NAVRITU DIGITAL

ANTI-BRIBERY & CORPORATE ETHICS

Effective Date: August 22, 2026

This Anti-Bribery & Corporate Ethics policy sets out NavRitu Digital's commitment to conducting business honestly and lawfully, wherever in the world we operate. It applies to all team members, leadership, and anyone acting on our behalf, including subcontractors and agents.

1. Our Commitment

We do not offer, give, solicit, or accept bribes, kickbacks, or other improper payments or benefits, to or from any person or organization, in any country in which we operate — whether dealing with private businesses or government officials. This commitment applies regardless of local custom or common practice, and reflects our obligations under applicable anti-corruption laws, including the Prevention of Corruption Act, 1988 (India), the UK Bribery Act, 2010, and the U.S. Foreign Corrupt Practices Act (FCPA), to the extent relevant to a given engagement.

2. Facilitation Payments

We do not make facilitation payments (small payments made to speed up a routine government action we're otherwise entitled to) under any circumstances.

3. Gifts & Entertainment

We recognize that reasonable, transparent business courtesies (a modest meal, a small branded item, attending an industry event) are a normal part of business relationships. Because the appropriate line depends heavily on context, culture, and the parties involved, decisions about gifts and entertainment — both offered and received — are made case-by-case, with sign-off from leadership, rather than against a fixed monetary threshold. As a general rule:

• Any gift or entertainment offered or received in connection with a business relationship should be disclosed to leadership
• Nothing should be offered or accepted that could reasonably be seen as intended to influence a business or government decision
• Gifts or entertainment involving government officials receive extra scrutiny given the heightened legal risk

4. Third Parties, Vendors & Subcontractors

We expect vendors, subcontractors, and agents acting on our behalf to uphold the same standards described in this policy. Where we engage a third party to interact with government officials or regulators on our behalf, we apply additional diligence before and during that relationship.

5. Government Officials

Interactions with government officials — including for licenses, permits, inspections, or approvals relevant to client projects — are conducted transparently and through proper channels. No payment, gift, or benefit is to be offered to a government official to expedite or influence an official act.

6. Record-Keeping

We maintain accurate books and records reflecting all transactions, consistent with applicable accounting and tax laws, and do not maintain off-the-books accounts or falsify records for any purpose, including to conceal an improper payment.

7. Raising Concerns

Any team member, client, vendor, or member of the public who suspects a violation of this policy can report it confidentially through our Grievance Redressal Mechanism or by writing to legal@navritu.digital, without fear of retaliation.

8. Consequences

Violations of this policy by a team member may result in disciplinary action, up to and including termination, and may be reported to relevant authorities where required by law.