Ethics & Compliance Program

Welcome to ROMeSIM, a brand owned by Ajawave Digital Private Limited

Ajawave Digital Private Limited is committed to maintaining the highest standards of ethics and compliance in all its business dealings. This Ethics and Compliance Program is designed to promote a culture of integrity and compliance within the organization.

DEFINITION OF CORRUPTION

Corruption includes any form of improper or illegal activity, including:

- Bribery

- Theft of funds

- Offering or accepting improper benefits

- Other improper activities

POLICIES AND PROCEDURES

Ajawave Digital Private Limited has implemented the following policies and procedures to prevent corruption and improper activities:

- A policy on preventing corruption and improper activities

- A procedure for reporting corruption and improper activities

- A procedure for investigating and resolving reports of corruption and improper activities

- A code of conduct for employees and officers

- A whistleblower protection policy

RESPONSIBILITY

All employees and officers of Ajawave Digital Private Limited have a critical role to play in preventing corruption and improper activities. Employees and officers are expected to:

- Comply with all applicable laws and regulations

- Adhere to the organization's policies and procedures

- Report any suspected corruption or improper activities

- Cooperate fully with investigations and audits

MONITORING AND EVALUATION

Ajawave Digital Private Limited's policies and procedures will be regularly monitored and evaluated to ensure their effectiveness. This will include:

- Regular audits and reviews of financial transactions

- Monitoring of employee and officer conduct

- Evaluation of the effectiveness of the Ethics and Compliance Program

PROTECTION AND IMMUNITY

Ajawave Digital Private Limited will provide protection and immunity to employees and officers who report corruption and improper activities in good faith. This includes:

- Protection from retaliation or reprisal

- Immunity from liability for reporting suspected corruption or improper activities

COMPLIANCE

All employees and officers of Ajawave Digital Private Limited must comply with this policy. Failure to comply may result in disciplinary action, up to and including termination of employment.

REPORTING CORRUPTION AND IMPROPER ACTIVITIES

Employees and officers who suspect corruption or improper activities must report their concerns to the designated reporting officer. Reports can be made anonymously or confidentially.

INVESTIGATION AND RESOLUTION

All reports of corruption and improper activities will be thoroughly investigated and resolved. Investigations will be conducted in a fair and impartial manner, and will include:

- Gathering of evidence

- Interviews with witnesses and suspects

- Analysis of financial transactions and other relevant data

DISCIPLINARY ACTION

Employees and officers found to have engaged in corruption or improper activities will be subject to disciplinary action, up to and including termination of employment.

EXTERNAL AUDITS AND REVIEWS

Ajawave Digital Private Limited will engage external auditors and reviewers to evaluate the effectiveness of the Ethics and Compliance Program. This will include:

- Regular audits of financial transactions

- Reviews of employee and officer conduct

- Evaluation of the effectiveness of the Ethics and Compliance Program

TRAINING AND AWARENESS

Ajawave Digital Private Limited will provide regular training and awareness programs to employees and officers on the Ethics and Compliance Program. This will include:

- Training on the code of conduct and policies and procedures

- Awareness programs on corruption and improper activities

- Training on reporting and investigation procedures

CONCLUSION

Ajawave Digital Private Limited is committed to maintaining the highest standards of ethics and compliance in all its business dealings. The Ethics and Compliance Program is designed to promote a culture of integrity and compliance within the organization. All employees and officers are expected to comply with this policy and report any suspected corruption or improper activities.