Code of Conduct v1 PDF

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1. CODE OF CONDUCT
1.1 PREAMBLE:
FINO Payments Bank Ltd. expects all its employees, business coordinators, district
coordinators and officers to act in accordance with high professional and ethical
standards. You must be, and be seen to be, committed to integrity in all aspects of
your activities and comply with all applicable laws, regulations and internal policies.
In accepting a position with FINO Payments Bank Ltd. or any of its subsidiaries, each
of you becomes accountable for compliance with the law, with the FINO Payments
Bank Ltd. code of conduct (‘the Code’), and with policies of your respective business
units.
The standards of the Code are not necessarily prescribed by the regulators - they are
something, which a well-respected institution must have in place and adhere to on an
ongoing basis. We therefore expect a high level of ethical conduct.
You must conduct your duties according to the language and spirit of this Code and
seek to avoid even the appearance of improper behavior. You should be aware that
even well intentioned actions that violate the law or this Code may result in negative
consequences for FINO Payments Bank Ltd. and for the individuals involved.
While covering a wide range of business practices and procedures, these standards
cannot and do not cover every issue that may arise, or every situation where ethical
decisions must be made, but rather set forth key guiding principles that represent
FINO Payments Bank Ltd.’s policy.
1.2 CONFLICT OF INTEREST AND OUTSIDE ACTIVITIES
1.2.1 Conflict Of Interest – general principles

Conflict of interest can occur if our business practices sacrifice interests of one set of
customers in favor of another or place business interests ahead of customers.
Document FINO Payments Bank Ltd. /People Controll Classification Internal

Name Management/HR/HR Department Manual/001 ed Copy
Version No. V2 Date November 1, 2017
©Copyright 2017FINO Payments Bank Ltd.Page3 of 246
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FINO Payments Bank Ltd., 2nd Floor, D 507 TTC Industrial Area, ShriSawan Knowledge IT Park, C/O Nand Kamal
InfotechPvt Ltd., MIDC Turbhe, Navi Mumbai - 400705.
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You would be expected to be sensitive to any activities, interests or relationships that

might interfere with or even appear to interfere with, your ability to act in the best
interests of FINO Payments Bank Ltd. and its customers.
Examples of situations that could involve conflict of interest include:
a) Selling a product that is profitable for FINO Payments Bank Ltd. but not
appropriate for the customer;
b) Ownership, by employees or their family members, of a significant interest in any
outside enterprise, which does or seeks to do business with or is a competitor;
c) Acting as a broker, finder, go-between or otherwise for the benefit of a third party
in transactions involving or potentially involving FINO Payments Bank Ltd. or its
interests;
d) Working, in any capacity, for a competitor, customer, supplier or other third party
while employed by FINO Payments Bank Ltd.;
e) Competing with FINO Payments Bank Ltd. for the purchase or sale of property,
products, services or other interests;
f) Having an interest in a transaction involving FINO Payments Bank Ltd., a
competitor, customer or supplier (other than as an employee, business
coordinator , district coordinator or officer of FINO Payments Bank Ltd. and not
including routine investments in publicly traded companies);
g) Directing business to a supplier owned or managed by, or which employs, a
relative or friend.
1.2.2 Conflict of interest arising out of personal Investments
While undertaking the personal investments, it should be borne in mind that such
investments might not:
Affect or appear to affect your ability to make unbiased business decisions for FINO
Payments Bank Ltd.;
Be contrary to FINO Payments Bank Ltd.’s interests (e.g. using proprietary knowledge
obtained through the course of employment to make investments that are not in the best
interest of FINO Payments Bank Ltd.);

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Be in the businesses of FINO Payments Bank Ltd.’s customers, suppliers, or competitors

that could cause divided loyalty, or even the appearance of divided loyalty.
1.2.3 Conflict of Interest – Dos and Don’ts
Do
Act in the best interests of FINO Payments Bank Ltd. and its customers and handle
activities, interests or relationships in a sensible manner.
Disclose/declare to FINO Payments Bank Ltd. About any employment/position
(honorary/ salaried) or support given to any external entity competing/ not competing
with FINO Business.
Handle Conflict of interest as mentioned above.
Don’t
Undertake personal investments or outside activities that create conflicts of interest
1.3 PRIVACY / CONFIDENTIALITY
1.3.1 Proprietary and Confidential Information
You must always protect the confidentiality of proprietary and confidential information
you obtain or create in connection with your activities for FINO Payments Bank Ltd., in
accordance with the applicable law. Your obligation to protect FINO Payments Bank
Ltd.’s proprietary and confidential information continues even after you leave the
company, and you must return all proprietary information in your possession upon
leaving FINO Payments Bank Ltd.
Proprietary and confidential information include any system, information or process that
gives FINO Payments Bank Ltd. an opportunity to obtain an advantage over competitors;
non-public information about FINO Payments Bank Ltd. businesses, its customers and
its employees, any other non-public information received.
Proprietary and confidential information about FINO Payments Bank Ltd., a customer,
supplier or distributor, should not be disclosed to anyone (including other employees)

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not authorized to receive it or has no need to know the information, unless such
disclosure is authorized by the customer, etc., or by law, appropriate legal process or
appropriate internal authorities.
Intellectual property of FINO Payments Bank Ltd. such as trade secrets, patents,
trademarks and copyrights, as well as business, research and new product plans,
objectives and strategies, records, databases, salary and benefits data, employee
medical information, customer, employee and suppliers lists and any unpublished
financial or pricing information must also be protected.
Unauthorized use or distribution of proprietary information violates the internal policies
and could be illegal. Such use or distribution could result in negative consequences for
both FINO Payments Bank Ltd. and the individuals involved, including potential legal
and disciplinary actions.
Acts of ignorance that could lead to such proprietary information, especially through
electronic means – like CDs etc., may lead to investigation and probe against the
employees.
We, at FINO Payments Bank Ltd., respect the proprietary rights of other companies and
their proprietary information and require you also to observe such rights.
1.3.2 Privacy of Employee Information

At FINO Payments Bank Ltd., we recognize and protect the privacy and confidentiality of
employee medical and personal records. Such records would be shared strictly on need
to know basis or as required by law, rule and regulation or when authorized by the
employee or as per subpoena or court order and requires approval by internal counsel.
1.3.3 Privacy and Confidentiality – Do's and Don’ts
Do
Properly control access to your work areas and computers

Ensure appropriate destruction of business related documents when not required for
work
Obtain any relevant information directly from the person concerned
Protect the physical security of official information

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Access to information or data by outsourced will also be subjected to the relevant

employee’s accountability, in case such data is misuse
Keep customer information secured at all times and uphold FINO Payments Bank Ltd.
Privacy Promise for customers
Limit access to information strictly to those with a legitimate business reason for
seeking that information
Comply with local data protection and privacy laws that affect the collection, use and
transfer of personal customer information
While accessing Intranet and Internet, ensure compliance with internal policies and
procedures
Ensure that worldwide electronic information exchange and dialogue, electronic
business dealings are all as per internal policies and procedures
Do not
Discuss sensitive matters or confidential information in public places

Transfer official information into personal databases or carry hard copies of official
information (otherwise than for official purposes) outside the office, without prior
permission from your superior
Pass information, in any manner, directly or indirectly to any recruitment/search
agencies or to competitor or any other organizations
1.4 GIFTS AND ENTERTAINMENT
1.4.1 Accepting Gifts and entertainment- General Principles
In general, all staff should not accept gifts - anything of value (including entertainment) from
current or prospective customers or suppliers, unless it is in accordance with the Code.
1.4.2 Giving gifts and entertainment - Bribery and corruption

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Bribery/Corruption is defined as the receiving or offering of an undue reward to any

third party.
You must note that FINO Payments Bank Ltd. follows zero tolerance approach
towards Bribery and Corruption.
You must not make any payment to or for anyone for the purpose of obtaining or
retaining business or for obtaining any favorable action. If you are found to be
involved in making such payments, you would be subject to disciplinary action as well
as potential civil or criminal liability for violation of the Code.
You should not offer or give any funds or property as donation to any government
agency or its representatives, in order to obtain any favorable performance of official
duties.
While you are expected to put in best of your efforts in every transaction, you will not
be penalized by FINO Payments Bank Ltd. for delayed performance of a transaction
solely on the grounds of refusal to pay bribes.
1.4.3 Gifts and entertainment – Do's and Don’ts
Do
Accept gifts only if it is in line with the Code and related internal guidelines
Do Not
Make any payment to or for anyone that could tantamount to bribe/corruption
1.5 PROTECTING FINO PAYMENTS BANK LTD.’S ASSETS
Protecting FINO Payments Bank Ltd.’s assets against loss, theft or other misuse is the
responsibility of every employee, business coordinator, district coordinator and officer. Loss,
theft and misuse of FINO Payments Bank Ltd.’s assets directly impact our profitability. Any
suspected loss, misuse or theft should be reported to your supervisor or the Chief Financial
Officer.

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1.5.1 Protecting FINO Payments Bank Ltd.’s Assets – Dos and Dont's
Do
Use FINO Payments Bank Ltd. assets (physical and intellectual) only for official
purposes
Report any misuse by any employee, outsourced or agents of FINO Payments Bank
Ltd. that comes to your notice.
Do not
Copy, sell, use or distribute information, software and other forms of intellectual
property in violation of licenses
Misappropriate FINO Payments Bank Ltd. assets as it is a breach of your duty and
may constitute an act of fraud against FINO Payments Bank Ltd.
Use official resources in another business in which you, a friend or family member is
involved
Use official stationery, supplies, and equipment for personal or political matters.
1.6 WORKPLACE RESPONSIBILITIES
1.6.1 Fair Employment Practices and Diversity
FINO Payments Bank Ltd. is committed to adoption of fair employment practices. It

ensures diversity of workplace through efforts to recruit, develop and retain the most
talented people from a diverse candidate pool. It upholds the principle that
advancement is based on talent and performance and there is a commitment to
equal opportunity.
As a fair employment practice, we expect that you shall not (during the course of your
service or upon cessation of your service for a period of six months from the date of
cessation) directly or indirectly on your own accord or on behalf or in conjunction with
any other person, convey or solicit or attempt to work or induce any employee or

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business associate to leave their current employment with FINO PAYMENTS BANK
LTD. and join the service of any competitor.
1.6.2 Fair Competition
Although it is common to gather information about the general marketplace, including

competitors' products and services, the Company wants to compete fairly.
1.6.3 Drug Free Workplace
You should ensure that your workplace is healthy and productive and free from drugs
1.6.4 Discrimination and Harassment and Intimidation
FINO Payments Bank Ltd. is committed to prohibition of harassment and intimidation

of employees in the workplace. FINO Payments Bank Ltd. discourages conduct that
implies granting or withholding favors or opportunities as a basis for decisions
affecting an individual, in return for that individual’s compliance. Such harassment is
the easier form of harassment to identify because it takes the form of either a threat
or a promise, whether explicit or implied.
FINO Payments Bank Ltd. has a Gender Neutral Policy that prohibits unwelcome
advances, requests for sexual favors, or other verbal or physical conduct where such
conduct has the purpose or effect of unreasonably interfering with an individual’s
work performance or creating an intimidating, hostile or offensive working
environment.
1.6.5 Safety in the Workplace
FINO Payments Bank Ltd. considers safety of employees as the primary concern.
FINO Payments Bank Ltd. is committed to safety of employees and expects its
businesses and employees to comply fully with appropriate laws and internal
regulations.
FINO Payments Bank Ltd. encourages responsible behavior of its employees and
colleagues that result in the best possible accident prevention measures. This
applies both to the technical planning of workplaces, equipment, and processes and
to safety management and personal behavior in everyday workplace.

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Your work environment, therefore, must conform to the requirements of health

oriented safety design and you must constantly be attentive to safety principles.
1.6.6 Fair Treatment of counter-parties
The quality of our relationships with our suppliers and other external counter-parties
often has a direct bearing on the quality of our products, services and ultimately our
customer relationships. We therefore expect our suppliers to operate to the same
standards as we expect of ourselves.
All such relationships with external counter-parties should be conducted in
professional and impartial manner. Vendor selection and hiring decisions must be
made objectively and in best interest of FINO Payments Bank Ltd., based on
evaluation of integrity, suitability, price, delivery of goods/ service, quality and other
pertinent factors. You should commit to fair contract and payment terms with them in
return of good service at a good price supplied in a responsible manner.
Your personal relationship with contractors, suppliers and vendors should be
disclosed to your superior at the time of entering into the transaction and should not
influence decisions made on behalf FINO Payments Bank Ltd. Negotiations with
customers and potential customers should be conducted in a professional manner.
Vendors or suppliers should not be used for any personal purposes, so as to have
any conflict of interest while dealing with them.
1.6.7 Corporate Opportunities
Employees, business coordinators, district coordinators and officers are prohibited

from taking for themselves business opportunities that arise through the use of
corporate property, information or position. No employee, business coordinator,
district coordinator or officer may use corporate property, information or position for
personal gain, and any employee, business coordinator, district coordinator or officer
may compete with FINO Payments Bank Ltd.
Competing with FINO Payments Bank Ltd. may involve engaging in the same line of
business as FINO Payments Bank Ltd., or any situation where the employee, business
coordinator, district coordinator or officer takes away from FINO Payments Bank Ltd.
opportunities for sales or purchases of property, products, services or interests.

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1.6.8 Contact with Media
In order to pro-actively manage our reputation with the media and to ensure
consistency of messages, interaction with media must only occur with the prior
approval of Corporate Communications team.
1.6.9 Workplace responsibilities – Do's and Don’ts
Do
Respect personal dignity, privacy, and personal rights of every individual

Work together with women and men of various nationalities, cultures, religions, and
races in a professional manner
Be open and honest and stand by your responsibility
Treat our customers, suppliers, competitors and employees fairly
Maintain the safe and healthy working environment provided by the company
Be committed to prevent wasteful use of natural resources
Do not
Discriminate, harass or offend anybody by whatever means, be it sexual or otherwise

Use FINO Payments Bank Ltd. systems to transmit or receive electronic images or
text of a sexual nature or containing ethical slurs, racial epithets or other harassing,
offensive or lewd materials
Obtain competitive information by unethical or illegal means, such as corporate
espionage or improper access to confidential information
Engage in contacts with competitors that could create even the appearance of
improper agreements, whether the contact is in person, in writing, by telephone or
through e-mail
Take unfair advantage of anyone through manipulation, concealment, abuse of
privileged information, misrepresentation of material facts or any other unfair dealing
practice
Do not issue directives to violate the terms of vendor’s contracts

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1.7 RAISING ETHICAL ISSUES
FINO Payments Bank Ltd. encourages employees to report to their

supervisor/HR/compliance, concerns and suspected violations of the Code, internal
policies, external legal and regulatory requirements etc. You may choose to remain
anonymous if you wish. All significant breaches should be escalated immediately.
FINO Payments Bank Ltd. will conduct prompt and thorough investigations of alleged
violation and take appropriate corrective action.
Retaliatory action against an employee for making a good faith report is prohibited.
HR takes appropriate actions against individuals who have broken laws, rules and
regulations.
An employee who knowingly violates the internal policies and guidelines shall be
subject to disciplinary action, including demotion or dismissal.
In case of any doubts in undertaking any new role, assignment or responsibilities,
please ensure all dos and don’ts are well understood, so as to avoid pleading
ignorance by overstepping on some protocols.
1.7.1 Investigations
You are required to cooperate fully with authorized internal and external investigations.
Making false (or misleading) statements to regulators/auditors/FINO Payments Bank Ltd.
representatives during investigations can be a criminal act that can result in heavy
penalties.
1.7.2 Raising ethical issues – Dos and Don’ts
Do
Report to your supervisor/HR/compliance, concerns and suspected violations of the

Code, internal policies, external legal and regulatory requirements etc
Do Not

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Knowingly withhold information that raises ethical questions and bring such issues to the
attention of senior management or ensure reporting as per the applicable Whistle Blower
Policy
Destroy records that are potentially relevant to a violation of law or any litigation or any
pending, threatened or foreseeable government investigation or proceeding.
1.8 SPECIAL RESPONSIBILITIES OF SUPERIORS AND MANAGERS
In addition to responsibilities as employees, supervisors and managers must abide by the:
Duty of selection - Carefully select the employees for a job in light of their personal
and professional qualifications. The duty of care increases with the importance of the
obligation to be entrusted to the employee
Duty of instruction - Formulate obligations in a precise, complete, and binding
manner, especially with a view to ensure compliance with provisions of instructions.
Duty of monitoring - Ensure that compliance with provisions of applicable laws /
regulations is monitored on a constant basis (duty of monitoring).
Duty of communication - Communicate to the employees that any violation of the
applicable laws / regulations are disapproved of and would have disciplinary
implications.
1.8.1 Special responsibilities – Do's and Don’ts
Do
Strive to create and sustain an environment that promotes ethical behavior

Assist your staff to understand and apply the internal policies and procedures
Encourage and practice whistle blowing, so as to avoid any doubts later as to an
offence being committed with your knowledge, which could be construed as
connivance by the employee
Do Not

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Issue directives to violate the terms of internal policies/procedures
1.8 Compliance with laws, rules and regulations
It is FINO Payments Bank Ltd.’s Policy to maintain an open and co-operative relationship
with our regulators and to comply with all applicable laws, rules and regulations. The
Company also disseminates information regarding compliance with laws, rules and
regulations that affect business.
Violation of the law must be avoided under any circumstances, especially violations that
attract punishment of imprisonment, monetary penalties, or fines. Notwithstanding the legal
consequences of such violation, any employee found guilty will be additionally liable to
disciplinary actions, initiated by the company for violating the Code.
Particular care should be taken to act legally in those areas where the law is evolving rapidly
or is being extended to cover activities that have not been covered by legal requirements in
the past.
Compliance – Do's and Don’ts

Do
Comply with all applicable laws, rules and regulations

Contact with regulators through designated officials as per internal guidelines
Do Not
Commit an illegal or unethical act, or instruct others to do so, for any reason
Commit such acts simply because you see someone else doing it, or your supervisor
not warning you
1.9 KEY IRREGULARITIES

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While the Company believes that the employees would realize and appreciate the
need to follow this Code in letter and spirit, in an unfortunate incident or act of
breach, corrective and deterrent action becomes unavoidable. Therefore any breach
of the stipulations mentioned in the Code should be treated as misconduct for which
appropriate penalty would be imposed.
Based on the intent, seriousness and mitigating/extenuating circumstances of such
non-compliance the breaches can be broadly classified into four categories as
detailed hereunder.
1.9.1 Habitual Irregularities
Repeated negligence in performing duties, depending on the gravity and

consequences to the Company may fall under this category. Illustrative behavior
includes:
Unpunctual or irregular attendance, leaving workplace without permission, habitual

or prolonged absence without leave
Negligence or failure to take due care while obtaining and preserving
documents/records
Negligence or failure to ensure accuracy and timely completion of work
Indecent/discourteous behavior with customers, employees, superiors etc
Not following the prescribed dress code
Showing an intransigent or unreasonably negative attitude to management and/or
fellow employee’s
Minor breach of health and safety requirements
Smoking in a non-designated area
Careless use of the Company’s equipment or furniture
Refusing to attend nominated training programs unless agreed upon with superior
Use of foul or abusive language (whether verbal or in writing)
Refusing a reasonable request to moderate changes in responsibilities if such a
change is a business necessity
Being under the influence of alcohol and/or drugs not medically prescribed when at
work (whether on FINO Payments Bank Ltd. premises or otherwise)

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Consumption or being under the influence of drugs not medically prescribed and/or
excessive alcohol at a management sponsored event
Indulging in habitual errors, negligence while performing duties
1.9.2 Gross/serious violations
Any act which is in breach of the Code, internal policies/procedures and which may
cause financial loss or reputation risk to the company falls under this category.
Illustrative behavior under this category includes:
Failing to comply with FINO Payments Bank Ltd. policies, procedures, rules and
working practices
Obstructing the customers from dealing with FINO Payments Bank Ltd. or obstructing
other employees from discharging their responsibilities
Engaging in any other trade/business/employment while in the employment of the
company without confirming with your supervisor
Participation in any demonstration against the company or its Officials
Accepting gifts and favors from clients and vendors in violation of relevant guidelines
Disrupting/slowing down of continuous customer service or work, in the branch or
office –either solely or by way of participation in strike, bandhetc
Taking a decision which has financial implications favoring you or any of your team
member or relatives
Involvement in harassment including sexual harassment or racial harassment
Failure to take all possible steps to protect the interest of FINO Payments Bank Ltd.
and to perform duties with utmost integrity, honesty, devotion & diligence
Indulging in any act which is likely to cause damage/loss to the property and which
are prejudicial to the reputation and interest of FINO Payments Bank Ltd.
Failure to act in the best judgment while performing duties as well as while exercising
delegated power entrusted by FINO Payments Bank Ltd.
Failure to avoid indebtedness in any manner while in service
Engaging in and/or facilitating any financial dealing/s including money lending
whatsoever with colleagues
Any act which brings or has the potential to bring disrepute to the image of FINO
Payments Bank Ltd. at all times

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Any other act which is against the ethos/culture of the company
1.9.3 Fraudulent Irregularities
Any act with a fraudulent or malafide intention irrespective of whether there was any
financial loss or loss of reputation of FINO Payments Bank Ltd. falls in this category. Some
illustrative behavior under this category would include:
Suppressing or misrepresentation of facts

Any act of creation/acceptance of fake/incorrect/fraudulent records or manipulation
of records with fraudulent intention i.e. fudging of records, MIS records etc
Failure of due diligence in any deal/transaction to avoid any possibilities of a fraud or
money laundering
Theft or pilferage or any dishonest act
Involvement in any act in the area of corruption, misuse of office, criminal offences,
suspected or actual fraud etc
1.9.4 Irregularities in High Risk Areas
Any act which may not be apparently with fraudulent intention but are considered as
High Risk area irrespective of any financial loss or loss to the reputation of FINO
Payments Bank Ltd. falls in this category. This includes:
Failure to act in spite of having knowledge of wrong things being practiced,
Failure to take corrective steps to stop such wrong practices,
Failure to escalate such matters to higher authorities
The areas considered, as High Risk will be assessed by the Senior Management of
the Company. The Senior Management of the Company will also have the power and
authority to notify the list of High Risk areas from time to time. It must be noted that
irregularities cited in the above categories are indicative in nature and the lists are
not exhaustive.
1.10 DISCIPLINARY PROCEDURES

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1. PURPOSE
This document defines the disciplinary procedure for employee related

misconduct/offence in FINO Payments Bank Ltd. and its group companies.
2. SCOPE
This procedure is pertinent to all on roll & contractual employees, including

trainees/Management Trainees in FINO Payments Bank Ltd. and its group
companies.
3. OBJECTIVES
FINO believes that the majority of our employees accepts the need for standards
of work and behavior and do not find any difficulty in abiding by them. However,
if any employees fails to achieve the required standards of work or conduct,
disciplinary action will be taken in a fair, objective, consistent and reasonable
manner.
4. DEFINITIONS/ABBREVIATIONS
Serial No Acronyms/terms to be defined Definition
1 IC Investigation Committee
2 IR Investigation Report
3 DAC Disciplinary Action Committee
4 DDR Due Diligence Report
5 SCN Show Cause Notice

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5. PROCESS
The procedure is designed to establish the facts quickly and to deal consistently
with disciplinary issues. No disciplinary action will be taken until the matter has
been fully investigated.
When handling employee disciplinary issues, the following guidelines shall be

followed:
¾ Employee related Misconducts are categorized as Minor, Major and
Extreme, which is covered in the Disciplinary Procedure
¾ An issue or misconduct can be reported by an employee or business or
ombudsperson
¾ Every Misconduct/violation should be highlighted to Disciplinary Action
Committee (DAC) members or to [email protected]
¾ DAC comprises of Risk / HR / Legal / Business representatives, members
of committee are:
¾ Risk - K Hari [email protected]
¾ HR - Anila [email protected]
¾ Business –Vipr Bhardwaj [email protected]
Amit Jain [email protected]
Anurag Jain [email protected]
Darpan Anand [email protected]
Note: Business Representative in DAC members will hold less weightage in the
final decision for a case in their own vertical.
¾ Minor Misconducts, DAC shall advice corrective/punitive action specified

in the Minor Misconduct grid
¾ Major and Extreme Misconducts, DAC shall initiate investigation thru
independent Investigation Committee (IC)
¾ IC shall investigate and submit, Investigation Report (IR) / Due Diligence
Report (DDR), to DAC

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¾ DAC will analyze and discuss the findings; and recommend action. In case
of Extreme Misconduct, may forward recommendation to Management
and seek guidance
¾ HR shall execute action according to Disciplinary Action Committee
recommendation
¾ The corrective/punitive action for Minor, Major and Extreme misconducts
shall be executed as per the Misconduct grid
¾ Case history with complete documentation, confessions, action taken/
not taken, guilty / not guilty, decision process & verdict; will be filed
appropriately/confidentially for reference at later stage, whenever needed
Disciplinary Procedure - Misconduct Grid (refer Annexure VII)

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6. PROCESS FLOW

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7. WORK RULES:
¾ At every stage employees will have the opportunity to state their case.
¾ An employee has the right to appeal against any disciplinary penalty.
¾ Employees on the “Written Warning stage” stands automatically
disqualified for any promotion or transfer opportunity upto 1 year after the
date of the written warning.
¾ During the course of enquiry, to undertake unbiased/uninterrupted
investigation;if needed, the employee may be suspended, and may be
prohibited from entering office premises. All endeavors shall be made to
conclude the enquiry within three months.
¾ On conclusion of enquiry, if employee is found not guilty he shall be
entitled to be reinstated to employment as Active.
1.11 COMPLIANCE WITH THE CODE
FINO Payments Bank Ltd. recognizes the need for this Code to be applied equally to
everyone it covers. All employees, business coordinators, district coordinators and
officers are expected to comply with all of the provisions of this Code. The Code will
be strictly enforced and violations will be dealt with immediately, including subjecting
persons to corrective and/or disciplinary action such as dismissal or removal from
office.
FINO Payments Bank Ltd. encourages all employees, business coordinators, district
coordinators and officers to report any suspected violations promptly and intends to
thoroughly investigate any good faith reports of violations. FINO Payments Bank Ltd.
will not tolerate any kind of retaliation for reports or complaints regarding misconduct
that were made in good faith. Open communication of issues and concerns by all
employees, business coordinators, district coordinators and officers without fear of

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retribution or retaliation is vital to the successful implementation of this Code. You

are required to cooperate in internal investigations of misconduct and unethical
behavior.
1.12 BUSINESS ATTIRE POLICY
1.12.1 Formal Dress Code
112.1.1. Purpose:
Maintaining a professional, businesslike appearance is very important to the success and

image of the Organization
All employees are expected, at all times to present a professional, businesslike image to
customers, stakeholders and general public. Thus, it is important for all employees to be
dressed appropriately and present a well groomed appearance at the office every day as this
impinges on the reputation of the organization.
1.12.1.2. Scope:
All employees of FINO Payments Bank Ltd. shall comply with the attire outlined in the policy.
1.12.1.3. Dress and Grooming Guidelines:
Caring for one’s personal appearance, hygiene and clothing; looking neat and smart may be
termed as Grooming.
1.12.1.3 Dress Code for Men: Formal
Formal Shirts
x Can be full or half sleeves. Should be tucked in

x Preferable colors: white, off white, pale, blue.
Trousers
x Dark colored trousers with or without pleats are preferred.

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Ties (When worn during Business Meetings)
x Choose a traditional silk tie that should co-ordinate with your attire
x The knot should be a perfect triangle.
Socks
x Color should co-ordinate with trousers (usually black, dark gray, dark brown, or dark
blue)
Shoes
x A good pair of leather shoes- black and brown/ tan shoe. Must be polished everyday.
Belt
x Formal belts with a sleek buckle.
Watch
x Formal belts leather strapped watches are preferred.

x If you wish to wear a metal strapped watch, make sure it fits the wrist properly.
What not to wear
x Shirts with thick stripes and checks

x Ties with images and designer logos
x White socks
x Shoes that look casual
x Shoes with worn out heels
x Belts with logos on the buckles
1.12.1.4 Formal Dress Code: Women
x Women can wear SalwarKameez, Sarees and Formal Shirts/ Trousers

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Shoes:
x Black Brown Shoes

x Small/ Flat Heels
Accessories:
x Studs or small rings as earrings

x Simple and small rings and chains
What not to wear:
x Plunging necklines and tight fitting clothes

x Colorful high heels and sandals
x Hoops and dangling earrings
x Ornamental/ Heavy jewelry
x
1.12.2 Casual Dress Code:
1.12.2.1Objective:
To build a comfortable work environment for the Employees on the last working day of the
Week.
1.12.2.2 Scope
All the corporate Employees/ consultants as well as Field employees are covered under this
Policy.
1.12.2.3 Applicability:
Employees can come in Casual Dress on last working day of the week, i.e.:
x 1st , 3rd& 5th Saturdays

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x Friday if Saturday is not Working

x Paid Holiday/ weekly offs if the employees want to work from Office.
On all other working Days, Dress Code Policy will be applicable.
1.12.2.4 Exceptions:
In case of Client/external meetings, employees have to be dressed in Proper Formals or

Business Casuals whichever is appropriate. Employees are not allowed to be dressed in
casuals in that case.
1.12.2.5 Definitions
Dress Code: A dress code is a set of rules governing a certain combination of clothing.
Formals: Worn in case of Business meetings and other business outings.
Business Casuals: Attire in Offices for a professional Environment.
Smart Casuals: Decent casual dresses that are worn outside.
1.12.2.6 Casual Dress Code for Men
Acceptable Attire includes the following:
Jeans
x Neutral shade trousers

x Denims
x Caudroy Trousers
Shirt:

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x Casual Shirt – short

x Casual Shirt – long tucked in
x Plain T-shirt (neutral colors)- preferably with collar
x Short Kurta
Jacket:
x Cotton/ Leather Jackets

x Full sleeves/ Half Sleeves plain Pullover/ Sweaters in Winters
Shoes
What not to Wear
x Sleeveless Shirts/ T- shirts

x Shirt/ T- shirts with Graffiti
x Red/ Green/ Orange colored trousers
x Shorts
x Capris
x Floaters
x Sleepers
x Belts with heavy buckle
x Heavy chains and Earrings
1.12.2.7 Casual Dress Code for Women
What to wear
Shirt:

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x Casual Shirt
x Casual plain T-Shirt
x Kurtis
Trousers:
x Denims- (Neutral Color)

x Trousers (Neutral Color)
Accessories:
x Studs or small rings as Earrings

x Simple and small rings and chain.
7.4 Shoes:
x Heels/ Flats
x Sport Shoes/ Sandals
What not to wear
x Short Shirts/ T- shirts

x Plunging neck lines and tight fitting clothes
x Hoops or dangling earrings
x Ornamental/ heavy jewelry
x Short Skirts
x Capris

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Note: The aforesaid List is illustrative and not exhaustive. However, the ‘what not to wear’
category is mandatory. Any dress must not be in contravention of the prevailing social
norms.
1.13 EMPLOYEE COMPLAINT RESOLUTION POLICY
1.13.1 POLICY OBJECTIVE
Employee Complaint Resolution Policy has been designed to establish a no threat

platform for employee(s) to raise their validated work-related complaints against another
employee or group of employees or an entity in work engagement with the Organization
(here referred to as Party) irrespective of the level or position the party is at. The policy
enables discussions between the aggrieved employee(s) (here referred to as
complainant) & the other party as well as provisions for corrective action taking, in case
required.
1.13.2 SCOPE
x All employees of FINO*.

x The policy covers scenarios such as:
¾ An employee registering a complaint against another employee or group of
employees.
¾ An employee or group of employees registering a complaint against an external
party in a workrelated engagement with the Organization.
¾ Group of employees registering a complaint against an employee or another group
of employees.
¾ An employee registering a complaint against his/her reporting manager or next
level manager.
x Complaints could include, but are not limited to, subjects such as day to day issues
(i.e. employeedifferences, arguments, dispute, and alleged non-cooperation),
discipline (including discharge fromservices), promotion, policy interpretation, benefit
administration, transfers, officeaccommodations, appraisal related etc.
x Registered complaints shall be dealt in through any of the following policies based on
the type of complaint:

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Type of complaint Related Policy
Whistle Blower Policy

Pertaining to violation of Code of Conduct or
any
of its clauses
Gender Neutral Policy
Pertaining to Harassment
Employee Complaint Resolution
Pertaining to unfair treatment regarding a Policy
work related subject, or a provision in the
Organization’s Policy
1.13.3 POLICY STATEMENT
FINO is committed to foster a fair & open work environment whereby an aggrieved
employee could register a validated complaint against another party, in pursuit of
initiation of a corrective action, if so established.
1.13.4 PROCEDURE
The following four-step complaint resolution procedure will apply to a complaint. The
Reporting
Manager, Next Level Manager & Human Resources Manager will be involved in
investigation of the complaint, unless the complaint is against any of these parties. If the
complaint is against any of these parties, the complainant may approach their respective
Next Level Managers.
The organization intends to resolve complaints promptly under most typical business
situations, however there could be scenarios where timelines could be extended
depending on the criticality/ complexity of the situation, to ensure a thorough
investigation. The complainant will be kept informed of the expected timelines for
closure.

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STEP 1: SUBMISSION OF A COMPLAINT
x Complainant shall report the matter via Email to his/ her Reporting Manager (or as
applicable) as early as possible (preferably within 10 days) of occurrence of the
alleged incident or the date s/he becomes aware of it.
x Based on the type of complaint the related policy will come into act.
STEP 2: INVESTIGATION OF A COMPLAINT
x Post receiving the complaint, the Reporting Manager/ Next Level Manager is
required to investigate the matter & based on the complaint will initiate
appropriate action.
x In case the complaint is pertaining to day to day issues the Reporting Manager/
Next Level Manager will encourage discussion between the complainant & the
other party to be able to resolve it amicably. The Reporting Manager/ Next Level
Manager is required to monitor the situation for closure.
x In case the complaint is pertaining to other critical issues as defined in Clause 2;
theReporting Manager/ Next Level Manager will be required to investigate the
case & seek more information orevidence from the complainant, if so required.
x The Reporting Manager/ Next Level Manager will be required to provide a
response to the complainant within two (2) working days of the receipt of the
complaint.
x If the complainant is not satisfied with the response from the Reporting Manager/
Next Level Manager, s/he may appeal that decision by expressing the complaint,
in writing, to the Next Level Manager within two (2) working days.
x The Next Level Manager will be required to further probe in tandem with the
ReportingManager to identify an appropriate solution to the complaint &
communicate the same to the employee within two (2) working days of the receipt
of the complaint.
x If the issue still persists the complainant may write to the Human Resources
Manager. Theconcerned Human Resources Manager in tandem with the Reporting
Manager & Next LevelManager will investigate the complaint and provide a written
response within two (2) workingdays of receiving the written complaint.
x The Reporting Manager/ complainantmay involve the Next Level Manager and
Human ResourcesManager at any point of time in the investigation process, to
deliberate on an appropriate solution/ action to the complaint.

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x Business Unit Head could be involved based on the severity of the case or as the
need arises
STEP 3: APPROPRIATE CLOSURE OF THE COMPLAINT AND RECORD KEEPING
x The final & binding decision shall be communicated to the employee in writing by
Reporting Manager/ Next Level manager or Human Resources Manager. The
written response will include an explanation for the decision taken.
x A copy of the registered complaint & action taken will be recorded in the
personal file of the complainant & the party against whom the complaint was
made; by Human Resources Department.
STEP 4: CORRECTIVE ACTION
x Based on the output of the investigation, appropriate corrective action shall be

taken.
x If the incident as per the complaint is established, the party against which the
complaint has been lodged shall be subject to verbal, written warning or a
disciplinary action leading up to termination of services.
x In case, it is so concluded that the complaint made is malafide and is a false
accusation or is an abuse of process, then appropriate action against the
complainant will be taken.
1.14EQUAL OPPORTUNITY AND NON-DISCRIMINATIONPOLICY
1.14.1 OBJECTIVE
The policy intends to establish equal opportunity & non discrimination practices
1.14.2 SCOPE AND ELIGIBILITY

The policy applies to all employees atFINO*, across all divisions and locations in India

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1.14.3 POLICY STATEMENT
“It is the policy of the Organization not to discriminate any employee or job applicant
based on caste, creed, race, color, religion, gender, age, LGBT (gay, bisexual, lesbian, or
transgender), national origin, pregnancy, marital status, family status, different ability,
HIV status, veteran status, or any other class protected by locallaws, but to base
decisions on employment as to further the principle of equal employment opportunity.”
All decisions or actions such as compensation, benefits, transfers, layoffs, returns from
layoff, organization-sponsored training, growth opportunities and social and recreation
programs will be administered without regard to race, color, religion, gender, age,
national origin,pregnancy, marital status, family status or disability, or veteran status, or
any other class protected by local laws.
The Organization prohibits discrimination against qualified differently abled individuals.

Qualified differently bled individuals are those who meet the skill, experience, education
or other employment requirements for the position being sought or held and can perform
the essential functions of the job they hold or desire, with or without reasonable
accommodations. Accommodations will be implemented in consultation with the
employee involved, and a medical examination by designated medical practitioner or
other evaluation as may be necessary to identify an appropriate and reasonable
accommodation. Any employee seeking an accommodation of his or her disability should
submit a written request to the Human Resources Department , complete with any
supporting medical documentation, and the Organization will endeavor to resolve the
accommodation request as promptly as possible.
The Equal Employment and Non-Discrimination Policy is an integral part of Code of

Conduct. Employees who experience or witness treatment or behaviour that is
inconsistent with these fair employment practices are encouraged to report such
incidents under the Employee Complaint Resolution Policy or the Whistle Blower Policy.
Victimization or harassment of any employee who reports any issue or cooperates with
an investigation will not be tolerated.

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14.1.4 FAMILY EMPLOYMENT
The Organization does not encourage the employment of any individual related to
another employee, if the related employee’s job creates actual or perceived issues of
favoritism, conflict of interest, internal control weakness, or workplace distraction, or
could interfere with the Organization’s ability to obtain conformity bonding or achieve
satisfactory regulatory or audit ratings. For purposes of this policy, related persons are
family members including husband, wife, son, daughter, mother, father, mother-in-law,
father-in-law, aunt, uncle, cousin, niece, nephew and equivalent related parties. All job
applicants are required to disclose such information to Human Resources Department at
the time of employment application, or when such relationship occurs as a result of
marriage. Failure to disclose such information may lead to termination of the concerned
employees. It is the responsibility of the Human Resources Representative to obtain such
information at the time of joining.
All employees are required to comply at all times with the letter and spirit of this policy of
no discrimination.
1.15 GUIDELINES FOR CONDUCTING INTERNAL MEETINGS
1.15.1 OBJECTIVE
Meetings are a core element of the decision making process. They are essential for,
planning, information sharing, strategizing, resolving problems and making informed
decisions. This document establishes guidelines for conducting internal meetings in the
Organization.
The guidelines apply to all employees at FINO*, across all divisions and locations in
India.
1.15.3 GUIDELINES
A) GUIDELINES FOR CONDUCTING MEETINGS – INDIVIDUAL & GROUP

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FOR THE FACILITATOR
x Have a clearly understood and agreed-upon objective for the meeting

x Have the agenda available to all the attendees before the meeting.
Mention it within the calendar invite for the meeting
x Be clear about who should attend the meeting:
1) Those who can contribute to the meeting’s objective
2) Key stake holders, decision making authorities and task executors
x Define roles of attendees in writing wherever required
1) Who facilitates?
2) Who records?
3) Who prepares?
x Send the calendar invite to all the attendee(s) sufficiently in advance, for
them to plan their time accordingly. (Refer: Annexure - Meeting Invite
Template)
x The invite should specify the following aspects:
1) Date
2) Time (start time- end time)
3) Venue (room/ conference number/ bridge number with participant
code)
4) Agenda
5) Mandatory attendees
6) Optional attendees
7) Setting a reminder alert prior to the commencement of the meeting
8) Important information that would be required for the meeting
9) Share necessary reference documents or presentations well in
advance of the meeting to enable the attendees plan and prepare the
items for discussion.
x Avoid last minute changes to time / venue / agenda, unless absolutely
necessary.
x Set up and test the enabling equipments before the scheduled time to
avoid any technical issues that may cause a delay.
x Consider various ways like flipcharts, whiteboards, overheads,
presentations for sharing information during the meeting:
x Punctuality is a must. Keeping people waiting is waste of productive hours.
x Stick to the time schedule of the meeting.

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x At the commencement of the meeting, state the decorum rules of the

meeting (viz. putting mobiles to silent ringtones on) and restate the
agenda.
x Use participative decision-making techniques during meetings. (viz. voting,
consensus). Clearly define the decisions made & establish the need for
follow-up.
x Practice, promote & expect accountability.
x Practice yourself & encourage attendees to listen intently to others during
the meeting.
x Create a feeling of openness. Generate spaces that encourage both ways
communication.
x Be polite and pay attention.
x If your meeting goes beyond 90 minutes, have a 5 to 10 minute refresher
break. Be firm about resuming at the end of the break.
x Document the feedback from attendees in the meeting feedback
document. (Refer: Annexure Meeting Feedback Template)
x Document Minutes of Meeting (MOM) & circulate it to all attendees &
absentees post the meeting for people to refer to & act upon accordingly.
FOR THE ATTENDES
x Response to the meeting invite is a must.

x Respond to the meeting invite timely to facilitate better planning. Honour
the accepted meeting invite.
x In case you are not able to attend the meeting, due to unavoidable
circumstances, inform the facilitator prior to the meeting
x If you are arriving late or required to leave early seek facilitator’s
permission prior to the commencement of the meeting.
x Complete all the pre-work and come prepared for the meeting. Follow the
rules set for the meeting.
x Do not start the meeting late or run over the communicated end time as
this indicates a lack of respect for other's time.
x Do not hold separate conversations during meeting discussion or
presentations. Having multiple conversations is not only rude, but it can be
both confusing and distracting for other attendees.

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x All the attendees of the meeting should consciously refocus from time to
time from tangential conversation to help meeting stay on track and
ensure meeting is effective.
B) MEETINGS THROUGH TELECONFERENCING

x Inform all attendees in advance via email about the date, time, dial-in-number,
password andmost importantly, the agenda.
x To ensure better productivity, set a time limit for the call.
x Be punctual.
x Set up test the enabling equipments before the scheduled time to avoid any
technical issues thatmay cause a delay. Preferably use landlines.
x Introduce attendees & re-establish the agenda.
x If there are multiple attendees at the same location, use ‘mute’ until you wish to
speak.
x Don't interrupt the other participant while she/he is speaking.
x While placing a call on hold, inform the call participant about the same.
x As there are no visual cues in teleconferencing, try to give strong audio clues like
introducingyourself before responding and pausing logically. Direct the questions
to specific individualsinstead of groups, hence saving time as they try to work out
who should field them.
x When working on cross-border deals with people who speak in different accent,
use simplelanguage, speak slowly, and allow them longer time to respond.
x If you are the facilitator, declare the meeting officially closed when the agenda is
complete. This ensures that the attendees are not still engaged. In case the time
over runs, either plan anothercall or stay in touch via email.
x The facilitator is the last person to disconnect the call post the meeting finishes.
C) MEETINGS THROUGH VIDEOCONFERENCING

x Make sure you have the IP address of the site you want to call.
x Set your camera pre-sets before you start the call.
x Use the "mute" button on the remote control when the remote attendees are
speaking, and resume when you wish to speak.

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x Avoid "dual sided talking"; allow the other site/person to finish speaking before
you speak. Dual talking may cause audio disturbances resulting in echo from the
audio bridge.
x Set up and test the enabling equipment before the scheduled time to avoid
technical issues.
x Place the microphone on the table in front of the people in the meeting. Mute the
microphone before moving it during a meeting.
x Speak in your normal voice. Ask the people at the other site if you are clear and
audible.
x Since the audio has a slight transmission delay, you may want to pause briefly for
others to answer you or to make comments.
x As with any meeting, try to limit off track conversations.
x For a smoother broadcast, make sure your presentation is in a ready shape. Test it
before you start the call.
a. CONDUCT DURING MEEETINGS

x Do make sure you have a clear purpose for the meeting and stick to it during
discussions.
x Your purpose should be to remain focused on the agenda and not get digressed
with tangent and off-beat thoughts.
x Do make sure that everyone is comfortable and is allowed to contribute freely to
the meeting.
x Be firm but polite while putting your thoughts across the table.
x Don't be critical or judgmental of ideas presented during brainstorming.
x All ideas should be captured and documented by the facilitator.
b. CLOSING OF THE MEETING

x Send Minutes of Meetings (MOM) to all attendees & absentees.
x Prioritize any next steps in reference to the topic of discussion in the meeting.
x Establish through group consensus or personal agreement what happens next and
who does what. Set parameters for accountability. Assign tasks and time limits.
x Highlight the meeting’s accomplishments and the roles of the attendees. If they
feel they and their time were valued, they are more likely to attend and work well
together again.
x Ensure whiteboard have been cleared post the meeting.

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x Ensure table is left clean for the next group. All stationery to be cleared. Paper
cups if any to be thrown into the dustbin
x Ensure enabling equipments (TV, projector, VC equipment) are switched off or put
on standby mode as instructed.
x Ensure all lights are switched off.
c. MINUTES OF MEETING
x Minutes of Meeting (MOM) are historical record of the discussions and progress of
the meeting.
x MOMs act as reminder of what happened in the previous meeting as well as a
record of accountability of the attendees.
x The meeting facilitator or an assigned convener should capture the details of the
meeting & generate MOM after the meeting is over & send it all the attendees.
MOM should be used as a reference document in the following meetings.
x The meeting facilitator should follow up with the attendees; in case tasks have
been assigned to them for completion; before the next meeting is scheduled.
x The meeting facilitator should raise an alarm; in case the attendees have not been
able to accomplish the task assigned to them.
d. EFFECTIVENESS OF MEETING
x It is important to conduct the meetings as per the defined guidelines to make the
meeting more effective.
x During the meeting the facilitator should periodically check with the attendees on
how they feel about the meeting progress.
x At the end of the meeting the meeting facilitator should take feedback from the
attendees.
1.16 HIV/ AIDS WORKPLACE POLICY
1.16.1 OBJECTIVE
The Organization has adopted a policy on non-discrimination against individuals those
are infected &affected by HIV/ AIDS.

The policy applies to all employees at FINO*, across all divisions and locations in India.

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1.16.3 POLICY GUIDELINES

x FINO is committed to fair, sound and non-discriminatory employment practices.
x HIV testing shall not form part of the recruitment and selection process.
x No employee shall be required to undergo HIV testing, unless undertaken with the
informed and explicit consent of the employee and with the objective being to assist
the employee in obtaining the appropriate support and care (counselling)/ Medical
help.
x Under no circumstances will employees be obliged to disclose their HIV status.
x Employees who develop, choose to disclose, or are diagnosed as HIV/AIDS positive
shall not be prejudiced, victimized or discriminated against on account of their medical
condition or status.
x The compulsory conditions of service, including pension/provident funds, medical aid,
stated benefits, annual leaves & others shall continue, as amended from time to time.
x Employees living with HIV/AIDS will be extended the same rights and obligations as all
other employees.
x All medical information regarding employees with HIV/AIDS will be kept strictly
confidential, except where required by law to be disclosed to specified people or/ with
the consent of the employee.
x The Organization will enable the employee with HIV related illness to work as long as
they aremedically fit to perform their assigned duties.
1.17 PERSONAL RELATIONSHIPS AT WORK POLICY
1.17.1 POLICY OBJECTIVE

To ensure that personal relationships at work do not interfere with work performance of
either individual or with effective functioning of the workplace. This policy also assists the
Internal Complaints Committee and the Steering Committeein taking appropriate action in
case of harassment at workplace.
1.17.2 SCOPE
All employees of FINO*.

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1.17.3 GUIDELINES
x An employee must declare to FINO (via email on [email protected]) any
personal relationship that could involve a potential conflict of interest for the employee
or otherwise conflict with the employee’s responsibilities at work.
x FINO will act upon such a declaration to ensure that any potential conflict of interest is
avoided and to ensure that the employee’s growth in the organization is not
compromised.
x Romantic or sexual relationships between staff members where one individual has
influence or control over the other’s conditions of employment are inappropriate. These
relationships, even if consensual, may ultimately result in conflict or difficulties in the
workplace. If such relationships exist or develops, it must be disclosed.
x An employee who does not declare a personal relationship at work in accordance with
the requirements of this policy will be subject to appropriate action in accordance with
FINO’s Disciplinary Procedure.
1.18 TOBACCO, ALCOHOL & DRUG FREE POLICY
1.18.1 OBJECTIVE
FINO* has adopted Tobacco, Alcohol and Drug Free Workplace policy, for promoting
wellness of employees & visitors

The policy applies to all employees, individuals in office premises & visitors at FINO,
across all divisions and locations in India
1.18.3 GUIDELINES
x FINO is a tobacco-free, alcohol free & drug free workplace. It is impermissible to
consume, be under the influence of or to store such items in the work stations or
display in the office premises as well as any such location where the employee is
located for work related reasons.
x It is prohibited to consume any form of tobacco (viz. cigarette or chewing tobacco) in
the office premises except in designated outdoor areas that the Organization or
building management, at its discretion, may establish as smoking areas.

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x FINO expressly prohibits use of drug, alcohol or any intoxicant substance in the office
premises or outside- during official work as well as in any company provided vehicles.
Disciplinary action shall be initiated against the individual, if found:
a) Being under the influence of alcohol, an intoxicant, an illegal drug, narcotic within
office premises or any other work-related location.
b) possessing, circulating, selling, dispensing, giving &/or purchasing alcohol, illegal
drugs orsources of illegal drugs, intoxicants, or narcotics to other employees or to
any other individualassociated with the organization or otherwise.
x FINO may, at its discretion, initiate drug screening for an individual at any time, in
casehis/her behavior appears to indicate drug or alcohol use in violation of the policy.
x FINO shall not be responsible for; neither will extend support or help to any
individualwho falls in an adverse situation under the influence of alcohol, drugs or any
intoxicant substance outside the office premises, beyond the office hours.
x All individuals covered in the policy shall also be governed by clients’, customers’,
partners’ similar established policies at their work locations. In absence of any such
published or communicated policy, this policy shall govern.
x Any individual being aware of an act of violation of the policy by another individual or a
group of individuals may inform the Ombudsperson under Whistle Blower Policy.
x Violation of the policy shall lead to initiation of disciplinary action leading up to
termination of services.
1.19 CONFLICT POLICY
The provisions of the Policy manual shall prevail if there is any conflict between any
provisions of the Policy manual and any other document, including any service contract.
2. GENDER NEUTRAL POLICY

1 BACKGROUND
FINO* believes that diversity is critical to its success. We seek to recruit, develop, and
retain talented people from diverse background, and every employee can advance at the
Company, based on her or his talent and performance and without regard for race or
colour, national or ethnic origin, age, disability, sex, sexual orientation, marital status,

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family status, religious belief, political opinion and/or involvement in the activities of a
union.
We are fully committed to equal employment opportunity and compliance with the letter
and spirit of the full range of fair employment practices and non-discrimination laws.
2 OBJECTIVE
The objective of this policy is to have a work environment that is free from all forms of
discrimination and harassment for all employees. FINO endeavors to ensure a safe,
secure and congenial work environment, so that employees can deliver their best without
any inhibition.
In that context, where a considerable percentage of the workforce is women, the need
was felt to spread awareness to prevent gender related harassment or discrimination,
and in event of such occurrence, provide recourse to the concerned individual.
PPLICABILITY
This policy applies to all allegations of sexual harassment made by an aggrieved person
against an employee of FINO irrespective of whether sexual harassment is alleged to
have taken place within or outside the organization premises. This Policy is also
applicable to all individuals who are on the organizations premises or on any other
property where the organization conducts its business
3 DEFINITIONS
a. Aggrieved personmeansanyemployee who alleges to have been subjected to any act
of sexual harassment by the respondent employed with FINO
b. Employeemeans employees at FINO and employees ofits subsidiaries. Employees
would include a person employed with FINO forany work on regular, temporary or ad
hoc basis, either directly or through agent, including a contractor, whether for
remuneration or not, or working on a voluntary basis or otherwise, whether the terms
of the employment are express or implied and includes a co-worker, a contract
worker
c. ICC means an Internal Complaints Committee that has been constituted to take up
and enquire into cases of sexual harassment and gender discrimination
d. Member means a Member of Internal Complaints Committee

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e. Presiding Officermeans Chairperson of Internal Complaints Committee

f. Respondentmeans person against whom the aggrieved person has made a
complaint
“Sexual harassment” includes any unwelcome, sexually determined behaviour, direct or

indirect, physical contact and advances, a demand or request for sexual favours,
sexually coloured remarks, showing pornography, any other unwelcome physical, verbal
or non-verbal conduct of a sexual nature. When any of these acts are committed in
circumstances where the victim of such conduct has a reasonable apprehension that in
relation to the victim’s employment or work, such conduct can be humiliating or may
constitute a health and safety problem, it will amount to sexual harassment. It may be
discriminatory when a woman/man has reasonable grounds to believe that her/his
objection would disadvantage her/him in connection with her/his employment, including
her/his recruitment or promotion, or when it creates a hostile work environment.
Sexual harassment may interfere with an individual’s performance by creating an
intimidating, hostile or offensive environment, which might occur as a single incident or a
series of incidents and may include, but would not be confined to the following:
1 Unwelcome sexual advances, whether by physical contact or otherwise, requests for
sexual favours, and verbal or physical conduct of a sexual nature whether explicit or
implicit in nature, made in return for a condition of instruction, employment,
participation or evaluation of a person’s engagement in any organization’s activity, or
otherwise in the course of employment:
a. Verbal, non-verbal, or physical conduct such as sexually coloured remarks or
jokes, letters, phone calls or e-mail, offensive hand or body gestures, showing of
pornography or other visual displays of degrading sexual images, lurid stares,
physical contact or molestation, stalking, sounds, display of pictures, signs, verbal or
non-verbal communication which offends the individuals sensibilities and affect
her/his performance;
b. Unwelcome physical contact such as patting, pinching, touching or putting an
arm around another person, unwanted declarations of affection, stalking or

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molestation or any quid pro quo behaviour such as seeking sexual favours in return
for promotion or benefits in employment;
c.Any form of sexual assault is committed where a person uses the body or any part of
it or any object as an extension of the body in relation to another person; and
d. Any such conduct as defined in (a) to (c) above is committed by a third party or
outsider in relation to an employee of the FINO or vice versa on the premises of the
Firm.
2 Sexual harassment may be of two kinds: hostile work environment and an attitude of
quid pro quo. It would include anyone or more of the following:
a. Hostile work environment constitutes sexual harassment directed towards an
individual because of gender and has a purpose or effect of: (i) creating an
intimidating, hostile, or offensive work environment, or (ii) unreasonable interfering
with another’s work performance. Generally, this includes sexually coloured or
derogatory remarks, showing pornography, any conduct which is not welcome and
could be deemed as being humiliating in the circumstances.
b. Sexual harassment by one in a position of power or influence constitutes quid pro
quo sexual harassment when: (i) submission by an individual is made either an
explicit or implicit term or condition of employment, or (ii) submission to or rejection
of such conduct is used as the basis for employment decisions affecting that
employee such as promotions, salary raises, etc.
c. Sexual harassment would also include anyone or more of the following unwelcome
acts or behaviour (whether directly or by implication) namely:
(i) physical contact and advances; or
(ii) a demand or request for sexual favours; or
(iii) making sexually coloured remarks; or
(iv) showing pornography or other visual display of degrading sexual images, lurid
stares, derogatory remarks, or sounds which would be intimidating and/or
humiliating; or

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(v) any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
4 COMPLAINTS MECHANISM
1.1 INTERNAL COMPLAINTS COMMITTEE
The Internal Complaints Committee has been constituted to take up and enquire
into cases of sexual harassment and gender discrimination. The Presiding Officer
and every ‘Member’ of the Internal Committee shall hold office for such period, not
exceeding three years, from the date of their nomination as may be specified by the
Steering committee . The committee members are as follows:
1. Tripali Mandape – Chairperson (Presiding Officer as per the act)

AVP-Product & Marketing
Phone: 9167202752
E-mail: [email protected]
2. Garima Kaushik- Secretary

VP -Digital & Innovation Group
Phone: 9811832371
E-mail:[email protected]
3. Dipti Ashok Nadkarni-Member

AVP -Alliances
Phone: 9167252914

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4. K. Harikrishnan-Member
SVP-Risk, Compliance & customer grievances
Phone: 9833108730
5. Shalini Rajani—Member
VP-Channel Training
Phone: 9711995815
6. Ashish Ahuja—Member
EVP- Products & Marketing
Phone: 9167202722
7. Darpan Anand—Member
SVP- Channel
Phone:9811766622
Email:[email protected]
8. Amit Jain — Member

EVP- Corporate Business

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Phone:9769012001
Email: [email protected]
9. NGO/ Third party Member
STEERING COMMITTEE
The Steering Committee has been constituted to objectively review the facts and
recommendations of the ICC in any case of sexual harassment or gender discrimination,
and decide as to the appropriate course of action for dealing with the same.
The members are:
1. MD & CEO
2. COO
3. Head HR
COMPLAINT PROCESS
a. Any aggrieved person may make, in writing, a complaint of sexual
harassment at workplace toany member of theICC within a period of three
months from the date of incident, and in case of a series of incidents, within
a period of three months from the date of last incident.Provided that where
such complaint cannot be made in writing, the Presiding Officer or any other
member of the ICC shall render all reasonable assistance to the aggrieved
person for making the complaint in writing. Provided further that the ICC for
the reasons to be recorded in writing, can extend the time limit not
exceeding three months, if it is satisfied that the circumstances were such
which prevented the aggrieved person from filing a complaint within the said
period.
b. Any complaint received by the members should be immediately forwarded to
the Presiding Officer, and this must be notified to other committee members

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at the earliest and not later than 3 days and a meeting should be called for
discussing the matter.
c. Notice shall be issued to the respondent within 7 working days of receipt of
the complaint and 10 working days shall be given for submission of reply
(along with the list of witnesses and documents.)
d. The complaint would be investigated by three members of the ICC with the
presiding officer and one out of the two members being females.
e. The complaint should contain all the material and relevant details
concerning the alleged harassment including the name of the contravener.
f. Confidentiality of the identity of the involved parties will be maintained by
the ICC members.
g. The ICC, before initiating an inquiry on the request of the aggrieved person
can take steps to settle the matter between her/him and the respondent
through conciliation, provided that no monetary settlement shall be made as
a basis of conciliation.
h. If a settlement has been arrived at, the ICC as the case may be, shall record
the settlement so arrived and forward the same to the Steering Committee.
The ICC shall provide the copies of settlement as recorded, to the aggrieved
person and the respondent. In case the settlement is arrived, no further
inquiry shall be conducted by the ICC.
i. In case conciliation is not received; notice will be issued to both parties for
hearing.
j. As an interim measure, ICC may recommend the following:
- The transfer of the aggrieved person or the respondent to another section
or Department as deemed fit by the ICC.
- Grant leave to the aggrieved woman upto a period of three months
- Restrain the respondent from exercising any administrative authority or
supervision or academic evaluation of the aggrieved person.
k. The ICC shall proceed to make an inquiry into the complaint in accordance
with the provisions of the service rules applicable to the respondent
l. The Presiding Officer shall convene the first hearing of the enquiry. The
respondent, the aggrieved person, and the witnesses shall be intimated at
least 7 working days in advance in writing of the date, time and venue of the
enquiry proceedings. The subsequent proceedings may be on a day to day
basis, to be decided by ICC.
m. Both parties will be given an opportunity to present their views to the
Committee.

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n. After examination of the complaint, the ICC will submit its recommendation
to the Steering committee.
o. Based on the enquiry report and recommendation of the ICC, the Steering
Committee would decide on the appropriate course of action.
p. If the employee is found guilty then the Steering Committee shall decide on
theappropriate punishment and in consultation with HR shall initiate the
disciplinary action, including a verbal or written warning, suspension, or
termination ofemployment. If the action amounts to offence under Indian
Penal Code, then theCompany will initiate criminal proceedings.In case the
complaint is found to be false, the complainant shall, if deemed fit, beliable
for appropriate disciplinary action by the ICC and the Steering Committee.
q. The entire process will be completed within 90 days from date of
submission of the complaint.
GUIDELINES FOR THE AGGRIEVED INDIVIDUAL
The primary focus of this policy is to ensure a congenial work environment that
is free from threat or fear. There are a few things you can do to help translate
the policy into day-to-day practices:
a. Discrimination can take many forms: spoken, unspoken, or physical.

Recognize that you may be conditioned to accept behaviours that infringe
on your rights and constitute harassment, as normal workplace conduct.
b. Firmly say NO. It is possible that the offender does not know that his/ her
behaviour is unacceptable to you. Promptly make direct statements and
communicate that the offender‘s conduct is not acceptable to you.
c. Participating in jokes and sexually tinged conversations is often taken as
tacit permission to continue. Communicate early on that this conduct is
unacceptable to you.
d. Warn the offender to immediately desist, first orally, and then if necessary,
follow it up with a warning in writing.
e. Assess the situation and appropriately time your complaint.
f. If you are unsure of the course of action to take in a given situation, we
encourage you to approach any of the committee members informally and
take their counsel.

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g. We also encourage you to discuss any issues you may have in this area
with your supervisor or with HR representatives.
h. Any concerns can be expressed or reporting can be made without any fear
of retaliation. The ICC and the Steering Committee will maintain
confidentiality and the person reporting as well as the person reported
against will be protected from unnecessary disclosure.
A NOTE TO SUPERVISOR
Constant reinforcement is needed to build a culture of openness and trust

which is congenial to performance. As people managers, you carry an
additional responsibility of providing an enabling climate to those working
under you. In this context, there are simple things that you can do to ensure
this:
a. If an employee approaches you with a complaint, please guide him/ her as

to the proper procedure for registering the complaint.
b. Often, the employee may not want to make a formal complaint, but may
seek your advice on how to deal with a situation. Please give the person a
patient hearing and if the matter cannot be resolved informally, guide the
individual to escalate the matter to the Complaints Committee.
c. There are different ways in which an employee can deal with such situations
e.g. directly confront the employee who is harassing him / her or formally
complain to the Internal Complaints Committee.
d. You could guide the aggrieved employee on the alternative available courses
of action he/she could choose and let the employee decide the course of
action.
e. Do not initiate an enquiry on your own.
f. When approached by an employee for your counsel, avoid making a quick
judgment as to right and wrong and hold back advice/ opinions.
g. It is often difficult for victims of discrimination/ harassment to come forward
with their complaints. Do not cross-question the individual or give the
impression of doubting the authenticity of her/his report.
h. Ensure privacy for the meeting and help the employee feel that
confidentiality will be maintained.

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i. Protect the privacy of the employee and treat her/him in a manner that
communicates respect for feelings and dignity.
j. Be conscious of your position and your power to impact the well-being of the
subordinate and the decisions she/he may make.
Gender discrimination is not an individual issue between persons involved.
This reinforces the tendency of the aggrieved to try to cope with their own
instead of complaining and seeking redressal. It must be treated as an
organizational climate issue.
CRIMINAL PROCEEDINGS
a. Where such conduct amounts to a specific offence under the Indian Penal
Code or under any other law, FINO based on the findings and advice of the
ICC may initiate appropriate action in accordance with law by making a
Complaint with the appropriate authorities.
b. The ICC would provide assistance to the aggrieved if they chose to file
Complaint under the Indian Penal Code.
c. The ICC would ensure that Complainants or witnesses are not victimized or
discriminated against while dealing with Complaints of sexual harassment.
MALAFIDE COMPLAINTS
a. If the enquiry reveals that the Complaint is unjustified or Complainant had
raised the concern with ulterior motives, the steering committee will counsel
the Complainant and recommend suitable action to prevent recurrence.
b. However, the Internal Complaints Committee or the Steering Committee will
ensure that the Complainant is not victimized.
PROESSIONAL CONSEQUENCES OF VIOLATION OF THE POLICY

a. Any employee, supervisor or manager who is found to have violated the
harassment policy (whether sexually harassing another employee of
opposite sex or the same sex or if any person falsely accuses another
person of sexual harassment) shall be subject to appropriate disciplinary
action.

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b. In the event any criminal proceedings are initiated the matter may be
referred to Head Legal or such other person as may be authorized by the
Steering Committee.
c. The organisation shall not tolerate any form of retaliation against employees
for bringing bona- fide Complaints or providing information about
harassment.
d. However, as per the findings of the enquiry of a Complaint it is found out
that the Complaint was false or was made with a mala fide intent, the
Complainant may be subject to disciplinary actions, up to and including
termination.
THIRD PARTY SEXUAL HARRASSMENT
Third-party sexual harassment is perpetrated not by employees of FINO but

rather by individuals outside the organization. The sexual harassment may
involve unwelcomed requests for sexual favours and verbal or physical
harassment that creates a hostile work environment or an attitude of quid pro
quo of sexual harassment.
Sources of third party sexual harassment:
a. Client(s)
b. Customer(s)
c. Vendor(s)
d. Supplier(s)
e. Independent contractor(s)
f. Consultant(s)
g. Employee(s) or contractor(s) of different companies
FINO encourages its third parties to have a commitment to a sexual

harassment free working atmosphere within their companies. The company will
play a facilitating role in redressal of complaints of sexual harassment in such
circumstances. If any act of sexual harassment occurs as a result of an act by
any third party or outsider FINO will take all steps necessary and reasonable to
assist the affected person in terms of support and preventive action.

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COMMITTEE TO SUBMIT ANNUAL REPORT
The Internal Committee shall prepare a report in a prescribed form and

submit the same to the Board on quarterly basis. An annual report consisting
the cases of all the 4 quarters to be submitted to the company.
Note: It may be mentioned here that any provision or procedure which may be found to be
missing here; shall be restored from Sexual Harassment of Women at Work Place Act
2013. This shall remain a guiding source for implementation of this policy. Needless to
say that the said act and any of its provisions shall prevail over the policy in case of
repugnancy amongst the two.
5 POLICY OBJECTIVE

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3

1.2 CONFLICT OF INTEREST AND OUTSIDE ACTIVITIES

1.2.1 Conflict Of Interest – general principles

Document FINO Payments Bank Ltd. /People Controll Classification Internal

Version No. V2 Date November 1, 2017

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 You would be expected to be sensitive to any activities, interests or relationships that

1.2.2 Conflict of interest arising out of personal Investments

Document FINO Payments Bank Ltd. /People Controll Classification Internal

Version No. V2 Date November 1, 2017

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 Be in the businesses of FINO Payments Bank Ltd.’s customers, suppliers, or competitors

1.2.3 Conflict of Interest – Dos and Don’ts

 Undertake personal investments or outside activities that create conflicts of interest

1.3 PRIVACY / CONFIDENTIALITY

1.3.1 Proprietary and Confidential Information

Document FINO Payments Bank Ltd. /People Controll Classification Internal

Version No. V2 Date November 1, 2017

©Copyright 2017FINO Payments Bank Ltd.Page5 of 246

1.3.2 Privacy of Employee Information

1.3.3 Privacy and Confidentiality – Do's and Don’ts

 Properly control access to your work areas and computers

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Version No. V2 Date November 1, 2017

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 Access to information or data by outsourced will also be subjected to the relevant

 Discuss sensitive matters or confidential information in public places

1.4 GIFTS AND ENTERTAINMENT

1.4.1 Accepting Gifts and entertainment- General Principles

1.4.2 Giving gifts and entertainment - Bribery and corruption

Document FINO Payments Bank Ltd. /People Controll Classification Internal

Version No. V2 Date November 1, 2017

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 Bribery/Corruption is defined as the receiving or offering of an undue reward to any

1.4.3 Gifts and entertainment – Do's and Don’ts

 Make any payment to or for anyone that could tantamount to bribe/corruption

1.5 PROTECTING FINO PAYMENTS BANK LTD.’S ASSETS

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1.6 WORKPLACE RESPONSIBILITIES

1.6.1 Fair Employment Practices and Diversity

 FINO Payments Bank Ltd. is committed to adoption of fair employment practices. It

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1.6.2 Fair Competition

Although it is common to gather information about the general marketplace, including

1.6.3 Drug Free Workplace

1.6.4 Discrimination and Harassment and Intimidation

 FINO Payments Bank Ltd. is committed to prohibition of harassment and intimidation

1.6.5 Safety in the Workplace

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Version No. V2 Date November 1, 2017

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 Your work environment, therefore, must conform to the requirements of health

1.6.6 Fair Treatment of counter-parties

1.6.7 Corporate Opportunities

 Employees, business coordinators, district coordinators and officers are prohibited

You would be expected to be sensitive to any activities, interests or relationships that

Be in the businesses of FINO Payments Bank Ltd.’s customers, suppliers, or competitors

Undertake personal investments or outside activities that create conflicts of interest

Properly control access to your work areas and computers

Access to information or data by outsourced will also be subjected to the relevant

Discuss sensitive matters or confidential information in public places

Bribery/Corruption is defined as the receiving or offering of an undue reward to any

Make any payment to or for anyone that could tantamount to bribe/corruption

FINO Payments Bank Ltd. is committed to adoption of fair employment practices. It

FINO Payments Bank Ltd. is committed to prohibition of harassment and intimidation

Your work environment, therefore, must conform to the requirements of health

Employees, business coordinators, district coordinators and officers are prohibited

Respect personal dignity, privacy, and personal rights of every individual

Discriminate, harass or offend anybody by whatever means, be it sexual or otherwise

FINO Payments Bank Ltd. encourages employees to report to their

Report to your supervisor/HR/compliance, concerns and suspected violations of the

Strive to create and sustain an environment that promotes ethical behavior

Issue directives to violate the terms of internal policies/procedures

Comply with all applicable laws, rules and regulations

Unpunctual or irregular attendance, leaving workplace without permission, habitual

Any other act which is against the ethos/culture of the company

Suppressing or misrepresentation of facts