ANTI CORRUPTION POLICY

Kala Azar Medical Research Centre (“KAMRC”), is committed to conducting all aspects of its conduct in keeping with the highest legal and ethical standards and ensures that all employees and other persons acting on its behalf to uphold its commitment.  In accordance with this commitment, KAMRC has adopted this Anti-Corruption Compliance Policy, which is applicable to all.
KAMRC will never allow bribery, kickbacks, or corruption of any kind, directly or through third parties, whether or not explicitly prohibited by this Policy or by law. KAMRC Personnel are not permitted to give or offer anything of value (including gifts, hospitality, or entertainment) to anyone for the purpose of improperly obtaining or retaining any advantage or disadvantages.  Also, KAMRC Personnel may not solicit or accept such improper payments.
This Policy and the internal controls have been designed to prevent bribery from occurring, avoid the appearance of wrongdoing and enable the Centre to respond promptly and effectively to any inquiries about its conduct.  KAMRC employees who violate this Policy may be subject to disciplinary action, up to and including termination.  KAMRC Personnel must conduct their activities in full compliance with this Policy, the laws of India and all applicable anti-corruption laws.

Under this Policy, KAMRC Personnel are not permitted to give or offer anything of value, directly or indirectly, to any Government Official or any commercial party for the purpose of improperly obtaining or retaining a business advantage.  “Anything of value” should be broadly interpreted to include cash, gifts to family members, forgiveness of a debt, loans, personal favors, entertainment, meals and travel, political and charitable contributions, business opportunities and medical care, among other items.  Simply put, bribes, kickbacks or similar payments are never permitted, whether made to a Government Official, associate or other private parties.  Similarly, KAMRC Personnel may not solicit or accept such payments.  This Policy sets forth various rules relating to gifts, entertainment, travel, meals, lodging and employment. As a general matter, the KAMRC competes for and earns business through the quality of its personnel, products and services, not with gifts or lavish entertainment.  The use of KAMRC funds or assets for gifts, gratuities, or other favors to Government Officials or any other individual or entity (in the private or public sector) that has the power to decide or influence the KAMRC objectives is prohibited, unless all of the following circumstances are met.
(a)            the gift does not involve cash or cash equivalent gifts (e.g., gift cards, store cards or gambling chips);
(b)            the gift is permitted under both local law and the guidelines of the recipient’s employer;
(c)            the gift is presented openly with complete transparency;
(d)            the gift is properly recorded in the KAMRC’s books and records;
(e)            the gift is provided as a token of esteem, courtesy or in return for hospitality and should comport with local custom.

Note that the provision of gifts, as well as the reporting requirements, in this Policy, apply even if KAMRC Personnel are not seeking reimbursement for the expenses (i.e., paying these expenses out of your own pocket does not avoid these requirements).
 
KAMRC Personnel must not accept, or permit any member of his or her immediate family to accept any gifts, gratuities or other favors from any person doing or seeking to do business with KAMRC, other than items of nominal value.  Any gifts that are not of nominal value should be returned immediately and reported to your supervisor.  If immediate return is not practical, they should be given to KAMRC.