unit must be approved in advance in writing by senior management.

10) CHARITABLE DONATIONS
Charities and donations could be used as a conduit for bribes. Luthra Industrial Corp. is keen to support charities, particularly those in its local communities, but must not do so at the request of customers unless approved in advance in writing by senior management. Charitable donations, whether made in cash or by way of contribution to charitable events, publications or fund raising initiatives must be approved in advance. Luthra Industrial Corp. does not allow gifts or donations to political parties.

11) RAISING A CONCERN
If an employee or an individual acting on behalf of Luthra Industrial Corp. is offered a bribe, or a bribe is solicited from them, they should not agree to it unless their immediate safety is in jeopardy. Should this be the case, the employee or individual should at first instance contact his/her immediate department head as soon as they are able to do so. The employee or individual may be required to give a written account of the events to assist with any investigation. If the department head is involved in such an act, the individual may directly contact the Director of Luthra Industrial Corp. for reporting such case.
a) Employees or individuals acting on behalf of Luthra Industrial Corp. are encouraged to raise concerns about any instance of bribery or corruption at the earliest possible stage. The employee or individual raising a concern can do so in confidence and without fear of reprisals. All reports raised are taken seriously and, where appropriate, investigated.
b) No employee or individual will be discriminated against in any way as a result of reporting a concern in good faith.
c) If any instance of bribery or corruption is identified; Luthra Industrial Corp. management will take the remedial steps immediately.
d) Luthra Industrial Corp. has its own system of investigating it’s staff member for violation of service conduct including financial irregularities, corruption, fraud or embezzlement. If the charges are proved the delinquent may be awarded penalties depending on the gravity of misconduct. These rules are based on the following principles:-
• The right of Luthra Industrial Corp. to take appropriate disciplinary steps against any delinquent staff member, who acts in a manner conflicting with the code of conduct and prescribed rules / regulations.
• At the same time the rules also recognize the right of delinquent staff member to a fair hearing and applicable and just disciplinary action.
• The emphasis of disciplinary action is on prevention, justice and rehabilitation.

12) PENALTY FOR BREACH OF THIS POLICY
Where anyone - whether individual or group of individuals, associated with Luthra Industrial Corp. in any form, whether the staff members, the ad-hoc staff engaged in the program activities of the organization, the consultants, the contractors, the interns, the partner organisations and any other party with a financial or trustee-beneficiary relationship with Luthra Industrial Corp. , breaches this policy during the course of business/employment with Luthra Industrial Corp. the penalty provisions will apply as per the Company policies. The party found guilty acknowledges that any breach of this Agreement may cause Luthra Industrial Corp. irreparable harm for which there is no adequate remedy at law, and, as a result of this, Luthra Industrial Corp. shall be entitled to the issuance by a court of competent jurisdiction of an injunction, restraining order, or other equitable relief in favour of itself, restraining the party from committing or continuing to commit any such violation.

• In a case if the management finds that any employee (receiver in this case) is asking/requesting or pressurising the supplier/party (giver in this case) for bribe in any form but giver is not giving bribe then disciplinary action against the receiver will be taken which could be the maximum of termination of the receiver from employment , forfeiting his dues of salary/funds along with legal proceedings in the court of law and monetary penalty of an amount 5 times the amount of bribe requested , discussed or involved.

• In a case if the management finds that any employee (receiver in this case) is requesting or accepting bribe/commission and the supplier/party (giver in this case) is also obliging in return for some benefits , then the disciplinary action against both the receiver and the giver will be taken which in the case of receiver could be the maximum of termination of the receiver from the employment , forfeiting his dues of salary/funds along with legal proceedings in the court of law and monetary penalty of an amount 5 times the amount of bribe requested, discussed or involved , and in case of giver could be the termination of business dealings , forfeiting of their outstanding dues along with legal proceedings in the court of law and monetary penalty of an amount 5 times the amount of bride offered , discussed or involved .

• In a case if the management finds that any supplier (giver in this case) is found offering bribe/commission but employee (receiver in this case) is not accepting it then it could lead to the termination of business dealings with the giver , forfeiting of their outstanding dues along with legal proceedings in the court of law and monetary penalty of an amount 5 times the amount of bride offered.

13) REPORTING & INVESTIGATINGPOTENTIAL BREACHES OF THIS POLICY
Where anyone believes the guidelines are not being complied with or they are being asked to carry out any act not in compliance with these guidelines, these concerns must be raised immediately with the immediate superior. If the immediate superior is not the appropriate person, then the employee's concerns must be brought directly to the attention of the senior management (partners).