“The NeuBrain Group prohibits, in absolute and unequivocal terms, any form of bribery or corruption — whether direct or indirect — in all business activities, in every jurisdiction, at every level.”
Strictly Prohibited Conduct
The following acts constitute grounds for immediate termination and potential criminal reporting — with zero tolerance and no commercial justification defence.
Sector-Specific Corruption Risk Map
Each NeuBrain Group venture carries distinct risk profiles. Our Program addresses each with targeted controls and awareness.
Monetary Thresholds & Pre-Approval
Gifts and hospitality are permissible only when transparent, proportionate, and recorded. The following limits apply across all Group entities.
| Scenario | Limit | Pre-Approval | Registration |
|---|---|---|---|
| Gift to a private sector contact | ₹1,000 | No (if under limit) | Yes |
| Receiving a gift from any contact | ₹1,000 | Disclose to Compliance Officer | Yes |
| Business meal (per person) | ₹3,000 | No (if under limit) | Expense record |
| Sponsoring client at an event | ₹5,000 | Yes — written | Hospitality register |
| Any gift/hospitality to a public official | ₹0 / NIL | MANDATORY — no exceptions | Pre-approval mandatory |
| Any item exceeding above limits | Case by case | MANDATORY — written | Mandatory |
All gifts given or received above ₹500 must be entered in the Gift & Hospitality Register within 48 hours.
Who Is Bound by This Program?
This Program applies to every individual who represents, acts on behalf of, or is associated with any NeuBrain Group entity — without exception and without regard to seniority, location, or engagement type.
Governing Law: Prevention of Corruption Act 1988 (+ 2018 Amendment) · IPC · Companies Act 2013 · PMLA 2002 · UK Bribery Act 2010 · U.S. FCPA · ISO 37001:2016 · OECD Anti-Bribery Convention
Policy Guidance
Answers to the most common compliance questions across our group's business verticals.
Report a Concern
Reporting a concern is an act of integrity, not disloyalty. Every report — including anonymous ones — is reviewed and acted on by the Compliance Officer.
Any person who reports in good faith is fully protected from dismissal, demotion, exclusion, or any adverse action connected to their report. Retaliation against a reporter is itself a serious disciplinary offence.
Our Six Core Values
The principles that guide every decision, every relationship, and every business interaction across the NeuBrain Group.
Act honestly in every interaction, without exception.
Maintain open and accurate records — always.
Own your actions and decisions at every level.
Treat every stakeholder with dignity and professionalism.
Deliver quality without compromise or shortcuts.
Speak up when something falls short of our standards.
Download the Complete Compliance Program
The full 14-section document — including all three declaration forms, the organizational operating procedures, and the accountability matrix — is available for download.