EMPLOYEE HANDBOOK – POLICY MANUAL DOCUMENT CONTROL Document Information Document ID /Name LeadSquared Employee Handbook Prepared by Version No. 1.3 Reviewed by Date of Release Document Classification 18th Nov 2021 Approved by HR Priya Srivastava (Senior Manager – Human Resources) Prashant Singh (COO & CISO Date 18th Nov 2021 Date 18th Nov 2021 Date 18th Nov 2021 C2 (Internal) Document History Version Number Revision Description 0.1 Draft 1.0 Revision Date Change Approver Baseline 31st January 2019 Sr. Management Sr. Management 1.3 ICC member list revised in POSH, Reimbursement policy in travel ISMS & HIPAA Policy, Disciplinary procedure - violation for ISMS and HIPAA policies, employee referral policy Leave Policy 12th 1.4 Re-drafting of handbook 1.1 1.2 July 2019 30th September 2019 Sr. Management 08th June 2021 Sr. Management 18th November 2021 Sr. Management Document Distribution Recipient’s name Designation Organization Copy # Purpose MarketXpander Services Pvt Ltd referred as “LeadSquared” in this document. Page 1 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Contents DOCUMENT CONTROL ........................................................................................................................... 1 1. PERSONAL CONDUCT .................................................................................................................... 5 2. EQUAL EMPLOYEMENT OPPORTUNITY ................................................................................... 9 3. ISMS (Information Security Management System) Policy ......................................................... 12 4. HIPAA (Health Insurance Portability & Accountability Act of 1996) Policy.............................. 13 5. Prevention of Sexual Harassment (POSH) .................................................................................. 13 6. Non-Disclosure and Confidentiality Agreement ........................................................................... 21 7. Employment Status and Records .................................................................................................. 22 8. Health and Safety Policy/ Procedures .......................................................................................... 24 9. Information Technology Acceptable Usage Policy ...................................................................... 26 10. PERFORMANCE MANAGEMENT SYSTEM .......................................................................... 33 11. REWARDS AND RECOGNITIONS ........................................................................................... 37 12. EMPLOYEE RELATIONS ........................................................................................................... 42 12.1 Discipline and its procedures ............................................................................................. 43 12.2 Disciplinary Appeal ............................................................................................................... 47 12.3 Grievance ................................................................................................................................. 48 13. WORK HOURS AND OFFICE TIMINGS.................................................................................. 49 14. LEAVE AND HOLIDAYS ............................................................................................................. 51 14.1 Types of Leave ........................................................................................................................ 52 15. TRAVEL – INTRACITY TRAVEL ............................................................................................... 59 16. TRAVEL AND ACCOMMODATION – DOMESTIC AND INTERNATIONAL TRAVEL ..... 62 Domestic Travel Policy ............................................................................................................................ 65 International Travel Policy....................................................................................................................... 66 Page 2 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 17. EMPLOYEE BENEFITS .............................................................................................................. 75 17.1 GRATUITY ................................................................................................................................ 75 17.2 GROUP HEALTH INSURANCE ............................................................................................ 75 17.3 EMPLOYEE WELFARE POLICY.......................................................................................... 76 17.4 EMPLOYEE REFERRAL POLICY........................................................................................ 79 18. SEPARATION ............................................................................................................................... 81 18.1 Termination.............................................................................................................................. 81 18.2 Retirement................................................................................................................................ 82 18.3 Return of our property .......................................................................................................... 83 19. NIGHT SHIFT ALLOWANCE ..................................................................................................... 83 20. RELOCATION POLICY ............................................................................................................... 84 21. EXTERNAL TRAINING AND DEVELOPMENT POLICY ....................................................... 85 22. SALARY ADVANCE POLICY ..................................................................................................... 87 23. WORKPLACE RELATIONSHIPS & ASSOCIATION POLICY .............................................. 89 24. WHISTLE BLOWER POLICY ..................................................................................................... 91 24.4 Reporting Mechanism/Compliant (Whistle Blower)................................................................. 94 25. CONFLICT OF INTEREST ......................................................................................................... 97 Page 3 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Policy & Procedures Manual - Introduction Our business is a people business. We rely on the talents and enthusiasm of all our employees in establishing a competitive advantage and building a successful organization. As a part of family each one of us should strive to achieve the goals of the organization within the framework that has been provided. Thus, this HR policy manual is not just a compilation of information on policies and processes but is a reminder of our responsibilities in ensuring effective implementation of the same. The LeadSquared Human Resources Policy and Procedures Manual has been developed to facilitate the implementation and clearly define LeadSquared’ s policies on human resource management. The Manual provides guidelines to be followed in the administration of these policies and assists all employees in defining who is responsible for each human resource management decision, and the correct procedure which is to be followed. The policies specified within are consistent with those of best practice management principles. They have the full support and commitment of LeadSquared management. The contents of this Manual shall not constitute nor be construed as a promise of employment or as a contract between the Company and any of its employees. HR policies must be kept current and relevant. Therefore, from time to time it will be necessary to modify and amend some sections of the policies and procedures, or for new procedures to be added. Any suggestions, recommendations or feedback on the policies and procedures specified in this manual are welcome. This should be provided by email. These policies and procedures apply to all areas of operations within LeadSquared and related entities. You are responsible for reading, understanding, and complying with the provisions of this Manual. Our objective is to provide you with a work environment that is constructive to both personal and professional growth. Our Philosophy and Values We are committed to a set of corporate values based on our philosophy of equal opportunity, fair treatment, creation of conducive climate of motivation and performance, recognition and reward and open-door communication which facilitates meaningful exchange of ideas. Page 4 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com A person who takes pride in his/her work is capable of putting in a much bigger effort to produce the best he/she is capable of. To develop the pride in one’s own work, the organization shall strive to create as much motivational climate as is expected. Every aspect of creativity shall be encouraged and in furtherance of this, calculated risk-taking shall be promoted at all times. As a corporate philosophy, we shall endeavor to attract, develop, and retain the best talent available and have the right person for the right job. In brief, we shall constantly strive to make the workplace endowed with a positive work-culture. 1. PERSONAL CONDUCT Policy Statement LeadSquared expects its employees to achieve and maintain a high standard of ethics, professional conduct, and work performance to ensure the Company maintains its reputation with all internal and external stakeholders. Objective To enhance LeadSquared’ s reputation as a quality service provider and an enjoyable, stimulating and challenging place to work. Application The policy will be seen to be successfully applied when all employees are seen to perform their duties professionally with skill, care, and diligence. This includes: • observing LeadSquared policies and procedures • treating colleagues with courtesy and with respect for their rights, duties, and aspirations • employees who do not conform to this standard of conduct will be subject to disciplinary action as detailed in this manual 1.1 Dress Code Dress choice is a matter of personal discretion, considering requirements for any protective clothing, customer/supplier interaction and professional environment. Be aware that work attire will have an impact upon LeadSquared’ s image as well as your work colleagues. Page 5 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com As a minimum standard, dress should be clean, neat, and professionally appropriate. LeadSquared reserves the right to request a staff member to dress to an appropriate standard as a condition of employment. If you are in a work environment with inappropriate clothing you may be sent home to change, before returning to work. 1.2 Personal Communications 1.2.1 Phone Calls [choose one of the following] The making and receiving of personal phone calls must be limited to a maximum of five minutes in duration, unless otherwise approved by your manager. Or It is acknowledged that personal communication is inevitable and sometimes necessary. It is expected this will be kept to appropriate or reasonable levels. 1.2.2 Email Email has legal status as a document and is accepted as evidence in a court of law. Even when it is used for private purposes, LeadSquared can be held responsible for the contents of email messages, including any attachments. Access to emails can be demanded as part of legal action in some circumstances. It is therefore important that email is used within the following guidelines: • email should mainly be used for formal business correspondence and care should be taken to maintain the confidentiality of sensitive information. Formal memos, documents and letters for which signatures are important, should be issued on company letterhead regardless of whether a physical or electronic delivery method is used • if electronic messages need to be preserved, they should be printed out and filed • limited private use of email is permitted, provided that such does not interfere with or distract from an employee’s work. However, management has the right to access incoming and outgoing email messages to determine whether staff usage or involvement is excessive or inappropriate • non-essential email, including personal messages, should be deleted regularly from the ‘Sent Items’, ‘Inbox’ and ‘Deleted Items’ folders to avoid congestion • all emails sent should include the approved company disclaimer Page 6 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com In order to protect LeadSquared from the potential effects of the misuse and abuse of email, the following instructions are to be observed by all users. • No material is to be sent as email that is defamatory, in breach of copyright or business confidentiality, or prejudicial to the good standing of LeadSquared in the community or to its relationship with staff, customers, suppliers and any other person or business with whom it has a relationship. • Email is not to contain material that amounts to gossip about colleagues or that could be offensive, demeaning, persistently irritating, threatening, discriminatory, involves the harassment of others or concerns personal relationships. • The email records of other persons are not to be accessed except by management (or persons authorized by management) engaged in ensuring compliance with this policy, or by authorized staff who have been requested to attend to a fault, upgrade, or similar situation. Access in each case will be limited to the minimum required to complete the task. • When using email, a person must not pretend to be another person or use another person’s computer without permission. • Excessive private use, including mass mailing, “reply to all” etc. that are not part of the person’s duties, is not permitted. Failure to comply with these instructions is a disciplinary offence and will be subject to appropriate investigation. In serious cases, the penalty for an offence, or repetition of an offence, may include dismissal. Staff need to be continually aware some forms of email conduct may also be open to criminal prosecution. 1.2.3 Internet The internet is a facility provided by LeadSquared for business use. Access is authorized by managers on the basis of business needs. Limited private use is permitted provided the private use does not interfere with or distract from a person’s work. Management has the right to access the system to determine whether private use is excessive or inappropriate. The following activities, using LeadSquared’ s internet access is not permitted: • attending to personal activities of a business nature • viewing, other than by accident, sites of incoming emails portraying obscene, violent, defamatory, and unlawful material and material that could cause LeadSquared to be in breach of equal opportunity or anti-discrimination legislation, verbally, in writing or pictorially Page 7 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • downloading or printing material as described above • showing to others, or allowing to be seen by others, items as described above • repeated or prolonged use that is not directly relevant to the user’s work • introducing computer viruses by failing to follow company IT procedures • downloading software from the internet or from unauthorized disks and CD ROMs on to the internal network Failure to comply with these instructions is a disciplinary offence and will be subject to appropriate investigation. In serious cases, the penalty for an offence, or repetition of an offence, may include dismissal. Staff need to be continually aware some forms of internet conduct may also be open to criminal prosecution. 1.2.4 Code of conduct (with outsiders): All the visitors to the premises must be met and the discussions held in the common reception/discussion area. An employee is not expected to: • Discuss his/her company related activities with an outsider. • Give out customer information. • Comment on issues that are a subject matter in the court of law. • Discuss financial projections of the company. • Discuss plans, programs, products, or operations of the company. If anyone is found to be transgressing this, he/she shall be liable for suitable disciplinary action including termination from the services & organization reserves the right to prosecute the employee concerned or recover the damage incurred thereof. Where the visitor is not a government official and is asking for any particulars, please put them in touch with your manager /HR or Administration to do the needful. In case you receive any phone calls seeking information about LeadSquared, please direct it to your Manager/HR or Administration Department. Page 8 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 1.3 Employee Communications 1.3.1 Employee Meetings Quarterly meetings after the end of each quarter and Annual meeting once in a year will be held from time to time. Details are generally communicated to all employees after the exact schedules are set. These informative meetings allow employees to be informed on recent company activities, changes in the workplace and employee recognition. 1.3.2 Document Centre and Portal for Communications All the documents related to HR policies announced from time to time for employee reference are placed in Alt worklife Portal which provide employees access to important posted information and announcements. The employee is responsible for reading necessary information posted on the portal. 1.4 Customer Relations Customers are among our organization’s most valuable assets. Every employee represents LeadSquared to our customer and the public. The way we do our jobs presents an image of our entire organization. Customers judge all of us by how they are treated with each employee contact. Therefore, one of our first business priorities is to assist any customer or potential customer. Nothing is more important than being courteous, friendly, helpful, and prompt in the attention you give to customers. We will provide customer relations and service training to all the employee with extensive customer contact. Our personal contact with the public, our etiquette on the telephone, and the communications we send to customers are a reflection not only of ourselves, but also of the professionalism of LeadSquared. Positive customer relations not only enhance the public’s perception or image of our company, but also pay off in greater customer loyalty and increased Sales and Profit. 2. EQUAL EMPLOYEMENT OPPORTUNITY 2.1 Policy Statement LeadSquared provides equal employment opportunity to all qualified persons without discrimination on the basis of age, sex, race, disability, marital status, or religion in accordance with applicable local, state, and national laws and regulations. LeadSquared will make reasonable job accommodation for persons with disabilities who can perform the essential functions of the position for which they are qualified and selected. All employment and promotion decisions will be based solely upon individuals’ qualifications, experience, prior contribution and demonstrated capacity to perform at higher or improved levels of performance and Page 9 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com will be in accordance with the principle of equal employment opportunity. LeadSquared will take whatever affirmative action is necessary to attract and retain qualified persons. 2.2 Objectives The objective of the Equal Opportunity Policy is to support the attraction and retention of employees that contribute most to the development of the LeadSquared business. 2.3 Application The Equal Employment Opportunity policy will be successfully applied when all roles are filled by the best qualified and experienced candidates available regardless of personal circumstances. 2.4 Process The Equal Opportunity Employment process is reflected throughout LeadSquared’ s staff recruitment and retention processes. 2.5 Who is responsible for ensuring policy is implemented? Each one of us is responsible for ensuring that our behavior is not discriminatory and that we follow the Company’s Equal Opportunities Policy and plays our part in achieving its objectives. The Company’s management takes overall responsibility for implementation of the policy and will ensure that the staffs that feel that they have not been treated in accordance with the policy have appropriate means of redress. 2.6 What is discrimination? There are several types of discrimination. 1. Direct discrimination is where a person is treated differently by reason of his/her race, sex, marital status, disability etc. 2. Indirect discrimination is not quite so obvious. Indirect discrimination takes place where a condition or requirement is imposed which an individual cannot comply with and where the condition/requirement is such that fewer persons in certain groups (by race or sex) can comply with it and the condition/requirement cannot be shown to be justifiable. 3. A final form of discrimination is victimization. Victimization occurs where a person is treated less favorably because he/she has started proceedings, given evidence, or complained about the behavior of someone who has been harassing them or discriminating against them. Page 10 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 2.7 What should one do if that one is being discriminated again? 1. One has a right not to be discriminated against in any way. If one is being discriminated against the following action is suggested: 2. If it is practical, one should make it clear to the person who is discriminating that their behavior is unacceptable and ask them to cease their discriminatory behavior. It is understood, however, that in many cases this may not be practical. 3. If the problem continues despite one having made it clear that the person’s conduct is unacceptable, (or if one feels that one cannot speak to them directly) one should ask one’s immediate supervisor to investigate and resolve the matter. If one cannot speak to one’s immediate supervisor about the problem (perhaps because they are the problem) then one should either speak to their manager or, if one would prefer, to the Manager, Human Resources. 2.8 What action will company take? 1. The Company will take the necessary steps to investigate the complaint. It is more than likely that Human Resources will be brought in since they have expertise in dealing with these types of complaints. They will see whether this is the type of situation, which can be resolved informally. If not, they will probably want to conduct investigatory interviews with both you and the person who is discriminating against you and also anyone else that is able to throw further light on the complaint. 2. Both you and the person against whom the complaint is made will have the right to be accompanied (by a friend or colleague); the person against whom the complaint is made will be given full details of the nature of the complaint and the opportunity to respond; and strict confidentiality will be maintained throughout any investigation into an allegation. Where it is necessary to interview other people, the importance of confidentiality will be emphasized. 3. If, after investigating the complaint, the Company agrees that there are reasonable grounds to uphold the complaint then disciplinary action will be taken against the person against whom the complaint is made under the Company’s usual disciplinary procedures. 4. The Company wishes all staff to realize that discrimination is a very serious offence and will be treated as gross misconduct under the company’s disciplinary procedure. An incident of discrimination is therefore likely to lead to dismissal; In addition, victimization of Page 11 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com a complainant is also gross misconduct and will also lead to severe disciplinary action including dismissal. 2.9 What should one do if one feels that one has been unfairly accused? One should use the company’s grievance procedure in the usual way. The Company will not tolerate discrimination, harassment or victimization in the workplace and will ensure that all complaints of such behavior are fairly investigated. Behavior of this type constitutes gross misconduct and will result in disciplinary action. 3. ISMS (Information Security Management System) Policy LeadSquared (MarketXpander Services Private Limited), is an Independent Software Vendor offering business process automation software and services to Customers worldwide. LeadSquared is committed to preserving the Confidentiality, Integrity and Availability of all information for successful day-to-day business operations. The security of information and other assets is therefore regarded as fundamental for the successful business operation of LeadSquared. LeadSquared has adopted an ISMS comprising of policies, procedures, and processes to effectively protect the information security requirements of all interested parties, both internal and external. The LeadSquared ISMS is aligned with the requirements of ISO/IEC 27001:2013. Our organization is committed to ensure – • Compliance to all legal, statutory, and regulatory requirements. • Privacy and confidentiality of information is preserved. • Sensitive and valuable information is safeguarded through adequate policies, procedures, and practices. • The integrity of information and information assets are maintained to ensure accuracy and completeness. • The availability of information is maintained to meet business and customer requirements. • Plans for business continuity are formulated, implemented, evaluated, and improved. • All employees are aware of the ISMS and responsibilities pertaining to their functions and roles. • Incident management system is established to ensure timely reporting and investigation of security breaches. Page 12 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • Risk based thinking is applied through a risk management framework and process. • The ISMS is continually improved. • Resources are allocated to implement, operate, and review the effectiveness of the ISMS. • All suppliers, sub-contractors and service providers abide by the ISMS policies of LeadSquared, besides compliance to all applicable statutory and regulatory requirements. Formal disciplinary procedures will be followed for employees/sub-contractors who violate the information security policies and procedures adopted by LeadSquared. 4. HIPAA (Health Insurance Portability & Accountability Act of 1996) Policy LeadSquared is committed to protecting the integrity, privacy, and security of confidential health information as required by law, professional ethics, and accreditation requirements. We acknowledge our duty and responsibility to protect the privacy and security of Individually Identifiable Health Information (“IIHI”) generally, and Protected Health Information (“PHI”) specifically, as defined in the HIPAA Privacy and Security Regulations and other applicable laws protecting the confidentiality of personal information, and under principles of general and professional ethics. LeadSquared is a business associate as defined by HIPAA. As an organization, we are committed to maintaining compliance with the HIPAA Privacy and Security Rules. Our organization and all our employees, comply with the requirements of the HIPAA regulations with respect to privacy principles of minimum necessary use, security safeguards and accountability; and make reasonable efforts to limit use of and access to PHI within our systems 5. Prevention of Sexual Harassment (POSH) 5.1 Introduction LeadSquared is committed to providing a safe environment for all its employees free from any discrimination on any ground and from harassment at work including sexual harassment. LeadSquared will operate a zero-tolerance policy for any form of sexual harassment in the workplace, treat all the incidents seriously and promptly investigate all allegations of sexual harassment. Sexual harassment is any unwanted, unwelcome, or uninvited behavior of a sexual nature which makes a person feel humiliated, intimidated, or offended. Sexual harassment can occur between an employee and a co-worker, supervisor, manager, agent, consultant, or contractor. Page 13 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Sexual harassment is not just unlawful during working hours or in the workplace itself. The behavior is unlawful in any work-related context, including conferences, work functions, business or field trips, and interactions with clients. 5.2 Purpose Our sexual harassment policy aims to protect person in our company from unwanted sexual advances and give them guidelines to report incidents. We won’t tolerate sexual harassment in our workplace in any shape or form. Our culture is based on mutual respect and collaboration. Sexual harassment is a serious violation of those principles. It is also unlawful. All complaints of sexual harassment will be treated seriously and promptly, with due regard to confidentiality. Disciplinary action will be taken against any employee who breaches the policy. 5.3 Scope This policy applies to every person at LeadSquared regardless of gender, sexual orientation, level, function, seniority, status, or other protected individuals. We are all obliged to comply with this policy. Also, we won’t tolerate sexual harassment from whether it happens within the office premises or outside. Employees, investors, contractors, customers, third party visitors and everyone interacting with our company are covered by the present policy. Any complaints or reports of sexual harassment will be treated promptly, seriously, and sympathetically. They will be investigated thoroughly, impartially, and confidentially. Managers and supervisors must act immediately on any reports of sexual harassment. Employees will not be disadvantaged in their employment conditions or opportunities because of lodging a complaint. 5.4 Policy Elements What is sexual harassment? Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated. It includes situations where a person is asked to engage in sexual activity as a condition of that person’s employment, as well as situations which create an environment which is hostile, intimidating or humiliating for the recipient. Sexual harassment can involve one or more incidents and actions constituting harassment may be physical, verbal, and non-verbal. Page 14 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Who is an Aggrieved Person? The Act recognizes the right of every person to a safe and secure workplace environment irrespective of age or employment/work status. Hence, the right of all people working or visiting any workplace whether in the capacity of regular, temporary, adhoc, or daily wages basis is protected under the Act. It includes all person whether engaged directly or through an agent including a contractor, with or without the knowledge of the principal employer. They may be working for remuneration, on a voluntary basis or otherwise. Their terms of employment can be express or implied. What is a Workplace? A workplace is defined as any place visited by the employee arising out of or during the course of employment, which includes co-working spaces, virtual workspace, including transportation provided by the employer for undertaking such a journey. As, per this definition, a workplace covers both the organized and un-organized sectors. What is sexual harassment at the workplace? “Sexual Harassment” includes anyone or more of the following unwelcome acts or behavior (whether directly or by implication), namely: • • • • • Physical contact or advances. A demand or request for sexual favors. Making sexually colored remarks. Showing pornography. Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature Key elements of workplace sexual harassment Very often situations that start off innocently end up in inappropriate and unprofessional behaviors. It is important to remember that workplace sexual harassment is sexual, unwelcome and the experience is subjective. It is the impact and not the intent that matters and it almost always occurs in a matrix of power. It is possible that a woman may experience a single instance of sexual harassment or a series of incidents over a period of time. It is important also to remember THE FIRST STEP TO PREVENTION IS that each case is unique and should be examined in its own context and according to the surrounding circumstances as a whole. The following table highlights the subjective nature of the experience and the impact it may have on the person involved, irrespective of the intent of such behavior. To enable prevention of sexual harassment at the workplace, RECOGNITION Workplace Sexual Harassment is behavior that is UNWELCOME SEXUAL in nature A SUBJECTIVE experience IMPACT not intent is what matters Often occurs in a matrix of POWER it is critical to recognize and differentiate between Page 15 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com welcome and unwelcome sexual behavior. Listed are some examples of how “unwelcome” and “welcome” behavior is experienced. UNWELCOME WELCOME Feels bad Feels good One-sided Reciprocal Feels powerless In-control Power-based Equality Unwanted Wanted Illegal Legal Invading Open Demeaning Appreciative Causes anger/sadness Happy Causes negative self-esteem Positive self-esteem 5.5 Prevention & Prohibition LeadSquared’ s rules on sexual harassment • No one has the right to sexually harass our employees. Any person in our company who is found guilty of serious harassment will be terminated, whether they are VPs or assistants. Also, if representatives of our contractors or vendors sexually harass our employees, we will demand that the company they work for takes disciplinary action and/or refuse to work with this person in the future. • Sexual harassment is never too minor to be dealt with. Any kind of harassment can wear down employees and create a hostile workplace. We will hear every claim and punish offenders appropriately. • Sexual harassment is about how we make others feel. Many do not consider behaviors like flirting or sexual comments to be sexual harassment, thinking they are too innocent to be labeled that way. But, if something you do makes your colleagues uncomfortable, or makes them feel unsafe, you must stop. Page 16 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • We assume every sexual harassment claim is legitimate unless proven otherwise. We listen to victims of sexual harassment and always conduct our investigations properly. Occasional false reports do not undermine this principle. • We will not allow further victimization of harassed employees. We will fully support employees who were sexually harassed and will not take any adverse action against them. For example, we will not move them to positions with worse pay or benefits or allow others to retaliate against them. • Those who support or overlook sexual harassment are as much at fault as offenders. Managers and HR especially are obliged to prevent sexual harassment and act when they have suspicions or receive reports. Letting this behavior go on or encouraging it will bring about disciplinary action. Anyone who witnesses an incident of sexual harassment or has other kinds of proof should report to HR. LeadSquared has a legal responsibility to prevent sexual harassment. What to do if you are being or have been sexually harassed • Any associate who feels that they have been or are being harassed, is encouraged to immediately inform the HR SPOC, or the associate should immediately inform one of the members of the Harassment Redressal Committee or send a mail to posh.committee@leadsquared.com. To address the complaints mechanism, we have set up an ICC (Internal Complaints Committee) who are the Harassment Redressal Committee members. The members are: Name Nalini Nagaraj Priya Srivastava Soumya Kant Singh Anu Sharma Murali Krishna • • Designation External Committee Member Presiding Officer IC Member IC Member IC Member Contact No 9535729293 7798299759 9545509394 8310022806 9632544225 Email Id nalinin@silveroakhealth.com priya@leadsquared.com soumya.kant@leadsquared.com anu.sharma@leadsquared.com murali@leadsquared.com The Company will promptly investigate any allegations of sexual harassment in as confidential a manner as possible, and take appropriate corrective action, if warranted. Associates are strongly advised to keep all records in sequence (events with date, time etc.) along with nature of the incident and description of those involved. 5.6 Redress This section is about Redress. It provides helpful information on who can complain, to whom, and what a complaint should contain. It also gives information and lays out the steps involved when a complaint has reached the Complaints Committee, in terms of the process, findings and recommendations. Page 17 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Who can complaint and where? The below table explains who can file a complaint and to whom: What should the complaint contain? The written complaint should contain a description of each incident(s). It should include relevant dates, timings, witness (if any), proof (if any) and locations; name of the respondent(s); and the working relationship between the parties. A person designated to manage the workplace sexual harassment complaint is required to provide assistance in writing of the complaint if the complainant seeks it for any reason. What can an employee expect? When it comes to redress for workplace sexual harassment, employee/worker has a right to expect a trained, skilled, and competent Complaints Committee, a time bound process, information confidentiality, assurance of non-retaliation, counselling or other enabling support where needed and assistance if the complainant opts for criminal proceedings. Rights of a Complainant • An empathetic attitude from the Complaints Committee so that she can state her grievance in a fearless environment Page 18 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • A copy of the statement along with all the evidence and a list of witnesses submitted by the respondent • Keeping her identity confidential throughout the process • Support, in lodging FIR in case she chooses to lodge criminal proceedings • In case of fear of intimidation from the respondent, her statement can be recorded in absence of the respondent • Right to appeal, in case, not satisfied with the recommendations/findings of the Complaints Committee Rights of the Respondent • A patient hearing to present his case in a non-biased manner • A copy of the statement along with all the evidence and a list of witnesses submitted by the complainant • Keeping his identity confidential throughout the process • Right to appeal in case not satisfied with the recommendations/findings of the Complaints Committee Protection Against Retaliation Retaliation includes: • marginalizing someone in the workplace with regard to their roles and responsibilities • socially ostracizing • intimidating someone or someone close or related to the victim; physically, psychologically, and emotionally Retaliation is a serious violation of the Prevention of Sexual Harassment policy and LeadSquared forbids any form of retaliation against anyone who has reported a suspected episode of harassment or has cooperated in any investigation involving a reported episode of harassment. • Any person found to have retaliated against an individual for reporting harassment will be subject to appropriate disciplinary procedures. • Anyone who experiences retaliation in the nature of intimidation, pressure to withdraw the case or threats for reporting, testifying or otherwise participating in the proceedings should report to the Committee immediately. • As with complaints of harassment, this too will be treated as a major misconduct and the Committee will take appropriate action to prevent/rectify the retaliation. Page 19 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Disciplinary action and repeat offenders: After a complaint is received, and once the investigation has been carried out, a determination will be made regarding the validity of the harassment allegations. If it is determined that harassment has occurred; prompt, remedial action will be taken. Employees who are found guilty of sexual assault will be terminated after the first complaint and investigation. Employees who are found guilty of sexual harassment (but not assault) the first time may: • Be reprimanded and fined. • Get a “below expectations” performance review. • See expected promotions and/or salary increases freeze for two years. We may also transfer harassers or take other appropriate action to protect their victims. We will terminate repeat offenders after the second claim against them if our investigation concludes they are indeed guilty. This discipline can include written disciplinary warnings, transfer, demotion, suspension, or termination. We apply these disciplinary actions uniformly. Employees of any sexual orientation or other protected characteristics will be penalized the same way for the same offenses. Outcomes as they affect the complainant should be discussed with the complainant to ensure that needs are met, where appropriate. Helping harassment victims Apart from investigating claims and punishing perpetrators, we want to support the victims of sexual harassment. Potential Outcomes: If the complaint is found to be justified, the complainant may be entitled to any or all of the following: The complainant may receive: • commitment the behavior will cease • private apology (verbal or written) • re-credit of any leave taken due to the harassment • payment of medical and counselling expenses • transfer, with no job disadvantage • other compensation Your job and benefits will not be jeopardized or altered if you choose any of those options or other means to recovery. Page 20 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Speak up, we listen Sexual harassment can exhaust those who endure it. Speaking up about this issue is often tough for fear of not being heard, upsetting managers and challenging corporate culture. Please don’t let these fears deter you. Our company will do everything possible to stop sexual harassment and any other kind of harassment from happening, while supporting harassed employees. We need to know what’s going on, so we can act on it. And by raising your voice on this issue, you help our company create a happy workplace and thrive. 6. Non-Disclosure and Confidentiality Agreement The protection of confidential business information and trade secrets is vital to the interests and the success of LeadSquared. Such confidential information includes but is not limited to, the following examples: Compensation data Pending projects and proposal Computer processes Research and development strategies Computer program & codes Scientific data Marketing strategies Computer lists Scientific formulae Technological data Scientific prototypes Customer lists Financial information Human Resource strategies New market research All employees and associated members are required to sign a nondisclosure agreement as pre-condition of employment. Employees or associated members who improperly use or disclose trade secrets or confidential business information will be subject to disciplinary action, up to and including termination of employment and legal action, even if they do not actually benefit from the disclosed information. Page 21 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 7. Employment Status and Records 7.1 Employment Categories It is the intent of LeadSquared to clarify the definition of employment classification, so the employee understands their employment status and benefit eligibility. REGULAR FULL-TIME employees are those who are not in a temporary or probation status and who are regularly scheduled to work full time schedule. Generally, they are eligible for LeadSquared benefits package subject to term, conditions, and limitations of each benefits program. PROBATION is those whose performance is being evaluated to determine whether further employment in a specific position or with LeadSquared is appropriate. Employees who satisfactorily completed the probation period will be notified of their new employment classification. CONTRACTUAL employees are those who are hired as interim replacements, to temporarily supplement the work force, or to assist in the completion of a specific project. Employment assignments in this category are of a limited duration. Contractual employees retain that status until and unless they are notified of a change. Contractual employees are ineligible for all of LeadSquared other benefits programs. CONSULTANTS are those who facilitate organizational change and/or provide subject matter expertise on technical, functional, and business topics during development or implementation. ACCESS TO PERSONNEL FILES LeadSquared maintains a personnel file on each employee. The personnel file includes such information as the employee’s job application, resume, record of training, documentation of performance appraisal and salary increases, and other employment record. Personnel files are the property of LeadSquared, and access to the information they contain is restricted. Generally, only Human Resources personal will have access to these files. Employees who wish to review to their own file should contact the Human Resources with reasonable advance notice, employee may review their own personnel files in LeadSquared office and in the presence of an individual appointed by LeadSquared to maintain the files. Page 22 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com PERSONNEL DATA CHANGE It is the responsibility of each employee to promptly notify LeadSquared of any changes in personnel data. Personal mailing addresses, telephone numbers, numbers and name of the dependents, individuals to be contacted in the event of emergency, educational accomplishments, and other such status reports should be accurate and current at all times. If any personal data has changed, notify the Human Resources Department. PROBATION PERIOD The probation period is intended to give new employees the opportunity to demonstrate their ability to achieve a satisfactory level of performance and to determine whether the new position meets their expectations LeadSquared use this period to evaluate employee’s capability, work habits, and overall performance. All new and hired employees work for on a probation basis for three months after their date of joining. Any significant absence will automatically extend the probation period by the length of absence. If LeadSquared determine that designated probation period is does not allow sufficient time to thoroughly evaluate the employee’s performance, the probation period may be extended for a specified period. Upon satisfactory completion of the probation period, employees enter the “regular” employment classification. Probation Confirmation/Extension will be done on Alt worklife portal. Process is as follow: • Manager raises the confirmation/Extension request for employee finishing probation on portal • The recommendation by manager and 1:1 discussion goes to BU Head for approval. • Payroll approval • HRBP approval • Employee can acknowledge and download letter from Alt worklife (Login>>HRIS>>My letter) After becoming regular employees, they may also be eligible for LeadSquared provided benefits, subject to terms and conditions of each benefits program. Employees should read the information for each specific benefits program for the details on eligibility requirements. Page 23 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com EMPLOYMENT APPLICATIONS LeadSquared relies upon the accuracy of information contained in the employment application, as well as the accuracy of other data presented throughout the hiring process and employment, any misrepresentation, falsification, or material omissions in any of this information or data may result in the exclusion of the individual from further consideration for employment or, if the person has been hired, termination of employment. 8. Health and Safety Policy/ Procedures Policy Statement LeadSquared is committed to providing and maintaining a safe work environment for the health, safety and welfare of our staff, contractors, visitors, and members of the public who may be affected by our work. We undertake to provide resources in terms of personnel, time, and financial outlay commensurate with the commitment we place on OHS (Occupational Health and Safety) to achieve these objectives. To do this, LeadSquared will: • develop and maintain safe systems of work, and a safe working environment • provide information and training at all levels in the organization to enable all employees to support this policy • require all risks to be assessed prior to engaging in new areas of operation, purchasing new equipment, and implementing new work methods, and that these risks continue to be reviewed All persons who are responsible for the work activities of other employees will be held accountable for: • identifying practices and conditions which could injure employees, clients, members of the public or our environment • implementing steps to control such situations • if unable to control such practices and conditions, reporting these to their superiors LeadSquared demands a positive attitude and performance with respect to health, safety, and the environment by all employees, irrespective of their position. Page 24 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 8.1 Smoking LeadSquared employs a nonsmoking policy. Smoking is not permitted on LeadSquared property or offices at any time. Smoking is accepted to be harmful to the health of those who smoke and those around them (passive smokers). Consequently, smoking while on company premises will be considered as gross misconduct and will render an employee liable to instant dismissal. Smokers who need to take breaks should do so during their allotted breaks. These breaks must be limited to 15 minutes from leaving the workplace to recommencing work. These breaks must not be taken at the entrance to LeadSquared offices. This is a poor representation of the Company and people who may be visiting LeadSquared, visitors do not want to be walking through a cloud of smoke. No special privileges will be afforded to smokers. Any additional breaks (outside of allotted breaks) must be approved by your manager - these must be limited to 10 minutes from leaving the workplace to recommencing work - and the time must be made up at the conclusion of the working day. Excessive smoking breaks will be regarded as absenteeism and disciplinary action may be taken. 8.2 Alcohol, Drugs (& Other Substance Abuse) This policy applies to all levels throughout LeadSquared. The policy is not concerned with social drinking or the taking of prescribed drugs for medical purposes, the concern is directed to instances where alcohol or other drug dependence or abuse affects the job performance and or/safety of any employee(s). LeadSquared is concerned by factors affecting an employee’s ability to safely and effectively perform work to a satisfactory standard. The Company recognizes alcohol or other drug abuse will cause short-term or long-term impairment to such work performance. LeadSquared is committed to creating and maintaining a safe, healthy, and productive workplace for all employees. LeadSquared has a zero-tolerance policy in regard to the use of illicit drugs on their premises or the attending of other business-related premises (e.g., clients) while under the influence of illicit drugs. Contravening either of these points may lead to instant dismissal. Attending work under the influence of alcohol will not be tolerated and may result in disciplinary action or ultimately dismissal. Page 25 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com LeadSquared, at times, makes alcohol available to staff over the age of 18. Limiting the consumption of any alcohol made available is the responsibility of the employee. Driving under the influence of alcohol or any other illicit drug is illegal, it is your own responsibility to ensure you comply with this. 8.3 Manual Handling It is the policy of LeadSquared to provide all employees with a safe and healthy working environment by identifying, assessing, and controlling manual handling risks within the workplace. While managerial staff are ultimately responsible for ensuring the health, safety and welfare of all staff, all employees are expected to participate by reporting potential and actual manual handling hazards within the workplace. In all circumstances, do not lift or manually handle items larger or heavier than you can easily support. If you are in any doubt, ask for assistance. 9. Information Technology Acceptable Usage Policy The purpose of LeadSquared’s Information Technology Acceptable Use Policy (“AUP”) is to prescribe the set of guidelines by which LeadSquared IT Assets may be used by the employees, independent contractors, vendors, and other users (“Users”) with access to LeadSquared’s information technology hardware, software, networks, telephone systems, mobile communications devices, and all other aspects of the information technology systems (“LeadSquared Technology Assets”). The goal of this Policy is to protect the LeadSquared Technology Assets and the information contained in the LeadSquared Technology Assets from misuse. Understanding and complying with this AUP is mandatory for all users. 9.1 User Responsibility and Compliance 9.1.1 The rules and obligations described in this policy apply to all Users of the LeadSquared Technology Systems. It is each User's duty to use the LeadSquared Technology Systems responsibly, professionally, ethically, lawfully, and conduct their activities accordingly. 9.1.2 This policy shall be implemented by the personnel at each business unit who are responsible for managing and protecting the LeadSquared Technology Systems. 9.1.3 Violations of this policy can result in immediate withdrawal or suspension of system and network privileges for individuals. Security privileges may be restored only upon approval by LeadSquared IT Management, Directors of LeadSquared. 9.1.4 LeadSquared reserves the right to modify, amend, or terminate any stipulation of this AUP at any time. Page 26 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com This Policy does not create a contract of employment and does not alter the status of any employee, independent contractor, vendor, or other user. 9.2 Proper Use of LeadSquared Technology Systems 9.2.1 Don’t Transmit or Store Improper or Unlawful Material. Users are strictly prohibited from storing, transmitting, or printing any improper materials on the LeadSquared Technology Systems. “Improper Materials” may include, but are not limited to, materials that (a) infringe the proprietary rights of another person, (b) contain commercial or personal advertisements, solicitations, promotions, or political material; (c) contain viruses or other destructive programs; (d) are harassing, embarrassing, sexually explicit, profane, obscene, intimidating, or defamatory, or (d) constitute fraud, or are otherwise unlawful. Users may not transmit Improper Materials by e-mail or any other form of electronic communication, such as fax, newsgroups, chat groups, instant messenger. Users may not display or store Improper Materials in any part of the LeadSquared Technology Systems. 9.2.2 Don’t Misuse the LeadSquared Technology Systems. Users may not use the LeadSquared Technology Systems for non-business related activities, such as (but not limited to) (a) sending non-business related mass distribution e-mails or chain letters, (b) subscribing to non-business related mailing lists, (c) spending excessive amounts of time browsing the Internet, visiting social networking sites or chatting via instant messaging programs, (d) gambling on the Internet, (e) participating in online sports, (f) playing computer games, (g) engaging in hacking activity. 9.2.3 Identify Yourself Accurately in Communications. Users must identify themselves honestly and accurately when sending email. Users may not alter the "From” field or any other attribution-oforigin field in email messages, or postings. Users may not communicate using personal accounts with clients. Users may not communicate through the LeadSquared Technology Systems either anonymously or under a pseudonym. 9.2.4 Limit Personal Use. LeadSquared is aware that Users may send personal communications through the LeadSquared Technology Systems. LeadSquared expects Users to limit such personal use to a minimum. You are strictly prohibited from making any personal use of the LeadSquared Technology Systems that (a) absorbs a large amount of System resources, (b) distracts you from your duties. 9.2.5 Use the Internet Cautiously. Users should exercise caution when browsing the Internet through Page 27 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com the LeadSquared Technology Systems. In order to avoid receiving unsolicited e-mail or e-mail containing offensive content, Users should avoid posting their LeadSquared Technology Systems email addresses on the Internet until unless if there is a business reason. LeadSquared may implement Internet blocking software to prevent receipt of unsolicited email or to restrict access to inappropriate Internet sites, however, LeadSquared is not responsible for such material. 9.2.6 Obey Copyright Laws. Users may not use the LeadSquared Technology Systems in a manner that infringes the copyright rights of others. Copyright law protects the exclusive rights in images, music, text, audiovisual materials, software, and photographs. The distribution, display, performance, or reproduction of any copyright protected material through the LeadSquared Technology Systems without the permission of the copyright owner is strictly prohibited. 9.2.7 Comply with Software Licenses. The LeadSquared Technology Systems include software that is licensed from third parties. Users must use any licensed software in accordance with the terms of the licensing agreement. Users may not reproduce or install any software that has not been properly authorized or purchased by IT Staff, LeadSquared IT Management, or other authorized personnel. No User may modify, revise, recompile, disassemble, reverse engineer, or otherwise alter any software licensed to LeadSquared without prior written authorization from the software vendor and LeadSquared. 9.2.8 Conserve Resources. Storage space on the LeadSquared Technology Systems is not an unlimited resource, and Users should take all possible steps to conserve the System’s capability. Users should delete unnecessary or unwanted files on a regular basis from network servers, e-mail inboxes and folders, and local hard drives. 9.2.9 No Unauthorized Software. Users may not reproduce or install on the LeadSquared Technology Assets any software that has not been properly authorized, licensed or purchased by LeadSquared. Users are not authorized to install and not limited to (a) Personal Wi-Fi hotspots to connect mobile phones such as Connectify, Thinnix, Custom Java applications, (b) Network sniffing tools such as ethereal, Wireshark etc. or (c) Download mangers such as IDM, DAP, iLivid, YouTube Downloaders and other video downloading tools. 9.2.10 Do not Access without Permission. Only Users who have been given approval or authorization to use LeadSquared Technology Assets are permitted to do so. Users should only access those LeadSquared Technology Assets for which they have permission, even in cases where Users might have the ability to access certain Assets for which they do not have permission. Page 28 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 9.3 Privacy 9.3.1 No Expectation of Privacy. Users should have no expectation of privacy in anything created, stored, sent, or received on the LeadSquared Technology Systems. User accounts on LeadSquared Technology Systems are issued to individuals to assist them in the performing their jobs and remain the property of LeadSquared. Users are permitted to access the LeadSquared Technology Systems for the purpose of conducting LeadSquared business, and personal use should be limited and is not private. 9.3.2 Use May Be Monitored. LeadSquared IT Management and limited others such as members of the Human Resources and Legal departments have access to and may review any information that Users create, store, send, or receive on the LeadSquared Technology Systems, including e-mail and instant messages, and communicate such information to others. 9.3.3 Blocking Hardware – Users may not transmit data through personal external devices such as USB pen drive, CD/DVD drive or Floppy disks. LeadSquared may block USB mass storage media connectivity. 9.3.4 Blocking Software - LeadSquared may implement Internet blocking software to restrict access to inappropriate Internet sites or prevent the receipt of suspicious emails. 9.4 Protection of LeadSquared’ s Confidential Information 9.4.1 What is Confidential Information? Users who have access to LeadSquared’ s confidential information must be careful to protect such information from disclosure to unauthorized recipients. “Confidential Information” includes, but is not limited to, financial information, business plans, marketing plans, employee contact data, software source and object code, outside contracts, and course materials. 9.4.2 How to Protect Confidential Information? In order to prevent unauthorized individuals from viewing such information, Users should exercise proper judgment when sending Confidential Information via e-mail or forwarding e-mail strings containing Confidential Information. 9.4.3 What is Highly Sensitive Information? Certain types of Confidential Information are highly sensitive and must be protected with the utmost security (“Highly Sensitive Information”) because unauthorized disclosure creates the most harm for the owner and greatest legal liability for LeadSquared. “Highly Sensitive Information” is comprised of the following: Page 29 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • Credit card numbers • Bank account numbers. • Passwords and logins. • Personal health information, relating to physical and/or mental health. • Information about sexual activity or orientation. • Information about race or ethnicity • Information about political opinions • Information about religious or philosophical beliefs • Information about trade-union membership • Information about the commission or alleged commission of an offence • Information about any proceedings for any offence committed, or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings. 9.4.4 How to Protect Highly Sensitive Information. Do not attempt to gain access to Highly Sensitive Information unless you are authorized to do so. If you are authorized to handle Highly Sensitive Information, you must follow these “rules of the road.” 9.4.5 Ensure unauthorized individuals cannot read your screen 9.4.6 Lock down your computer if you must leave your desk. 9.4.7 Never send Highly Sensitive Information by email unless it is absolutely necessary; or it is contained in an attachment that is password-protected. 9.4.8 Print out Highly Sensitive Information only if absolutely necessary; or if you need to keep a printed copy, lock it up. 9.4.9 Report Breaches. You should immediately report any unauthorized disclosure of Confidential or Highly Sensitive Information at IT Support Help desk immediately. 9.5 Logins and Passwords 9.5.1 Login Accounts. Users may be assigned a unique login account consisting of a User ID and password (“LeadSquared Login”). Users are responsible for all transactions made using his or her LeadSquared Login. No one may access the LeadSquared Technology Systems by entering another User’s LeadSquared Login. All Users are expected either to lock up or logoff the workstation when they are away from their work area for extended periods of time, and to log off their workstation before leaving for home at the end of each business day, unless the Page 30 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com logoff interferes with an application or normal operation running on the workstation. Users may not disguise their identity while using the LeadSquared Technology Systems. 9.5.2 Password Security. Users are responsible for safeguarding their LeadSquared Login password. Individual passwords should not be printed, stored online, posted on sticky notes, or shared with others. Users are prohibited from using or disclosing another User’s password. 9.5.3 Password Maintenance. Where possible, passwords should be obscure and a minimum of eight characters in length. For optimum security, passwords should include uppercase, lowercase, numbers, and special characters (i.e., @ - # - $ - &). Where applicable. 9.5.4 Passwords Do Not Imply Privacy. As discussed in Section C, Users should have no expectation of privacy when using the LeadSquared Technology Systems. The fact that certain Users are granted access to password-protected areas of the LeadSquared Technology Systems does not imply that such Users retain any expectation of privacy in material created or received within the LeadSquared Technology Systems. LeadSquared IT Management reserves the right, without prior notice, to inspect, examine, audit, read, print, and monitor all data stored on the LeadSquared Technology Systems. 9.6 Security 9.6.1 System and Network Accessibility. Users may access only LeadSquared Technology Systems to which they have authorization. A User’s ability to gain access to other computers or networks within the LeadSquared Technology Systems does not imply a right to such access unless such access is specifically authorized. Users may not browse the LeadSquared Technology Systems in order to gain access to unauthorized areas. 9.6.2 Network Security. Each User is responsible for ensuring that the use of external public networks, such as the Internet, does not compromise the security of the LeadSquared Technology Systems. This responsibility includes refraining from any activity that might networks can introduce malicious programs into the LeadSquared Technology Systems such as viruses, worms, Trojan horses. 9.6.3 Security Controls. Users shall not connect to the LeadSquared Technology Systems by any means other than by those specifically defined by the Divisional IT Staff or LeadSquared IT Management. Personally, owned computers should not be connected to the LeadSquared Technology Systems without prior approval. Users may not disable security controls, such as virus scanners, personal firewalls, and audit trails. Users may not attempt to discover security Page 31 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com flaws. Tampering with any software protections or restrictions placed on computer applications, files or directories is strictly prohibited. 9.6.4 Monitoring. As described earlier the IT Staff, LeadSquared IT Management, and limited others such as members of the Human Resources and Legal departments may monitor a User’s use of the LeadSquared Technology Systems. Monitoring includes, without limitation, reviewing previously viewed Internet sites, material downloaded or uploaded by Users to and from the Internet, and e-mail or instant messages sent and received by Users. Monitoring may be performed at any time, and without prior notice to LeadSquared Users. LeadSquared may monitor its Users for any reason within its sole discretion, including, but not limited to, preventing, or investigating allegations of abuse, assuring compliance with copyright laws, conducting technology audits, conducting internal investigations, or complying with legal or regulatory requests for information. 9.6.5 Physical Security. Users shall take all reasonable and cautious measures to physically secure hardware items belonging to the LeadSquared Technology Systems. Users shall not attempt to circumvent any such physical security measures. Laptop Users should lock the laptop or store the laptop in a secure location whenever it is not in use. 9.7 VOIP User has access to VOIP phone to communicate with customers. The VOIP phone is accessible from conference & discussion rooms. VOIP phones will be provided to end user to carry to their home based on approval from BU heads with business reasons only. 9.7.1 Voicemail 9.7.1.1 Voicemail Setup. If a user has access to the LeadSquared Telephone system, he or she should record an appropriate internal and external voicemail greeting and change the voicemail password from the system default to a unique password. 9.7.1.2 Voicemail Precaution. Users should be cautious when conveying Confidential Information in voicemail messages to others. Users should not play voicemail over speakerphones where others might overhear Confidential Information. 9.7.2 Call recording LeadSquared reserves the right to record the calls made through phone systems. LeadSquared IT team will store the recordings up to 3 month and more based on need. Page 32 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 9.8 Virus & Malware Prevention Viruses & Malware possess the potential to causes substantial damage to individual computer systems and networks. Each User is responsible for taking reasonable precautions to ensure he or she does not introduce viruses or Malware into the LeadSquared Technology Systems. To that end, Users should not open e- mail or file attachments from unknown sources or disable virus protection software installed on the LeadSquared Technology Systems. Laptop Users should comply with virus definition update announcements as required. All Users should report suspected viruses & malware activity to Divisional IT Staff or LeadSquared IT Management immediately and disconnect their machines from LeadSquared Network. 9.9 Destruction of Hardware and Software 9.9.1 General. LeadSquared has made significant investments in hardware and software to provide the essential tools necessary to its Users. Users must not willfully destroy or otherwise delete any software licensed to or owned by, or any hardware purchased, leased, or otherwise in the possession of LeadSquared. Any such damage or destruction shall subject the User to disciplinary action under this policy. LeadSquared reserves the right to seek payment through legal action for any damage incurred by the User. 9.9.2 Hardware damages – Users are responsible to keep hardware safe such as Desktop, laptop, headset, External storage devices, Internet dongles, Mouse & Keyboards. In case of physical damages of hardware Users are liable to pay charges defined by IT Management. 9.10 Incident Reporting Procedure If you come across any suspicious email, please report it to reportspam@leadsquared.com immediately and take no further action until advised. For any IT related issues, please drop an email to it@leadsquared.com 10. PERFORMANCE MANAGEMENT SYSTEM Introduction At LeadSquared we aim to be an employer of choice– one where people want to work. As a business we are committed to giving all members of our team every opportunity to develop their careers, to contribute to our business and to share in its success. The Performance Management System is designed to support the completion of the work of the organisation. It will also define, measure, and recognise the contribution of individuals and help the organisation establish achievable goals for all its people – it is a team-based approach. Page 33 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com At any stage, if you have any questions or concerns you can raise them with your manager. 10.1 Performance Management Philosophy We believe everyone who comes to work really does want to realise their potential and develop their relationships with others (managers, colleagues, and clients). Work is characterised by feelings of satisfaction, frustration, opportunity, exasperation, stimulation, excitement and even feelings of fairness and dishonesty. To succeed and excel, we recognise people need to know what is expected of them, what authority they have and how they are performing. In addition, the approach to managing them needs to be consistent. If our organisation can help its people feel more of the positive emotions and eliminate most of the negative, then we will have come a long way to be an employer of choice. The Performance Management System is designed to be the foundation for fulfilling careers at LeadSquared. 10.2 Position Descriptions All LeadSquared employees will have position descriptions, these will only be produced in an agreed format and amendments need to be approved by Management. Objectives The objective of all position descriptions is to provide an accurate picture of the responsibilities required within specific job roles, the authority levels attached to that role and a clear explanation as to how the output of the role is to be measured. Application The policy on position descriptions will be successfully applied when all position descriptions are used as the basis for performance appraisals and when amendments are completed. Any changes to position descriptions deemed necessary by managers will be communicated as soon as practicable to the employee and this will be implemented by both parties sign a copy. Process Introduction and Amendment of Position Descriptions All employees will receive individual briefings on their position descriptions from their manager. Page 34 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Position descriptions will always be discussed in detail at job interviews. 10.3 Probationary Period Reviews Policy Statement All new employees are appointed with the intention of the placement being permanent unless otherwise stated in the letter of offer. All new employees will serve a probationary period mentioned in the appointment letter to ensure both LeadSquared and the employee are happy with a permanent commitment to the role. Managers should engage new employees in informal performance-based feedback regularly and have specific meetings to discuss progress after one and two months respectively. Prior to the completion of the probationary period new employees will undergo a performance appraisal to provide feedback on performance, guidance on future direction and to set selected specific objectives for the next performance appraisal period. Objectives The objective of the probationary performance appraisal is to ensure both LeadSquared and the employee are satisfied the role is as agreed and a re-commitment to the permanent nature of the position can be made. Application The policy on probationary performance appraisals will be successfully applied when all probationary appraisals are completed within six months of employment commencing. Process • The manager and the employee will agree on the date for a performance appraisal meeting. In the case of all probationary period appraisals, this must be in the month when the probation completion date arrives. • The manager will prepare a written performance appraisal in the approved format and provide this to the employee. • The manager and the employee will meet and agree any objectives for the next appraisal period. Page 35 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 10.4 Performance Appraisals Policy Statement All employees will undergo performance appraisals with their immediate managers on timing that is based on the level of their role. All performance appraisals will be timed from the date employment commenced. This is to ensure performance management is a regular, rather than occasional management responsibility. Performance appraisals are separate from remuneration reviews. Objectives The objective of the performance appraisal system is to constantly monitor progress of the capabilities and achievements of employees, to facilitate the ongoing development of team members and to identify when an employee has demonstrated readiness for greater responsibility. The objective of individual performance appraisals is to review work performance based on both capabilities and achievement of specific performance objectives. Performance appraisals also provide feedback to LeadSquared on the achievability of objectives and the capability of managers to manage their employees. Application The policy on performance appraisals will be successfully applied when all employees’ appraisals are completed within the required time frames. Process • The manager and the employee will agree on the date for a performance appraisal meeting. This must be within the allowable time frame for each role. The frequency of performance appraisals is noted on position descriptions. • The manager will prepare a written performance appraisal in the approved format and provide this to the employee. • The manager and the employee will meet and agree any objectives for the next appraisal period. 10.5 Professional & Personal Development Policy Statement Page 36 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com LeadSquared, in partnership with the employee, will maintain a professional and personal development plan for each employee. LeadSquared’ s role in this is as a supportive facilitator. It will be up to the employee to take a leading role in managing their own development within an approved structure. Funding for professional and personal development will be considered for support by LeadSquared on its merits. LeadSquared may, from time to time, require employees to attend specific training or instruction delivered by internal or external facilitators. This may be on or off-site. Development may take the form of training, education, mentoring, coaching, or counselling. Objectives The objective of the professional and personal development policy is to provide a structured environment for learning and development for the individual within and external to the company. Application The policy on professional and personal development will be successfully applied when employees are managing their own development plans. Process • During the appraisal process the manager will identify and document which areas the employee’s performance may be enhanced by further training. The manager will identify specific courses where possible. • The employee and manager will then work together to complete a professional development plan for the employee. • In response to this the employee can source their own solutions instead of, or in addition to, the manager’s suggestions. Requests to attend these should be submitted in writing to the employee’s immediate manager and must include: o suggested dates o costs o anticipated outcomes 11. REWARDS AND RECOGNITIONS Page 37 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com INTRODUCTION Employees not only want good pay and benefits. They also want to be valued and appreciated for their work, treated fairly, do work that is important, have advancement opportunities, and opportunities to be involved in the organization. Recognition and rewards play an important role in workplace and organizational programs to attract and retain their employees. It is the day-to-day interactions that make employees feel that their contributions are appreciated and that they are recognized for their own unique qualities. This type of recognition may contribute to high morale in the work environment. So, it’s extremely important that managers, who communicate the organizational goals to employees, are included in the development of recognition programs. PURPOSE To recognize and reward outstanding contributions & efforts, to improve and boost Employee Loyalty & Motivation. Recognition is a leadership tool that sends a message to employees about what is important to the leaders and the behaviors that are valued. Managers can use this tool to help employees understand how their jobs contribute to the organization’s overall goals and how their performance affects the achievement of those goals. OBJECTIVES • To align employee performance and achievements in line with Company’s Value Charters & Mission Objectives. • To reward these performance incidents in monetary or non-monetary terms indicating organizational recognition and appreciation towards the employees. • To encourage improvements in productivity, quality of work and customer service. What’s most important in a recognition program? TO SENIOR TO EMPLOYEES: MANAGEMENT: Increases productivity TO MANAGERS OF PROGRAM: Satisfies recognition Includes efficient Needs Administration Produces Return On Creates positive Excites employees Investment (ROI) recognition experience Page 38 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Improves attitudes Provides a wide selection Creates pride of attractive, personalized awards Builds loyalty and Provides timeliness of Pleases management Commitment Recognition Generates positive Guarantees quality of Feedback Award Empowers the workforce Fosters open Develops a partnership communication of with the workforce Involves all employees appreciation Assures efficiency The objective is to differentiate between, and effectively fulfill, all three levels of concerns (senior management, employees, and managers of the program) and achieve levels of performance beyond expectations. SCOPE APPLICABILITY Software Engineering Department including Product Development team, Mobile Team and QA team. Exclusions: The Management of the company are excluded from this program. REWARD GUIDELINES The following chart summarizes reward value parameters. These values apply to cash awards, as well as to non-cash rewards with monetary value (such as event tickets and gift certificates). Table 1 Reward Guidelines Code Reward Value R1 No monetary value (Star Approval Frequency Per Needed Person/Team Manager As often as badges) R2 No appropriate No monetary value (certificate Manager of appreciation) R3 Taxable? As often as No appropriate No monetary value (trophy) Head of One time per fiscal Department year No Page 39 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com R4 Up to Rs. 5000 (non-cash, Head of For every star- No Vouchers of Amazon/Flipkart/ Department badges earned Head of One time per fiscal Department year Head of After completion of Department 10 years in the Similar) R5 Up to Rs. 10000 (cash) R6 Up to Rs. 25000 (cash) Yes Yes company POLICY PROCEDURE Payroll Considerations One-time cash rewards are administered through the additional pay panels of the HR System. The amount is added during the normal payroll cycle. Tax Law Compliance Reward and recognition activities will follow all applicable tax laws. GENERAL RULES Nomination: (Individuals / Teams / Groups): All Managers / Department Heads (along with inputs from immediate Superiors / Reporting Authorities wherever applicable) can nominate employees/teams who have shown reward -worthy performance, behavior, skills, or competence. Benchmarking Reward-worthy: To align employee performance to Company’s Values & Mission Objectives, the standards can be set against the soft skill & Technical Skill. Employee showcasing exceptional examples of following up these values can be considered for Rewards & Recognition Program: • Exemplary effort • Suggesting a new or modified business practice (innovation) • Project completion (exceptional cases) • Outstanding achievements • Customer service TYPES OF REWARDS Page 40 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Types of Rewards Quarterly (Division wise/ Common) Department specific (Varies from department to department) (SOQ – Star of the Quarter) Nominated by respective Managers and directly approved as per the department specific norm. Nominated by Managers and approved by HODs. The awards are distributed in Quarterly meet. Annual (Common) (EOY – Employee of the Year) Nominated and approved by HODs. The awards are distributed in Annual meet. DETAILS DEPARTMENT SPECIFIC AWARDS Different departments have different reward policy which is specific to the nature of work in the department. The detailed policy as per the employee benefit program will be shared to the employee at the time of joining or as and when a policy is published. QUARTERLY AWARDS Periodicity: The nominations for these awards should be submitted to the respective Head of Department keeping Human Resource team in cc, latest by one week prior to the all-hands Quarterly meet. Manager’s Responsibility: The respective Manager in a Division is responsible to assess various parameters (refer Rewards and Recognition Policy (Managers) - LeadSquared) for the specific awards within the team and send an email with the details of the nomination along with the reasons to HOD via emails keeping the Human Resource Team in cc. 1. SOQ – Star of Quarter (Department wise) The Star of the Quarter Award publicly recognizes an employee for its key contribution during the quarter for the overall growth of the company during the respective quarter and bringin g in the most significant impact in the company. Reward & Award: R2 and R3 (See Table 1) Workflow: (Steps involved) Page 41 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com i. The HR Team Collects the data from all the respective Divisions and sends the consolidated report to HODs for final decision. ii. The awards are announced and distributed by HODs in the all-hands quarterly meet. ANNUAL AWARDS Periodicity: The nominations for these awards shall be submitted by all the Head of Department to Human Resource team, latest by fifteen days prior to the Annual meet. 1. EOY- Employee of year The Employee who is the key contributor for the overall growth of the company in the year and bringing in the most significant impact in the company. Reward & Award: R2, R3 and R5 (See Table 1) Workflow: (Steps involved) i. The Founding Team/HODs decides based on various parameters and provides the data latest by fifteen days prior to the annual meet to the HR Team. ii. The awards are announced and distributed by HODs in the all-hands annual meet. 2. Service Award The awards can be provided for length of service. Employees must have at least five years of service to receive a service award. Reward & Award: R2, R5 (For completion of 5 years) and R6 (For completion of 10 years) (See Table 1) Workflow: (Steps involved) i. The HR Team collects the data and sends a consolidated report to HODs for final approval based on the above-mentioned eligibility. ii. The awards are announced and distributed by HODs in the all-hands annual meet/ quarterly meet. NOTE: All the managers/supervisors and HR Team are requested to refer Rewards and Recognition Policy (Managers) – LeadSquared for further guidelines on the policy. 12. EMPLOYEE RELATIONS LeadSquared believes that work conditions, wages, and benefits it offers to its employees are competitive with those offered by other employers in this industry. If employees have concerns about work conditions or compensation, they are strongly encouraged to voice these concerns openly and directly to their seniors. Page 42 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Our experience has shown that if employees deal openly and directly with their seniors, the work environment can be excellent, communications can be clear, and attitudes can be positive. We believe that LeadSquared demonstrates its commitment to employees by responding effectively to employee concerns. In an effort to protect and maintain direct employer/employee communications, we will do anything we can to protect the right of employees to speak for themselves. 12.1 Discipline and its procedures Policy Statement LeadSquared has a human resources’ strategy that recognises the value of its people. Part of this strategy is the fair treatment of all employees. This requires a minimum standard of conduct and performance be agreed, set, and communicated with all employees. If employees do not meet this standard, appropriate corrective action, such as training, should be undertaken. Discipline should only be engaged with an employee on a performance issue if all other corrective action has failed to achieve the desired result. Where an employee has deliberately breached a Company policy or procedure, or engaged in misconduct, disciplinary procedures should be initiated. Employees should be treated fairly, and the proper procedures should be followed. Employees must be made aware of their responsibilities, counselled, and given the opportunity to reach the standards expected of them and the chance to defend themselves before action is taken. It is a requirement to have a third party attend a disciplinary meeting, and notes taken be signed as a true record of discussions. The expected standard must be clearly defined, and the measurement criteria understood. A reasonable date for achievement of standards must be agreed. This should be shown as a minimum time, e.g., within one month. For serious issues, employees must be advised in writing and such advice should be recorded on the employee’s personnel file. Process 12.1.1 Poor Performance Wherever possible the Performance Management System should be used to manage employee performance. However, there may be times when performance, conduct or employee attitude need to be immediately addressed. Page 43 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com If employees fall below required performance standards and performance management processes have not been adequate to address the issue, they must be personally counselled and then given written confirmation of their deficiencies in performance (a written warning). Such written warnings must clearly define the deficiency, the expected standard, by when it should be achieved, how the company will help the employee achieve the improvement required and the consequences of failing to do so. A record of all meetings, training and/or coaching given, and a summary of discussions must be kept by the manager concerned and a copy placed on the employee’s personnel file. This should include date, location, and time of discussion. If an employee consistently fails to meet agreed standards, he/she has been counselled and appropriate support/training has been offered and/or given, then further action is required. This may lead to the employee being dismissed. If an employee has not been performing as required, and: • all possible corrective action, including training and coaching, has been undertaken • the manager concerned has documentation showing the conversations taken place, agreed action plans, and other communication with the employee • the employee has been informed of the standards required and his/her performance deficiency(ies) with action plans in writing on at least two occasions and the consequences of failing to meet the required standards • the employee has been given the opportunity to appeal or respond to the issues highlighted on each occasion • no other suitable option, or other appropriate positions, are available If all these processes have been followed and the employee’s performance still has not improved, then the employee may be dismissed*. 12.1.2 Misconduct 1. Purpose of the procedure/Introduction LeadSquared sets high standard of conduct and performance for the individual employees. Employees are expected to adhere to the code of conduct established by the company. This Page 44 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com procedure sets out the action which will be taken when the company rules are broken and provides a fair, effective, and consistent method of dealing with disciplinary matters such that the employees are guided and feel encouraged to conform to the code of conduct. 2. Principles • Employees are expected to know the standard code of conduct and work expected of them. • Employees will be given details of misconduct, and any evidence in support of the misconduct if it is available, in meeting with the management. • In a subsequent meeting with the management, that will be conducted two working days after the initial meeting, the employee will be given the chance to state the case from his or her point of view and defend his position. • An employee is entitled to be accompanied by a work colleague at the Disciplinary meeting. • No employee will be dismissed for a first breach of discipline, except in cases of gross misconduct. Examples of gross misconduct are breach of sexual harassment policy and non-disclosure agreement signed by the employee. But the categorization if a misconduct as gross or otherwise is entirely at the discretion of the management. • Employees have the right to appeal to the Management of the company against any disciplinary action taken. Final decision taken by the Management will be acceptable to everyone. However, for cases where any law of the land is violated, the process will follow the guidelines established by the government applicable for the case concerned. 3. Informal discussions Before taking formal disciplinary action, the manager will make every effort to resolve the matter by informal discussion with the employee. Only when this fails to bring about the desired improvement should the formal disciplinary procedure be implemented. 4. First Formal Written Warning If conduct or performance is unsatisfactory, the employee will be given a written warning or performance note by the manager. Such warnings will be recorded but disregarded after three months of satisfactory service, providing there have been no subsequent disciplinary issues. 5. Second Formal Written warning Page 45 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com If the employee’s conduct or performance continues to be unsatisfactory even a month after they have received first formal written warning, a disciplinary meeting may be called. Disciplinary meeting will be attended by the employee concerned, immediate manager of the employee, Head of HR, Head of the Department the employee belongs to. In addition, Head of Operations may also attend the meeting. The employee concerned will have the right to be accompanied by a colleague too. The employee will be given a second formal written warning after this meeting. Six months after the second formal written warning, if no further disciplinary action has been found necessary and the minor breach has been resolved, the warning will expire. 6. Final written warning If the employee’s work or conduct fails to improve even a month after the first Disciplinary meeting discussed in point number 5 above, then one more Disciplinary meeting will be convened that will be attended by the same set of people as in the first Disciplinary meeting. A final warning will be given to the employee stating that any further misconduct or continued poor performance will result in a dismissal with appropriate notice per the policy of the company at that point in time. Employees will be paid for this notice period. After a period of 12 months, if no further disciplinary action has been found necessary and the issue has been resolved, the warning will expire. 7. Gross misconduct Summary (instant) dismissal for gross or very serious misconduct is possible (depending on the facts involved) for the following: insubordination, drunkenness, dishonesty, assault, deliberately endangering the safety of others, commission of a criminal offence on our site, and objectionable language**. Managers must, however, consult with senior management prior to taking this action*. An employee can be dismissed without notice on grounds of gross misconduct. For such misconducts, the employee will be suspended with pay while the circumstances of the alleged incident are investigated. A dismissal must be confirmed in writing within 2 working days from the date of the informal discussion or the disciplinary interview. For cases where any law of the land is violated, the process will follow the guidelines established by the government applicable for the case concerned. Page 46 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com In such cases follow the procedure below: • investigate the alleged offence thoroughly, including talking to witnesses, if any • ask the employee for his/her response to the allegation (taking notes of this discussion) • consult with the next most senior manager regarding possible action • if still appropriate, following a thorough investigation, terminate/dismiss the employee • keep a file on all evidence collected and action taken in these circumstances All procedures must be followed in accordance with employment equal opportunity/anti-discrimination legislation. *Note: In all such cases ‘procedural fairness’ guidelines will apply. This means the warning and dismissal process must allow the employee to offer their view of the events concerned. The employee must have every chance to defend himself/herself and has the right to appeal a decision made. If this process is not followed the dismissal may be overturned by an Industrial Relations authority. **Note: For some offences LeadSquared retains the right to report the matter to the police where charges may be laid. The police will be notified about any criminal act against the Company or another member of staff. Management has a duty of care to shareholders and staff and always will be subordinate to legal process. 12.1.3 Violation of company’s ISMS and HIPAA policies Any violation of the company's ISMS or HIPAA policies will result in disciplinary access and will be assessed on a case-by-case basis. It will be determined if the action was voluntary, accidental, or related to a lack of awareness. Consequences could range from warning and re-education to termination of employment. 12.2 Disciplinary Appeal Policy Statement During all stages of the disciplinary process employees have the right to appeal against any disciplinary action taken against them. An employee who believes the disciplinary action taken against them is unfair, can appeal the process. An appeal will be treated fairly, dealt with discreetly and actioned promptly. Page 47 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com This policy should be read in conjunction with the grievance policy. Process An employee is entitled to lodge a written appeal to their supervisor’s manager detailing his/her objections to the disciplinary action within three working days of notification. Managers should: • acknowledge receipt of the employee’s objection • investigate the matter thoroughly • report back to the employee within seven days If the appeal is disallowed an employee is entitled to appeal to the next most senior manager. The next most senior manager should investigate the matter and report back to the employee within 10 working days. The employee has no further right of appeal under this process if the second appeal is disallowed. All procedures must be followed in accordance with employment equal opportunity/anti-discrimination legislation. 12.3 Grievance Policy Statement LeadSquared supports the right of every employee to lodge a grievance with his/her manager if the individual believes a decision, behaviour or action that affects their employment is unfair. We aim to resolve problems and grievances promptly and as close to the source as possible with graduated steps for further discussions and resolution at higher levels of authority as necessary. Grievances should be actioned discreetly and promptly dealt with in an objective manner. Process The employee should attempt to resolve the complaint as close to the source as possible. This can be at a quite informal and verbal level. If the matter is not resolved, then further steps need to be taken. All available attempts to settle a grievance before starting the formal grievance process should be taken. For the formal grievance process to begin, complainants must fully describe their grievance in writing, including dates and locations wherever possible and the remedies sought. Page 48 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com The person(s) against whom the grievance/complaint is made should be given the full details of the allegation(s) against them and should have the opportunity and reasonable time to respond before resolution is attempted. The duration of this should not exceed one week. If resolution is still not reached, the matter will be referred to the Management for consideration and final decision. A grievance taken to this level must be in writing from the employee. The employee’s manager will forward to the Management any additional information thought relevant. The Management will provide a written response to the employee and communicate with any other parties involved. If the matter is still not resolved, the employee will be advised of his/her rights to pursue the matter with external authorities if they wish. In some circumstances, it may not be appropriate for an employee to discuss his/her grievance with the immediate manager. Grievances relating to harassment would fall into this category and an employee should be able to make their approach to a more senior manager. All procedures must be followed in accordance with employment equal opportunity/anti-discrimination legislation. The above procedure takes place for individual employee grievances. Whatever the outcome, it will affect the attitudes of each party and their long-term relationship. The issues which sparked the grievance should be reviewed by management at executive level, so the dispute does not reoccur. 13. WORK HOURS AND OFFICE TIMINGS POLICY INTENT By implementing an employee work hours and office timings policy we ensure that our business operations run smoothly, the company’s and employee’s security is not compromised, and our employees (both in-office and remote ones) can plan their work schedule. This Policy Shall define: 1. Number of expected hours of work per day/week. 2. Flexibility in working hours Page 49 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 3. Office timings for women DEFINITION 1. Office timings defines the in-time and out-time of an employee in the office premises. 2. Flexible working time when employees choose to shift their everyday schedule by starting the day later or leaving earlier. The total of working hours doesn’t change. “Core hours” may be established during which an employee is obliged to be present at the workplace. An employee is required to work during a core time and must work to maintain the average working hours during the accounting period of a month. ELIGIBILITY This policy applies to all our employees who work in regular shift, who need an alternative arrangement about their work schedules and who are eligible by nature of their job. POLICY AND PROCEDURES Your regular attendance at work and punctuality are important factors to your success personally and to the success of our organization as a whole. We all work as a team to provide services to our affiliates and clients, and this requires that each person be at office premises or at their project sites at the assigned times. If a situation arises which makes it impossible to report to office, or if you are going to be late, you must immediately contact your appropriate supervisor. Regular office hours are, 48 paid hours per week, Monday to Friday 9:30am to 7:00 pm., which includes lunch breaks and evening break. LeadSquared provides flexible timings to all those employees who are eligible by nature of work. This policy aims to encourage employees to consider flexible working arrangements with consideration of employee safety. The organization recognizes that a better work-life balance can improve employee motivation, performance, and productivity, and reduce stress. Therefore, the organization wants to support its employees achieve a better balance between work and their other priorities, such as caring responsibilities, leisure activities, further learning, and other interests. The organization is committed to agreeing any flexible working arrangements, provided that the needs and objectives of both the organization and the employee can be met. However, it restricts women employees to leave office Page 50 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com premises latest by 7:00 PM. If the work demands extra work beyond 7:00 PM, they are free to continue their work after reaching home. Provisions relating to office time of women Section 66 of the Factories Act, 1948 imposes restriction on employment of women to work at office between 7.00 pm to 6.00 am. All the female employees should leave the office premises latest by 7:00 PM. If the work demands them to stay back beyond 7:00 PM, they should drop an email at women@leadsquared.com to notify the reason for stay cc’ing their respective manager who is supposed to give his/her consent to stay back and also the employee should mention arrangements of travel they have done to ensure their safe travel back home. The Managers will require a very strong reason to provide the consent to hold back a woman employee beyond 7:00 PM at office premises. Any misconduct towards the policy will be treated as an in-disciplinary act and an appropriate action will be taken against it by the management. 14. LEAVE AND HOLIDAYS Purpose The purpose of leave policy for employees is to lay guidelines regarding when to avail leaves and the process to take leave with pay, leave without pay, Leave of absence policy and so on. Guideline • The year for leave is a calendar year which starts from January 01 to December 31st. • All leave record of the employees shall be maintained in HRMS tool. • All leaves should be applied on HRMS tool before proceeding on leave. In case of emergency, when a leave cannot be applied in advance, telephonic intimation/e-mail to the immediate reporting manager should be done and it must be updated before the cutoff date of the attendance cycle on HRMS tool. • Leave entitlements are calculated from the date of commencement. If an employee joins during the middle of the calendar year, the annual leaves granted are calculated on prorata basis for that calendar year. Page 51 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • We encourage all our employees to utilize their available leaves to the maximum possible extent to maintain their work life balance. • Employees may apply for leave depending upon their leave balance available to their credit on HRMS tool. • An employee can avail paid leave depending upon the leave balance available to him/her. Also, unpaid leaves can be availed only when entire leave balance is exhausted, and employee is in need of such leave which shall be approved from the immediate reporting manager. • If you are absent for a continuous period of 3 (three) working days without obtaining your manager's approval, the Company may construe this as an act of abandonment and the same will be deemed as your notice to terminate this employment. • Weekends and any holiday lying between the sanctioned leave periods will be excluded and not be counted as leave in case of sick and earned leaves. • No Leave for the succeeding year shall be availed in the current year. 14.1 Types of Leave There are different types of Leaves given and listed in Company HR Annual Leave Policy. The leaves can be categorized as Annual Paid Leave or Unpaid Leave as follows: • Earned Leave • Sick Leave • Maternity Leave • Paternity Leave • Leave Without Pay • Covid Specific Leaves 14.1.1 Privilege/Earned Leave Eligibility – Full time employees • Maximum 18 days of Earned Leave will be credited to an employee in a calendar year (entitlement @1.5 leaves per month). • Leave application for Earned leave must reach reporting manager at least 1 week in advance. Page 52 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • For new joiners joining during the middle of year, earned leave will be credited on pro-rata basis. • For existing full-time employees, entire 18 Earned leaves will be credited in the beginning of the calendar year. However, if an employee leaves the organization in the middle of the year, the entitlement for Earned leaves will be pro-rated for the number of months served in the organization and any extra leaves availed more than the entitlement will be adjusted as part of Full and Final Settlement. o For full time employees, earned leaves if unutilized will be encashed by default by the end of every calendar year at the rate of his/her last drawn CTC until and unless the employee opts out of this and declares to opt for carry forward. o Partial carry forward of any unutilized Earned leave will not be allowed. o Privilege/Earned leave can be accumulated up to a maximum of 45 days. Any Leave accumulated above 45 days will lapse automatically. • Employees who have resigned from their duties, earned leave entitlement would be calculated on pro-rata basis till their last working day for encashment. • For the calculation of LTA, 5 consecutive days leaves are compulsory to be availed by an employee (inclusive of holidays). How to apply for Earned Leave? Employee must apply for earned leave at least 1 week in advance through HRMS tool. Once applied, notification will reach immediate reporting manager. Once approved leave notification will reach employee. Leave balance after deduction will be updated on HRMS tool. 14.1.2 Sick Leave Eligibility – Full time employees, interns, and contractual employees • Maximum of 12 days of Sick Leaves will be credited to an employee in a calendar year (entitlement @1 leave per month). • For new joiners joining during the middle of the year, sick leaves will be credited on pro-rata basis. • For existing full-time employees leaves, 12 Sick leave will be credited in the beginning of the year. However, if an employee leaves the organization in the mid of the year, Page 53 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com the entitlement for Sick leaves will be pro-rated for the number of months served in the organization and any extra leaves availed over and above the entitlement will be adjusted as part of FNF. • For existing interns, and contractual employees, sick leaves will be credited monthly by the start of the calendar month @ 1 sick leave per month. • Maximum 12 days of sick leave can be availed by an employee in a year. • Sick leave is a paid leave. • Sick leave can be taken for minimum of half day and maximum of the entire leave balances However, if an employee avails more than 2 consecutive days of sick leave, a supporting medical prescription and fitness certificate by a MBBS doctor will be required to be submitted to get the availed leaves approved for the same. • Leave for more than 2 days without evidence submission can be taken as earned leave. • Sick leave can also be clubbed with earned leave or any other type of leave. • Sick leave not availed during the year will automatically lapse at the end of each calendar year. How to apply for Sick Leave? Sick leave applied by an employee on HRMS tool. For approval, the leave notification will reach the immediate reporting manager. Once approved, approval notification will reach to employee. Leaves are deducted from leave balance from the employees account and latest balance updated on HRMS tool. 14.1.3 Maternity Leave Eligibility – Female Full-time employees • Maternity benefits cannot be claimed by a female full-time employee unless she has worked with the Company for a period of not less than 80 days in the twelve months immediately preceding the date of her expected delivery. • The maximum period for which any female employee shall be entitled to maternity leave shall be twenty-six (26) weeks of continuous leave. The twenty-six weeks can be broken up to pre- and post-delivery period provided that not more than eight (8) weeks of leaves be availed prior to the day of delivery. Page 54 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • Leave taken for prenatal treatment during the first 7 months of pregnancy will be considered as normal leave and not maternity leave. • Other types of leave can be taken in conjunction with maternity leave providing the total period of absence from work does not exceed 52 weeks. • Applications for maternity leave should include personal details, a medical certificate detailing the expected date of confinement or birth, proposed commencement date and duration of leave. • In case of miscarriage or medical termination of pregnancy, a female employee shall, on production of such proof as may be prescribed, be entitled to leave for a period of six weeks immediately following the day of her miscarriage or her medical termination of pregnancy where the pregnancy is terminated other than by birth of a living child and the employee has not commenced maternity leave. • Maternity leave will not count towards continuous service. • Maternity leave can be availed for a maximum of two child births. How to apply for Maternity Leave? Before proceeding on Maternity Leave it is needed to be applied on HRMS tool and must be approved by the reporting manager. The woman employee proceeding on Maternity leave must also submit doctor’s certificate to HR. Leave in case of adoption of child or birth through surrogacy. In case of adoption of child or childbirth through surrogacy a woman employee is entitled for 12 weeks of leave. These Leaves can be availed on when the child has started living with the parents. Maternity leaves including adoption shall not exceed two times availing such leaves during the employment period. Process of leave in case of adoption of child or childbirth through surrogacy In the above-mentioned case leave must be applied at least 6 weeks before the date of adoption. All legal certificate and required documents must be submitted to HR while applying through RMS tool. Page 55 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 14.1.4 Paternity Leave Eligibility – Male Full-time employees • Paternity leave is a paid leave available for a maximum of three days at the time of confinement per childbirth for a maximum of two child births. • Other types of leave can be taken in conjunction with paternity leave providing the total period of absence does not exceed two weeks. • The paternity leave must be taken within 15 days of childbirth, failing which the leaves will lapse. • The leave must be taken at a stretch. • In case of adoption or surrogacy leave can be taken only if child starts living with the parents. • Applications for paternity leave should include personal details, a medical certificate detailing the date of confinement or birth, proposed commencement date and duration of leave. • Where the pregnancy is terminated other than by the birth of a living child and the employee has not commenced paternity leave, his entitlement to such leave ceases to exist. • Paternity leave will count towards continuous service. How to apply for Paternity leave? Paternity leave is applied by an employee on HRMS tool. For approval, the leave notification will reach the immediate reporting manager. Once approved, approval notification will reach to employee. Leaves are deducted from leave balance from the employees account and latest balance updated on HRMS tool. 14.1.5 Covid Specific Leaves Eligibility – Applicable for calendar year 2021 for full time employees and interns • If you have been infected by COVID-19, then an extra 10 days of paid leave (PL) will be granted to you which you can utilize for recovery. If one of your family members has been infected and you have to play role of caretaker, then 5 days of extra leave Page 56 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com will be provided (this can be availed only once irrespective of number of members getting infected in the family). This is applicable for infections happening since 1st Jan 2021 till 31st Dec 2021. • The employee needs to send the supporting documents to HR Team to get the sufficient leave balance added in this category to avail. • The extra unused leaves under this category will get lapsed if unutilized and shall not get carried forward. How to apply for COVID Specific leave? An employee shall first send the supporting documents via email to HR team to get the sufficient balance added in this category in HRMS tool. For approval, the leave notification will reach the immediate reporting manager. Once approved, approval notification will reach to employee. Leaves are deducted from leave balance from the employees account and latest balance updated on HRMS tool. 14.2 Leave without Pay Eligibility – Full time employees, interns, and contractual employees • As the name suggests, leave without pay results in Salary deduction if utilized. If one wants to apply for Leave without pay, they must apply through HRMS tool. Approval of leave without pay is at the discretion of the management. • An employee can avail leave without pay in case existing leave balance is exhausted and employee needs leave due to unforeseen circumstances. • In case no approval taken for leave without pay, such absence of employee will be considered as unauthorized leave. • Disciplinary action will be taken in case of absence without approval. • No salary would be given to employee for the days leave without pay is availed. • An application giving number of days, personal details, employment details, and the reason for the leave should be submitted by the employee. • Other types of appropriate paid leave should be used before approval for leave without pay can proceed. Page 57 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • Failure to return to work on the date stipulated may result in loss of continuity or termination. Extension of leave will be considered on an individual basis. An exchange of letters is required setting out all conditions. • Any intervening weekly offs will be included in Leave without pay. • Leave without pay will not count towards continuous service. How to avail leave without pay? Loss of Pay can be availed by an employee by applying on HRMS tool for approval from immediate reporting manager. Once approved by immediate reporting manager, leave can be availed by employee. Leave will be updated as loss of pay on HRMS tool. 14.3 Unauthorized Leave Eligibility – Full time employees, interns, and contractual employees • Unauthorized absence refers to absence from work without requisite approval. • The employee will need to offer an explanation to the immediate manager in the event of any unauthorized absence. The employee will not be eligible for payment of salary for this period of absence. 14.4 Leave during notice period Employees can NOT avail leave while serving their notice period. Any leave taken during notice period will result in leave without pay or extension of relieving date by number of days leaves were taken during such period (as per mutual agreement with the immediate manager). 14.5 Cancellation of Leave Approved leave can be cancelled depending upon the business demand. Leave once cancelled by reporting manager an automatic notification will reach to the employee and the HR. Leave balance will be updated accordingly by HR. Page 58 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 14.6 Extension of Leave • In case of extension of leave due to any unforeseen circumstances the employee must inform reporting manager in advance. It is employee responsibility to regularize leave on HRMS tool once employee has resumed back on duty. • The extended leave must be applied on HRMS tool in case of planned extension so that both the reporting manager and HR are informed automatically. • Leave extended without permission will be treated as loss of pay. 14.7 Leave Calculation on Resignation/Termination Eligibility – Full time employees In case employee has resigned from the services or on termination of employee privilege leave will be calculated till the last working day of the employee and will be paid during the full and final settlement of the employee. 15. TRAVEL – INTRACITY TRAVEL GENERAL This policy is applicable to employees of LeadSquared based in India who travel within city limits for any business purpose. Any travel for business purposes, within and around the city by road and return on the same day is considered as Intra-city travel. COVERAGE / NON-COVERAGE All permanent employees of LeadSquared based in India whose roles require regular visits to prospects and customers. Examples of such roles/functions: • Field Sales Team in different cities • Solutions Team • Customer Success and Implementation Team in different cities Examples of purpose of visit: • Sales Meeting with prospect • Solutioning discussion with prospect Page 59 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • Onsite onboarding of customer • Customer User Training The policy is NOT applicable to every employee in above mentioned functions. An employee needs to be covered specifically in the policy. The company will communicate this entitlement while making an offer, during joining formalities or at any time during employment as applicable. Employees who make one-off visit to customers are not covered in this policy. They should talk to their manager about any travel reimbursement applicability. Staff not covered: Staff on Contract SUMMARY OF POLICY - LEVEL WISE ENTITLEMENTS “Meeting Day” = A particular day where a person has made at least one intra-city business visit. An employee can claim for a fixed amount of Rs. 400 per diem per Meeting Day for intra-city travel without any bills OR claim with actual travel bills for travel with radio taxi travelling agencies like OLA, UBER etc. Local agency cabs bills will not be acceptable. Please note that an employee can only claim for any one option among the above-mentioned options. *Conditions Apply. Please check next section for details. POLICY DETAILS AND CONDITIONS • The policy is NOT applicable to an employee by default. An employee needs to be covered specifically in the policy. The company will communicate this entitlement while making an offer, during joining formalities and at any time during employment as applicable. • The policy is only applicable for travel within city in which employee is based. • Employees will have to share the expense details on or before 5th of every month and the reimbursement will be done on or before 15th of every month. • Any expense which is not claimed within 30 days from the day of expenditure for reimbursement, will not be considered. • Claim details should contain the date of meetings and client name. Page 60 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • No manual bills will be accepted. • The entitlement amount is applicable if at least one intra-city meeting has been done by the employee on the day for which the claim is made. • The entitlement amount will remain unchanged even if more than one meeting is done on a given day. • The entitlement will be based on the claim made by the employee on meetings and approval of his/her manager for the same. • The company reserves the right to assign or remove the entitlement to any employee at any time. The company may also change the amount of entitlement based on ground realities. • The employees are free to choose the mode of transport – Bike, Car, Metro, Taxi, Bus etc. • No travel receipts are required for the entitlement of Rs. 500 per diem. In case the employee wants to claim more than this amount then the actual bills will be required at the time of claim. Manager’s confirmation on employee’s visit is required for the claim. SETTLEMENT / REIMBURSEMENT All employees are expected to submit the statement of expenses by sending an email to travel@leadsquared.com cc’ing the respective manager within two (2) weeks after the return from the travel. The statement of expenses includes all the expenses that qualifies for reimbursement and amount paid against Per Diem by filling the Travel Reimbursement form which is also available on HRMS Portal. The same should be approved by the reporting manager as well. All the necessary details must be filled in the Reimbursement form. If the details filled are found to be incomplete, the reimbursement against that will not be done. Expenses without receipts whereever applicable will not be considered for reimbursement. Reimbursement will be done within the eligibility and limits specified in the policy document. The cutoff date for filing claim and getting the approval is 5th of every month and the reimbursements for the same will be done by 15th of the same month. Page 61 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com For e.g. an employee filing a claim on 1st Sep, gets the approval by respective manager by 4th Sep, is eligible for reimbursement by 15th Sep. But if the employee files the claim by 6th Sept and gets approval by 8th Sep will be eligible to get the reimbursement by 15th Oct. If any balance amount must be paid to the employee or vice versa, the equivalent value in INR will be computed by finance based on their accounting policy. Employees are expected to exercise prudent business and personal judgement regarding expenses covered by this policy. 16. TRAVEL AND ACCOMMODATION – DOMESTIC AND INTERNATIONAL TRAVEL General This policy is applicable to employees of MarketXpander based in India, who travel between cities for business purpose inside or outside India. Travel within India will be called as “Domestic Travel” and travel to outside India will be called “International Travel”. Coverage/Non-Coverage The policy covers only inter-city travel. It does not cover intra-city travel of employees based in a city. All permanent employees of MarketXpander based in India including Engineering, Sales, Marketing, Success, Support and Shared Services are covered in the policy. Staff/Scenarios not covered: • Staff on Contract Page 62 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • Interns Staff on Contract and Interns may be covered in the policy on case to case basis based on manager’s or management’s approval. Per Diem (or Daily Allowance) is not applicable in case of: • Employees located outside Bangalore visiting Bangalore office to attend monthly/quarterly/annual meetings. Summary of Policy Note that some items mentioned here are subject to prior manager / management approval. Please refer to details in subsequent sections for more information. Domestic Travel International Travel Economy Class where flight is available. Second Tier AC where Air / Train Class flight is not available. Economy class flight As per actuals. Company will book Air / Train Fare As per actuals the tickets. Below USD 70 per night (or equivalent amount in respective Hotel Class Below Rs. 3000 per night currency of the country visiting) Taxi Class Ola or Uber or similar radio taxi Uber or Dedicated Car Taxi Expense As per actuals As per actuals Page 63 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com As per the Per Diem rates in the next table Travel Allowance per day or Per Diem (to cover for (may change depending upon meals / personal Rs. 1000 country) expenses) (check coverage restrictions) (check coverage restrictions) Travel Insurance Not Applicable Company will provide Generally, not applicable (employee Company will provide Per Diem for will get Per Diem post travel). Can be the travel duration via cash or cash Travel Advance provided upon request. in foreign currency Food expenses Covered in Per Diem. Covered in Per Diem. The company may provide a phone with International SIM card on case Phone/Data Expenses Not Applicable to case basis Expenses (Lunch/Dinner Reimbursement on actuals Reimbursement on actuals with Client) (need prior approval) (need prior approval) Business Entertainment Country Name Per Diem Rate (in US Dollars) USA $ 60 Singapore $ 50 UAE $ 50 South Africa $ 50 Europe $ 50 Australia $ 50 New Zealand $ 50 Malaysia $ 40 Indonesia $ 40 Philippines $ 40 Page 64 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Vietnam $ 40 Thailand $ 40 Domestic Travel Policy Domestic travel is defined as travel between two cities within India. It can be undertaken in following scenarios: • Visiting a customer • Visiting another city to host/attend an event • Visiting a college/university for recruitment • Any other business reason if approved by employee’s manager Mode of Travel Default mode of travel is flight. Use economy class flight for domestic travel unless: • Destination is not connected by flights (in such cases you may fly till nearest airport and then use Train or Bus or taxi) • Travel by Train / Bus is faster and substantially cheaper than flight. Class of Travel Mode of Travel Class of Travel Flight Economy Train Second Tier AC Bus Volvo AC or Equivalent Notes Use any other taxi service only if Taxi Ola or Uber or Radio Taxi Ola/Uber cannot be availed. Page 65 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Accommodation Use any business hotel / service apartment or guest house with per night charge of Rs. 3000 (+taxes) or less. Bed & Breakfast can be covered in the hotel rental. Original receipts/bills need to be submitted. Local (Intra-city) commute during domestic travel Any travel for business purposes within and around the city by road and return on the same day is considered as Intra-City Travel. The default mode of Intra-city travel is Radio Taxi like Ola and Uber. Per Diem or Daily Allowance The company will pay Rs. 1000 per day per employee during domestic travel. This amount is intended to cover food and general living expenses. No expense receipts are required to claim this amount. The Per Diem amount will be paid for non- working days (like weekend / holidays) also if they fall in between the duration of employee travel. Example: Onward journey starting on Friday of one week and return journey on Wednesday of next week will be counted as 5 days for Per Diem. Per Diem (or Daily Allowance) is not applicable in case of: • Initial joining / onboarding visit of new employees. • Employees located outside Bangalore visiting Bangalore office to attend monthly/quarterly/half yearly/annual meetings International Travel Policy Any travel for business purpose from India to another country is considered foreign travel. Economy class flight will be used for all foreign travels. An additional train/bus journey may be needed if destination is far from landing airport. Visa Processing The company will take care by providing applicable Visa to employee for foreign travel. Page 66 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Accommodation Use any business hotel / service apartment or guest house with per night charge of USD 70 (or equivalent amount in respective currency of the country visiting) or less. Bed & Breakfast can be covered in the hotel rental. Original receipts/bills need to be submitted. Travel and Medical Insurance Any employee traveling outside India must carry International Travel and Medical insurance. The company will provide the same. Intra-city travel during international visit Use metro, bus, taxi services like Uber - whichever is fastest and cheapest. In some cases, a dedicated rental car for the duration of stay may be a better option. The employees can avail the same with consent from his/her manager. Per Diem or Daily Allowance The company will pay USD 50 (or equivalent amount in respective currency of the country visiting, refer the table for Per diem in summary above) per day per employee during foreign travel to most countries which have cost of living equivalent to USA. The amount may change (increase/decrease) for a specific country if its cost of living is substantially different from USA. This amount is intended to cover food and general living expenses. No expense receipts are required to claim this amount. The Per Diem amount will be paid for non- working days (like weekend / holidays) also if they fall in between the duration of employee travel. Example: Onward journey starting on 1st of month and reaching India on 1st of next month, is counted as 30 days for Per Diem. Foreign currency The company will provide foreign currency in advance as cash / card to cover the Per Diem amount. Holiday Calendar and Leaves The employees, when onsite, will follow the client’s holiday calendar (if the visit is in context of a customer). Page 67 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com The employees will have to discuss with their manager and client before availing their Privilege Leave (if any). Other Business Expenses Expenses related to business entertainment or any additional expenses incurred during the travel or transit from India to the destination will be reimbursed at actual with approval from your Manager. If invited to participate in an international meet / conference / trade fair and the company has approved it, the expenses not covered by the sponsoring authority will be provided by the company and within a limit which will be communicated. Expenses excluded from reimbursement • All personal communication expenses (Telephone, Fax, Courier etc.) • Conveyance and other expenses incurred on pleasure trip or sightseeing. • Any change in routing of the Travel to cover additional locations entailing additional airfare for personal purposes. • Stay beyond the business requirement, expenses incurred on spouse, children and others. • Personal expenses of any nature. e.g. personal cosmetics, visits to hairdressers, purchase of newspapers/magazines, buying alcohol and tobacco. • Any other additional claims other than those specifically allowed above are excluded. Travel arrangement process For prior arrangements and Travel advance, kindly send the following details on email to travel@leadsquared.com at least one week in advance with a copy to your manager with following details: Destination Dates (Start and end date) Duration (days) Visa Air Ticket Visa on Arrival OR I have valid Business Visa OR Requesting Travel desk to arrange Visa MMT (will book myself); OR Page 68 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Requesting Travel Desk to Book MMT (will book myself); OR Requesting Travel Desk to Book MMT (will book myself); OR Requesting Travel Desk to Book Hotel Travel Insurance Destination Currency Per Diem rate (per day) Mention the per diem for the Country you are visiting as per travel policy Total Per Diem Additional Travel Advance Needed Reason for Additional Travel Advance Total (Per Diem + Additional Advance) Amount Needed in Cash Amount Needed in Travel Card All fields of the above table are mandatory. Without such email to travel@leadsquared.com, no per diem will be provided. The employees need to submit all the necessary bills and receipts against the utilization of the advance amount within thirty (30) days after they return from the travel. The excess amount if un-utilized should be returned to the finance team. If the bills against the advance amount is not submitted, then the excess amount will be adjusted from the salary. Settlement/ Reimbursement All employees are expected to submit the statement of expenses and the supporting bills by sending an email to travel@leadsquared.com only cc’ing the respective manager within thirty (30) days after the return from the travel. The statement of expenses includes all the expenses that qualifies for reimbursement and amount paid against Per Diem by filling the Reimbursement form which is also available on HRMS Portal. The same should be approved by the reporting manager as well. Note the following: 1) Attach all bills 2) All bills must have classification (type of expense) and purpose (business purpose of expense) 3) Kindly fill the Reimbursement form An employee will NOT be eligible to travel again if he/she has not cleared settlements of previous travel. Page 69 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com All the necessary details must be filled in the Reimbursement form. If the details filled are found to be incomplete, the reimbursement against that will not be done. The reimbursement of the tickets will be based on the submission of the ticket and the boarding pass. Expenses without receipts where ever applicable will not be considered for reimbursement. Employee must ensure that all expenses are done within the eligibility and limits specified in the policy document. The cutoff date for filing claim and getting the approval is 5th of every month and the reimbursements for the same will be done by 15th of the same month. For e.g. an employee filing a claim on 1st Sep, gets the approval by respective manager by 4 th Sep, is eligible for reimbursement by 15th Sep. But if the employee files the claim by 6th Sept and gets approval by 8th Sep will be eligible to get the reimbursement by 15th Oct. If any balance amount must be paid to the employee or visa versa, the equivalent value in INR will be computed by finance based on their accounting policy. Employees are expected to exercise prudent business and personal judgement regarding expenses covered by this policy. Guide for International travelers Things to be done before you confirm plans during your trip Destination Safety • Research the safety and security situation of your planned destination. • Learn more about your destination, and how to get there safely Learn about: o Political climate, weather, crime, what to bring, health issues, cultural differences, risks, differences in laws, what to expect, transportation, holidays or election days o The location of the nearest Respective country embassy and/or your home country’s embassy. Travel Planning • Check your passport and get a visa (if required) Passport basics: o It can take several months to get a passport; apply now if you don’t have one o Your passport should be valid for at least 6 months after you return from travel Passport Security: Page 70 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com o In some countries you must carry your passport at all times o Take your passport if you are taking a short trip from your base city o In many countries, hotels are required to photocopy or hold guests’ passports overnight (it’s common, but find out in advance if this is true for your destination) o Report a lost or stolen passport immediately to your nearest embassy. Put together a “lost passport kit,” which should be kept separate and includes copies of all your important documents (including the ID page of your passport) as well as photo IDs and the contact information for the nearest country embassy. • Determine if you'll need a visa o Check the respective country or your home country’s embassy. Then answer these questions: What type of visa do I need? How long will it take for my visa to arrive? Will I need a transit visa (for a layover or travel through another country on the way to my destination)? Health and Insurance • Visit your personal physician before you go Schedule a travel consultation with a travel medicine clinic or your personal physician at least 6-8 weeks before you depart o Schedule your appointment early; many immunizations are given in a series over time o A list of travel clinics can be found online. Travel clinics are generally fee-for-service, meaning the cost of the visit may not be covered by your family health insurance. Find out before you go. Make sure to discuss: • vaccinations traveling with medication other health concerns for the destination Understand your health insurance coverage and contact information o Don’t make assumptions about what will be covered. o Determine if your current health insurance plan covers you while abroad, including for chronic medical conditions, non-emergency physician visits, pre-existing conditions. • Insurance Card Page 71 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com o Take your health insurance card with you and familiarize yourself with policies and procedures. o The travel assistance insurance will provide the following: Assistance for medical emergencies including emergency medical evacuation and repatriation. Emergency medication assistance Lost document assistance Emergency cash advance Legal access Emergency translations and interpreters Emergency political evacuation Concierge services Finances • See to your cash needs (ATM card, credit cards) and tell your bank and credit card companies that you’ll be traveling o Ask if they charge foreign transaction fees o Ask if you’ll need a PIN to make purchases abroad o Find out what the exchange rates are for the countries you will be traveling in at • Clean out your wallet or purse and take only the credit cards and ID you will need • Find out if traveler’s checks are a viable option or if you should rely on a debit/credit card and ATMs to obtain cash Important Documents • Take photocopies of important documents and itinerary; give one set to your family and take one set with you • • Make copies of the following documents o Passport identification page and visa o Driver’s license o Insurance cards o Credit cards (front and back) o Flight and other travel itineraries o Immunizations and prescriptions o Significant medical history (e.g., surgeries, major illnesses) Then... o Leave a copy of each at home with family and/or a friend Page 72 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com o Keep a copy in your luggage (separate from any originals) o Scan and email copies to yourself or store photos of them on your smart phone and laptop Communications • Look into cell phones and communicating (internet accessibility, telephone cards and costs) • Cell phones Ways to get a cell phone for your travel: o Ask your current cell phone service provider to unlock your respective country phone o Buy an international plan for your cell phone if it can be used in the country you are visiting (check with your carrier) o Buy a phone when you reach your destination then purchase a SIM card that can be recharged on a pay-as-you-go basis • Check in o Set a schedule for weekly check-ins with a family member at home so someone knows you’re safe • Receiving calls from home o Making international calls from your cell phone can be expensive, but incoming calls may be free o Skype and Google Voice may offer cheaper international calling rates from other countries. • • Collect calls o Learn how to make collect calls from your destination o Find country-specific telephone codes online Emergency phone numbers o • Make a list of emergency phone numbers and bring it with you. Emergency cell phone use o If you are using your cell phone during an emergency that could last hours or even days, try texting Instead of calling to save battery life on your phone Safety During Your Stay • Be aware of the cultural differences and abide by the local customs. Page 73 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com o Be aware of the cultural differences and abide by the local customs. o Request a hotel room between floors two and seven. Some fire department ladders will not reach above the seventh floor. o Always check the nearest fire stairwell, hoses, and emergency telephone when checking in to a hotel. o Be aware of your surroundings o Invest in a good map of the city you are visiting o Use the “buddy system” – try to travel in groups consisting of colleagues or locals from the country. • Road crashes and suggestions for road safety: o Do not ride in unofficial taxis or buses. o Avoid overcrowded vehicles or vehicles that are in poor condition. Do not travel at night, especially in rural or mountainous areas. Carry a cell phone. o Ride vehicles with accessible and functional seat belts. o Do not ride with drivers who seem to be fatigued, under influence of alcohol or medication or distracted. o Be alert for irresponsible driving (e.g. speeding, inattention to driving, disregard for signage and signals). o Speak out if driver is speeding or driving irresponsibly. o If driver continues to drive irresponsibly, politely ask to be let out at first safe opportunity. o If renting a car abroad, always purchase the additional liability insurance. o If driving, be sure to research and understand the applicable laws, including road signs. For reimbursements during travel • Keep receipts for all work-related expenses • Keep your department informed of any changes to your itinerary or serious issues that occur during your trip. Upon Return • Submit travel expenses according to the company policy. Page 74 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 17. EMPLOYEE BENEFITS 17.1 GRATUITY Gratuity means reward payable to an employee by an employer in lieu of continuous service It becomes payable upon cessation of employment and after rendering a continuous service of not less than five years, either on retirement or upon resignation. However, in case of death or disablement, the Gratuity benefits will be applicable irrespective of the number of years of service completed by the employee. The gratuity payable to employee can be totally forfeited: • If service of such employee is terminated for his riotous or disorderly conduct or any other act of violence on his part: or • If service of such employee has been terminated for any act which constitute an offence involving moral turpitude provided that such offence is committed by him in the course of his employment. As per the prevailing provisions of the Gratuity Act, the Gratuity shall be payable on the basis of the following formula (subject to a maximum ceiling laid down under the Act) (15/26) x (Last Salary* drawn) x (number of completed years of service), where 6 months or more of service is considered as one year. * Salary as defined in the Payment of Gratuity Act, 1972. 17.2 GROUP HEALTH INSURANCE LeadSquared offers the following health and life insurance programs for employees: 1. GMC (Group Mediclaim Coverage) – Group Mediclaim coverage (GMC) is a medical health insurance plan offered to the group of people where the benefits offered are similar to all the members of the group. The policy takes care of the hospitalization expenses and other allied expenses as opted by the LeadSquared. This is applicable to full-time employees only. This includes employee, two parents (or in-laws), 1 spouse and 2 children. The detailed policy document will be shared separately to the employees at the time of joining. Page 75 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 2. GPA (Group personal Accidental Coverage) – The group personal accident policy is a type of group insurance policy which offers financial protection against any accidental injuries, accidental disability, or accidental death. This is applicable to the employees and Interns. The employee specific / intern specific detailed document of the policy will be shared separately at the time of joining. 17.3 EMPLOYEE WELFARE POLICY PURPOSE The purpose of this policy is to provide guidelines for all the employees to utilize the employee welfare budget at LeadSquared for team bonding activities. SCOPE The following members of LeadSquared are covered: • • • • Fulltime employees Employees under probation period Interns Direct Contractors EXCLUSIONS: All the members who are not listed above are excluded from this program. APPLICATION: Employee Welfare expenditure must be for team bonding purpose and to have fun in groups. The objectives of this Policy are to: • • Give direction to LeadSquared employees on the conduct expected when incurring and approving Employee Welfare expenditure, Define Employee Welfare expenditure and the approval and monitoring process of such Page 76 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • expenditure, Ensure that all LeadSquared Employees comply with the Employee Welfare policy DEFINITION OF EMPLOYEE WELFARE The “provision of Employee Welfare” refers to the provision of: • • Any recreational activity or anything decided by the group of employees for team bonding. Accommodation or travel connected with or to facilitate such Employee Welfare EXCLUSIONS The employees cannot utilize the welfare fund for the following: • • • For exchanging gifts to spend the welfare fund For overnight stays in teams For alcohol consumptions during the welfare fund utilization THE BUDGET The budget for the Employee Welfare expenses is Rs. 1000 per employee per quarter irrespective of the levels of employee position. This includes all types of expenses incurred for the activity like travel, stay, food, etc. (Please note that alcohol consumption is not included) If there is a new joiner in the team, the budget for the new member allotted depends on the date of joining. If the new joiner joins within first 45 days of the quarter, the new joiner will be eligible for Rs. 1000 for that quarter. If the new joiner joins after 45 days of the quarter, the new joiner will be eligible for Rs. 500 for that quarter. The details of the quarters are: Quarters Q1 Q2 Q3 Q4 Details 1-Jan to 31-Mar 1-Apr to 30-Jun 1-Jul to 30- Sep 1-Oct to 31-Dec The employees can utilize the budget in teams which can be either department wise or region wise. The various existing departments are: Page 77 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • • • • • • • • • • Engineering (Software Development, Product Management and Testing) Mobile Team Sales India Sales International Sales Development Presales Marketing Customer Support Customer Success Shared Services (Human Resource, Talent Acquisition, Finance & Accounting, Administration & Procurement) This can be changed from time to time as per the company strategies. PRINCIPLES The key principles underlying this Policy are that Employee Welfare expenditure must be: • • • • Only incurred for employees’ benefit. All the supporting documents like bills, receipts and expense form shall be submitted to finance team via email for reimbursements and corporate, accounting and taxation purposes, with the department/team purpose identified subjected to the budget mentioned above. With prior approval of reporting manager. In accordance with the company’s decorum. POLICY DETAILS AND CONDITIONS: • • • • • • • Team members of a department/region are supposed to plan the recreational activity outside of the work premises once in every quarter along with the reporting manager for fun and team bonding. The reporting manager’s consent is a must. One or multiple teams can plan the Employee Welfare expenditure together for a quarter. Individual employee cannot claim this budget if unutilized. An individual also cannot utilize this budget for private affairs and later claim for the amount. Any employee is not allowed to bring in any of their respective family members or friends outside of the LeadSquared team for such activities. The budget per employee remains fixed irrespective of whether the employee is associated with one or multiple teams in one quarter. If an employee changes the team within a quarter, the employee can utilize the budget only once (either along with the former team or the later team) If a department/employee has not utilized the budget in one quarter, it can be carried forward to a maximum of one quarter post which it gets lapsed. I.e. if the Page 78 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • department’s/team’s budget is carried forward to next quarter, the sum of amount for first and the second quarter is clubbed together and granted to the department/team subject to submission of the supporting documents. If the expenditure is more than the allotted budget, the reimbursement will only be limited to the budget mentioned above. STEPS INVOLVED: • • • When a department’s/region’s members decide to plan the event, the respective reporting manager must send a prior mail to all the team members stating the details of the event and inviting all the team members for the same. It is the reporting manager’s responsibility to gather all the bills and receipts and the expense form duly filled once the event is completed and submit a copy of it within next three working days to the finance team cc’ing HR and respective Head, informing about the event via email. The email also must contain the list of team members who have taken part in the event. The finance team then verifies all the supporting documents and reimburses the amount according to the criteria mentioned above. 17.4 EMPLOYEE REFERRAL POLICY Purpose The purpose of the Employee Referral Program is to recruit high quality talent for the open positions of the company. Recruiting great talent is important for LeadSquared’s continued growth and success. The market for recruiting talent is challenging and the competition is quickly increasing. The employee referral program is intended to bring in the best possible talent for mission of equal employment opportunity for all candidates. To be eligible to receive an employee referral award, the following criteria must be met: Employee Eligibility ➢ You must be an employee at the time of the referral and the award payout Page 79 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com ➢ You should not be involved in the hiring process of the eligible position. ➢ All the employees of LeadSquared except the members of Management, Talent Acquisition and Human Resources are eligible for referral bonus. Candidate Eligibility ➢ Candidates must meet the basic qualifications for employee referral award-eligible positions. ➢ Candidates must follow the prescribed application process for the position. ➢ Candidate and the employee who referred must still be employed in LeadSquared in the offered position in good performance standing when the payout of the referral bonus Award Eligibility ➢ All the open positions of LeadSquared are eligible for referral bonus, the open positions will be updated on our careers page on a regular basis. ➢ In the event the same candidate is referred by more than one employee/source, the person/source who submitted the referral first will receive credit for the referral. ➢ Once an employee refers any candidate, they will have to undergo all selection procedure & once the candidate gets selected, it would be communicated to the employee by Talent Acquisition if the referral is hired. ➢ Award payments will be included in the employee’s regular paycheck and will be subject to all applicable taxes. Referral Amount Relevant Experience Referral Fee (Rs.) Paid when referred employee completes 2+ years 50000 6 months How to Submit a Referral To participate in this program, an employee must upload their referrals against the open job roles on our recruitment portal MyNextHire Account. Link: https://leadsquared.mynexthire.com/employer/referrals Page 80 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Please login using your LeadSquared O365 id. You will be able to track the status of all the candidates referred here. 18. SEPARATION 18.1 Termination The employment is terminable by either side by giving notice (as per the terms of the offer letter) or payment in lieu thereof. However, such notice will not be deemed necessary in case of termination on grounds of serious neglect or dereliction of duty, breach of rules and regulation or conduct prejudicial to the interest of the company. In case you remain absent from duty without prior permission in writing from the management or if you proceed on leave without prior sanction or overstayed the sanctioned leave without first getting it sanctioned, for a continuous period of eight days, your service is liable to be terminated without any further reference to you. Your services would cease automatically on your attaining the age of 60 years. You are liable to be retired early if the company doctor to be mentally or physically unfit to carry out your duties certifies you. Any employee who wishes to resign from the services of the Company should give the required notice period as per the terms & conditions of his appointment letter. The employee should also mention his / her present address & contact telephone number, since the Accounts & HR divisions require this information to notify their full and final settlement. The employee is required to submit a written letter / email of resignation, indicating the last working day, and submit it to his/her Reporting Manager. The notice period required to be given by an employee while submitting his / her resignation is as follows: • In case the employee wants to be relieved earlier, he/she shall surrender in lieu thereof salary equivalent to the days for which the notice falls short of the period. However keeping in view the exigencies of work, management has right to either accept the resignation letter and relieve the employee earlier or ask him / her to serve the entire period of notice. In the event of an employee resigning from the company without giving the stipulated notice affects the work and also does not permit the company from recovering the security deposits/ advance of company by the time he / she leaves the company the outstanding amount shall be recovered from his / her full and final salary payment and for all purpose he / she will be treated as absconding. Page 81 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com The employee’s Reporting Manager should normally accept the resignation, and the acceptance will clearly mention: • Date of resignation • Date of acceptance • Notice period (to be served or waived off) At the time of full & final settlement, all the reimbursements will be cleared on a pro-rata basis against relevant bills. In case the employee does not submit the bills, the Company will pay this amount and treat this as taxable income. In case the employee decides to withdraw the resignation within the stipulated notice period, and the employee’s Reporting Manager accepts the withdrawal of resignation, there will not be any break in their services and the continuity of service will be maintained. If the employee wishes to reconsider his / her decision after the full & final settlement (this practice, however, will not be encouraged), and the employee’s reporting manager agrees to accept the employee back in to the Company, the employee’s appointment will be treated as a fresh appointment and the employee will not get any benefit for the previous period, such as bonus, gratuity, LTA, Medical, PF, etc. The employee who resigns has to surrender the company assets in his / her possession including company laptop/ telephone/ any other company’s property at the time of leaving the services of the company. Any excess payment made to the employee such as excess leave, loans advances etc. the same shall be adjusted / deducted while settling his / her full and final payment. HR Department shall conduct an Exit Interview with the employee and observations recorded in the prescribed format in the respective personal file. An experience & relieving certificate will be issued to the employee within next two weeks after the date of relieving of the employee. 18.2 Retirement The normal age for retirement is 60, and it is our policy for employees to retire at the end of the month in which their 60th birthday falls. In certain circumstances consideration may be given to fresh employment being offered to you after retirement. Such offers will be totally at the discretion of the Chief Executive Officer or Chief Operating Officer. Page 82 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 18.3 Return of our property On the termination of your employment, you must return all our property which is in your possession or for which you have responsibility. Failure to return such items will result in the cost of the items being deducted from any monies outstanding. 19. NIGHT SHIFT ALLOWANCE 19.1 Objective The objective to frame this policy is to provide additional benefit to employees in any department who all are working at Night Shift based on Company’s official requirement. 19.2 Eligibility All the employees of LeadSquared including trainees/interns who are on rolls of the company are covered under this policy. 19.3 Summary If an Employee is being asked to work at Night Shift based on the official requirement, then that Employee is eligible to claim the Night Shift Allowance for the period/number of Days he/she has worked in the Night Shift at the rate of Rs. 300/night worked. Night Shift Allowance will be paid to that employee over and above his/her CTC. 19.4 Procedure • Night Shift Allowance will be paid to only those employees who work in Night Shift based on the official requirement. • This Night Shift work shall be approved from the Manager of that particular Employee. • The employee needs to submit monthly night shift data (days on which he/she has done night shift) to HR and Finance department keeping the reporting manager in cc and the reporting manager needs to approve. • The cycle for calculating the night shift allowance shall be in sync with the attendance cycle which is 25th of a month till 24th of next month. • This information shall be shared with HR and Finance department by concerned employee/intern and the approval shall be received from the reporting manager latest by on or before 25th of every month. • The Night Shift Allowance will be processed and disbursed to the Employee along with the Salary pay-out of that particular month. Example: Ram has worked in Night Shift from 1st December to 15th December. He will be eligible for Night Shift Allowance as per the calculation given below: Page 83 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Ram has worked at Night Shift: 11 Days (Excluding 4-week offs) Night Shift Allowance: 300*11= Rs. 3300/The employee shall submit the details and get the approval from his reporting manager latest by 25th of December. 20. RELOCATION POLICY 20.1 Purpose Relocation Package is a package provided to the employee joining LeadSquared to provide comprehensive financial and other relocation assistance to compensate the employee of the cost of relocation. 20.2 Eligibility • Employees joining only as fulltime employees. • The employee joining must have accepted a job offer from LeadSquared which requires him/her to relocate from his/her current location to the job location which is different from their current location. 20.3 Bonus Components Travel a. LeadSquared will provide Economy class air travel to the joining location (for the Candidate/Employee, Spouse and Children). Final move flight tickets may only be booked as a one-way ticket from departure location to destination location. b. If the Candidate/Employee will have to make the necessary arrangements for travel by any other mode of transport (Bus/India Railways). Company will reimburse these expenses at actuals upon submission of the bills and approval from Hiring Manager/HRBP. Note: If the Candidate/Employee opts to travel by Indian Railways, the reimbursement is limited to AC 2 tier fare. Page 84 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Transit Stay LeadSquared will arrange for interim accommodation in the company identified hotel/ guest house up to a maximum of 7 days/6 nights for the Candidate/Employee only, starting one day prior to the Date of Joining. Note: Miscellaneous expenses (like Laundry, ‘Lunch & Dinner’ and ‘Telephone & Internet’ charges) at the hotel/ guest house should be borne and directly paid by the Candidate/Employee. As per Income Tax rules, any relocation stay beyond 7 days will attract Income Tax on the entire duration of the stay. In such cases rent paid for the entire accommodation shall be treated as employee’s income and taxed as per Income Tax guidelines. In other words, tax liability arising out of the payment of rent on behalf of employee shall be deducted from employee's salary. Relocation Allowance A one-time payment of INR 50,000 will be offered to cover miscellaneous incidentals incurred during the relocation that are not otherwise reimbursed. This amount will be paid along with the first payroll after deducting applicable taxes. Please Note: In the unlikely event, the employee chooses to leave LeadSquared before the completion of one year of employment (excluding the notice period) with the Company, the relocation allowances will be construed as debt due and should be repaid fully by the employee before his/her last working day. 21. EXTERNAL TRAINING AND DEVELOPMENT POLICY 21.1 Introduction LeadSquared Learning & Development policy is an initiative taken by the organization to ensure that the employees in LeadSquared have access to learning, development and training opportunities which enable them to gain suitable knowledge and skills to carry out their role within LeadSquared, and to develop their talent in ways that fits with LeadSquared’ s vision to meet its strategic objective. 21.2 Eligibility All full-time employees who are on Indian payroll of LeadSquared and have successfully completed probation are eligible to avail the benefits from this policy. Contractual employees and interns are ineligible. Page 85 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com For any exceptions to the above, the employee must get required approval from respective HRBP & BU Head. 21.3 Purpose The purpose of the Learning & Development policy is: ➢ To ensure that employees are supported and enabled to meet the changing demands of LeadSquared so that the group achieves its strategic objectives. ➢ To facilitate employee development/or personal development through assisting staff member to broaden, deepen and thereby further enhance their existing skill base. ➢ To provide a working environment where continuous learning and development takes place to help employees in their roles, increase motivation and enhance staff retention. 21.4 Guidelines Employees must ensure that the training course they want to take, helps them in their current/next level job role at LeadSquared. ➢ Prior approval of the employees’ respective manager and BU Head before taking up any training course will be required. ➢ Employees need to fill and submit the training request form with all relevant training/certification course details to consider the request. ➢ The reimbursement limit for any training/certification courses for an employee can be maximum up to Rs. 50,000 in the tenure of one financial year (1st Apr to 31st Mar) or 5% of their annual fixed CTC whichever is lower (The CTC at the time of start of the course will be considered). Amount can be utilized for one course or multiple courses in the said duration. ➢ This shall include a co-pay system where 80% of the course amount shall be reimbursed by the organization with the upper capping into consideration and 20% shall be paid by the employee himself/herself. ➢ Employee will be eligible for the reimbursement only when a successful completion certificate is produced at the time of claim. Page 86 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com ➢ To reimburse the training/certification cost, employee must submit all the relevant bills and certificate of completion/ passing scorecard to HRBP. ➢ Reimbursement amount will be on actuals, or the limit as defined in policy, whichever is lower. ➢ Employee must sign an undertaking with LeadSquared for one year from the date of completion for certification which states that, in the unlikely event of his/her employment ending in the Company (Voluntary resignation only) before completion of one year from the date of completion towards such trainings, the reimbursed amount will be construed as debt due and should be recovered in full, from the employee as part of full and final settlement. ➢ Please ask your HRBP to provide you the External Learning & Development Request Form for requesting for such trainings. 22. SALARY ADVANCE POLICY 22.1 Policy Brief LeadSquared Salary advance policy describes the eligibility and terms for advancing salary to all our employees as short team loan with appropriate repayment model at zero interest rate. 22.2 Scope The Salary Advance policy applies to all our full-time and contractual employees regardless of their position. Part time employees or interns who have contract span of more than one year may also be included in this policy. Any exceptions to above need approval from BU head & HRBP. 22.3 Policy Elements “Salary Advance” refers to employees receiving a portion of their pay before their next normal salary day. This doesn’t include any money paid to employee for relocation or work-related expenses. Any salary advance given must be considered as loan (without interest) and repaid to the company in full. 22.4 Guidelines Page 87 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com ➢ Employee must finish at least six months or probation period (whichever is later) with LeadSquared. ➢ Salary Advance amount eligibility as mentioned below: Duration with Organization Amount (Max eligibility) Repayment (Max) After completion of at least six 1 month of salary with a 6 monthly installments months of services capping of 5 lacs After completion of at least 2 months of salary with a one year of services capping of 5 lacs After completion of at least 3 months of salary with a one and half year of services capping of 5 lacs 12 monthly installments 12 monthly installments ➢ Employees need to fill and submit the salary advance request form with justification of requirement and submit to respective HRBP and BU Head for approval. Post approval, Payroll team will process the request. ➢ Employee can take salary advance only once in a calendar year. ➢ To be eligible for another salary advance, an employee must have cleared all previous dues with the company. ➢ LeadSquared has full rights to reject the salary advance. ➢ In case of exit of employee (voluntary and involuntary) before the full repayment of salary advance, the balance amount will be recovered in full as part of full and final settlement. ➢ Please note that there can be monetary impact due to TDS for each salary advance cases based on your tax structure ➢ Kindly ask for the salary advance request form from your respective HRBP when required. 22.5 Salary Advance Reasons LeadSquared has predefined the reasons for availing the salary advance. The below list is exclusive: 1. Medical Emergency 2. To cover purchase of necessities (as deemed appropriate by LeadSquared management) 3. Any other emergency (as deemed appropriate by LeadSquared management) Page 88 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com 23. WORKPLACE RELATIONSHIPS & ASSOCIATION POLICY 23.1 Policy Brief LeadSquared workplace relationships & association policy provides guidelines our employees should follow around possible involvement of a personal nature with a colleague. We want to make sure that relationships won’t cause awkwardness or problems in our workplace. 23.2 Scope This policy applies to all our existing employees regardless of gender, sexual orientation, or other protected characteristics. LeadSquared strongly believes that a work environment where employees maintain clear boundaries between employee personal and business interactions is necessary for effective business operations. Although this policy does not prevent the development of friendships between co-workers, it does establish boundaries as to how relationships are conducted during working hours and within the working environment. In the context of this policy, “workplace relationship” includes consensual romantic/amorous relationships. We explicitly prohibit non-consensual relationships. 23.3 Guidelines Before you date a colleague Before you decide to date a colleague, please consider any problems or conflicts of interest that may arise. Please note that employees dating each other cannot be a part of same team. Their respective manager must shift one of them to a different team and update the HRBP immediately. To enable this, the concerned employees must inform their respective Managers and subsequently their HRBPs about the same as soon as possible. Acceptable Behavior We expect you to always behave appropriately and follow our Code of Conduct. This means you and your partner shouldn’t behave in a way that: ➢ Hinders our operations. ➢ Embarrasses your colleagues ➢ Distracts your colleagues from their duties Examples of acceptable behaviour are: ➢ Passing by your partner’s office to talk to them for a short time. ➢ ➢ Discussing your joint vacation plans during breaks Coming to and leaving from work together Page 89 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Examples of unacceptable behaviour are: ➢ Arguing in the workplace. ➢ Improper physical conduct with each other in front of colleagues or clients ➢ Exchanging an excessive number of instant messages or calls during working hours ➢ Boasting about or discussing your relationship in your colleagues’ presence ➢ Expecting/providing favours from the position the partner is in Employees who exhibit such unacceptable behavior will face disciplinary action. When you begin dating a colleague HR won’t get involved in your private lives and will always be discreet. Please inform HR as soon as you become involved and start dating. We want to be aware of these relationships so that we handle any conflicts of interest in a better way. Also, make sure to: ➢ Keep your personal issues and discussions out of the workplace. ➢ Be productive and focused as always. If you find that your work is affected by dating a colleague, seek counselling from your manager, HR, or Counsellor. After you stop dating a colleague If your relationship ends, maintain professionalism, and ensure you won’t disrupt our workplace. You mustn’t badmouth your former partner, sabotage their work, or reveal any intimate details. All these actions break our code of conduct about respect in the workplace and you will face disciplinary action from the management against the same. If your former partner behaves this way, report them to HR and we will investigate as soon as possible. If you’re facing emotional or psychological issues, talk to our in-house counselor. Dating Managers Individuals in supervisory or managerial roles and those with authority over others' terms and conditions of employment are subject to more stringent requirements under this policy due to their status as role models, their access to sensitive information, and their ability to affect the employment of individuals in subordinate positions. To avoid accusations of favoritism and abuse of authority, we strictly prohibit supervisors from dating their team members or those who report to their team members (directly or indirectly). If they do, they’ll face disciplinary action up to and include termination. Employees who are from the level of manager and above are also forbidden from dating anyone who is below the same level, even if they’re in another department. Page 90 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Employees who are below the level of manager may have a relationship with colleagues from other teams or departments if that person is at the same level or within two levels below them. If you break these rules by dating someone who’s a direct report or below the acceptable level of seniority, it’s in your best interest to disclose your relationship as you may face more severe disciplinary action later. Employees will not face demotion, victimization, or loss of benefits. Managers may receive a reprimand depending on the circumstances. We may terminate those who repeatedly disregard this restriction. When one of the former partners becomes manager If an employee gets promoted or transferred from another department, they may find themselves managing a colleague they used to date. In this case, either of the two should let us know. When managing a former partner, you must be extra careful with how you behave towards them. You’re not allowed to favor or retaliate against them. You should do everything possible to prove that you’re treating every team member in a fair and professional way. Document every information or incident necessary for performance reviews and ask for your manager or HR’s advice if you need to discipline or reward your former partner. Couples who are married or in a domestic relationship The following guidelines address employees who are already married, have a domestic partner or other long-term relationship. If you’re the hiring manager for your team, you’re not allowed to consider your spouse or partner for hiring. Doing so might raise questions of favoritism in the hiring process. You are not allowed to refer your partner to other teams or departments. We have a strict “No hiring” policy for Spouses at LeadSquared. 24. WHISTLE BLOWER POLICY 24.1 Scope This policy is applicable to all employees (Full time, part time, interns, direct and indirect contractual employees) of MarketXpander Services Pvt. Ltd. referred as “LeadSquared” in this document. 24.2 Purpose LeadSquared is committed to comply with the highest standards of professionalism, honesty, integrity, and ethical behavior, in line with the Company’s Code of Conduct and Ethics. Page 91 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Section 177 of the Companies Act, 2013 (“Companies Act”) require each company to establish a vigil mechanism for directors and employees to report genuine concerns or grievances. This policy aims to provide a secure environment and to encourage employees of the Company to report unethical, unlawful, or improper practices, acts or activities in the Company and to prohibit managerial personnel from taking any adverse personnel action against those employees who report such practices in good faith. This Policy should neither be a route for taking up a grievance about a personal problem/issue nor be route for raising unfounded or frivolous allegations against colleagues. This policy: • Provides a platform and mechanism for the Employees and Management to voice genuine concerns or grievances about unprofessional conduct without fear of reprisal • It provides an environment that promotes responsible and protected whistle blowing. It urges Employees and Management to report any suspected violation of any law that applies to the company and any suspected violation of the Group Values or LeadSquared’ s Code of Conduct. • Above all, it is a dynamic source of information about what may be going wrong at various levels within the company, and which will help the Company in realigning various processes and take corrective actions as part of good governance practice. 24.3 Policy Every employee of LeadSquared is expected to promptly report to the management any actual or possible violation of the Code of Conduct or any other unlawful or unethical or improper practice or act or activity concerning the Company. The unlawful or unethical or improper practice or act or activity (hereinafter referred to as an “Alleged Wrongful Conduct”) may include, but is not limited to, any of the following: • A violation of any law • Breach of contract • Manipulation of company data/records • Pilferage of confidential/propriety information • Wastage/misappropriation of company funds/assets • Misuse or misappropriation of the Company’s assets • A substantial and specific danger to health and safety • An abuse of authority. • Misappropriation of company assets or resources • Conflict of interest Page 92 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com • Inappropriate sharing of confidential information • Financial fraud of any nature • Non-adherence to safety guidelines • Inaccurate financial reporting • Bribery & Corruption • Insider trading • Other forms of Harassment – Victimization, Bullying, Discrimination etc. • Concurrent employment • No manager, director, department head, or any other employee with authority to make or materially influence significant personnel decisions shall take or recommend an adverse personnel action against an employee in knowing retaliation for a disclosure of information, made in good faith, about an Alleged Wrongful Conduct. DEFINITION The definitions of some of the key terms used in this Policy are given below. a. “Alleged wrongful conduct” means unlawful / unethical / improper practice / act or activity. b. “Audit Committee” means the audit committee constituted by the management of the Company. c. “Disclosure” means concern raised by a written communication made in good faith that discloses or demonstrates factual information that may evidence unethical or improper activity which may be either contrary to the laid down policies of the Company or may be contrary to the acceptable standards of integrity and ethics in similar organizations. d. “Subject” means a person against or in relation to whom a Disclosure has been made or evidence gathered during the course of an investigation. e. “This Policy” or “Policies” means this Whistle-Blower Policy. f. “Whistle-Blower” means an employee making a reporting under this Policy. Any Employee or Director who reports/discloses or demonstrates evidence of an alleged wrongful conduct that may constitute breach of the Company’s Code of Conduct or Values. Roles, Rights and Responsibilities of Whistle-Blowers Whistle-Blowers provide initial information based on a reasonable belief that an Alleged Wrongful Conduct has occurred. The motivation of a whistle-blower is irrelevant to the consideration of the validity of the allegations. However, the intentional filing of a false report, whether orally or in writing is itself considered an improper activity, which the Audit Committee has the right to act upon. Whistle-Blowers shall refrain from obtaining evidence for which they do not have a right of access. Such improper access may itself be considered an improper activity. Whistle-Blowers have a responsibility to be Page 93 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com candid with the members of the Audit Committee or others to whom they make a report of alleged improper activities and shall set forth all known information regarding any reported allegations. Anonymous Whistle-Blowers must provide sufficient corroborating evidence to justify the commencement of an investigation. An investigation of unspecified wrongdoing or broad allegations would not be undertaken without verifiable evidence. Because investigators are unable to interview anonymous WhistleBlowers, it may be more difficult to evaluate the credibility of the allegations and, therefore, less likely to cause an investigation to be initiated. Whistle-Blowers are “reporting parties,” not investigators. They are not to act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the investigating authority. The identity of the Whistle-Blower will not be disclosed except where required under the law or for the purpose of the investigation. We also recommend the Whistle-blower not to disclose his/her identity to anyone else apart from the grievance committee. A Whistle-Blower’s right to protection from retaliation does not extend immunity for any complicity in the matters that are the subject of the allegations or an ensuing investigation or any other misconduct or wrongdoing. This Policy may not be used as a defense by an employee against whom an adverse personnel action has been taken for legitimate reasons or cause under Company rules and policies. It shall not be a violation of this Policy to take adverse personnel action against an employee, whose conduct or performance warrants that action, separate and apart from that employee making a disclosure. Disqualification While it will be ensured that genuine Whistle-Blowers are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection will warrant disciplinary action. Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistle-Blower knowing it to be false or bogus or with a mala fide intention. Whistle-Blowers, who make any Disclosures, which have been subsequently found to be mala fide or malicious or whistle-blowers who makes three or more Disclosures, which have been subsequently found to be frivolous, baseless, or reported otherwise than in good faith, will be disqualified from reporting further Disclosures under this Policy. This itself will be considered as an improper activity which the Audit Committee members have the right to act upon. 24.4 Reporting Mechanism/Compliant (Whistle Blower) Page 94 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Any Director/ employee willing to report/ disclose Alleged Wrongful Conduct may do so in any of the following manner: • In writing, duly addressed to the Ethics Counsellor via email/letter. The email can be sent to grievance.redressal@leadsquared.com. • Complaints can also be sent to the Ethics Counsellor from the official e-mail ID of the Director/ employee. The contact details/ address of the Director/employee should however be provided. In case of absence/ incorrectness of the same, the complaints will be treated as anonymous/ pseudonymous complaints and may not attract further action. • Reporting can also be made to Ethics Counsellor over Telephone. The Whistle Blower would, however, be required to disclose his/her identity and furnish sufficient information for verifying his/her identity by the Ethics Counsellor. Additional information, as deemed necessary, will be sought by the Ethics Counsellor receiving the call. • The Whistle blower whether by letter/email/telephone should provide specific and verifiable information. The details in the complaint should be specific and verifiable. Disqualification In respect of Alleged Wrongful Conduct, those concerning the employees at the levels of Vice Presidents and above should be addressed to the Chairman of the Audit Committee of the Company and those concerning other employees should be addressed to the Ethics Counsellor (or in our case BU head of the respective department) of the Company. One can reach out to the below committee by writing at grievance.redressal@leadsquared.com as well. The contact details of the Chairman of the Audit Committee, other members and the Ethics Counsellor of the Company are as under: • Chairman, Audit Committee: Sudhakar Gorti (9741153900) (Employer) • Prashant Singh (Contact – 9901662111) (Employer) • Soumya Kant Singh (Contact – 9545509394) (Employee) • Priya Srivastava (Contact – 7798299759) (Employee) • Ethics Counsellor: Ms. Neha Goel (Contact – 9986581271) (Representative from Legal and Compliance Department) If reporting in respect of Alleged Wrongful Conduct is received by any executive of the company other than Chairman of Audit Committee or Ethics Counsellor, the same should be forwarded to the Company’s Ethics Counsellor for further appropriate action. They must take appropriate care so that the identity of the WhistleBlower does not get divulged in the process. All Alleged Wrongful Conducts should preferably be reported in writing so as to ensure a clear understanding of the issues raised. Page 95 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Investigation All reports under this Policy will be promptly and appropriately investigated, and all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action, in accordance with applicable law. All concerns raised by the Whistle Blower under this Policy will be investigated by the Chairman of the Audit Committee through a committee comprising members (mentioned above), unless otherwise specified by the Audit Committee. The name of the Whistle-Blower will not be disclosed to the members of the Committee unless required for the purposes of the investigation. The Committee will meet and conduct the investigation in a fair manner, as a neutral fact-finding process without the presumption of guilt. The Committee will complete its investigations and deliver a written report of its findings to the Audit Committee (“Investigation Report”) within 10 working days of receiving the reference from the Audit Committee. The decision of the Chairman of the Audit Committee shall be final and binding on all concerned. All information disclosed during the course of investigation shall remain strictly confidential. Everyone working for or with the Company has a duty to cooperate in the investigation of reports of violations. Failure to cooperate in an investigation, or deliberately providing false information during an investigation, can be the basis for disciplinary action, including termination of employment. If, at the conclusion of its investigation, the Company determines that a violation has occurred, the Company will take effective remedial action commensurate with the nature of the offense. This action may include disciplinary action against the accused party, up to and including termination. Reasonable and necessary steps will also be taken to prevent any further violations of Company policy. The investigation shall be completed normally within 45 days of the receipt of the Protected Disclosure. Protection No unfair treatment will be meted out to a Whistle-Blower by virtue of his/her having reported an Alleged Wrongful Conduct under this Policy. The Company, as a policy, condemns any kind of discrimination, harassment, victimization, or any other unfair employment practice being adopted against the Whistle-Blowers. Complete protection will be given to the Whistle Blowers against any unfair practice. The Company will take steps to minimize difficulties, which the Whistle-Blower may experience as a result of making the disclosure. The identity of the Whistle Blower shall be kept confidential to the extent possible under applicable laws. Any other employee assisting in the investigations or furnishing evidence shall also be protected to the same extent as the Whistle Blower. Page 96 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com Notification Heads of the Departments are required to notify and communicate the existence and contents of this Policy to their employees. The new employees shall be informed about the Policy by the HR department. Document Retention All documents related to reporting, investigation, and enforcement pursuant to this Policy shall be kept in accordance with the Company’s record retention policy and applicable law. 25. CONFLICT OF INTEREST Prior to your employment with LeadSquared, you may be conducting business activities which potentially give rise to real or perceived conflict of interest with LeadSquared’ s objectives and future activities. Employees have an obligation to conduct business within timeline that prohibit to actual or potential conflicts of interest. This policy establishes only the framework within which LeadSquared wishes business to operate. The purpose of these guidelines is to provide general direction so that employees seek further clarification on issue related to the subject of acceptable standards of operation. Transaction with outside firm must be conducted within the framework established and controlled by CXO Level of LeadSquared. Business dealings with outside firms should not result in unusual gains for those firms. Unusual gain refers to bribes; product bonuses, special fringe benefits, unusual price breaks, and another windfalls design ultimately benefit the employer, the employee, or both. Promotional plans that could be interpreted to involve unusual gain require specific CXO Level approval. An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or far of relative because of LeadSquared business dealings. For the purpose of this policy, a relative is any person whose relationship with the employee is similar to that of persons who are related by blood or marriage. No “presumption of guilt” is created by the mere existence of a relationship with outside firms. However, if employees have any influence or transactions involving purchases, contracts, or leases, it is imperative that they disclose to the CXOs of LeadSquared as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties. Personal gain may result not only in cases where an employee or relative has a significant receives any kick back, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving LeadSquared. Page 97 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com In such circumstances, any business or other external interests that have a real or perceived conflict of interest should be declared to LeadSquared. The Company will review the potential areas of conflict with the employee and mutually agree on practical, commercial arrangements, which may include, but is not limited to, the following: • LeadSquared purchases the intellectual property right of the business in question • you combine your business into LeadSquared business, and you are compensated accordingly • you cease your business or remove yourself from active involvement You will at all times advise management of any other interests you or any related bodies corporate in which you participate, have or are potentially entering into that could cause conflict with your employment, interests, or commitment in LeadSquared. Where there are external involvements that do not represent a conflict of interest, these must not affect performance or attendance whilst working at LeadSquared. If such involvement does affect performance or attendance, it will be considered as a conflict of interest giving rise to the remedies described above or disciplinary proceedings including dismissal. Approval must be given from management before approaching any customers for commercial or noncommercial external interests. This includes fund raising, sponsorship and similar activities. If you would like any clarification of any of the policies or procedures contained within this HR Manual, please contact your respective HRBP who will be glad to provide guidance and support. Page 98 of 98 Confidential MarketXpander Services Pvt. Ltd www.leadsquared.com