Paytm Payment Services Limited Policies

Policies

Privacy
Grievance
Nomination and Remuneration
CSR
Candidature Notice
Annual Returns
Annual Action plan
CSR Committee
Resignation
ABAC

This policy is an electronic record in terms of the Information Technology Act, 2000 and rules framed thereunder, as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This Privacy Policy is adopted by Paytm Payments Services Limited (“PPSL”), a company incorporated in accordance with the provisions of the Companies Act, 2013 and having its registered office at 136, First Floor, Devika Towers, New Delhi – 1100019 (hereinafter referred to as “We” or “Our” or “Us” or “Company”) for its website https://www.paytmpayments.com (hereinafter referred to as ”Website”). The terms “you", "Your" and “User” refer to a person who uses the Website or services of the Company or undertake a transaction on the website or mobile application of the merchant where the PPSL services are integrated.

PPSL Services shall include but not be limited to payment aggregation services, payment gateway services or any other services, features developed or deployed by the Company from time to time..

This Privacy Policy is a legally binding policy between you, the user and Company and governs the use of any Personal Information collected or provided on the Website or any Personal Information received by the Company. If you do not agree with all of the terms or have any objection to granting your consent as stated hereinabove, kindly do not download, install, use or access the Website or otherwise use the PPSL Payment Services and /or payment gateways of Paytm on the merchant site.

This Privacy Policy is aimed and intended to provide the users and registered members with information in relation to the online practices pursued by the Company especially with respect to the Personal Information provided by the users/registered members on the Website. The privacy policy is also intended to address the collection, use, sharing, storage and dissemination of information pertaining to users undertaking a transaction on website or mobile application of Merchants where Company’s Payment Services are integrated.

Your privacy is of utmost importance to us and protection of Personal Information is a key commitment for us. We are governed by the provisions of applicable law in India including the Information Technology Act 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 to maintain the privacy of Personal Information. Personal Information means any information that relates to a natural person, which is capable of identifying a person. Personal Information does not include information that is freely available or accessible in public domain.

Apart from the Privacy Policy stated herein below, Customers should note the instructions that are provided on the website or the web application of the merchant including any privacy policy or terms and conditions therein.

I. General

We may collect personal and non-personal information about the users. Such information and data may be collected on the basis of the information that Users provide on the Platform or through technologies as more particularly set out in this Privacy Policy.

Please note that the access and use of the Website is restricted for persons above the age of 18 only. The Website and services are not intended for minors and the Company does not target any of its services to minors. The Company does not knowingly collect Personal Information from minors. If you are under the age of 18, please do not register to use the services and do not provide us with any Personal Information.

II. Personal Information

II.A Information we collect about Merchants:

We collect information about merchants accessing, using or registering on the Website to avail the services. Such information may be collected at the time of accessing the Website, registering or creating an account on the Website or availing any service. At the time of sign up we may collect information pertaining to name, address, mobile number or user’s app details. In addition, while undertaking onboarding of merchant, we collect information based on the category of merchants (sole proprietorship/partnership/HUF/private or public company, Trust, society etc.). Such information includes proof of company details (registration details, partnership deed, certificate of incorporation GST details, utility bills etc.), PAN details, bank account details and details of authorised signatory (driving license, passport, Aadhar, Voter ID etc.). Such information may include Personal Information where it is individually or in combination with other information, capable of identifying an individual.

IIB. Information we collect about Customers

We collect and generate various data points about Customers who access a Merchant website or mobile application where our Payment Services are integrated. Customer here refers to individuals undertaking transactions on the Merchant website with the use of payment aggregation services as provided by the Company. Personal Information we may collect from the Customer is set out herein below:

Personal details (e.g. name, contact details including, residential address, date of birth, documents such as identity card / passport details / Aadhaar details / PAN / Voter ID / driving license, and/or education details) provided by the User to Us to avail various products/services from Us and for processing the transactions.
details including transaction history, balances, payment details, for effecting transfer of monies through various payment channels provided by us.
financial details (e.g. income, expenses, and/or credit history) needed as part of request for some of our products/services;
images of documents/ photos required to avail any of our products/services.
voice recordings of our conversations with our customer care agent with you to address your queries/grievances;
employment details (e.g. occupation, positions held, employment history, salary and/or benefits) as part of our record retention for credit/various product evaluations or required under applicable law including Prevention of Money Laundering (Maintenance of Records) Rules, 2005.
specimen signature(s) for processing of User instructions received by us through our various payment and delivery channels;
opinions provided by Use to us by way of feedback or responses to surveys;
information obtained from User mobile device by way of using our app like device location, communication information including contacts and call logs, device information (including storage, model, mobile network), transactional and promotional SMS/app notifications. Such information is used for preparing reports and analytics for improving services which are rendered to Use.

IIC. Collection of information through Automated Technologies

The Website also recognizes and collects the home server of visitors IP address, URL request, browser type, and date and time of your request. For example, we can tell which Internet Service Provider our visitors use, but not the names, addresses or other information about our visitors that would allow us to identify a particular visitor to our Web Site unless such information is voluntarily provided by the user. We may share non-personally identifiable information (such as referring/exit pages, anonymous usage data, and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain services.

III. Sharing of Personal Information

Except in the limited circumstances as set out in this Policy, we do not share any Personal Information without your consent. In various processes / submission of applications / availment of product/service offerings, we even seek your explicit consent of to use / share your Personal Information.

However, we may share limited information as part of our business and operational processes with designated personnel, partners or service providers including group companies on a “need-to-know” basis to perform the various functions including risk analytics, verification and authentication of the information which is submitted including as part of the know your client and anti-money laundering obligations, assessment of Merchant websites, monitoring of transactions on the Merchant website/mobile applications, creation of an account with banks and facility providers providing services, conducting quality assurance testing, providing technical and customer support, providing collection or recovery related services or providing specific services in accordance with your instructions. Third parties are required not to use your Personal Information other than to provide the services.

We may share Customer data with competent/ legal/statutory/regulatory agencies / authorities, banks/financial institutions/card networks /facility providers partners/service providers acting on our behalf (as the case may be) in following cases:

For enabling provision of the products/services availed by you, strictly on a “need to know” basis and subject to applicable laws;
Authentication and authorisation of transactions undertaken on the merchant site and processing any requests for chargebacks, refunds etc..
Where such information is directed or required by legal/regulatory / statutory / governmental authorities under applicable laws/regulations though a legally obligated request.
Where such information is required by financial institutions to verify, mitigate or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations.

We may disclose information in the aggregate to third parties relating to User behaviour in connection with actual or prospective business relationship with those third parties, such as advertisers and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertising banners.

IV. Use of Personal Information

a. We use Personal Information provided by you in our business activities for providing our products/services or the products / services of our partners and to perform, among other actions, the following:

to facilitate the transactions or report on these transactions;
to undertake research and analytics for offering or improving our products/services and their security and service quality;
to check and process User requirements submitted to us for products/services and/or instructions or requests received from User in respect of these products/services;
to share with User, updates on changes to the products/services and their terms and conditions;
to take up or investigate any complaints/claims/disputes including pursuing any collection related activities;
to respond to User queries or feedback submitted by you;
to verify User identity for us to provide products/services to the User;
to carry credit checks, screenings or due diligence checks as lawfully required by us;
to monitor and review products/services from time to time;
to undertake financial/regulatory/management reporting, and create and maintain various risk management models;
for conducting audits and for record keeping purposes;
for selective offers and promotions.

b. External processing: We may provide User personal information to our affiliates or other trusted businesses or persons or service providers engaged by us, or institutions that partner with to assist Us with providing the User with products/services to better serve needs of the User and interests, based on the instructions of the User and in compliance with Our Privacy Policy and any other appropriate confidentiality and security measures.

c. Our security practices and procedures limit access to personal information on need-only basis.

d. When we dispose of your Personal Information, we use reasonable procedures to erase it or render it unreadable (for example, shredding documents, wiping electronic media or anonymising such information).

e. We also use Personal Information to fulfill the requirements of applicable laws/regulations and/or court orders/regulatory directives received by us.

V. Purging of Personal Information

a. A merchant availing payment aggregation services may delete its Paytm account at any point of time by making such choice in writing to Us. Upon termination of such services, we will discontinue any external processing as mentioned above, except where external processing is required for regulatory reasons. However, we may retain Personal Information of a merchant as long as the purpose for its usage exists, after which the same is disposed off by us except for any record retention required as per applicable law.

b. Please note that we may be required to store transaction logs and data for longer periods post the deletion of an account. Further, in the event of the pendency of any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect, we may retain Personal Information for such longer duration as may be required to ensure compliance with applicable laws.

VI. Disclaimer and Limitation of Liability

Without prejudice to anything stated herein and in addition to the disclaimers provided elsewhere in this policy, the users/members by accessing the Website and/or registering on the Website or otherwise using Paytm services specifically acknowledge and understand that whilst the Company shall make all reasonable endeavors to protect and secure the confidentiality of the information provided by the users/members, the Company shall not be liable in the following circumstances (please note that this is not an exhaustive list and the specification of any instances hereinbelow shall be in addition to other defenses which may be available to the Company under applicable laws):

) Credit Fraud or other criminal offences committed by any third party with the use of credit cards/debit card etc. or other bank details provided by the members/users which fraud or offence has been committed in spite of the reasonable security measures adopted by the Company as part of its Website infrastructure or where such fraud or criminal offence is committed owing to negligence, acquiescence or connivance or assistance, whether voluntary or involuntary of the user/member.
Unauthorised Use (i.e. use, reproduction, distribution, disposition, or any other activity, including, without limitation, decompilation, reverse engineering, modification or disassembly etc. without the authorisation from the Company) or Unauthorised access (access, or to attempt to access, or to penetrate, or attempt to penetrate by any third party’s computer software or electronic communications system, including, without limitation, hacking, introduction of any virus, malware, spyware, trojans, any intrusion resulting in the corruption or loss of data etc.) of the Website by a user/member or by any third party which may cause any loss or damage to the user/member or the third party where such unauthorized use or access could not be prevented despite reasonable safety precautions undertaken by the Company.
Disclosure of information by the Company pursuant to any enquiry or notice received from a governmental authority pertaining to the activities of the user/member on the Website.

VII. Cookie Policy

We may use cookies to improve the quality of services offered on the Website. Please note that a “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. We may use cookie and tracking technology depending on the features offered. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). Persistent cookies can be removed by following your browser help file directions. If you choose to disable cookies, some areas of Website may not work properly or at all. No Personal information is collected via cookies and other tracking technology; however, if you have previously provided Personal Information, cookies may be tied to such information.

VIII. Log Files

Like most standard websites we may use log files. This includes IP (internet protocol) addresses, browser type, ISP (internet service provider), referring / exit pages, platform type, date / time stamp and number of clicks to analyze trends, administer the Website, track user's movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. The same may be used to track the behavior of the customers or identify the area of interest of the customer, which might further be useful for advertisement, promotions etc.

IX. Links to other websites

Our website may contain links to other websites which are not maintained by us. This privacy policy only applies to Us. Users are requested to read the other websites’ privacy policies when visiting these websites. In addition, Customers undertaking transactions on the Merchant websites/mobile applications are required to read the terms and conditions and privacy policy as available on such sites/application and which govern the use, sharing, collection and dissemination of information on the merchant’s sites. Please note that while we require our merchant’s to specify terms and conditions and privacy policy on their website, we are not responsible for any misuse of information provided by a Customer on the merchant site.

X. Reasonable Security Practices and Procedures

We have implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. We take various steps and measures to protect the security of the your Personal Information from misuse, loss, unauthorised access, modification or disclosure. We use latest secure server layers encryption and access control on our systems. Our safety and security processes are audited by a third party cyber security audit agency from time to time.

XI. Policy Review & Updates

The policy will be reviewed by us and when required, the same may change at any time. The latest and most updated policy will be found on this page.

While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we recommend that you review this policy periodically

Introduction

Paytm Payment Services Limited (“PPSL”) is a payment aggregator / payment gateway that helps merchants collect payments from their end-customers.

Objective

This policy outlines a structured grievance redressal mechanism available to customers for escalating their complaints with PPSL. PPSL will ensure to deal with all complaints in a transparent and timely manner.

Governance Structure

Oversight Framework: The Board of Directors of PPSL will be responsible for the overall compliance to this Policy and Compliance Team will act as a custodian to this policy. Each line of businesses are responsible for their respective processes as detailed in this policy.

Terms of Reference

“Complaint” means a representation in writing or through other modes as specified in this policy, alleging deficiency in service on the part of PPSL and seeking relief thereto. Further, complaints shall not include enquiries or request received from the customers.
“Complainant” can be a customer lodging complaint with PPSL.
“Customer / Merchant” refers to the merchant on boarded by PPSL on platform to use PPSL’s payment solution to collect payments from end-customers.

Redressal Mechanism

Level 1: Merchant Care Executive

If the Complainant has a grievance, they can connect with the support team via the Paytm merchant application or the Paytm merchant dashboard.

Alternatively, complainant can also reach via email at pg.support@paytmpayments.com

Resolution Time*:

For the complaints emanate on account of unsuccessful or failed transactions, the timeline for resolution shall be 4 working days. Wherein a 'failed transaction' is a transaction which has not been fully completed due to any reason not attributable to the customer such as disruption of communication links, timeouts of session and non-credit to beneficiary’s account due various causes.
For any other complaints, resolution shall be provided within 5 to 7 working days from the date of receipt of the complaint by PPSL.

Level 2: Grievance Officer

If timely resolution is not provided at Level 1 or Complainant is not satisfied with the resolution provided, the customer may escalate the complaint to the Nodal Officer.

The Nodal Officer shall ensure that an effective resolution* is provided to the customer within 15 working days from the date of escalation of grievance.

The details of Nodal Officer are as under:

Name of the Principal Nodal Officer: Mr. Anubir Singh Anand

Email id: nodal.officer@paytmpayments.com

*Resolution time does not include time taken by the Complainant to provide required information/ documentation.

If any case / transaction is related to a third party or outside the PPSL, then the TAT will be dependent on the respective Partner Banks/Network Providers etc. Resolution time will include this TAT along with the PPSL’s internal resolution time.

In exceptional circumstances, where PPSL is unable to reach a conclusion within 15 working days, PPSL will respond with a rationale and indication as to when a final response can be expected, which will be within 30 business days of PPSL receiving the complaint.

The Complainant must approach Level 2 with a previous Service Request Number on which the PPSL did not respond or satisfactory response was not provided. This is to ensure that the Complainant gets correct resolution in a timely manner.

Acknowledgement and Tracing of Complaints:

The PPSL shall provide an automated ticket number (Service Request Number) at each level to enable the complainant to track status.

PPSL aims to acknowledge the complaints promptly post receiving the complaint.

Objective and purpose

To lay down criteria and terms and conditions with regard to identifying persons who are qualified to become Directors (Executive and Non-Executive) and persons who may be appointed in Senior Management and Key Managerial positions and to determine remuneration of Directors, Key Managerial personnel and Other employees.
To determine remuneration based on the Company’s size, financial position, trends and practices on remuneration prevailing in peer companies in the similar industry.
To provide them reward, linked directly to their efforts, performance, dedication and achievement relating to the Company’s operations.
To retain, motivate and promote talent and to ensure long term sustainability of talented managerial persons and create competitive advantage.

Scope of the Policy

The policy shall be applicable to the following in the Company: 1. Directors 2. Key Managerial Personnel (KMP) 3. Senior Management 4. Other employees of the Company

Constitution of the Nomination and Remuneration Committee

Notification issued by the Ministry of Corporate Affairs on 5th July, 2017, amending the Companies (Appointment and Qualification of Directors) Rules, 2014. The Company being a wholly owned subsidiary of One97 Communications Limited do not require to comply with the provisions of having a Nomination and Remuneration committee. Hence, the aforesaid committee has not been constituted and Board of Directors shall perform the duties as applicable.

Appointment criteria and qualifications

Letter of appointment shall be issued based on the recommendations of the Board on the basis of the guidelines for the same under the Companies Act, 2013 or the Company Internal policy.
The Board shall identify and ascertain the integrity, qualification, expertise and experience for appointment to the position of Directors, KMPs & Senior Management.
A potential candidate should possess adequate qualification, expertise and experience for the position he/she is considered for appointment. The Board shall review qualifications, expertise and experience, as well as the ethical and moral qualities possessed by such person, commensurate to the requirement for the position.
The Board shall determine the suitability of appointment of a person to the Board of Directors of the Company by ascertaining the ‘fit and proper criteria’ of the candidate.
The Company shall not appoint or continue the employment of any person as whole time director who has attained the age of seventy years. Provided that the term of the person holding this position may be extended beyond the age of seventy years with the approval of shareholders by passing a special resolution based on the explanatory statement annexed to the notice for such motion indicating the justification for extension of appointment beyond seventy years.
The Board shall ensure that there is an appropriate induction & training programme in place for new directors, members of senior management, and KMP.
The Board shall take care of any matters relating to the continuation in office of any director at any time including the suspension or termination of service of an executive director as an employee of the Company subject to the provision of the law and their service contract.

Term / Tenure

Managing Director/Whole-time Director
- The Company shall appoint or re-appoint any person as its Chairman & Managing Director, Executive Chairman, Managing Director or Executive Director for a term not exceeding five years at a time.
- No re-appointment shall be made earlier than one year before the expiry of term of the Director appointed.
Independent Director
- An Independent Director shall hold office for a term up to five years on the Board of the Company and will be eligible for re-appointment on passing of a special resolution by the Company and disclosure of such appointment in the Board's report.
- No Independent Director shall hold office for more than two consecutive terms, but such Independent Director shall be eligible for re- appointment in the Company as Independent Director after the expiry of three years from the date of cessation as such in the Company. The Board shall take into consideration all the applicable provisions of the Companies Act, 2013 and the relevant rules, as existing or as may be amended from time to time.

Remuneration

In discharging its responsibilities, the Board shall have regard to the following policy objectives:
- To ensure the Company’s remuneration structures are equitable and aligned with the long-term interests of the Company and its shareholders;
- To attract and retain competent executives;
- To plan short and long-term incentives to retain talent;
- To ensure that any severance benefits are justified.
The remuneration / compensation / commission etc. to the whole-time director, KMP, senior management & other employees will be determined and approved by the Board.
The remuneration to be paid to the MD and/or whole-time director shall be in accordance with the percentage/ slabs/ conditions laid down in the Articles of Association of the Company and as per the provisions of the Companies Act, 2013 and the rules made there under.
Increments to the existing remuneration / compensation structure of the Senior Management excluding the Board of Directors comprising of members of Management one level below the Executive Director, including the Functional Heads will be jointly decided by the Chairman & Managing Director and Head- Human resources.
Remuneration to Whole-time/ Managing Director, KMP, senior management:
- Fixed pay – The MD and/or whole-time director / KMP and senior management shall be eligible for a monthly remuneration as may be approved by the Board and the shareholders wherever applicable. The breakup of the pay scale and quantum of perquisites including, employer’s contribution towards provident fund, pension scheme, medical expenses, club fees and other perquisites shall be decided and approved by the Board.
- Minimum Remuneration – If in any financial year, the Company has no profits or its profits are inadequate, it shall pay remuneration to its MD and/or Whole-time Director in accordance with the provisions of Schedule V of the Companies Act, 2013 and if the Company is not able to comply with such provisions, previous approval of the Central Government shall be required to be obtained.
Remuneration to Non-Executive / Independent Director:
- Remuneration – The remuneration / commission shall be fixed as per the slabs and conditions mentioned in the Articles of Association of the Company and with the provisions of Companies Act, 2013 along with the rules made there under.
- Sitting Fees – The Non- Executive/ Independent Director may receive remuneration by way of fees for attending meetings of Board thereof. Provided that the amount of such fees shall not exceed the limits prescribed under Companies Act, 2013.

Removal

Due to reasons for any disqualification mentioned in the Companies Act, 2013 and rules made there under or under any other applicable Act, rules and regulations, the Board with reasons recorded in writing, removal of a director, KMP or senior management personnel or functional heads, subject to the provisions and compliance of the Act, rules and regulations.

Retirement

The director, KMP, senior management & functional heads shall retire as per the applicable provisions of the Companies Act, 2013 along with the rules made there under and the prevailing policy of the Company. The Board will have the discretion to retain the Directors, KMPs & Senior Management even after attaining the retirement age, for the benefit of the Company.

Diversity

The Company aims to enhance the effectiveness of the Board by diversifying it and obtain the benefit out of it by better and improved decision making. In order to ensure that the Company’s boardroom has appropriate balance of skills, experience and diversity of perspectives that are imperative for the execution of its business strategy, the Company shall consider a number of factors, including but not limited to skills, industry experience, background, race and gender.
The policy shall confirm with the following two principles for achieving diversity on its Board:
- Decisions pertaining to recruitment, promotion and remuneration of the directors will be based on their performance and competence; and
- For embracing diversity and being inclusive, best practices to ensure fairness and equality shall be adopted and there shall be zero tolerance for unlawful discrimination and harassment of any sort whatsoever.
In order to ensure a balanced composition of executive, non-executive and independent directors on the Board, the Company shall consider candidates from a wide variety of backgrounds, without discrimination based on the following factors:
- Gender - The Company shall not discriminate on the basis of gender in the matter of appointment of director on the Board. The Company encourages the appointment of women at senior executive levels to achieve a balanced representation on the Board.
- Age - Subject to the applicable provisions of Companies Act, 2013, age shall be no bar for appointment of an individual as director on the Board of the Company.
- Nationality and ethnicity - The Company shall promote having a boardroom comprising of people from different ethnic backgrounds so that the directors may efficiently contribute their thorough knowledge, sources and understanding for the benefit of Company’s business;
- Physical disability - The Company shall not discriminate on the basis of any immaterial physical disability of a candidate for appointment on Company’s Board, if he/she is able to efficiently discharge the assigned duties.
- Educational qualification - The proposed candidate shall possess desired team building traits that effectively contribute to his/ her position in the Company. The Directors of the Company shall have a mix of finance, legal and management background, that taken together, provide the Company with considerable experience in a range of activities including varied industries, education, government, banking, and investment.

Minutes of Board Meeting

Proceedings of all meetings must be recorded as minutes and signed by the Chairman of the same meeting or Chairman at the subsequent meeting as required under Companies Act, 2013 and amended from time to time and Secretarial standards issued by Institute of Company Secretaries of India (ICSI) from time to time in this regard. Minutes of the Board meetings will be tabled at the subsequent Board meeting.

Disclosure of this policy

The policy shall be disclosed in the Annual report of the Company, as required under Companies Act, 2013, Rules made there under and the Listing Agreement, as amended from time to time and as may be required under any other law for the time being in force.

Review

The Board as and when required shall assess the adequacy of this policy and make any necessary or desirable amendments to ensure it remains consistent with the Company’s objectives, current law and best practice.

Background

Corporate Social Responsibility (CSR) is strongly connected with the principles of Sustainability; an organization should make decisions based not only on financial factors, but also on the social and environmental consequences. Corporates must recognize that their business activities have wide impact on the societies in which they operate.

This policy shall apply to all CSR initiatives and activities taken up at the various work‐centres and locations of Paytm Payments Services Limited (hereinafter referred to as “PPSL or the Company”), for the benefit of different segments of the society, specifically the deprived, underprivileged and differently abled persons.

Definitions

ActAct means Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014 (including any statutory modification(s) or re-enactment(s) for the time being in force).
Corporate Social Responsibility (CSR)CSR means and include but not limited to the activities as specified in this policy pursuant to Schedule VII of the Act, but contribution directly or indirectly to the political party, business done by the Company in its normal course, activities only for the benefit of employees and activities done outside India will not be considered as CSR activity.
Net profitNet profit means the net profit of the Company as per its financial statement prepared in accordance with the applicable provisions of the Act, but shall not include the following namely:
- Any profit arising from any overseas branch or branches of the Company, whether operated as a separate company or otherwise; and
- Any dividend received from other companies in India which are covered under and complying with the provisions of section 135 of the Act.
CSR ExpenditureCSR Expenditure shall include all expenditure including contribution to corpus, or on projects or programs relating to CSR activities specified in this policy as approved by Board on recommendation of CSR Committee.
CSR CommitteeCSR Committee means the committee constituted under the provisions of Section 135 of the Act.

CSR Activities

The followings are the wide categories of the activities under which the Company may work to undertake CSR activities:

Eradicating hunger, poverty and malnutrition, promoting health care including preventive health care and sanitation including contribution to the Swatch Bharat Kosh set-up by the Central Government for the promotion of sanitation and making available safe drinking water.
Promoting education, including special education and employment enhancing vocation skills specially among children, women, elderly, and differently abled and livelihood enhancement projects;
Promoting gender equality, empowering women, setting up homes and hostels for women and orphans, setting up old age homes, day care centers and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agro-forestry, conservation of natural resources and maintaining quality of soil, air and water including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga;
Protection of national heritage, art and culture including restoration of building and sites of historical importance and works of art: setting up public libraries; promotion and development of traditional arts and handicrafts:
Measures for the benefit of armed forces veterans, war widows and their dependents, Central Armed Police Forces (CAPF) and Central Para Military Forces (CPMF) veterans, and their dependents including widows;
Training to promote rural sports, nationally recognized sports, paralympic sports and Olympic sports;
Contribution to the Prime Minister’s National Relief Fund or Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Schedule Castes, the scheduled tribes, other backward classes, minorities and women;
(a) Contribution to incubators or research and development projects in the field of science, technology, engineering and medicine, funded by the Central Government or State Government or Public Sector Undertaking or any agency of the Central Government or State Government; and (b) Contributions to public funded Universities; Indian Institute of Technology (IITs); National Laboratories and autonomous bodies established under Department of Atomic Energy (DAE); Department of Biotechnology (DBT); Department of Science and Technology (DST); Department of Pharmaceuticals; Ministry of Ayurveda, Yoga and Naturopathy, Unani, Siddha and Homoeopathy (AYUSH); Ministry of Electronics and Information Technology and other bodies, namely Defense Research and Development Organization (DRDO); Indian Council of Agricultural Research (ICAR); Indian Council of Medical Research (ICMR) and Council of Scientific Industrial Research (CSIR) , engaged in conducting research in science, technology, engineering and medicine aimed at promoting Sustainable Development Goals (SDGs).;
rural development projects;
Slum area development, declared as such by the Central Government or any State Government or any other competent authority under any law for the time being in force;
disaster management, including relief, rehabilitation and reconstruction activities;
Any other funds or activities as may be notified by the Central Government, from time to time, as contribution towards CSR expenditure.

Execution process

The Company may undertake its CSR activities, as approved by the CSR Committee, directly by the Company or through a registered trust or a registered society or a company established by the Company or its holding or Subsidiary or associate company under section 8 of the Act or otherwise.

The Company may also undertake CSR activities through any trust, society or section 8 company which is not established by the Company or its holding or subsidiary or associate company, if such trust, society or section 8 company shall be having an established track record of three years in undertaking similar programs or projects or where the corpus is created exclusively for a purpose directly relatable to a subject covered in Schedule VII of the Act.

The Company may also collaborate with other companies for undertaking projects or programs or CSR activities in such a manner that the CSR Committees of respective companies are in a position to report separately on such projects or programs.

The Board/ CSR Committee should ensure that the above mentioned entities with which it undertakes CSR activity has registered itself with the Central Government in the manner as given under the Act

Utilization of fund

The Company shall utilize at least 2 percent of the average net profit made during the last three (3) immediately preceding financial years in the CSR activities as enumerated above in this policy. In any case, if in any year the Company fails to spend such amount on CSR, the Board will, in its report made under section 134 (3) (o) of Companies Act, 2013, specify the reasons for not spending the amount and, unless the unspent amount relates to any ongoing project, as described in Section 135 (6) of the Companies Act, 2013, transfer such unspent amount to a Fund specified in Schedule VII, within a period of six months of the expiry of the financial year.

Further, if the Company spends an amount in excess of the requirements as provided in Section 135 of the Act, Company may set off such excess amount against the requirement to spend under Section 135 of the Act, under the heading ‘Utilization of fund’, for up to immediate succeeding three financial years or for such time in such manner, as may be prescribed under the Act.

Surplus arising from CSR activity

The surplus arising from CSR projects, programs or activities shall not form part of the business profit of the Company.

Monitoring Mechanism

To ensure effective implementation of the CSR programmes undertaken a monitoring mechanism will be put in place by the Company. The CFO would place a monitoring report of the CSR projects under implementation to the CSR Committee. The progress of CSR programmes under implementation will be reported to Board of Directors on a regular basis. The CSR Committee will conduct impact studies on a periodic basis, about effectiveness of CSR activities on the society.

Reporting Mechanism

CSR Committee will obtain feedback from beneficiaries about the programmes and report to the Board of Directors, the feedback received from the beneficiaries of CSR Activity. Appropriate documentation of the Company’s CSR Policy, annual CSR activities, executing partners, and expenditure entailed will be undertaken on a regular basis and the same will be available on the website of the Company. CSR initiatives of the Company will also be reported in the Annual Report of the Company.

Budget monitoring:

The Company establish an accounting system to ensure proper accounting of CSR spends.

CSR Committee:

Composition of the CSR Committee: The composition of the CSR Committee of the Board shall be as constituted by the Board of Directors from time to time in terms of the provisions of Section 135 of the Act
Responsibility of the CSR Committee:
- formulate and recommend the CSR Policy to the Board for approval
- monitor the Policy from time to time and recommend changes to the Board
- recommend the amount of expenditure to be incurred on CSR projects
- constitute a transparent monitoring mechanism for ensuring effective and efficient implementation of the CSR projects.
The Committee will meet atleast once in a year to discuss and review CSR activities and Policy. A quorum of two members is required to be present for the proceedings to take place. The Committee members may attend the meetings physically or via such audio-visual means as permitted under the Act.
A member of the CSR Committee may resign by a written notice stating the reasons for such resignation, addressed to the Board of Directors of the Company. The resignation shall be effective from the date of acceptance of the resignation in the meeting of the Board of Directors or after 30 days from the date of the resignation, whichever is earlier.
In case of the resignation of any member of the CSR Committee, the Board of Directors shall appoint a new member to fill the vacancy created as such within reasonable time. The new member shall be appointed in keeping with the constitution requirements of the CSR Committee.
The CSR Committee will review the philanthropic activities of the Company and will provide progress update to the Board of Directors at such intervals as it deemed fit.
The CSR Committee shall have the authority to obtain professional advice from external sources and have full access to information contained in the records of the Company as well as the powers to call such employee(s), senior official(s), Representative of CSR Partners, external consultant or such other persons and for such purpose as may be deemed expedient for the purpose of accomplishments of overall CSR Objectives laid down under the Act.

AMENDMENTS

The Board of Directors on its own and/or as per the recommendations of CSR Committee can replace or amend this policy, as and when required as deemed fit. Any or all the provisions of the CSR Policy would be subject to revision/amendment in accordance with the Regulations on the subject as may be issued from relevant statutory authorities, from time to time.

Download Candidature Notice under Section 160 of the Companies Act for FY 2022-2023

Download Candidature Notice under Section 160 of the Companies Act for FY 2024-2025

Download Annual Return for FY 2020-2021

Download Annual Return for FY 2021-2022

Download Annual Return for FY 2022-2023

Download Annual Return for FY 2023-2024

Download Annual action plan for FY 22-23

Download Annual action plan for FY 23-24

Download Annual action plan for FY 24-25

Download Composition of CSR Committee

Mr. Indu Bhushan (DIN: 09302960) tendered his resignation from the office of Independent Director of the Company effective June 30, 2024.

Mr. Bhavesh Gupta (DIN:07826662), tendered his resignation from the office of Director of the Company effective from May 4, 2024.

Mr. Vivek Kumar Mathur (DIN - 03581311) tendered his resignation from the office of Director of the Company, effective from August 3, 2023.

Mr. Praveen Sharma (DIN - 09308709) tendered his resignation from the office of Managing Director and CEO of the Company, effective from August 1, 2022.

Mr. Deepankar Sanwalka (DIN - 07175396) tendered his resignation from the office of Additional Director of the Company, effective from May 18, 2022.

Mr. Vikas Garg (DIN - 07871975) tendered his resignation from the office of Director of the Company, effective from February 22, 2022.

1. Statement of Policy and Applicability

Paytm Payments Services Limited (the “Company” or “PPSL”) have formally adopted this Policy, for the purpose of this Anti-Bribery and Anti-Corruption (ABAC) Policy (hereinafter referred to as “Policy”).

The Company and its management is committed to the highest level of professional and ethical standards in the conduct of its business. It has zero tolerance for bribery and corruption in any form, whether directly or indirectly.

This Policy applies to all Stakeholders (as defined below) and lays out the guiding principles for all Stakeholders in order to ensure compliance with Applicable Laws in all dealings, transactions and expenses for and/or on behalf of the Company. The Company expects all the Stakeholders to adhere with this Policy.

2. Persons Responsible for this Policy

The Company’s Head of Legal is responsible for maintaining and implementing this Policy, and shall provide reports to the Audit Committee (who shall, as representative of the board of directors, have the responsibility for monitoring the effectiveness and reviewing implementation of this Policy) of the Company about the status of the Company’s anti-corruption compliance efforts. The Head of Legal is authorized to (i) delegate to team members the day-to-day Policy functionalities; and (ii) approve exceptions to the Policy as warranted; any such exceptions must be documented. Stakeholders may reach out to the Head of Legal for all approvals, clarifications, queries or disclosures relating to this Policy at the contact coordinates set out below:

Head of Legal, Paytm Payments Services Limited, 8th Floor, Skymark One, Tower-D, Plot No H-10 B, Noida, Uttar Pradesh 201301; or e-mail ID: nodalabac@paytmpayments.com

The term Head of Legal as used in the succeeding paragraphs of this Policy shall include by reference such officials of the Company who are delegated day-to-day functionalities for implementing this Policy.

3. Important Definitions

The following capitalised terms used in the Policy shall have the meanings ascribed to them below:

Anything of Value: “Anything of Value” covers almost all forms of benefit, which includes but is not limited to:

provision of cash or cash equivalents (such as pre-loaded cards or payment instruments, gift cards etc.), loans, gifts, prizes, sponsorships etc;
offering favourable terms / discounts on a product or service;
offering personal favours, including offers of employment (including future employment), either to an individual or any of his/her relatives;
providing entertainment/hospitality, such as paying for or subsidising travel, hotel or restaurant bills, living expenses, costs of trips or resort stays, discounted or free premium tickets to sports/entertainment events etc.;
making political donations;
bestowing any Undue Advantage i.e. gratification (in any form, pecuniary or otherwise) other than any legitimate consideration, fee or remuneration etc

Applicable Laws: All national / international laws and regulations relating to bribery and corruption and allied laws, which may be applicable to the Company and all Stakeholder(s) in places where the Company has or may carry out official work.
Bribe/Bribery: To “bribe” or “bribery” means directly or indirectly indulging in any corrupt practice by offering, promising, giving, accepting, authorizing, soliciting, deriving or acquiescing to ‘Anything of Value’ (including an offer thereof) irrespective of location(s) or making a quid pro quo arrangement, in violation of Applicable Laws, to an individual, a Government Ofﬁcial(s) or a Government Entity(s), or to an employee of a Commercial entity or Government entity for the purpose of obtaining or retaining business, to win or retain a business/commercial advantage, or to influence a decision regarding PPSL or otherwise in violation of the Applicable Laws.

Illustrative examples of bribe may include (i) payment of cash, inflated commissions, fake consultancy arrangements, unauthorized rebates/discounts, kickbacks, or expensive gifts; or (ii) Facilitation Payments (as defined below).

Commercial Entity: Any non-governmental (whether domestic or foreign) entity, commercial corporations, business or institution with whom PPSL has executed a business agreement or with whom the Company is contemplating or evaluating a business relationship and includes their employees and officers.
Facilitation Payment: Offering, bestowing or giving ‘Anything of Value’ to a Government Ofﬁcial, in order to secure or speed up any discretionary or non-discretionary government action, such as:

issuing / obtaining permits and licenses;
processing passports, visas or work orders etc.

Government Ofﬁcial: “Government / Public Ofﬁcial”, for the purposes of this Policy, shall include:

An ofﬁcer or employee, regardless of rank, of (a) any national, state or local government agency or department, including but not limited to the police and other law enforcement authorities, customs ofﬁcials, tax officials, issuers of government permits / approvals / licenses and/or immigration ofﬁcials; (b) an inter-governmental international organization; or (c) business or commercial enterprise or entity that is owned or controlled in whole or in part by any government agency;
A political candidate or a political party or any ofﬁcer or employee of a political party;
Any private person acting in an ofﬁcial capacity for or on behalf of any government or public international organization ;
Members of the judiciary and officers of court(s);
Any person recognized to be a ‘public servant’ or public official under the Applicable Laws.
Family members and close business associates of any of the individuals specified above. (A family member of a Government Official shall mean a spouse, sibling, parent or child of the Government Official. A close business associate of a Government Official includes all persons who have any common financial interest or significant personal relationship with the Government Official and includes current or former partners, co-owners, joint-venture partners, or co-investors with, or consultants or advisors to, the Government Official.);

Government Entity: A Government/Public Entity for the purposes of this Policy shall include any office, agency, subdivision or other body of any national, state or local government, including government committees or commissions and regulatory agencies, any Court or government-controlled businesses, corporations, companies or societies or an inter-governmental international organization.
Stakeholders: Stakeholders refers to and includes internal as well as external stakeholders of PPSL:

Internal Stakeholder(s) include member(s) of the Board of Directors of PPSL, employee(s), which includes permanent, fixed-term/ contractual, or temporary employees as well as interns and project trainee(s).
External Stakeholder(s) includes any individual or entity, including but not limited to merchants, sellers, consultants, customers, Commercial Entity(ies), vendors, donees, or Intermediaries working or acting or performing services on behalf of and/or for PPSL [and their respective employees, representative(s) or agent(s)], and Governments Official(s).
Intermediaries means and includes any agent, service provider, consultant, lawyer, accountant, customs brokers, freight forwarder, lobbyist, distributor, contractor, vendor, supplier, retainer, who is engaged or retained to assist the Company in any function of the business that requires or involves interaction with any level of Government or Government / Public Official in any of the countries in which the Company operates.

4. Prohibition on Bribery and Facilitation Payments

PPSL prohibits Bribery and Facilitation Payments in all forms. The Company strictly prohibits Stakeholders to offer, promise to offer, accept, solicit, abet or authorize a corrupt practice, to pay Bribe to any Government Official or Commercial Entity, directly or indirectly, to improperly influence their official acts or decisions, or to obtain or retain business/commercial advantage for Company or for any other person or entity, or to secure any improper advantage, or personal gain, or to otherwise violate (or abet the violation of) the Applicable Laws in any manner.

5. Books, Records and Internal Controls

PPSL shall implement requisite internal controls to prevent and detect potential violations of this Policy or of Applicable Laws and regulations. All Internal Stakeholders must completely and accurately document the amount of all transactions, including payments made on behalf of or expenses incurred by PPSL, in accordance with Applicable Laws.

PPSL mandates all External Stakeholders to prepare and maintain, accurate records and adequate documentation for all transactions, to avoid any non-compliance with PPSL’s ABAC Policy and any other related policies, as well as Applicable Laws.

6. Compliance with Anti-Bribery and Anti-Corruption Policy

All Stakeholders are required to comply with this Policy, at all times. To this end, all Stakeholders must read the contents of this Policy and understand the extent to which the Policy shall affect their daily work. Any questions in this regard should be directed to the PPSL’s head of legal.

Any Internal Stakeholder who fails to adhere to this Policy, or authorizes or allows a subordinate to violate it, shall be subject to appropriate disciplinary action, including potential demotion or dismissal. PPSL also reserves the right to terminate its contractual relationship with and/or initiate such other further action(s) as deemed appropriate or required under Applicable Laws against any External Stakeholder who violates any Applicable Law or the provisions of this Policy.

7. Review of Business Expenditures and Policy Framework on Gifts, Hospitality and Entertainment

PPSL’s Finance team shall review the transactions expenditure claims by Internal Stakeholders thoroughly, specifically related to travel and entertainment / hospitality, gifts, donations, etc. and shall have right to refuse payment or reimbursement of any expenditure that appears unreasonable / suspicious, despite it having been previously approved by the relevant functional head.

All business expenditures must:

be incurred in the ordinary course of business and backed by accurate documentation, without requiring anything in return, or without creating the impression that the Company expects something in return as a “quid pro quo”;
not be incurred if the same in any manner could encumber the independence / agency of the person/entity who is the beneficiary of the business expenditure;
be permissible under the policies and procedures stipulated by the recipient’s employer, as well as any Applicable Law, and should be reasonable and appropriate given the circumstances; comply with PPSL’s procurement procedures, as applicable; be approved pursuant to any business-level approval requirements; and comply with any other relevant policies that may apply to a Stakeholder related to such activities.

Any person authorized to approve such business expenditures, should be mindful of the above principles while considering a request for approval of such business expenditures, especially in case of expenditures involving Government Officials. In case of any doubts regarding the legal permissibility of such expenditures, the approving authority may seek guidance from the Head of Legal.

A. Gifts

PPSL permits giving or receiving of gifts by the Stakeholders, directly or indirectly, of a modest value, subject to approval matrix and guidelines stated below:

Gifts to Commercial Entities	Gifts to Government Officials	Approving Authority
Up to INR 8,000 (or equivalent amount, if incurred in Foreign Currency) per person	Up to INR 4,000 (or equivalent amount, if incurred in Foreign Currency) per person	Head of Department (for gifts to persons engaged/employed with Commercial Entities) Head of Department & Head of Legal (for gifts to Government Officials)
INR 8,000 to INR 16,000 (or equivalent amount, if incurred in Foreign Currency) per person	INR 4,000 to INR 8,000 (or equivalent amount, if incurred in Foreign Currency) per person	Head of Department & Head of Legal
Above INR 16,000 (or equivalent amount, if incurred in Foreign Currency)	Above INR 8,000 (or equivalent amount, if incurred in Foreign Currency) per person	Prohibited, exceptions may be approved by Head of Legal
Note: The limits prescribed above are applicable for gifts given to a person/financial year and will be subject to Applicable Laws.

PPSL’s Internal Stakeholders can receive gifts, subject to limits stipulated for Commercial Entities in the Table above, in their professional capacity from External Stakeholders. The gift should be made as a courtesy or token of regard or esteem and should be given openly and transparently.

Gifting Guidelines

Giving and receiving of gifts on certain occasions including festivals, such as Diwali, Christmas, Eid, etc. is permissible basis the above mentioned approval matrixes. Any gifts exchanged must comply with the Applicable Law.
Gifts must be bona fide and given or received in the normal course of business and nothing should be expected in return.
Gifts should be moderate (Note: Cash and/or bullions are not allowed) and should not be lavish, extravagant and frequent.
Gifts should not be designed / given / received to influence the judgment or encumber the independence of the person receiving the said courtesy.

B. Business Hospitality & Entertainment

PPSL does not prohibit receiving or giving of reasonable business related hospitality (includes meals only), provided such hospitality or entertainment, is reasonable, appropriate, modest, and bona fide. Such business hospitality or entertainment must always be approved at the appropriate level of Company management i.e. the concerned HOD, SMP or any KMP or the Head of Legal.

PPSL’s Internal Stakeholders can receive reasonable, appropriate, modest, and bona fide hospitality / entertainment in their professional capacity from the Company or Commercial Entities or Government Officials. Such hospitality / entertainment should be extended as a courtesy or token of regard or esteem and should be given openly and transparently. While extending hospitality towards Government Officials, due care should be taken that the same is not in violation of the Applicable Laws. In case of any doubts regarding permissibility, please consult the Head of Legal.

PPSL’s Internal Stakeholders may also attend business events sponsored by External Stakeholders which enable opportunities for learning, engagement and business development, subject to approval from their respective HOD, who may consult the Head of Legal if they deem appropriate to seek guidance.

Guidelines for Hospitality / Entertainment

Hospitality in the form of meals and refreshments may be provided in connection with business meetings, or as a courtesy or token of regard or esteem and should be extended openly and transparently.
Notwithstanding the aforesaid, no hospitality shall be extended nor any entertainment expenses be incurred in respect of massage, sauna, adult entertainment, gambling, any other illegal or immoral entertainment and any entertainment that may (potentially) damage PPSL’s reputation.

C. Travel and Accommodation for Government Officials

The Company discourages payment of expenses relating to travel and accommodation of Government Officials except in exceptional circumstances when (i) such travel relates directly to the Government Official’s execution or performance or discharge of their official duties; (ii) is permitted under the rules governing the employment of the said Government official(s); and (iii) is pre-approved by the Chief Compliance Officer or Head of Legal of PPSL. Such expenses shall be reasonable, bona-fide and properly documented.

8. Contribution(s), Donation(s), Fine(s)/ Penalty(ies) or Sponsorship(s)

A. Political Contributions

PPSL prohibits making any political contribution(s), directly or indirectly, by or on behalf of the Company.

B. Charitable Contributions or Donations

Contribution(s)/ donation(s) shall be made only in line with Company’s CSR policy, and to donees that are onboarded in accordance with the prescribed due diligence questionnaire, enclosed as Annexure 1 to this Policy.

All such Contribution(s)/ donation(s) must be made in line with Applicable Laws and after receiving a written approval from the CSR Committee of the Company.

C. Sponsorships (other than as part of normal course of business operations)

Company may sponsor certain sports, cultural, educational or other promotional activities. All such sponsorships must be made for bonafide objectives and be pre-cleared with the concerned HOD or Senior Management Personnel (SMP/KMP) or Head of Legal. Such activities or expenses would be governed by written sponsorship agreements and would be closely monitored by the Company to ensure that these payments are not used in an inappropriate or illegal manner. Additionally, necessary background checks / verification shall be conducted before executing the sponsorship agreements.

D. Fines and penalties

In case any fines or penalties are imposed on the Company by a Government Entity in connection with operations of the Company, which the Company does not wish to challenge/appeal before the courts of law or appellate authority, the copy of such notice for fines and penalties should be sent to the Finance team. Upon respective approvals from the relevant Head of Department and the Chief Compliance Officer, fines and penalties shall be paid solely from funds transferred directly to the Government Entity from the Company’s corporate office or regional office via wire transfer or cheque (only in exceptional cases should the amount be paid in cash) and a written acknowledgement/receipt of the payment shall be obtained. A copy of the written acknowledgement/receipt shall be sent to the Head of Legal for records.

9. Dealing with Government Officials

A. Engagement or hiring of services of ex-government officials

PPSL allows merit based engagement with or hiring of services of ex-Governmental Officials, subject to compliance with such standard operating procedures as may be prescribed.

B. Inspections

Every time a Government Official arrives at a Company premises including the corporate, regional or sales office to conduct an inspection, Company employees should cooperate with the conduct of any such legitimate inspection.

A log must be maintained on site at the Company premises, containing the date, name of Government Official and his/her Government Entity, and purpose of each visit. If any expenses including any meals, travel or lodging are incurred during the inspection, these expenses must be recorded and must be consistent with the Policy.

10. Engaging third parties /Intermediaries

PPSL engages with third party(ies) including Intermediaries for legitimate business purposes and on commercially justifiable terms.

Third parties/Intermediaries can put the Company at risk if they do not follow ethical business practices. All contracts with third parties must be in writing and detailing the scope of work, must be legally vetted and executed between the parties. Every contract must also include appropriate anti-bribery and anti-corruption clauses. Third-parties must also undertake that in the event they sub-contract any part of the contracted services, they shall be responsible for all acts of the sub-contractor(s) and shall obtain anti-corruption undertakings from the said sub-contractor(s) which shall be on par with their anti-bribery and anti-corruption undertaking/ commitments to the Company. In case a third party refuses to sign-off the anti-corruption verbiage, it should not be appointed or retained to work with PPSL. The Legal Department is responsible to ensure that all the agreements have appropriate Anti-Bribery and Anti-Corruption clauses.

All potential Intermediaries shall be required to undergo prescribed due-diligence (enclosed as Annexure 2 to this Policy) and shall be onboarded subject to satisfactorily clearing the same.

11. Trainings, Monitoring and Review of the Policy

A. Training

All Internal Stakeholders shall be required to participate in the Anti-Bribery and Anti-Corruption training sessions mandatorily once in every financial year. The Company shall also endeavour to conduct Anti-Bribery and Anti-Corruption training sessions for Intermediaries engaged by it.

B. Monitoring & Review

Internal Stakeholders shall acknowledge and sign off having to attend the Anti-Bribery and Anti-Corruption training and declare their compliance with the same.

The Human Resources team shall ensure that all Internal Stakeholders receive / undergo the annual training, and records of the attendance of the training sessions and acknowledgment/sign offs by the Internal stakeholders shall be maintained.

12. Reporting of violations of the Policy

A. Whistle-blowing Mechanism

The Company expects all its Stakeholders to read, understand and comply with this Policy, and requires reporting of any incident of violation of this Policy or the Applicable Laws and regulations.

Not reporting the instances of violations of this Policy or of the Applicable Laws on timely basis may, in some cases, potentially expose the Company to legal action. All Stakeholders shall raise the concerns, if any, about the instances of bribery or suspicion of corruption at the earliest possible stage, and should report any such concerns or suspicions on the Vigil Mechanism / Whistle Blower Mechanism implemented by the Company. The identity of the complainants will be kept confidential during investigations, and may be disclosed only on a ‘need-to-know’ basis to others. The Company also accepts anonymous complaints; however, the Stakeholders are encouraged to disclose their name and contact details for follow up discussions and further investigations.

PPSL will ensure that any Stakeholder, who based on a reasonable belief that a possible violation or suspected wrongdoing has occurred, reports/ complaints under the Whistle Blower Mechanism will ‘NOT’ be subjected to any retaliation, regardless of whether or not the concern is ultimately substantiated. Retaliation includes discrimination, reprisal, harassment, victimization or vengeance.

B. Investigation

Complaints received through the Vigil/Whistle Blower Mechanism or any potential violation of this Policy or of Applicable Laws reported to any Internal Stakeholder shall immediately be forwarded for investigation by the concerned team.

The Company will timely investigate all the complaints. The investigators shall ensure compliance with all the regulatory requirements during the course of investigation.

C. Disciplinary Action on Non-compliance

After the completion of the investigation, the investigation report shall be finalised, and the Company shall initiate disciplinary actions (as appropriate) based on the findings and recommendations of such report. The disciplinary action(s) may include a verbal warning, written warning, suspension (with or without pay), pay reduction, demotion, withholding of perquisites like bonus etc. leading up-to dismissal or termination of the suspect, initiation of appropriate legal proceedings, recovery of damage or loss to Company, penalties imposed by authorities including fines and imprisonment etc.

13. Waiver and Amendment of the Policy and Grievance Redressal Mechanism

PPSL is committed to continuously review and update the ABAC policies and procedures based on requirement(s), material learnings and any changes in Applicable Laws, or when PPSL enters any new market/ sector/ country or in case of enhanced risk environment. It is clarified that applicable changes in any Applicable Law will immediately come into force and prevail, irrespective of amendment of the Policy.

Anyone who wants to raise grievance relating to this Policy, regarding contents or provisions hereof, should reach out to the Head of Legal at abac@paytmpayments.com

New ideas are brought to life at Paytm everyday.

Read all about it on our Blog.