Anti-Bribery & Anti-Corruption Policy

1. Purpose

Welookup Insights LLP (“Welookup”, “we”, “us”) is committed to conducting business ethically, transparently and in compliance with applicable anti-bribery and anti-corruption laws. This policy sets the minimum standards expected in all business dealings.

2. Scope

This policy applies to Welookup’s partners, owners and designated partners, employees, associates, contractors, consultants, agents and representatives, and to third parties acting on Welookup’s behalf. Everyone within scope is expected to understand and follow this policy when conducting Welookup business.

3. Prohibition of bribery and corruption

No person acting for or on behalf of Welookup may directly or indirectly offer, promise, give, request, agree to receive or accept money or anything else of value where it is intended to improperly influence a business decision, government action or commercial outcome, secure an improper advantage, or reward improper conduct. This prohibition applies whether the benefit is offered personally or through an intermediary.

4. Government officials

Particular care is required in dealings with government officials, government departments and agencies, public international organisations, and government-owned or government-controlled entities. No improper payment, facilitation payment, gift, benefit or other advantage may be offered, promised or given to influence an official act or obtain an improper advantage.

5. Gifts, hospitality and business courtesies

Gifts, meals, entertainment, travel and hospitality must be reasonable, lawful, transparent, infrequent, business-related and appropriately recorded. They must never be offered or accepted to improperly influence a decision or create an obligation. Cash and cash equivalents are not acceptable business courtesies. Heightened caution and any applicable client or legal approvals are required when a government official is involved.

6. Third parties

Welookup expects consultants, agents, contractors, resellers, intermediaries and other third parties acting on its behalf to comply with applicable anti-corruption laws and this policy. Third-party relationships should have a legitimate business purpose, proportionate compensation and appropriate contractual terms. Concerns identified before or during an engagement must be escalated and addressed.

7. Books and records

Business transactions, expenses, gifts, hospitality and payments must be recorded accurately, completely and in reasonable detail. False, misleading, incomplete or undisclosed payments, accounts, descriptions or accounting entries are prohibited. Supporting documentation must be retained in accordance with applicable legal, contractual and record-retention requirements.

8. Facilitation payments

Facilitation payments and other unofficial payments intended to speed up or secure routine government action are prohibited. The only exception is where a payment is made in response to an immediate threat to a person’s health or safety. Any such incident must be reported promptly to Welookup management or legal@welookupinsights.com and documented accurately.

9. Conflicts of interest

Personnel must disclose any actual or potential personal, financial or other conflict of interest that could affect, or appear to affect, an impartial business decision. Disclosures should be made promptly to management or legal@welookupinsights.com so that appropriate safeguards can be considered.

10. Reporting concerns

Employees, associates, contractors, partners, customers and other stakeholders may report suspected bribery, corruption, fraud, misconduct or a possible violation of this policy to legal@welookupinsights.com. Reports will be assessed and handled appropriately. Welookup will protect confidentiality to the extent reasonably possible and permitted by law, but cannot guarantee absolute anonymity or confidentiality in every circumstance.

11. Non-retaliation

Welookup prohibits retaliation against anyone who raises a concern in good faith, seeks advice, refuses to participate in suspected misconduct, or participates in an investigation. A report made in good faith will not result in adverse treatment merely because it is not substantiated.

12. Training and awareness

Personnel involved in Salesforce-related business and other relevant business activities receive appropriate anti-corruption and business ethics training during onboarding and periodically thereafter, consistent with applicable requirements and the nature of their responsibilities. Personnel are expected to seek guidance when a situation is unclear.

13. Compliance with applicable laws

Welookup conducts business subject to applicable Indian anti-bribery and anti-corruption laws, including relevant provisions of the Prevention of Corruption Act, 1988 and other applicable criminal, corporate and procurement laws. Where relevant to a transaction, client relationship or location, applicable international anti-corruption requirements may also apply. If standards differ, personnel must follow the stricter lawful requirement and seek guidance where needed.

14. Enforcement

Suspected violations may be reviewed or investigated as appropriate. A violation may result in disciplinary action, termination of employment or engagement, contractual remedies, recovery of losses, and/or referral to the appropriate authorities where required or permitted by law.

15. Ownership and review

This policy is maintained by Welookup Insights LLP and may be reviewed and updated periodically to reflect changes in law, business activities and identified risks. Questions about this policy should be directed to legal@welookupinsights.com.

Last updated 22 September 2026.