1. Introduction and Commitment

PIGSO LEARNING Private Limited is committed to conducting its business ethically and in full compliance with all applicable laws and regulations in India and the over 50 countries where we offer our educational services. This commitment extends to trade compliance, encompassing sanctions, export controls, and embargoes, as well as the prevention of bribery and corruption in all its forms. We uphold the highest standards of integrity and transparency in all our interactions.

This policy outlines the principles and procedures that guide PIGSO LEARNING, its employees, contractors, and anyone acting on its behalf, to ensure adherence to trade compliance and anti-corruption laws, including the Foreign Trade (Development and Regulation) Act, 1992, the Prevention of Corruption Act, 1988 (as amended), and other relevant Indian regulations. We also recognize the importance of respecting the sovereignty and laws of other nations and will strive to comply with applicable regulations in countries where our partners or customers are located, including relevant U.S. laws like the Foreign Corrupt Practices Act (FCPA) in anticipation of potential collaborations involving U.S.-based entities or products.

2. Trade Compliance Policy

PIGSO LEARNING is committed to complying with all applicable trade laws and regulations, including those related to:

• Sanctions and Embargoes: We will not engage in any transactions with individuals, entities, or countries that are subject to economic sanctions or trade embargoes imposed by India or other relevant international bodies (e.g., UN, EU, US where applicable to our operations or future collaborations).
• Export Controls: We will ensure that the export of any controlled goods, software, or technology (if applicable to our educational content or operational tools in the future) adheres to all relevant export control regulations and licensing requirements.
• Prohibited Parties: We will not conduct business with individuals or entities listed on prohibited parties lists maintained by relevant government authorities.

3. Anti-Corruption Policy

PIGSO LEARNING has a zero-tolerance policy towards bribery and corruption. We strictly prohibit the offering, promising, giving, soliciting, or accepting of any bribe, kickback, or other undue advantage, whether directly or indirectly, to or from any person or entity, including government officials, private sector employees, or any other party, to obtain or retain business or secure any improper advantage. This prohibition applies to all our business activities worldwide.

This includes, but is not limited to:

• Offering or providing anything of value (e.g., money, gifts, hospitality, favors) with the intent to improperly influence a decision.
• Soliciting or accepting anything of value in exchange for providing an improper advantage.
• Facilitation payments made to expedite routine government actions are generally prohibited. Any exceptions must be pre-approved by senior management and accurately recorded.

4. Customer Due Diligence and Screening Procedures

To ensure compliance with trade regulations and anti-corruption policies, PIGSO LEARNING will implement robust customer due diligence (CDD) and screening procedures. These procedures will be risk-based and will include:

• Identification and Verification: Obtaining and verifying the identity of our customers, including their legal name, address, and other relevant information.
• Beneficial Ownership: Where applicable, identifying and verifying the beneficial owners of customer entities.
• Screening Against Prohibited Parties Lists: Regularly screening customers against relevant sanctions lists, export control lists, and other prohibited parties lists issued by Indian authorities (e.g., DGFT), as well as relevant international lists where applicable (e.g., OFAC, UN sanctions lists). This screening will be conducted at the onboarding stage and periodically thereafter.
• Enhanced Due Diligence (EDD): Conducting enhanced due diligence for customers identified as high-risk based on factors such as their location, industry, or relationship with politically exposed persons (PEPs). EDD may involve gathering additional information, conducting more thorough background checks, and obtaining senior management approval for the business relationship.
• Transaction Monitoring: Monitoring customer transactions for any red flags or suspicious activities that may indicate a breach of trade compliance or anti-corruption laws.

5. Compliance Responsibilities

• All Employees and Associated Persons: Are responsible for understanding and complying with this policy in their day-to-day activities. They are obligated to report any suspected violations of this policy or applicable laws immediately to their manager or the designated compliance officer.
• Management: Is responsible for promoting a culture of compliance within their teams, ensuring that employees receive adequate training on this policy, and for taking appropriate action to address any identified compliance risks or violations.
• Compliance Officer: The Company will designate a Compliance Officer who will be responsible for overseeing the implementation and enforcement of this policy, conducting risk assessments, developing and delivering training programs, and investigating reported violations.

6. Record Keeping

Accurate and complete records of all transactions and interactions with customers and business partners must be maintained in accordance with applicable legal and regulatory requirements. These records should clearly document the purpose of the transaction or interaction.

7. Training and Awareness

PIGSO LEARNING is committed to providing regular training and awareness programs to its employees and relevant associated persons on trade compliance and anti-corruption laws and this policy. This training will equip individuals with the knowledge and understanding necessary to identify and avoid potential violations.

8. Reporting Violations

PIGSO LEARNING encourages the reporting of any suspected violations of this policy or applicable laws without fear of retaliation. Reports can be made to the employee’s manager, the Compliance Officer, or through any other reporting channels that the Company may establish. All reports will be treated seriously and investigated appropriately.

9. Consequences of Non-Compliance

Violations of this policy may result in disciplinary action, up to and including termination of employment or contractual relationships. 1 PIGSO LEARNING may also be subject to legal and regulatory penalties for non-compliance with applicable laws.  

10. Policy Review and Updates

This policy will be reviewed and updated periodically to ensure its effectiveness and alignment with evolving legal and regulatory requirements and the Company’s business operations.

Date of Implementation: 30th July 2024

Approved By: Mayank Panchal – Director of PIGSO LEARNING 

This policy demonstrates PIGSO LEARNING’s commitment to ethical business practices and compliance with all applicable trade and anti-corruption laws, both in India and internationally, as we continue to expand our global reach and explore future collaborations.