Effective Date: August 2025

DALTIN EDU PRIVATE LIMITED (Edvia.ai)

Applicable To: All students, parents/guardians, employees, consultants, interns, vendors, contractors, recruitment partners, admissions teams, management personnel, freelancers, agents, platform users, university partners, service providers, and associated third parties.

1. PURPOSE

DALTIN EDU PRIVATE LIMITED ("Edvia") is committed to conducting all business activities ethically, transparently, professionally, and in compliance with applicable Indian laws and internationally accepted anti-bribery and anti-corruption standards.

This Anti-Bribery & Anti-Corruption Policy ("ABAC Policy") establishes a zero-tolerance approach towards bribery, corruption, kickbacks, fraudulent commissions, undisclosed incentives, unethical payments, misuse of company resources, conflict of interest, improper hiring influence, unauthorised vendor or partner dealings, fake refunds or financial manipulation, and data misuse or unethical platform practices.

The purpose of this policy is to protect the integrity, reputation, operational credibility, institutional relationships, technological systems, and ethical governance framework of Edvia.

This policy forms part of Edvia's public ethical governance framework and applies to all business interactions conducted through or in association with the organisation, whether online, offline, directly, or indirectly.

2. BUSINESS MODEL CONTEXT

Edvia operates primarily as a B2C overseas education platform, a technology-enabled admissions and recruitment ecosystem, and a business facilitation and institutional support platform.

Edvia does not generally operate through direct cash handling or advance payment collection into personal employee or company accounts.

Accordingly, this policy particularly emphasises ethical partner dealings, recruitment integrity, vendor transparency, technology procurement ethics, hiring ethics, platform misuse prevention, data integrity, commission transparency, institutional relationship protection, and ethical student engagement.

3. SCOPE

This policy applies to all individuals and entities associated with, interacting with, representing, using, partnering with, or conducting business with Edvia, including but not limited to students, parents/guardians, employees, contractual staff, management, directors, HR teams, recruitment teams, sales teams, marketing teams, admissions teams, technology teams, consultants, freelancers, vendors, third-party agencies, service providers, university partners, referral partners, recruitment agencies, platform users, contractors, and external representatives.

4. DEFINITION OF BRIBERY & CORRUPTION

Bribery includes offering, promising, giving, requesting, or accepting any financial or non-financial advantage to improperly influence a business decision, process, service outcome, recruitment activity, admission process, or institutional relationship.

Corruption includes abuse of authority, influence, access, systems, data, position, or business relationships for personal, financial, or unfair advantage.

This may include cash payments, gifts, personal commissions, referral kickbacks, hidden incentives, personal favours, manipulated hiring decisions, fake invoices, fake refunds, unofficial vendor commissions, recruitment-related kickbacks, admission manipulation, preferential treatment in exchange for benefits, data selling or misuse, and unauthorised financial arrangements.

5. STRICTLY PROHIBITED ACTIVITIES

The following actions are strictly prohibited:

5.1 Recruitment & Hiring Misconduct

Accepting money or favours from candidates, manipulating interview outcomes, influencing hiring decisions for personal benefit, sharing confidential hiring information, prioritising vendors or candidates due to personal incentives, and accepting commissions from recruitment agencies without disclosure are strictly prohibited.

5.2 Vendor & Procurement Corruption

Receiving kickbacks from vendors, undisclosed commission arrangements, creating fake invoices, inflated procurement pricing, personal relationships influencing procurement decisions without disclosure, and unauthorised vendor onboarding are strictly prohibited.

5.3 Partner & University Misconduct

Accepting undisclosed commissions from institutions, manipulating student allocation for personal gain, misrepresenting partnerships, making unauthorised promises to partners, and creating non-transparent referral arrangements are strictly prohibited.

5.4 Financial & Payment Misconduct

Requesting payments into personal accounts, unapproved financial collections, hidden financial arrangements, fake refunds or manipulated refund processing, misuse of company subscriptions, budgets, or financial systems, and unauthorised reimbursements are strictly prohibited.

5.5 Technology & Data Misconduct

Selling student, candidate, company, or institutional data, sharing confidential information externally without authorisation, misusing administrative access, unauthorised software procurement, accepting incentives from software vendors, and manipulating platform systems or lead flows improperly are strictly prohibited.

6. GIFTS, HOSPITALITY & BUSINESS COURTESIES

No stakeholder associated with Edvia may accept expensive gifts intended to influence decisions, accept cash or cash equivalents, accept personal travel sponsorships or luxury hospitality intended to influence business outcomes, or provide gifts or benefits to improperly influence admissions, hiring, procurement, or partnerships.

Reasonable and lawful business courtesies of nominal value may be acceptable only if they are transparent, non-influential, professionally appropriate, lawful, and properly disclosed where required.

All material gifts, hospitality, sponsorships, or benefits must be disclosed to management where applicable.

7. CONFLICT OF INTEREST

All stakeholders must disclose situations where personal interests may conflict with Edvia's interests.

This includes relatives working with vendors, institutions, or partners; personal financial interests in vendors or agencies; external freelancing or business activities creating conflict; personal relationships influencing recruitment, procurement, admissions, or partnerships; and hidden financial interests connected to business decisions.

Undisclosed conflicts may result in disciplinary, contractual, legal, or operational action.

8. THIRD-PARTY & VENDOR COMPLIANCE

All vendors, consultants, agencies, freelancers, partners, and third parties associated with Edvia are expected to comply with ethical business standards.

No stakeholder may appoint vendors unofficially, approve payments without documentation, create hidden side arrangements, accept hidden commissions, use unofficial contracts or undocumented agreements, or engage in unethical referral or commission practices.

Vendor onboarding and partnership processes must follow approved and documented procedures.

9. RECORD KEEPING & TRANSPARENCY

All transactions, approvals, procurement activities, admissions activities, partnerships, communications, and business dealings must be properly documented, transparent, auditable, reflect genuine business purpose, and follow lawful and approved processes.

False accounting, fake documentation, concealment, manipulated records, or misleading representations are strictly prohibited.

10. WHISTLEBLOWER & REPORTING MECHANISM

Any stakeholder may report suspected bribery, corruption, fraud, financial irregularities, vendor misconduct, recruitment manipulation, admission misconduct, data misuse, ethical violations, or unauthorised financial activity.

Reports may be made to the HR Department, Business Management, Directors, or Ethics or Compliance Authority, if constituted.

Retaliation against individuals reporting concerns in good faith is strictly prohibited.

11. INVESTIGATION RIGHTS

Edvia reserves the right to conduct internal investigations, audit communications, systems, and transactions, review financial and operational records, suspend platform or system access during investigations, seek documentation, clarifications, or evidence, and review institutional, vendor, or stakeholder relationships where concerns arise.

Failure to cooperate with investigations may result in disciplinary, contractual, operational, or legal action.

12. CONSEQUENCES OF VIOLATION

Violation of this policy may result in warning notices, suspension of services or access, platform restrictions, financial recovery proceedings, vendor or partner blacklisting, contract termination, employment termination, legal action, criminal complaint where applicable, and reporting to relevant authorities or institutions.

Serious violations involving fraud, bribery, financial misconduct, fake documentation, or unethical influence may lead to immediate termination of association.

13. STAKEHOLDER RESPONSIBILITY

All individuals and entities associated with Edvia are expected to act ethically and transparently, avoid bribery, corruption, or improper influence, protect confidential information, follow lawful and approved processes, avoid conflicts of interest, report suspicious or unethical conduct, maintain integrity in all dealings with students, institutions, vendors, and partners, and protect the reputation and operational integrity of Edvia.

Failure to comply with this policy may result in disciplinary, contractual, operational, or legal consequences.

14. POLICY REVIEW

This policy may be amended, revised, interpreted, or updated by management at any time based on operational changes, regulatory requirements, business expansion, compliance obligations, technological developments, organisational risk assessment, institutional requirements, or legal requirements.

15. POLICY APPLICABILITY & ACCESS

This policy is published on official company platforms, systems, HRMS tools, and/or websites; applicable to all stakeholders interacting with Edvia; and intended to establish ethical standards across all business relationships, platform activities, admissions processes, and operational dealings.

Any individual or entity engaging with, accessing, using, representing, partnering with, or conducting business with Edvia shall be deemed to have accepted and agreed to comply with this policy.

Edvia reserves the right to interpret, enforce, amend, update, or revise this policy at its discretion based on legal, operational, compliance, institutional, or business requirements.