India Employees Handbook on HR Policies

India Employees Handbook on

Human Resources Policies

September 2020
India Employees Handbook on HR Policies

Contents
I.Welcome................................................................................................................................................................................3
II.Our Work Environment ................................................................................................................................................4
Our Story ............................................................................................................................. 4
Our Mission ......................................................................................................................... 4
Core Values .......................................................................................................................... 4
Open Door Communication.................................................................................................. 5
Equal Opportunity Employment .......................................................................................... 5
Disability Accommodation ................................................................................................... 5
Employment of Relatives ..................................................................................................... 6
Conflicts of Interest.............................................................................................................. 6
III.Work Schedule & Pay Procedures ..........................................................................................................................8
Work Schedules ................................................................................................................... 8
Pay Procedures .................................................................................................................... 8
Time Keeping....................................................................................................................... 8
IV. Time Off and Group Benefits ....................................................................................................................................9
Holidays............................................................................................................................... 9
Annual Leave (Paid Time Off) .............................................................................................. 9
Sick Leave/Casual Leave ...................................................................................................... 9
Maternity Leave ................................................................................................................. 10
Paternity Leave.................................................................................................................. 10
Bereavement Leave ........................................................................................................... 10
Group Benefits ................................................................................................................... 11
V.Standards of Conduct .................................................................................................................................................. 12
Worldwide Code of Business Conduct and Ethics ............................................................... 12
Appearance Guidelines ...................................................................................................... 12
Harassment Prevention ..................................................................................................... 12
Confidentiality ................................................................................................................... 14
Company Resources........................................................................................................... 14
Solicitation......................................................................................................................... 15
Tobacco Products .............................................................................................................. 15
Drug and Alcohol Use......................................................................................................... 15
VI.Safety & Security.......................................................................................................................................................... 17
Verification of employment................................................................................................ 17
Security ............................................................................................................................. 17
Safety Policy....................................................................................................................... 18
VII.Performance Reviews.............................................................................................................................................. 20
Performance ...................................................................................................................... 20
VIII.Prevention of Sexual Harassment (POSH) .................................................................................................... 21
India Employees Handbook on HR Policies

I.Welcome

It is a pleasure to welcome you as an employee of Data Axle Solutions India Private Ltd

This employee guide is full of useful information that will enable your experience - whether it is
on Day One or Day One Thousand.

While it is vital that you understand your role and responsibilities, it is also very important for
you to know how to be a great citizen at Data Axle.

The employee handbook to Human Resources Policies (“Handbook”) is designed to give you clear,
easy-to-use, guidelines for our Human Resources Policies and provide a framework to help us all
work together productively.

As you read through this Handbook you will see that at times you are redirected to policies that
are global and/or defined by specific departments. You are expected to read and follow all these
policies. You will find such policies on our corporate intranet.

No employee guide can anticipate every circumstance or question about policy. If you have any
questions about any of the information in this Guide or want to make sure you understand how a
specific policy applies to you, check with your Manager or a Human Resources Representative.

This guide summarizes current company policies that may be amended, varied, or eliminated by
the Company at any time without notice. This guide does not constitute the terms of a contract
of employment and should not be construed as a guarantee of continued employment.
India Employees Handbook on HR Policies

II.Our Work Environment

Our Story
Data Axle, part of Infogroup Holdings Inc has been an industry leader in data, marketing
solutions, sales, and research for over 45 years. We are a privately held company with
opportunity throughout North America and Asia.

Our Mission
Data Axle - data, applications, and services that help you make and save money. Our
commitment to accuracy, service and innovation drive customer acquisition, retention, and
product enhancement.

Core Values
Our core values are what got us here and we will carry them forward as we continue to serve
our customers. Our core values define our beliefs, guide our decisions, and drive our actions.
They are the glue that connects us worldwide, inspiring us to be a powerful force in the industry
and a great place to work. We believe that how we do our job is equally as important as what
we do. We value employees who consistently demonstrate these core values:

TRUST TRANSPARENCY TENACITY

We have 45+ years of Our proprietary, cloud- We don’t rest until we
history in crafting based data platform know it’s right. That’s
solutions that help provides real-time, why we make more
businesses large and verified updates to our than 24 million
small grow revenue. business and consumer verification calls per
files. year to ensure our data
is of the highest quality
and accuracy
India Employees Handbook on HR Policies

Open Door Communication

We promote an open dialogue with employees. You are encouraged to offer suggestions to
improve products, processes, policies, and practices to make the Company an even better place
to work.

Employees are encouraged to seek information and solutions to resolve any work-related
problems/concerns by contacting their immediate supervisor. Supervisors should try to gather
information about an issue in a timely fashion and respond to the employee in a timely manner.
If the matter cannot be resolved, employees should speak with their Human Resources Manager.

We prefer that employees refer to their immediate supervisor for assistance. However,
supervisors should realize that employees do not always feel free to talk directly with them about
all matters. Therefore, employees are encouraged to discuss any such concerns with the Human
Resources Manager.

Equal Opportunity Employment

We believe that the best working environment is one where everyone is treated with fairness and
respect.

Our commitment to equal opportunity employment is an integral part of our company’s culture
and Core Values. We are an equal opportunity employer and, as such, work to ensure equal
employment opportunity for individuals regardless of age, sex, religion, marital status, disability,
or medical condition. The business activities impacted by equal employment opportunity
include, but are not limited to, hiring, promoting, training, transfer, termination of employment,
compensation, benefits, and client and community relations.

Each of us is responsible for ensuring that the work atmosphere is maintained in a business-like
professional environment. Our goal is to attract, select, develop and retain employees on the basis
of skill, knowledge, ability, performance, and interest; and to foster an environment in which
employees are evaluated on their contributions to company business results and demonstrating
our Core Values.

If you have a complaint of discriminatory treatment or intimidation, discuss it with your

immediate Manager and with your Human Resources Representative. If you are not comfortable
speaking directly with your immediate manager, you are encouraged to speak directly with
Human Resources. Human resources will investigate your complaint and will remain confidential
to the extent possible. Retaliation against employees who bring a legitimate complaint against
other employees, managers, customers, or vendors is prohibited.

Disability Accommodation
The Company is committed to promoting equal employment opportunities for all individuals with
disabilities in accordance with the applicable provisions of the “Right of Persons with Disabilities
Act, India and as otherwise required by applicable national, state or local law.

In accordance with applicable laws, Company policy strictly forbids all forms of intentional
discrimination against qualified applicants or employees with disabilities, and to the extent
applicable requires reasonable accommodation for seating needs and access to facilities as
necessary for such individuals to perform the essential functions of the job safely and efficiently
without serious risk to health and safety (unless such an accommodation imposes an undue
hardship on the company). Employees should report any need for accommodation to their
India Employees Handbook on HR Policies

Manager and their Human Resources Representative. The Company will work with the employee,
through an interactive process, to determine reasonable and appropriate accommodation.

Employment of Relatives

Employment of relatives may, in certain situations, constitute a conflict of interest. Relatives

include, but are not limited to, a spouse, children, parents, stepfamily, brothers, sisters,
grandparents, and in-laws. For purposes of this policy, relatives may also include close personal
relationships such as co-workers who are dating, co-residents, domestic partners and legal
dependents.

The following situations are prohibited:

• An employee may not report directly or indirectly, in the same chain of command, to a
relative.

An employee may not be hired or placed in a working relationship where a relative can influence
(directly or indirectly) the performance rating, salary, bonus, or any terms or conditions of
employment. Should one of the above situations occur, the Company will attempt to find a suitable
internal position to which one of the affected employees may transfer. If accommodations of this
nature are not feasible or reasonable, the employees will be permitted to determine which of
them will resign. If the employees cannot decide, the Company will terminate one of them
pursuant to this provision for cause.

Conflicts of Interest

Employees are prohibited from engaging in any activity, practice, or conduct which conflicts with,
or appears to conflict with, the interests of the Company, its customers, or its suppliers. Since it is
impossible to describe all of the situations that may cause or give the appearance of a conflict of
interest, the prohibitions included in this policy are not intended to be exhaustive and only
include some of the more clear-cut examples.

Employees are expected to represent the Company in a positive and ethical manner and are
obligated to avoid conflicts of interest and to refer questions and concerns about potential
conflicts to their supervisor or the Human Resources Department. Senior management and
employees who have contact with customers and suppliers may be required to sign a special
statement acknowledging their understanding of and adherence to this policy.

Employees are not to engage in, directly or indirectly, on or off the job, any conduct which is
competitive to the Company. Such prohibited activity also includes any illegal acts in restraint of
trade.

While employed with the Company, and unless otherwise expressly authorized by the Company’s
CEO or CFO or Head of HR in writing, employees are prohibited from working for any organization
that does business with or is a competitor of the Company. This prohibition on employment
includes serving as an advisor or consultant to any such organization unless that activity is
conducted as a representative of the Company.

Employees must disclose any meaningful financial interest they or their immediate family have
in any firm or organization that does business with or that competes with the Company. The
India Employees Handbook on HR Policies

Company may require divestiture of such interest if it deems the financial interest to be in conflict
with Company interests.

Employees and their immediate families are not to accept gifts, except those of nominal value (not
more than $25), or any special discounts or loans from any person or firm doing, or seeking to do,
business with the Company. The definition of gifts for purposes of this policy includes the
acceptance of lavish entertainment and free long-distance travel and lodging.

Employees are not to give, offer, or promise, directly or indirectly, anything of value (more than
$25) to any representative of a customer, of a potential customer, or of a financial institution in
connection with any transaction or business that the Company may have with that customer,
potential customer, or financial institution.

Employees may learn or become aware of information about the Company which, if known to the
public, might affect the decision of a reasonable investor to buy, sell, or hold securities or debt
issued by the Company. Employees are prohibited from misusing such material inside
information prior to public disclosure by purchasing or selling Company securities or debt for
their own benefit or for the benefit of members of their immediate family. In addition, employees
are not to disclose inside information to anyone, either inside or outside the organization, who
does not have a legitimate business need to know.

Any conflict or potential conflict of interest must be disclosed to the Company. Failure to do so
will result in discipline, up to and including termination.

Examples of conflicts of interest include, but are not limited to:

• Using proprietary or confidential Company information for personal gain or to the

Company’s detriment.
• Using Company assets or labour for personal use.
• Acquiring any interest in property or assets of any kind for the purpose of selling or
leasing it to the Company.
• Committing the Company to give its financial or other support to any outside activity or
organization without proper authorization.
• Accepting outside employment or engaging in outside business activities that require an
employee’s personal attention or work during scheduled work hours with the Company.
India Employees Handbook on HR Policies

III.Work Schedule & Pay Procedures

Work Schedules
For most roles, employees are required to normally work under the standard working hour
system, i.e. 9 hours per day (normally from 9 am to 6 pm), based on a 5 day working week, with
a one hour break (thirty minutes’ meal time and two breaks of fifteen minutes each) every day.
Hours may be adjusted as needed based on the requirements of the Company, and hours
applicable to each employee’s role.

To ensure the smooth and efficient running of the Company, employees may occasionally be
required to work beyond the normal hours of work as may be necessary for the proper
performance of their duties, without being entitled to receive any additional remuneration for
any work done outside normal hours of work.

The Company expects employees to be at work on time, and to work according to the Company's
established and announced work hours. Absenteeism and tardiness place a burden on other
employees and on the Company, and inconveniences customers. In the rare instance when an
employee cannot avoid being late to work or is unable to work as scheduled, the employee must
notify his or her manager as soon as possible in advance of the anticipated tardiness or absence.
Absent extenuating circumstances, an employee must call his or her manager on any day the
employee is scheduled to work and will not report to work. Excessive absenteeism and/or
tardiness may lead to disciplinary action up to and including termination. The Company may
determine that absenteeism or tardiness is excessive if, based on the facts and circumstances, it
is found to be disruptive to the Company, the employee’s co-workers, or the customers.

Pay Procedures

Payment of Salary

Pay checks are normally deposited on a monthly basis, on the 30th of each month, subject to
deduction of tax at source in accordance with the Company's normal payroll practices. If a pay
date falls on a weekend or holiday, you will be paid on the last business day before the weekend
or holiday. Salary for the first and final month of employment shall be pro-rated according to the
period of service. If you observe an error in your pay check, please report it immediately to Payroll
by email.

Deductions

Employees agree and acknowledge that the Company may, subject to applicable laws, at any time
during the term of employment or cessation thereof, deduct from their salary, or final settlement,
any amounts owed by the them, including but not limited to, any outstanding loans, advances,
overpayments or costs incurred by the Company due to any damage or loss to Company property,
etc. caused by them.

Time Keeping

Employees must record their time at the start and at the end of each work period, including
before and after the meal break. Any employee who fails to report or inaccurately report hours
worked will be subject to disciplinary action, up to and including termination of employment.
India Employees Handbook on HR Policies

IV. Time Off and Group Benefits

Holidays
Employees are entitled to 10 public holidays (8 fixed and 2 floaters) which may be changed from
year to year. The Company will publish the list of holidays that will be granted in a calendar year
before the commencement of that calendar year. These will be based on holiday schedules
announced by the State.

Annual Leave (Paid Time Off)

(a) Annual leave provides employees the chance to rest, relax, and renew themselves. Every
employee is entitled to 21 days of annual leave in a year, prorated as per the portion of
the year during which the employee is employed with the Company. For this policy, year
means calendar year. The leave will accrue to employees at end of each month at rate of
1.75 days per month. Employees are encouraged to use leave time in the year in which it
is earned. However, if an employee is unable to utilize all accrued leave in one year, this
will be added to the annual leave, they are entitled to in the succeeding year, subject to
such accumulation being up to a maximum of 45 days. Unutilized annual leave balance
will be encashed only at the time of separation up to a maximum of 30 days. Public
holidays and weekends that prefix, suffix or fall in intervening period of the Annual leave
will not be counted as part of annual leave. Carry over of leave at end of year is capped at
10.

(b) The application for taking annual leave must be submitted by an employee sufficiently in
advance (not less than one week) for the same to be processed and sanctioned or
otherwise and intimated to him/her. When leave is required for a period of more than 15
days, the leave application would have to be submitted at least two weeks in advance for
the consideration of the Company to enable the manager to make alternate arrangements.
No employee shall proceed on annual leave unless his/her leave application has been
sanctioned. In the event an employee proceeds on annual leave before the leave
application is sanctioned, he/she would be treated as being on unauthorized leave on a
loss of pay basis for that duration.

Sick Leave/Casual Leave

(a) Company values attendance at work and is committed to improving the general well-
being of its employees to achieve this. Although the Company aims to secure regular
attendance, employees are not expected to attend work when they are unwell.

(b) Employees are eligible for 8 days of sick or casual leave per calendar year, prorated as per
the portion of the year during which the employee is employed. The leave entitlement will
be credited at start of calendar year or joining date whichever is later. The leave is not
carried over to next year. It is also not encashed.

(c) If the circumstances permit, prior notice of the need to take sick/casual leave must be
provided by the employee to their manager. If not, the employee must communicate the
reason for absence as soon as possible to their manager on the first day of absence,
preferably within one hour of commencement of the Company's established and
announced work hours (if not earlier).

(d) For sick leave over three days, an Employee is required to submit a medical certificate
from a registered medical practitioner within two days of returning to work or, at the
Company's request, submit to a medical examination by a Company nominated registered
practitioner.
India Employees Handbook on HR Policies

Maternity Leave
(a) Female Employees who have worked with the Company for a period of not less than 80 days
in the 12 months immediately preceding the date of expected delivery are entitled to maternity
leave (along with maternity benefit) for 26 weeks, of which not more than eight weeks should
precede the Employee's expected date of delivery. The policy is guided by Maternity Benefit
Act.

(b) A female Employee who legally adopts a child who is less than three months old is entitled to
paid adoption leave of 12 weeks from the date when the child is handed over. The employee
will be eligible to avail the leave upon production of appropriate proof of a legal adoption, for
example the adoption deed. Employee should have worked with the Company for a period of
not less than 80 days.

(c) A female Employee who is a commissioning mother, i.e. a biological mother who uses her egg
to create an embryo implanted in any other woman is entitled to paid surrogacy leave for a
period of twelve weeks from the date when the child is handed over to her. The employee will
be eligible to avail the leave upon production of appropriate proof including a medical
certificate from a registered medical practitioner. Employee should have worked with the
Company for a period of not less than 80 days.

(d) Female Employees are entitled to 6 weeks' paid leave in the event of miscarriage or medical
termination of pregnancy upon production of a medical certificate from a registered medical
practitioner.

(e) If the female Employee is suffering from illness arising due to pregnancy, delivery, premature
birth or miscarriage, she is entitled to leave for 1 additional month upon production of
appropriate proof including a medical certificate from a registered medical practitioner.

(f) An Employee who is to take maternity, adoption or surrogacy leave is requested to give three
months' notice to her manager to make arrangements for the period of her leave. The Employee
should not undertake any employment, temporary or part- time or otherwise with any other
organization during maternity leave.

(g) Female employees will also be entitled to two nursing breaks and visits to the creche in
accordance with the provisions of the Maternity Benefit Act.

Paternity Leave
Male employees are entitled to a paid paternity leave for 10 business days on the birth of their
children.

Bereavement Leave
Employees may take up to two weeks (10 business days) of paid bereavement leave in an year to
attend a funeral or memorial service and help with family matters, in the event of a death of an
immediate family member. For purposes of bereavement leave, an "immediate family member”
is defined as including the following: spouse, child, stepchild, sister/brother, parent, step parent
,grandparent, domestic partner, or child of a domestic partner, mothers- and fathers-in-law, sons-
and daughters-in-law, brothers- and sisters-in-law. Employees are expected to submit proof of
such bereavement to claim the paid leave.
India Employees Handbook on HR Policies

Group Benefits

(a) Group Medical Insurance

Employees and their family will be provided Health Insurance Cover. This is a family floater
program for Employee + 5 dependent members including parents or parent-in-laws. The sum
assured is INR 500,000 per year. Company has entered into a contract with an insurance
provider who will facilitate the process. Details of the program are shared separately.
(b) Group Personal Accident Insurance

Employees only are covered under a Group Accident Insurance. Sum assured is 3 x Annual CTC.
It provides a short-term disability benefit for up to 104 weeks
(c) Transport for women working beyond 8pm in office

Company is committed to providing transportation to home for female employees required to

work beyond 8pm. Female employees are required to inform the transport coordinator by 7pm
if they expect to work beyond 8pm in order to make arrangements for transport. If a female
employee working beyond 8pm plans to make their own arrangement for travel from office,
then they are still expected to inform the transport coordinator that they will not require
transport although they plan to leave late from office. This is essential compliance required
based on state security laws for women.
India Employees Handbook on HR Policies

V.Standards of Conduct
Worldwide Code of Business Conduct and Ethics

Worldwide Code of Business Conduct and Ethics is intended to ensure compliance with legal
requirements and our standards of honest and ethical business conduct. Anyone conducting
business for our Company and/or its subsidiaries, including employees, officers, directors,
contractors and agents, must adhere to these standards in day-to-day activities, and comply with
all applicable policies and procedures. You are advised to review the complete policy on our
intranet.

Appearance Guidelines
Each employee is an ambassador of the Company and must come to work properly groomed and
appropriately dressed for their position, the type of work to be performed and the events of the
day. The definition of what is appropriate may vary from day to day and from employee to
employee. “Dress for your day” consideration should always be given to meetings that employees
may have with customers, vendors and other visitors and guests, as well as things going on
around the company.

We believe that a comfortable and casual work environment supports maximum productivity
among all employees. To that end, the dress code is “jeans/ smart business casual” Monday
through Friday. Employees who are expecting to meet with customers, clients or other business
associates should always wear business appropriate dress (including employees working on site
with customers). The way we dress reflects the image of Company.

Any employee who requires a reasonable accommodation regarding dress standards for reasons
based on religion, disability or other grounds should contact the Human Resources Department.
Reasonable accommodation may be granted unless it would cause an undue hardship on the
Company.

In addition to dressing appropriately, all employees are always expected to wear their company
identification badge while at work.

Harassment Prevention

Policy Summary

In order to promote a productive work environment free of harassment, the Company does not
tolerate offensive or unwelcome verbal or physical conduct by any employee, as well as
customers, vendors, or other person in the work place, who harasses, disrupts, or interferes with
another person's work performance or who the Company learns or has reason to suspect is
creating an intimidating, offensive, or hostile environment based on religion, colour, sex, sexual
orientation, age, national origin, disability, creed, marital status, medical condition, genetic
information or characteristics, or any other characteristics protected by applicable national or
state laws.

All forms of sexual harassment are specifically forbidden under this policy. Applicable law defines
sexual harassment as unwanted sexual advances, jokes, requests for sexual favors, or visual,
verbal, or physical conduct of a sexual nature when:
India Employees Handbook on HR Policies

• Submission to the conduct is made a term or condition of employment.

• Submission to or rejection of the conduct is used as basis for employment decisions
affecting the individual; or
• The conduct has the purpose or effect of unreasonably interfering with the employee's
work performance or creating an intimidating, hostile, or offensive working
environment.
The following is a partial list of forms of harassment (if severe or pervasive):
• Offering employment benefits in exchange for sexual favors
• Making or threatening reprisals after a negative response to sexual advances
• Unwelcome verbal or physical conduct, such as making or using derogatory comments,
epithets, slurs, sexually explicit jokes, invitations or comments about any employee's
body or dress
• Unwelcome sexual advances or propositions
• Unwelcome verbal or physical conduct of a sexual nature, verbal commentary about an
individual's body, sexually degrading words to describe an individual, or suggestive or
obscene letters, notes, or invitations
• Visual conduct such as derogatory and/or sexually oriented posters, photography, cards,
cartoons, drawings, or gestures
• Unwelcome physical conduct such as touching, assault, or impeding or blocking
movements
• Retaliation for reporting harassment or threatening to report harassment

All Personnel Covered

• This policy applies to all personnel in the workplace, including all employees of the
Company, as well as all temporary employees engaged through a third-party agency,
contract workers, vendors, and customers.

Complaint Procedure

• If an employee believes that he/she has been harassed on the job, or if an employee is
aware of the harassment of others, the employee should provide a written or verbal
complaint to his/her manager, or if such complaint involves them to their next higher
manager, and to their Human Resources Representative as soon as possible. The
complaint should be as detailed as possible, including the names of individuals involved,
the names of any witnesses, direct quotations when language is relevant, and any
documentary evidence (notes, pictures, cartoons, etc.). An internal complaints committee
will be constituted as soon as feasible as per applicable law. Employees may report to the
committee once formed as well.
• All reported incidents of harassment will be investigated promptly, effectively,
thoroughly, and objectively. The exact nature and extent of the investigation will depend
on the particular circumstances surrounding the complaint. Any employee determined
by the Company to be responsible for unlawful harassment will be subject to appropriate
disciplinary action, up to and including termination. Because a hostile-free work
environment is so important, the Company may take disciplinary action against an
employee who exhibits poor judgment or engages in inappropriate behavior, including
sexually inappropriate conduct, even if it is welcome or falls short of being severe or
pervasive. When the investigation has been completed, all parties will be advised of the
results of the investigation.
India Employees Handbook on HR Policies

• Applicable law also prohibits retaliation against any employee by another employee or by
the Company for using this complaint procedure in good faith for filing, testifying,
assisting, or participating in any manner in any investigation, proceeding, or hearing
conducted by a governmental enforcement agency. Additionally, the Company will not
knowingly permit any retaliation against any employee who complains of harassment in
good faith or who participates in an investigation in good faith. If an employee believes
that he or she has been retaliated against, the employee should immediately report the
suspected retaliation to their HR Representative.

Confidentiality

The internal business affairs of the organization particularly confidential information and trade
secrets represent proprietary assets that each employee has a continuing obligation to protect.
Information designated as confidential is not to be discussed with individuals outside the
organization and is to be only discussed within the organization on a "need-to-know" basis. In
addition, employees have a responsibility to avoid unnecessary disclosure of confidential internal
information about the Company, its employees, its customers, and its suppliers.

This responsibility is not intended to impede normal business communications and relationships
but is intended to alert employees to their obligation to use discretion to safeguard internal
Company information.

Employees authorized to have access to confidential information may be required to sign special
non-disclosure agreements and must treat the information as proprietary Company property for
which they are personally responsible. Employees are prohibited from attempting to obtain
confidential information for which they have not received access authorization. Employees
violating this policy will be subject to discipline, up to and including termination, and may be
subject to legal action.

All media inquiries and other inquires of a general nature impacting the organization should be
referred to Corporate Communications. In addition, all external publications, speeches, or other
official declarations must be approved in advance by the Corporate Communications Department.
Inquiries seeking references or other information concerning current or former employees
should be referred to the Human Resources Department.

Company Resources
Company provides resources (equipment, materials, information, instructional manuals and
other documents) to help us fulfill our responsibilities. These include a variety of technology
resources, including telephone, computers, e-mail, voice-mail, software, Internet connections,
and mobile phones. Remember that these are provided or approved for use by employees, for the
purposes of company business only. These resources, including the equipment and data stored
in the system, are and remain at all times our property. As such, all messages created, sent,
received or stored in the system as well as all information and materials downloaded into
technology resources are and remain our property.
Our authorized representatives may routinely retrieve and/or review any message composed,
sent, received, stored or downloaded on Company’s technology resources. At any time and
without prior notice, we reserve the right to monitor the usage of our technology resources.
Managers must request reports of such information through Human Resources.
The policies can be found Intranet/IT. We expect employees to familiarize themselves with
these policies.
India Employees Handbook on HR Policies

Solicitation

The Company prohibits solicitation of employees during work time and on Company property.
Employees may not solicit other employees during work times or on Company property.
Employees may not distribute literature of any kind during work times, or in any work area at
any time, except in connection with a Company-sponsored event.

The posting of materials or electronic announcements is not permitted.

Non-employees (including former employees) may not solicit employees or distribute any kind
of literature on Company’s premises. Employees may only admit non-employees to work areas
with prior management approval or to conduct official Company business. Non-employees
must be accompanied by an employee at all times.

Tobacco Products

The Company complies with all applicable national, state, and local regulations regarding
smoking in the workplace and provides a work environment that promotes productivity and the
well-being of its employees.

The Company recognizes that smoking in the workplace can adversely affect employees.
Accordingly, smoking is restricted at all Company facilities.

Smoking and chewing tobacco are prohibited inside the Company buildings except in designated
areas. This policy applies to employees during working time and to customers and visitors while
on Company premises.

Employees are expected to exercise common courtesy and to respect the needs and sensitivities
of co-workers with regard to the smoking policy. Smokers and users of chewing tobacco have a
special obligation to keep designated smoking areas litter-free and to not abuse break and rest
period rules, if any. Users of chewing tobacco must dispose of such in a proper container, placing
the container inside a trash can. Complaints about smoking and/or chewing tobacco should be
resolved between co-workers if possible, but may be brought to the attention of the Human
Resources Department as necessary. Employees violating this policy by smoking or chewing
tobacco in undesignated areas may be subject to disciplinary action up to and including possible
termination.

Drug and Alcohol Use

The Company workplace is maintained free from the effects of drug and alcohol use. The Company
is concerned about the use of illegal drugs, controlled substances, narcotics, or alcoholic
beverages on Company premises or work sites. The unlawful manufacture, possession,
distribution, transfer, purchase, sale, use, or being under the influence of controlled substances,
alcohol or illegal drugs while on Company property, while attending business-related activities,
while on duty, or while operating a vehicle or machine leased or owned by Company is strictly
prohibited and may lead to corrective action, up to and including immediate termination.
Employees, their possessions, and Company-issued equipment and containers under their
India Employees Handbook on HR Policies

control are subject to search and surveillance at all times while on Company premises or work
sites or while conducting Company business.

In addition, the Company prohibits the off-premises abuse of controlled substances, as well as
the possession, use, or sale of illegal drugs, when those activities adversely affect job
performance, job safety, or the Company's reputation in the community.

With the approval of management, employees may be permitted to consume moderate amounts
of alcohol at Company-sponsored events, or when socializing or entertaining for purposes of
Company business; but only if appropriate in the circumstances, and never to the extent that the
employee could be considered to be under the influence of alcohol. Failure to act responsibly may
result in disciplinary action up to and including possible immediate termination.

The use of prescription drugs and/or over the counter drugs may also affect or impair an
employee’s job performance or threaten the safety of the employee or others. Any employee
using prescription drugs that may impair performance during working time must notify his or
her supervisor before commencing or resuming work so that the Company may determine
whether the drugs will create a risk to health and safety or interfere with the employee’s ability
to perform the essential job functions.

The Company will encourage and reasonably accommodate employees with chemical
dependencies (alcohol or drug) to seek treatment and/or rehabilitation. To this end, employees
desiring such assistance should request a treatment or rehabilitation leave. The Company is not
obligated, however, to continue to employ any person whose performance of essential job duties
is impaired because of drug or alcohol use, nor is the Company obligated to re-employ any person
who has participated in treatment and/or rehabilitation if that person remains unable to perform
their essential job functions as a result of dependency.

Additionally, employees who are given the opportunity to seek treatment and/or rehabilitation,
but fail to successfully overcome their dependency or problem, will not automatically be given a
second opportunity to seek treatment and/or rehabilitation. This policy on treatment and
rehabilitation is not intended to affect the Company's treatment of employees who violate the
regulations described above. Rather, rehabilitation is an option for an employee who voluntarily
seeks treatment to end that dependency.
India Employees Handbook on HR Policies

VI.Safety & Security

Verification of employment

• The Company responds in an accurate and responsible manner in regard to all authorized
employment verification requests. The Company is extremely concerned about the
accuracy of information provided to individuals outside the Company regarding current
or former employees. Therefore, no employee may provide (either on- or off-the-record)
any information regarding current or former employees to any non-employee.

• The Human Resources Department should be notified promptly of any formal or informal
requests for information about current or former employees. The Human Resources
Department will normally verify only a former employee's dates of employment and
position held. A written disclosure authorization and release may be required before any
additional information is furnished.

Security

The Company makes reasonable efforts to provide for the security of its property, its employees,
and authorized visitors on Company premises. Below is a summary only.

The security of facilities, as well as the welfare of our employees, requires that every individual
be constantly aware of potential security risks. An employee should immediately notify his/her
supervisor when unknown persons are acting in a suspicious manner in or around the facilities,
or when keys, security passes, or identification badges are lost or misplaced.

Customers, suppliers, and guests must sign in, identify themselves, and obtain a special visitor's
Security Access badge. Visitors must be escorted by a Company employee at all times while on
the premises. Additionally, each visitor must sign out and return the visitor's Security Access
badge upon leaving the premises.

Company property or equipment may not be removed from the premises without authorization.
Employees who want to take Company property or equipment off the premises must have their
supervisor's written authorization and submit to the onsite Facility Manager or
representative. Employees are responsible for the proper care and return of all Company
property and equipment assigned to their possession.

Employees may enter or remain on Company premises outside their normal working hours only
when they have been authorized to do so by their supervisor.

Employees are expected to exercise reasonable care for their own protection and for that of their
personal property while on Company premises and while away from the premises on business.
The Company assumes no responsibility for loss, damage, or theft of personal property.

Illegal acts committed by employees will be reported to law enforcement authorities.

India Employees Handbook on HR Policies

Security Access Badges

It is our policy to limit facility access to employees who work at the facility. Employees working
at a facility that requires a security access badge are responsible for carrying the badge at all times
while at work. Employees are responsible for their own entry in the work area and should not
use their badge to allow unknown individuals into the work environment. Loaning a badge to a
known or unknown person is prohibited.

New Hire Access Badges

New employees working in a facility with a security badge system will be issued a badge upon
hire.

Temporary Access Badges

Temporary badges may be issued for the following reasons:

• Consultants who will be working in the facility longer than one week.
• Employees from out of town or another location who will be working in the facility for
longer than two days.
• Trainers who will be working in the facility for longer than one week.
• Maintenance crews who need access to the facility.
• Temporary or contract employees who will be working at the facility and are assigned to
an approved Staffing Requisition in Human Resources.

Temporary badges require the approval of the Manager and the department head.

Replacement Badges

Replacement badges will be issued for lost or damaged badges. We reserve the right to charge
any employee a fee for excessive lost or damaged badges that must be replaced.

Lost badges must be reported to Human Resources, and the onsite Facility Manager or Facilities
representative immediately.

For security reasons, unused badges or found badges must be returned to Human Resources or
the onsite Facilities Representative.

Termination

Badges must be returned to Human Resources or the onsite Facilities Representative upon
termination of employment.

Safety Policy

It is Company policy to comply with all applicable federal, state, and local health and safety
regulations and to provide a work environment free from recognized hazards. Employees are
expected to comply with all safety and health requirements whether established by the
Company or by national, state, or local law.
India Employees Handbook on HR Policies

Summary

Employees should report to the Safety Coordinator/Fire Warden or their supervisor all observed
safety and health violations, potentially unsafe conditions, threats of violence, suspicious
individuals or activities, and any accidents resulting in injuries to employees or customers.
Employees are encouraged to submit suggestions to the Safety Coordinator/Fire Warden
concerning safety and health matters. Violations of Company safety rules, regulations, or
procedures will result in disciplinary action, up to and including termination.

Workplace Violence

Company prohibits any and all physical and/or verbal acts or threats of violence, whether made
in jest or seriously, by an employee against any other employee, customer, vendor, or visitor on
company premises or elsewhere in connection with the workplace or working environment. In
addition, Company strictly prohibits the possession or use of any licensed or unlicensed handgun,
knives or other weapon on company premises – including parking lots, entrances and exits, break
areas, and surrounding property - by any employee, customer, vendor, or visitor, excluding law
enforcement officials.

Maintenance of Work Areas

Work areas must be kept clean and orderly at all times.

Employees are responsible for maintaining their work areas in a clean and orderly fashion.
Employees should:

• Make sure that aisles, floors, and walls are free of debris and other unnecessary items
and that all end-of-the-shift tasks have been performed.
• Monitor the facilities and equipment and notify the Facilities Help Desk where
appropriate.
• Arrange for the removal of any items from the workplace that are not needed for the
flow of business or will adversely affect the electrical usage designed for the workplace
area.
• All foods and coffee are to be prepared in the lunchroom and/or break room only.
• Personal electrical heaters are not permitted per office lease agreement with landlord.
• Report to the On-Site Safety Coordinator/Fire Warden any existing or potential
workplace hazards and safety violations.
• Ensure the proper disposal of all trash, waste, and scrap.

The Company will attempt to maintain the temperature, lighting, and noise level of its facilities at
a level that is both comfortable for employees and appropriate for the nature of its operations.
Employees should inform their supervisor of any concerns about working conditions.
India Employees Handbook on HR Policies

VII.Performance Reviews
Performance
Probation Evaluation

Employees who are subject to probation periods must go through an evaluation that will be conducted
before the completion of their probation by their respective supervisor. The employee shall initially
be on probation for a period of three (3) months from the date of joining the Company. The supervisor
will assess the Employee's performance to determine whether the Employee has met the recruitment
conditions and inform the Employee of the assessment result. Based on the evaluation and
assessment, the probation period may be extended, the Employee's position may be confirmed, or
his/her employment may be terminated. The Employee will be deemed to continue on probation until
the confirmation of his/her employment has been communicated to him/her in writing.

Performance Evaluation Program

Employees will undergo periodic performance evaluations. The evaluation is conducted by the
Employee's manager who will provide performance feedback to the Employee. Generally,
performance evaluations will be conducted bi-annually. However, the frequency of performance
evaluations may vary depending upon the Company's needs, the Employee's length of service,
position, past performance, changes in job duties or performance problems, etc.

The performance evaluation may cover factors such as the quality and quantity of the work
performed, job knowledge, judgment, initiative, teamwork and cooperation and work attitude. The
purpose of the performance evaluation is to give the Employee formal feedback on job performance,
identify areas for improvement and set objectives or goals for future work performance.

A positive performance evaluation does not guarantee an increase in salary or promotion. Salary
increases and promotions are solely within the discretion of the Company and depend up on many
factors in addition to performance.

After the evaluation is verbally discussed and delivered to the Employee, the Employee will be
required to acknowledge the evaluation as discussed and given to the Employee by his/her supervisor.
The performance evaluation will be kept as confidential as possible by all parties and will become part
of the Employee's records.

Employees will have the opportunity to respond to their performance evaluation.

Performance Improvement

In the event an Employee is found not to meet required standards of performance, the Employee
shall be given an opportunity to improve their performance as per the Company's basic
requirements. If, despite this, the performance of the Employee fails to improve, this could lead to
termination of employment.
India Employees Handbook on HR Policies

VIII. Prevention of Sexual Harassment (POSH)

Objective

Data Axle is committed to providing a workplace that is free of harassment and bullying irrespective
of their gender, race, creed, religion, place of origin, sexual orientation, disability or economic status.
Data Axle employees have the right to work in an environment free from any form of discrimination
and conduct which can be considered harassing, coercive, or disruptive particularly behavio rs that
tantamount to sexual harassment as defined in this policy. This policy (“POSH Policy”) will assist
individuals who believe they have been subjected to sexual harassment seek support and remedial
action.

Scope & applicability

The Policy will apply to all individuals engaged by or associated with the Company, regardless of their
position, including consultants, contract workers, trainees, vendors and visitors on the premises.

It prohibits sexual harassment of women by men, of men by women or between the same sexes.
Sexual harassment is unlawful irrespective of who is involved in the behaviour.

What constitutes sexual harassment?

Sexual Harassment includes any one or more of the following unwelcome acts or behaviors (whether
directly or by implication):

• Physical contact and advances

• A demand for request for sexual favors
• Making sexually colored remarks
• Showing pornography; or
• Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

Further, the following circumstances may amount to sexual harassment if it occurs or is present in
relation to any other act of sexual harassment:
• implied or explicit promise of preferential treatment in employment
• implied or explicit threat of detrimental treatment in employment
• implied or explicit threat about present or future employment status
• interference with work or creating an intimidating or offensive or hostile work environment; or
• humiliating treatment likely to affect health or safety.

An indicative list of behaviors that constitute sexual harassment is mentioned at the end.

Prohibition of workplace sexual harassment

Data Axle has a ‘zero-tolerance’ approach to any instance of sexual harassment. Sexual harassment of
any individual at DataAxle’s workplace, whether during or after office hours, is strictly prohibited
under law and this POSH Policy. For the purpose of this policy, it is clarified that ‘workplace’ also
includes any place visited by an employee arising out of or during the course of employment .
India Employees Handbook on HR Policies

Internal Complaints Committee

DataAxle has constituted an Internal Complaints Committee (“ICC”) to investigate into allegations of
Sexual Harassment at the Company’s workplace. The Company reserves the right to add to, remove
or replace the ICC members from time to time. Please see “The HUB” portal for details of members of
DataAxle ICC.

Reporting Sexual Harassment

Complaints under this Policy may be lodged with any member of the ICC.

Complaints should be made in writing or via email (as soon as possible, not later than 3 months from
the date of occurrence of the incident alleged to constitute sexual harassment (in case of a series of
incidents, within a period of 3 months from the date of the last incident). The aggrieved individual
may request the ICC to provide reasonable assistance for making the complaint in writing. In case the
complainant is under any physical or mental incapacity, the complaint can be made by the legal heir
or any other person authorized in writing by the complainant. Hard-copy complaints should be
submitted to ICC member or Human Resources and email complaints should be sent to
([email protected]). All complaints, whether in hard-copy or email form, should be clear
and should include details of the incident or incidents, supporting documents, names of ind ividuals
involved and the names and addresses of the witnesses. The ICC may extend the time limit not
exceeding three months, if it is satisfied that there were unavoidable circumstances which prevented
the aggrieved woman from filing a complaint within the said period.

If the complainant would like to initiate action under the Indian Penal Code, 1860 (“IPC”), she may
inform the ICC of the same, and DataAxle shall provide necessary assistance to file such complaint.

Resolution process

Conciliation: Before the ICC initiates an inquiry into the complaint, the complainant may request the
ICC to settle the matter between the complainant and the respondent through conciliation before
initiating an inquiry. However, no monetary settlement shall be made the basis of the conciliation. In
the event a settlement has been reached, further inquiry shall not be conducted.

Inquiry: All claims of sexual harassment will be promptly and thoroughly investigated by the ICC in
accordance with the principles of natural justice and the provisions of law. Neither the complainant
nor the respondent shall be allowed to bring in any legal practitioner to represent them in their case
at any stage of the proceedings before the ICC.

The ICC shall submit an enquiry report to DataAxle’s authorized representative upon conclusion of the
inquiry. The report of the ICC shall be deemed to be the enquiry report for purposes of any disciplinary
rules applicable to the employee against whom a complaint of sexual harassment w as made. Where
the ICC determines that the allegation against the respondent has been proved, it may recommend to
DataAxle to take action for sexual harassment as misconduct in accordance with the provisions of the
Company’s applicable policies.

In the event the ICC determines that the complaint is false or malicious, the ICC may recommend to
DataAxle to subject the individual making the false complaint to disciplinary action, up to and including
termination of employment. It is hereby clarified that mere inability to substantiate a complaint or
provide adequate proof shall not attract action against the complainant.
India Employees Handbook on HR Policies

Disciplinary actions for cases of sexual harassment may range from oral/written warnings to extension
of probation, transfer, demotion including termination from the services of the organization.

Protection against retaliation

DataAxle forbids any form of retaliation or victimization against anyone who has filed a complaint of
workplace sexual harassment or has cooperated with the ICC in any investigation of a complaint of
workplace sexual harassment.

Individuals are encouraged to report to Human Resources if faced with victimization or retaliation.

Retaliation and/or victimization constitute misconduct as per DataAxle policy warranting disciplinary
action.

Confidentiality
All incidents/grievances reported will be treated seriously , sensitively and with utmost
conf identiality as is practically possible. Contents of the complaint, the identity and
addresses of the complainant, respondent and witnesses, any inf ormation relating to
conciliation and inquiry proceedings, recommendations of the ICC and the action take n by
the Company shall be treated as conf idential.

If any person entrusted with the duty to handle the complaint, inquiry or any
recommendations of the ICC, contravenes his/her conf identiality obligation, he/she shall
be liable to disciplinary action, in accordance with the provisions of the Company policies,
as applicable.

Consensual Relationships
DataAxle believes romantic or sexual relationships between a manager or other
supervisory employee and his or her staf f (reporting directly or indirectly), could create
compromising conf licts of interest at work.

It is theref ore in the best interest of all concerned, that if there is such a relationship, the
involved parties inf orm management so the reporting chain can be changed to ensure no
direct or indirect reporting relationship.

General

All employees at DataAxle have a responsibility in contributing to a mature and respectful work
environment. All employees are personally responsible for their actions and must ensure that their
behavior does not constitute sexual harassment whether it happens deliberately or inadvertently.

DataAxle reserves the right to modify and amend the provisions of this Policy, so as to comply with
applicable legal requirements, internal policies, or with a view to fine tune or alter the provisions of
this Policy to the extent deemed necessary by DataAxle from time to time. If any of the provisions
contained herein are found to be invalid, illegal or unenforceable in any respect, the validity, legality
and enforceability of the remaining provisions shall not in any way be affected or impaired.

Please contact Human Resources for any questions or further guidance in relation to this Policy.
India Employees Handbook on HR Policies

Sexual Harassment may include

• Using sexually abusive and offensive language or comments that put down people because of
their sex or sexual orientation or appearance;
• Phone calls or messages on electronic mail or computer networks which are threatening,
abusive or offensive to employees in a sexual manner;
• Sexual messages, text, or images which may be perceived by the recipient as creating a hostile
work environment;
• Suggesting or insisting that someone wear revealing clothing;
• Intrusive questions about sexual activity, Tales of sexual exploits, Comments about people’s
(women/men) bodies or intruding on the privacy of an employee;
• Repeated requests for sexual favors, sexual advances or repeated pressure for dates and
social contact especially when person invited has refused/ignored similar invitations;
• Sexually suggestive comments, sexually colored propositions, insults or threats;
• Telling lewd jokes about sex or sexual orientation;
• Offensive language that insults/demeans including using terms of endearment; and
• Singing or humming vulgar songs, ballads or words.
• Graphic descriptions of pornography including graffiti in the office premises;
• Displaying of books, photographs, paintings, films, pamphlets, packages, etc. containing
'indecent representation of women/men',
• Material that is sexual in nature, sexist, sexually explicit is displayed in the workplace,
circulated, or put in someone’s workplace or belongings, or on a computer or fax machine or
on the internet or any other public display system or public in the work premises;
• Offensive gestures, staring, leering or whistling with the intention to insult or discomfort
another;
• Even if not directly done to a particular individual, uttering a word, making a gesture or
exhibiting any object with the intention that such word, gesture, or object be heard or seen
by an employee;
• Sounds, gestures or display of offensive books, pictures, cartoons, magazines, calendars; or
derogatory written materials at one’s desk or workplace;
• Viewing, showing or mailing pornographic posters, Internet sites, cartoons, drawings; and
• Suggestive letters, phone calls, electronic instant messaging or e -mail messages.
• Intentional touching of the body, example- Unwelcome hugs, kisses, brushing, fondling,
pinching, patting etc.
• “Accidentally” brushing sexual parts of the body,
• Any displays of affection which can make others uncomfortable or are inappropriate at the
workplace even if the recipient welcomes it.
• Indecent exposure or coerced sexual intercourse.
• Use of technology to induce different remote sensations on the body including, but not limited
to pain and sexual stimulation,
• Sexual assault or using criminal force to any woman, intending to outrage or knowing it to be
likely that he will thereby outrage her modesty.