SIFY TECHNOLOGIES LIMITED

Anti-Corruption Policy

INTERNAL

Sify Technologies Limited

II Floor, Tidel Park, No.4, Rajiv Gandhi Salai, Taramani, Chennai
600113 India

Document
Title

Main Anti-corruption Policy

Document Version

1.0

Version Date

25/03/2013

SIFY TECHNOLOGIES LIMITED

ANTI-CORRUPTION POLICY
Document Status

Final

Author(s)

L V Veeranjaneyulu.Y, Legal Department

Approved by

M P VijayKumar, CFO

Change History
Version

Revision Date

Revised By

Description

Distribution list
Name & Title

Purpose

To All Employees

To prohibit bribery in any form in any transaction the Company

or its representatives deal with or part of.

TABLE OF CONTENTS

1.0 BACKGROUND

2.0 PURPOSE

3.0 SCOPE

4.0 POLICY

5.0 PROCEDURE

6.0 RETENTION OF RECORDS

7.0 AMENDMENT

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1.0 Background
1.1 Sify Technologies Ltd, being a NASDAQ listed Indian Company, is required to comply with various
statutory obligations. One of such important obligations is to have a policy on AntiCorruption. Among the several Anti-corruption legislations worldwide, the most important
legislation relevant to the Company, its Directors, employees, and third party agents are

1.1.1 The US Foreign Corrupt Practices Act, 1977 (FCPA) US Law

1.1.2 The Prevention of Corruption Act, 1988 (PCA) Indian Law
Both the legislations deal severely against the corruption practices. FCPA mostly addresses
Supply Side of corruption while the focus of PCA is mostly on the Demand Side. We are
subject to both the legislations.

2.0 Purpose
2.1 Sifys reputation for honesty and integrity is an important constituent of the Companys financial
success, and of the personal gratification of its employees and to ensure the same, Sify
strictly prohibits bribery in any form. Sify and its employees shall not conduct themselves in
such a manner that is or is perceived as Industrial espionage or commercial bribery, fixing
or rigging on any the Companys transactions. This policy guides comprehensively but not
completely all the concerned on transactions in the Company and all the concerned are
expected to be more self driven to keep up the spirit of the policy.

3.0 Scope
3.1 All Directors, Employees (including Subsidiaries) of the Company, and its agents, representatives
and consultants irrespective of place of work (collectively referred as Representatives).

4.0 Policy
4.1

FCPA COMPLIANCE POLICY:

4.1.1 FCPA prohibits paying, offering, promising to pay (or authorizing to pay) money or
anything of value to foreign officials, foreign political parties, political officials or
any candidate for foreign political office with the intent:

4.1.1.1
4.1.1.2

Of Influencing any act or decision;

Of Inducing the official to do or omit to do any act in violation of his or her

lawful duty;

4.1.1.3

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To obtain any improper advantage; or

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4.1.1.4

To induce an official to use his or her influence

improperly to affect or influence any act or decision.

4.1.2 FCPA prohibits corrupt payments through agencies or intermediaries. It is important

for Sify to follow the usual business due diligence procedure while selecting agents
or intermediaries to represent Sify.

4.1.3

Payment - is not limited to money but includes anything of value including nonmonetary gifts, free trips and other forms of non-cash favors.

4.1.4 Exception: There are exceptions to the above for facilitating payments to expedite
a routine administrative action to which a person is otherwise entitled. It is
important for employees to understand the difference between a bribe and
facilitating payment.
Bribe

Facilitating payment

A sum of money or other enticement offered

or given with the intention to gain advantage
in favor of the giver or any other person (For
example: any money, goods or services
provided to a government official to obtain or
retain an advantage in a contract).

Payment of money to expedite a routine

governmental action to which the giver is otherwise
entitled to (For example: Paying Fees to a
government even when not required for
registration, permits, visas, licenses, phone service,
utilities supply, police protection, etc).

4.1.5 Sanctions / penalties for violating FCPA:

4.1.5.1

Criminal fines imposed on companies up to $2

Million;

4.1.5.2 Criminal fines imposed on individual officers, directors, agents or

shareholders up to $100,000 and imprisonment up to 5 years. (It
is to be noted that there is a possibility that under the Alternative
Fines Act, these fines may be actually quite higher the actual
fine may be up to twice the benefit that the defendant sought to
obtain by making the corrupt payment. Any fines imposed on
individuals may not be paid by their employer or principal);
4.1.5.3 Civil penalties of up to $10,000 and additional fines imposed by courts if the
action is due to a SEC enforcement action.
4.1.5.4 Other than the penalties which may be imposed (as set forth above), there
are several other liabilities
that may be faced by a company violating the FCPA, including:
4.1.5.4.1

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Facing a private cause of action for treble

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damages under the Racketeer Influenced and Corrupt
Organizations Act (RICO);
4.1.5.4.2 Being barred from doing business with the Federal government.
(An Indictment alone can lead to suspension of the right
to do business with the government); and
4.1.5.5 Other legal actions: e.g. federal prosecutions under state commercial
bribery statutes, being ruled ineligible to receive export licenses,
and being suspended or barred by the SEC.
4.2

PCA COMPLIANCE POLICY:

4.2.1 PCA prohibits the following acts
4.2.1.1 Payment / receipt of any gratification which gives satisfaction to the
recipient of any kind.
4.2.1.2

Passing of Inducement, incentive monetary or non-monetary

4.2.2 Liability for violation:

4.2.2.1
4.2.2.2

Imprisonment from 6 months to 5 years, if

habituated up to 7 years
Fine

4.2.3 Consequences of violation: Any representative found guilty will be immediately

suspended from their engagement with the Company and all his payments will be
suspended till clearance of charges against him and also a complete note will be
enclosed to the respective representative HR File.
4.2.4 Alleged or found guilty representative shall cooperate with the investigating agencies,
internal or external and shall disclose complete facts with all evidences is in possession or
has knowledge of such evidences.

5.0 Procedures under the Policy 5.1 Representative / Whistle Blower who is aware of bribe, etc..:
Any representative becomes aware of any attempt to bribe shall immediately bring to the notice of
immediate superior / HR- Head / Legal officer / CFO. The identity of such representatives will be kept
secret.

5.2 To do and Not to do:

To DO

Not To Do

1.Representatives to understand local law, operating

procedures ,restrictions or disclosure requirements
on compensation

1. Failing to abide by the local laws, regulations and

the operating procedures.

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2.Comply with any applicable
conducting any Sify related activities

restrictions

in 2. Noncompliance with the restrictions in any

transactions.

3.Representatives to seek advice before: A) Incurring 3.Deviation in the set procedure for expenses
incurred towards govt. officials , gifts , donations ,
charitable contributions and contribution to political
expenses on govt. officials.
parties
B) Giving gifts, donations, charitable contributions
c) Contribution to political parties.

5.3 Contact details for clarification: Please contact the following persons incase of any doubt
in the applicability of anti-corruption of laws:
S.No

Department

Name

Mail ID

Finance

Giridharan T

giridharan.thiruvengadam@sifycorp.com

Legal

L V Veeranjaneyulu.Y

venkat.anjan@sifycorp.com

Compliance

Jayasree Chandrasekaran

jayasree.narayanan@sifycorp.com

6.0 Retention of Records: The records under this policy will be maintained for 8 years or till closure of
litigation, if any, whichever is longer.

7.0 AMENDMENT: The Company reserves its right to amend or modify this
Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such
amendment or modification will be binding on the employees unless the same is notified to the employees in
writing.

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