RAWBIT FOUNDATION

Policy Commitment

All associates of RAWBIT FOUNDATION shall strive to avoid any conflict of interest between the interests of the organization and their respective personal, financial, professional, and business interests.

1. Applicability

This Conflict of Interest Policy is applicable to all employees/staff, volunteers, consultants, trustees, members of the Board of Trustees and members of any committees (collectively referred to as "Associates") of RAWBIT FOUNDATION.

Conflict of interest includes actual conflicts, potential conflicts, and perceived conflicts of interest that may compromise the objectivity and integrity of decision-making processes.

2. Scope

The principles set forth in this Policy are applicable to all Associates of RAWBIT FOUNDATION. It is the responsibility of all Associates and Third Parties to follow and adhere to all elements described in the Policy.

This policy covers all aspects of organizational operations, including but not limited to procurement, hiring, partnerships, financial transactions, and strategic decision-making.

3. Purpose

To provide guidance to conduct/perform with professionalism, integrity, honesty, and moral and ethical standards
To protect the integrity and reputation of the organization's decision-making process
To avoid any actual, potential or perceived conflict between personal interests and organizational interests
To lay principles for undertaking responsibilities with undivided loyalty and without personal conflicts

4. Policy Framework

Conflicts of interest may arise when an Associate places personal interests before the interests of the organization. Such personal interests may exist or appear to exist due to relationships with individuals or entities which can influence or appear to influence objectivity or efficiency.

A. Indicative Scenarios

Situations that may lead to actual, potential or perceived conflict of interest include:

Employment Relations

A Board member related to a staff member when decisions about pay or employment conditions are being made

Financial Interests

Conducting transactions on behalf of the organization with entities in which the Associate holds financial or commercial interest

Gifts & Favors

Accepting gifts, favors, or anything of monetary value from donors or vendors (except unsolicited gifts of nominal value)

Dual Loyalties

Owing fiduciary duties to another entity while engaged in transactions with RAWBIT FOUNDATION

Family Benefits

Participating in evaluation or administration of contracts that directly or indirectly benefit the Associate or their relatives

Ownership Stakes

Holding financial interest or position of influence in entities working with RAWBIT FOUNDATION

Note on Relatives: "Relatives" include spouse, parent, child, sibling, grandparent, grandchild, uncle, aunt, cousin, niece or nephew (including "step" relationships such as step-parent, step-child, step-siblings).

B. Categories of Conflict of Interest

1. Financial Transactions

Any financial arrangement or participation in the business of an actual or potential vendor or service provider
Direct or indirect involvement in organizational operations with vendors/stakeholders
Securities transactions that may place Associate's financial interests against organizational interests

2. Outside Employment & Interest

Employment with another employer that qualifies as conflict of interest
Membership on committee/Board of organizations competing for the same funding
Being privy to information affecting funding allocation to competing organizations
Associates must choose between RAWBIT FOUNDATION and conflicting employment

3. Hiring Relatives

Associates cannot hold direct reporting relationship with relatives
Relatives cannot participate in hiring, evaluation, selection, discipline, or promotion decisions
Hiring managers must ensure all applicants declare information about relatives in the organization
Referred relatives go through normal selection process
Improper to place two relatives in professional affiliation that compromises organizational assets

4. Promotions & Transfers

Provisions of this Policy must be adhered to while transferring or promoting an Associate within the organization to prevent conflicts of interest.

5. Relationship/Fraternization

Associates cannot have relationships with their manager
Associates in relationships cannot have the same reporting Manager

6. Decision Making Process

Associates must disclose any actual or perceived conflict of interest while being part of any decision-making process or team. Whenever an Associate finds themselves in a position of conflict of interest, they must:

Disclose the conflict immediately
Recuse themselves from that process

C. Reporting Mechanism

Reporting Obligations:

Every Associate must promptly report any actual or reasonably suspected violation
All reports will be promptly and thoroughly investigated
Information on Associates reporting violations shall remain confidential
Retaliation against whistleblowers will not be tolerated

Disclosure Requirements:

Upon appointment, each Associate must make full written disclosure of interests
Disclosures must be recorded and updated at least annually
Board members must disclose conflicts at the beginning of each board meeting
All disclosures and subsequent actions will be noted in minutes

Important: This Policy supplements good judgment. Associates should maintain its sanctity and respect both its spirit and wording.

D. Due Diligence of Partners

Partner organizations are covered by their own Conflict of Interest policies
RAWBIT FOUNDATION shall conduct robust due diligence to ensure partners have sufficient policies and systems in place
This Policy forms an integral part of contracts between RAWBIT FOUNDATION and its partners
Partner organizations must ensure strict compliance with this Policy

5. Violations of Policy

An Associate who violates this Conflict of Interest Policy, regardless of whether financial loss to the organization results or not, may receive appropriate disciplinary action up to and including termination.

This shall be in addition to other legal and remedial actions available to the organization under applicable law.

6. Exceptions and Review of Policy

Any deviations from this Policy require approval from the Management Committee
The organization reserves the right to modify and/or review provisions from time to time
Reviews will ensure compliance with applicable legal requirements or internal policies

Conflict of Interest Declaration Form

Annual Declaration Requirements:

All Associates must complete an annual Conflict of Interest Declaration stating:

I do not have any foreseeable conflict of interest related to RAWBIT FOUNDATION functions and operations

I hold a conflict of interest (requires detailed disclosure)

Disclosure Details Required:

Name of party/individual with whom you may have a relationship
Details of your relationship with the party
Relationship of the conflicted party with RAWBIT FOUNDATION
Any other relevant details

Report Conflict of Interest Concerns

Maintain transparency and integrity in all our operations

Email

rawbitfoundation@gmail.com

Contact Number

+91 9172696951

Address

Saibaba Nagar, Wadgaon Road, Yavatmal, Maharashtra, PIN 445001

This policy is reviewed annually and updated as needed.

Version 1.1 | Document Owner: Operations/HR

Last Updated: February 23, 2026

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Conflict of Interest Policy