Anti-Corruption Policy

1. Commitment

Cornwill Realty Corp. ("the Company") maintains a zero-tolerance approach to bribery and corruption in all business dealings and relationships, wherever we operate. We are committed to acting professionally, fairly, and with integrity in all our business relationships and transactions.

This policy reflects our commitment to the highest ethical standards and compliance with the Prevention of Corruption Act, 1988 (as amended), the Companies Act, 2013, and all other applicable anti-bribery and anti-corruption laws.

2. Scope

This policy applies to all individuals working for or on behalf of the Company at all levels, including:

• Directors, officers, and employees (permanent, temporary, and contractual)
• Consultants, contractors, and their personnel
• Agents, intermediaries, and business partners
• Joint venture partners and affiliates
• Any other person or organisation acting on behalf of the Company

3. Prohibited Conduct

The following conduct is strictly prohibited:

• Offering, promising, giving, or accepting any bribe — whether in cash, kind, or any other inducement
• Facilitation payments to government officials or regulatory authorities
• Offering gifts, entertainment, or hospitality intended to influence business outcomes
• Making political contributions on behalf of the Company without prior Board approval
• Charitable donations that could be construed as an attempt to gain business advantage
• Engaging third parties, agents, or intermediaries to perform any act prohibited under this policy

4. Gifts and Hospitality

The Company does not accept or offer gifts, entertainment, or hospitality that could reasonably be perceived as an attempt to influence a business decision. Any gift or hospitality exceeding ₹5,000 in value must be pre-approved by the Compliance Officer and recorded in the Gifts & Hospitality Register.

5. Due Diligence

The Company conducts appropriate due diligence on all business partners, joint venture partners, agents, and contractors. Enhanced due diligence is required for relationships involving government contracts, land acquisition, regulatory approvals, or politically exposed persons.

6. Record Keeping

All financial transactions must be accurately recorded. False or misleading entries in books, records, or accounts are strictly prohibited. Original supporting documentation must be maintained for all payments.

7. Reporting Violations

Any person who suspects a violation of this policy must report it immediately via the Whistle Blower mechanism. Reports may be made in writing to the Compliance Officer at compliance@cornwill.com, or anonymously through the channels described in the Whistle Blower Policy.

The Company will not tolerate any retaliation against any person for reporting concerns in good faith, even if the concern proves to be unfounded.

8. Consequences of Violation

Violations of this policy may result in disciplinary action up to and including termination of employment or contract, and may also result in civil or criminal prosecution under applicable laws.

9. Training

All employees and relevant third parties receive periodic training on this policy and anti-corruption obligations applicable to their roles.

This policy is approved by the Board of Directors of Cornwill Realty Corp.