This policy applies to all RANNG employees, directors, contractors, agents, and business partners acting on RANNG's behalf, across every activity that carries bribery risk — gifts and hospitality, procurement, supplier and agent relationships, customs and government interactions, and sales and business development, in India, the EU, and every other market RANNG serves or sources from.

• Bribery — offering, promising, giving, or accepting anything of value to improperly influence a decision or gain an unfair business advantage. 

• Corruption — the abuse of entrusted power or position for private gain, whether by a RANNG representative or someone dealing with RANNG. 

• Facilitation payments — small, unofficial payments made to expedite a routine government action (e.g. customs clearance). These are prohibited under this policy, even where locally tolerated in practice.

Gifts and hospitality connected to RANNG business must be reasonable, modest, infrequent, and properly recorded. Cash or cash-equivalent gifts (e.g. gift cards) are never permitted, and lavish entertainment is prohibited regardless of value. Written approval from [APPROVING ROLE, e.g. Managing Director] is required before accepting or offering any gift above [€300 — confirm threshold/currency] in value, or hospitality above [€800 — confirm threshold/currency].

Charitable donations and sponsorships must serve a legitimate purpose, be subject to basic due diligence on the recipient, and be documented in writing. RANNG does not make political contributions except with prior written approval from [APPROVING ROLE], and any such contribution must be fully documented and transparent.

Before engaging an agent, distributor, or other third party to act on RANNG's behalf, RANNG conducts due diligence proportionate to the risk involved, including identity verification, a basic corruption-risk assessment, and confirmation that proposed compensation is reasonable and commercially justified. RANNG contracts with third parties include anti-corruption obligations and audit rights. Warning signs include requests for unusually high commissions, payments to third-country accounts, or reluctance to document the relationship in writing.

Interactions with customs officials, inspectors, licensing authorities, or any other government official must be professional and documented. Any gift or hospitality involving a public official — however modest — requires prior written approval under Section 5 and must comply with the law applicable to that official.

All transactions must be accurately recorded and made through traceable banking channels, with proper supporting documentation. Off-the-books accounts, undocumented cash funds, and false or misleading invoices are prohibited.

RANNG provides periodic anti-bribery training to staff in roles with elevated exposure — including sales, procurement, logistics, and customs — and keeps this policy accessible to employees and relevant business partners.

Concerns about actual or suspected bribery should be reported to: [COMPLIANCE CONTACT — name/role and email] RANNG does not tolerate retaliation against anyone who reports a concern in good faith, even where the concern turns out to be unfounded.