7 Con Technologies Pvt. Ltd
Human Resource Policies and Procedures
Introduction

7 Con Technologies Pvt. Ltd Human Resources (HR) policies describe the strategic content for 7 Con Technologies' people initiatives. It is based on our values and missions, is addressed to all those who are dealing with people and to all HR professionals.

More than any other factor, it is the know-how, skills and competence of our people which will decide on the Group's success in the marketplace. Therefore, it is crucial how we treat our people and each other within our Group and how we define our values and objectives.

Recognizing this, 7 Con Technology's Corporate Management has created this policy to address key issues as to how we attract, retain and develop our people.

7 Con Technologies Pvt. Ltd New Delhi,

Sujeet Kumar Pandey Director

Table of Contents

Introduction

1    7 Con Technologies' values and leadership principles

2    Dealing with People

3    Joining 7 Con Technologies Pvt. Ltd.

4    Recruitment Policies and Procedure

5    Compensation and Benefits

6    Leave Policy

7    Maternity Policy

8    Professional Development

9    Policy on prevention of sexual harassment at workplace

10    Grievance Handling Policy

11    Anti Bribery / Corruption Policy

12    Corporate Disciplinary Measures and Procedures

13    Employee Code of Conduct and Business Ethics Policy

14    No Smoking Policy

15    Social Compliance Policy

16    Fire Protection Program and    Policy

17    Business Integrity Policy

18    Data integrity Policy

19    Corporate Social Responsibilities

7 Con Technologies' values and leadership principles

Values describe how 7 Con Technologies employees behave. They are the basis of our business relationships. Therefore, special attention is paid to the 7 Con Technologies' values and the company culture.

The 7 Con Technologies' values are:

-    Safety

-    Create value for the customer

-    Commitment to people development

-    Visible leadership

-    Integrity

7 Con Technologies' values and leadership principles

7 Con Technologies Pvt. Ltd leaders live these values by showing the way through their actions. Successful team leaders manage with:

-    Respect, trust and fairness

-    Clarity and focus

-    Openness and truthfulness

-    Drive

-    Commitment to employees

-    Accountability

-    Teamwork

-    Truthful, timely and continuous information

A Shared Responsibility

Each employee has a distinct responsibility in dealing with people be it as a leader of a team or as a peer.

HR managers and their staff are there to provide professional support in handling people matters but should not substitute themselves to the responsible manager. Their prime responsibility is to contribute actively to the quality of HR management throughout the organisation by proposing adequate policies, ensuring their consistent application and coherent implementation with fairness.

Acting as business partners, the HR manager advises and offers solutions which results in positive impact on the organisation's effectiveness. Furthermore, she/he proposes best practices and provides state-of-the-art support and counseling to her/his colleagues. Together they act as co-responsible partners for all HR matters.

This partnership is the key for efficiency in people management.

The communication skills of the HR staff must be appropriate to deal with all delicate matters as they occur frequently in human relations issues. They gain their credibility not only from their professional contribution but also through the care and the excellence of their communication skills.

Dealing with People

The 7 Con Technologies Pvt. Ltd. Management and Leadership Principles describe the management style and the corporate values, specifically in the area of interpersonal relations. Their respect calls for specific attitudes which deserve to be outlined in the present policy:

_ A prerequisite for dealing with people is respect and trust. There can be no room for intolerance, harassment or discrimination of any kind as they are the expression of an elementary lack of respect. This principle suffers no exception and is to be applied at all levels and under all circumstances.

_ Transparency and honesty in dealing with people are a sine qua non for efficient communication. Based on facts and on a sincere dialogue, such transparency is the only solid basis for boosting continuous improvement.

_ This is to be complemented by open communication with the purpose of sharing competencies and boosting creativity. It is particularly relevant in a flat organisation to convey systematically all information to those who need it to do their work properly. Otherwise no effective delegation or knowledge improvements are possible.

_ To communicate is not only to inform. It is also to listen and to engage in dialogue. Every employee has the right to an open conversation with superiors or colleagues.

_ The willingness to cooperate and to help others is a required basis for assessing potential candidates in view of a promotion.

_ In case of discord between an employee and her/his superior or another employee, the possibility must be offered for a fair hearing. The HR staff will provide assistance to ensure that the disharmony is dealt with impartially and that each party has the opportunity to explain her/his viewpoint regardless of hierarchical position.

Joining 7 Con Technologies

The long-term success of the Company depends on its capacity to attract, retain and develop employees able to ensure its growth on a continuing basis. This is a primary responsibility for all managers.

7 Con Technologies' policy is to hire staff with personal attitudes and professional skills enabling them to develop a long-term relationship with the Company.

Diversity and Inclusion

Recognizing the importance of diversity in the workplace, our Diversity and Inclusion Project is in a process of rolling out several initiatives designed to encourage greater diversity at an organisational level.

Our vision is to create workplace environment which is rich in diverse people, talent and ideas. Our focus is to maximize the power of Diversity & Inclusion to drive superior business results and sustainable competitive advantage in a dynamic global marketplace Additional practices include:

•    Operating on a personal basis founded on teamwork and first-name relationships

•    Promotion from within

•    Practicing objective, careful hiring methods

•    Encouraging and assisting employee development by communicating regularly with employees

•    Providing training opportunities and recognizing accomplishments

•    Compensating employees fairly and maintaining a safe work environment

•    Shunning favouritism

•    Respecting each employee's point of view

Employee Orientation Program

Objective of the program is to endeavor and ensure that new employees are naturally and seamlessly integrated with the Company. The program is to be conducted prior to commencement of work by the new employee and also when substantial changes to program and procedures transpire.

Responsibility: The said program will be implemented through Orientation Committee consisting of following members:

i)    Head- HR: Chairman

ii)    Head of the concerned department

iii) Immediate Reporting Manger of the employee.

The Committee while implementing the program will ensure the following:

•    Employee is informed about 7 Con Technologies' Mission, core values and culture.

•    Employee is informed of critical company policies viz. Safety, Grievance Redressal, Confidentiality, Overtime, Leave etc.

•    Employee is made aware of the process to report violation of the policies.

•    Employee is given a thorough explanation of his job duties and expectations from him/her.

•    He/she is made aware of the metrics to measure success/failure in the job, resources available to employee to succeed in the job.

•    He/she should be explained how the job shall contribute to Company's goals.

•    HR representative designs formal induction program for new joiners and the same should be sent to the manager of the department.

Recruitment Policies and Procedure

Towards the growth of an organisation in this competitive business world everyone needs the effective and resultant manpower. Manpower is the utmost important and therefore requires sound recruitment and selection process. Our employment policy is to ensure that:

Selection is strictly on merit without any consideration for caste, creed, gender, religion, race, color, provincial or national origin, disability, sexual orientation, political opinion and other similar factors

Child labor is not allowed

Working hours and other service conditions are designed for better health, environment and social condition of employees and are in accordance with the prevailing applicable laws of the country

Human Resource Development through further education and training is encouraged.

Age & Eligibility

In no circumstances any person below 18 years of age shall be employed The age shall be verified from:

(a)    Birth certificate of Municipality or Government body

(b)    High School Certificate of a Government recognized board showing the age of the person

(c)    Ration Card / Election ID Card showing a clear photograph of a person

Education

Minimum qualification criteria is a university graduate

No person who has convicted for a criminal offence or is mentally and physically unfit to perform the required job would be employed

Procedure

The recruitment process need passing through various stages. Therefore to fit the right person for the right job we have to follow complete recruitment cycle, this involves:

(i)    Manpower Requirement Analysis - Managers needs to analyze the scope of recruitment in their respective departments / teams and forward their recruitment request to the HRD

(ii)    HRD then review / discuss and evolve detailed job description & Key Result Areas for the openings

(iii)    HRD then start sourcing through various channels including job posting, advertisement & empanelled recruitment agencies

(iv)    Responses will be thoroughly screened and short listing based on the required criteria be done at initial stage

(v)    Telephonic interviews followed by face-to-face interaction / skill-tests (if required) with the short listed candidates to be done

(vi)    Filtered candidates will then interviewed by the respective Mangers

(vii)    Background verification / reference checks will be done for selected candidate (viii) Final Evaluation and verifications of documents

(ix) Final discussion and roll-out job offer

Migrant Worker Employment Policy

This Migrant Worker Employment Standards and Implementation Guidance applies both to 7 Con internally as well as its suppliers/sub contractors. It contains a series of performance standards that provide clarity to our organization as well as suppliers and their third party labour contractors on what is required to comply with the forced labour and human trafficking provisions.

These provisions are a culmination of international standards established by widely-recognized and credible organizations such as the United Nations' International Labour Organization (ILO). This section details the standards for the ethical and fair employment of migrant workers. The Supplier is responsible for ensuring that these standards are met for its company, subcontractors and for the companies that it hires to recruit and employ migrant workers.

The standards are divided into three parts reflecting the employment cycle of a worker:

A.    Before Employment - standards that should be met before and during the recruitment process and before a worker arrives to the 7 Con or any of its Supplier's facility.

B.    During Employment - standards that should be met throughout the duration of the worker's employment either at 7 con or at the Supplier's facility.

C.    After Employment - standards that should be met after the worker's employment ends.

A.BEFORE EMPLOYMENT

At 7 Con we ensure that workers shall not be subject to any form of forced, compulsory, bonded, or indentured labour. All work must be voluntary and workers must be free to terminate their employment at any time, without penalty. Prison labour is also not permitted. Our Suppliers must also develop a written corporate policy or code of conduct for the hiring and employment of migrant workers, which sets out specific protections for migrant workers throughout the employment in accordance with applicable laws. As an alternative, supplier can adopt the 7 Con Policy in this regard and shall provide an undertaking that due compliance to the policy and standards are being ensured.

DURING EMPLOYMENT

It shall be ensured that no deduction is made or workers are required to lodge deposits or security payments. If a deposit is required by receiving country law, a receipt shall be issued for any deposit deducted from the wages of, or otherwise lodged by, workers. It shall be ensured that such deposits are reimbursed to workers as soon as possible but no later than one month following employment termination or the expiry of the purpose of the deposit, whichever is earlier. Same standards apply to all suppliers of 7 Con.

Control

7 con and all its suppliers shall ensure that their respective workers shall retain possession and control of their personal identity documents, such as passports, identity papers, travel documents, and other personal legal documents at all times. The only permitted exception is after workers' arrival in the receiving country where there is a short term need to make original identify documents available to government agencies for the processing of visas, work permits or other legally mandated purposes. Surrender of original identity documents shall not be required nor identity documents would be withheld, or workers' access restricted to their identity documents under any circumstances. Supplier may obtain and retain copies of workers' original identity documents. Third party recruiters, employment agents, and labour brokers are expressly prohibited from holding workers personal identity documents. Same standards apply to all suppliers of 7 Con.

Storage

7 con and all its suppliers shall provide each migrant worker working with them, individual secure storage for identity documents, such as passports, identity papers, travel documents, and other personal legal documents. Storage shall be freely and immediately accessible to migrant workers at all times. Storage shall be accessible to migrant workers without assistance and there shall be no barriers to access. Storage shall be lockable, fire-resistant, water-resistant, and secured against unauthorized access. Migrant workers may choose to store their identity documents in such storage but Supplier shall not require workers to do so. There shall be no third party access to, or control of, migrant workers' bank accounts, except to directly deposit wages or compensation payments in accordance with the written contract of employment.

Mandatory or forced savings schemes are expressly prohibited.

No Overtime is permitted to any employee any time

Production Quotas

No such production quotas or piecework rates shall be set at such a level that workers need to work beyond regular working hours to earn the legal minimum wage or prevailing industry wage (excluding overtime). Same standards apply to all suppliers of 7 Con.

Drinking water

Worker's access to drinking water inside the place of production or Supplier-provided facilities and accommodation shall not be restricted.

Toilets

Worker access to toilets in any manner, including limiting toilet breaks or non-payment of toilet breaks, shall not be restricted.

Physical movement

Supplier shall not restrict worker's freedom of movement inside the place of production or Supplier-provided facilities, including the worker's accommodation, except where necessary for worker safety.

Curfew

It shall be ensured by 7 Con as well as our suppliers that no curfews or geographical limits on worker movement beyond Supplier-provided accommodation shall be imposed, except where necessary for worker privacy or safety.

Personal leave

Migrant workers shall be free to return to their home country during periods of annual or personal leave without having to pay any form of deposit, and free for the threat of termination or other penalty. Same standards apply to all suppliers of 7 Con.

Any migrant worker shall not be prevented from contacting his or her sending (or home) country Embassy or Consulate. Same standards apply to all suppliers of 7 Con.

Respectful Environment

It shall be ensured that the workplace is free of any form of harsh, abusive, or inhumane treatment. The use or threat of physical or sexual violence, harassment and intimidation against a worker, his or her family, or co-workers is strictly prohibited. Frontline supervisors and managers shall receive ongoing training on positive management techniques.

Disciplinary procedure:

Disciplinary procedures is equally applied to both migrant workers and local workers and supervisory or management staff and it is applied progressively (for example: verbal warning; written warning; suspension; termination) The implementation procedures including notification of the nature of the complaint, the opportunity for migrant workers to state their case. The procedure should not include abusive or inhumane disciplinary measures such as corporal punishment, mental or physical coercion, or verbal abuse of workers. An impartial and objective appeal process is also followed. Same standards apply to all suppliers of 7 Con.

Grievance procedure:

Our grievance procedure is a non-retaliation policy and a designated responsible individual ( Head HR) to whom migrant workers can submit grievances.

Grievances are to be investigated promptly in a non-discriminatory manner and, save in the case of anonymous complaints, status updates given to the worker through to final resolution. Updates including the final resolution are to be recorded in writing with a copy to the worker in their language and explained to illiterate workers in a language they understand. Same standards apply to all suppliers of 7 Con.

C. AFTER EMPLOYMENT

We ensure repatriation of migrant workers at the conclusion of their contract or in the event that the Supplier terminates the contract for any reason, except due to documented gross misconduct or illegality, before the contract end date. We do not penalize migrant workers for voluntarily terminating their employment contracts at any time. Examples of penalties include, but are not limited to, withholding of wages, bonuses, or allowances already earned, early termination fines or deductions, or the forfeiture of lawful deposits or savings accounts.

Reasonable notice is defined as the lesser of that provided for in the contract of employment or minimum notice provided for by receiving country law, but in no case shall it exceed 30 days. If the migrant worker voluntarily terminates the contract of employment prior to the contract end date without providing reasonable notice, Company or supplier as the case may be, shall not be responsible for paying for repatriation, unless the migrant worker terminated due to harassment, abuse or other serious violation of the worker's rights by the employer.

Compensation and Benefits

7 Con Technologies favors competitive, stimulating and fair remuneration structures offering an overall competitive and attractive compensation package. Remuneration includes salary, any variable part of remuneration as well as other benefits.

Each operating company will establish a compensation practice taking into account relevant external compensation levels as well as the requirement of internal fairness. It is recommended to undertake regular surveys so as to gather relevant information on the remuneration levels practiced at a local or national level.

7 Con Technologies' policy is to strive to position itself as an employer offering remuneration levels above the average of the relevant benchmark. 7 Con Technologies' reviews regularly its competitive position with other companies so as to keep in line with the market trends. However, the evolution of remuneration is in the first instance determined by the capacity of the Company to improve its productivity.

Wage and salary structures should be kept simple and avoid unnecessary complexity so as to provide effective compensation and reward.

Remuneration structures should specifically facilitate the implementation of flat organisational structures and be flexible so as to be able to adapt to the evolution of the market conditions. This means broad spans allowing sufficient flexibility to effectively reward high professional insight and performances as well as individual potential.

Specifically at management level, the variable part of the remuneration may be substantial. This part will be linked to a combination of group, business and individual or team target achievements. The higher the remuneration level, the more important will become the variable part.

It should be understood that, however important remuneration is for each employee, it is not remuneration alone that will stimulate the motivation of the staff.

The HR management sees to it that the implementation of the remuneration policy is fair throughout the organisation and that its spirit is duly reflected.

Leave Policy

At 7 Con we have a properly defined policy for grant of leave to our employees. Broadly the policy delineates the scheme of leave applicable to regular / confirm employees and employees on probation / trainees. The leave policy inter-alia deals with the following aspects:

1.    Category of leaves

2.    Sanctioning authority

3.    Procedure to avail leave

4.    Extension / reduction of leave

I. Category of leaves - The list of leaves allowable at 7 Con are as under:

(a)    Casual Leaves    7

(b)    Sick Leaves    8

(c)    Paid Leaves - One paid leave for each 20 days after the completion of 240 days in a year

(d)    Maternity Leave - for female employees who have completed atleast 80 working days

(e)    Other holidays

Casual Leaves - All employees including those on probation as well as trainees, are entitled to avail a total of 7 (seven) casual leaves in a calendar year. However, an employee shall not be permitted to fragment the casual leaves available to him and the minimum leave under this category shall be for one full working day.

Sick Leave - All employees including those on probation as well as trainees are entitled to avail a total of 8 (eight) casual leaves in a calendar year. An employee shall also be permitted to fragment one sick leave into two half days of sick leave.

Paid Leaves - This category of leave is available to confirmed employees only. Further only such of said employees shall be entitled to this leave who has completed a minimum of 240 days in service in a year after confirmation of his services.

Maternity Leave - for female employees who have completed atleast 80 working days

Other Holidays - All National Holidays

II. Sanction Authority:

Designation of Employee

Confirming Authority

Sanctioning Authority

Executive

Team Leader

Manager

Team Leader/s

Manager

Department Head

Manager

Department Head

Director /s

III.    Procedure to avail leave

The application for leave is to be addressed to the sanctioning authority with approval of the confirming authority. Any leave for a period exceeding two days needs prior approval of the sanctioning authority before proceeding on leave. Number of casual leaves cannot exceed leaves for two working days at a time.

IV.    Extension / reduction of leave

All leaves sanctioned by the concerned authority are subject to cancellation by the department head. In such a case the concerned employee is to be informed beforehand about cancellation or reduction of leave. An employee who has proceeded on leave may seek extension of the leave and such extension can be allowed only by the sanctioning authority.

Maternity Leave and Benefit Policy

1.1    Objective of the policy:

The Maternity Leave and Benefit policy intends to:

a.    Regulate the employment of women in the organization for certain period before and after child-birth

b.    Provide maternity benefit

c.    Ensure that the organization meets all obligations as mandated by the statutes of the state.

1.2    Effective:

The Policy will be in force with effect from 1st February, 2016

1.3    Applicability:

The female employees (Regular, Probationers and Trainees) of the organization

1.3.1    Leave Benefit

1.3.1.1    Eligibility

•    All female employees on confirmed employment who are not covered under the ESI Act, 1948 and have completed 80 days of continuous service with the company are eligible for Maternity Leave.

•    The maximum period for which any employee is entitled to maternity benefit shall be 26 weeks of which 12 weeks can be availed pre-delivery and 12 weeks post delivery. However, if the employee wishes to take it all 24 weeks post delivery she can avail that too.

•    Eligibility of benefit is restricted up to two surviving children only.

1.3.1.2    Regulations

•    The applicant should inform about her pregnancy to the HR department minimum 2 months in advance before proceeding on leave.

•    The application should be supported by a medical certificate confirming the pregnancy and expected date of child birth.

•    Maternity leave may be combined with accrued Earned leave with prior approval.

•    The applicant can avail twelve weeks leave before the date of delivery and twelve weeks leave post delivery. The maximum leave benefit under normal circumstances will be 24 weeks (6 months).

•    Un-availed Maternity Leave is non-encashable.

•    The weekly offs and holidays falling during this period will be part of the leaves availed.

•    It shall be ensured that any pregnant employee is not exposed to any work / function having probability of radiation in any manner.

•    In case of emergency, on call Ambulance facility and doctor is available and Hospital at 0 Km

1.3.1.3    Leave for Illness arising out of Pregnancy

•    Any employee ssuffering from illness arising out of pregnancy, delivery, premature birth of child (Miscarriage, medical termination of pregnancy or tubectomy operation) is entitled to 4 weeks leave with pay, in addition to 12 weeks leave stipulated in 1.3.1.2 above.

•    The employee shall produce a valid medical certificate from a registered medical practitioner along with her leave application and forward it to the HR department minimum 2 weeks in advance.

•    The leave benefit under this clause is permissible only for the purpose it is intended for.

1.3.1.4    Leave without pay

•    Leave without Pay are approved leaves which can be sanctioned only when employee is medically un-fit and unable to resume her duties and also has availed leave under clause 1.3.1.3 (leave for illness arising out of Pregnancy).

•    In such cases, the employee shall produce a medical certificate stating the valid reason for such leaves.

•    In normal circumstances, the benefit under this clause is limited to 4 weeks in addition to leaves provisioned under clause 1.3.1.3 above.

1.3.2 Pay Benefit

•    The employee will be paid salary for the period stipulated in clauses 1.3.1.2 (Regulations) and 1.3.1.3 (Illness arising out of Pregnancy) above.

•    The maternity benefit amount (salary) for the period preceding the date of expected delivery will be paid in advance. e.g. An employee proceeding on Maternity leave from any date between 10th to 20th of a particular month, then she will be paid the salary for the next month in advance.

•    The maternity benefit amount (Salary) for the subsequent period shall be paid within two days of delivery of a child subject to intimation from the concerned employee to the HR department.

•    In addition, an amount of Rs.250/- will be paid one time "Medical Bonus".

•    The pay benefit for "Earned Leaves", if availed in continuation with Maternity Leave shall be as per the "Leave Policy" in force.

1.4 Procedures & General Rules

•    The leave application for availing "Earner Leave" accrued by the employee shall be produced minimum 2 weeks in advance.

•    The leave application for availing "Leave without Pay", shall be submitted minimum 2 weeks in advance. The sanctioning of leave under this clause is at the sole discretion of the sanctioning authority of the Company and should not be perceived as a right for entitlement.

•    In normal circumstances, the employee should resume her duties post maternity benefit stipulated above; failing which the leave period will be treated as unauthorized leave. Consequently, disciplinary action will be initiated and no salary will be paid for these days.

•    Leave deductions (Leave without pay and Notice Period) shall be calculated at the rate of gross payroll salary.

Special Mention: Resignations post Maternity Benefit.

• If an employee wishes to exercise her option to resign her employment immediately after availing the leave with salary benefit under "Maternity" is accepted only on medical grounds. In such case, the reasons stated in the medical report will be mentioned in the relieving letter.

NOTE:

I.    The onus of timely submission of approved leave application forms to the HR department lies completely on the person and while processing the payroll no prior intimation will be sent to the defaulting individuals. Information regarding number of paid days will be mentioned in the pay slip of the month.

II.    Any exceptions would have to be approved by the relevant authority.

III. The "Maternity Leave Application Form" is appended below.

This policy is enforced w.e.f 1st April, 2017 and supersedes all previous policy.

MATERNITY LEAVE APPLICATION FORM

PERSONAL DETAILS

First    Last

Middle Name:

Maternity Leave Type

Start Date

Return Date

Remarks(if any)

*Leave prior to child birth (max. 12 weeks)

Leaves post child birth (max 12 weeks)

Earned Leave combined with Maternity Leave (subject    to

accrued    leave

balance)

2 Leave for illness arising out of pregnancy (max 4 weeks)

3 Leave without Pay (Max 4 weeks)

* Medical certificates required for periods of medical leaves

* - Please provide medical certificate for ( 1 ), ( 2 ) & ( 3 ) above.

Applicant Signature:

Recommending Authority

Approving Authority

HR Use Only

Professional Development

The vision of Training & Development is to become a professional Development center, capable of providing quality programs to support the strategic objectives, while addressing the training and development needs to enhance individual performance

Adequate training programs are developed at the level of each operating company capitalizing on the availability of local, regional or global resources of the Group. It is the responsibility of HR staff to assist the management in the elaboration of training programs.

Objective of Training and Development

Training programs should, as much as possible, be based on action learning and reduce ex-cathedra teaching to the strict minimum.

It is necessary to make optimal use of e-learning programs as a complement to or a substitute for formal training programs.

According to needs they should be made available at shop floor level and enlarge the access to training. It is the role of each manager to assess progress achieved as a result of training programs. Training program should aim to:

•    Upgrade existing knowledge & skills of employees to enable them of successfully accomplish their duties and responsibilities.

•    Provide an opportunity for competency development.

•    Upgrade Technical knowledge.

Assessing and Developing

Each employee is in charge of her/his own professional development. However, the Company endeavours to offer the opportunity to progress for those having the determination and the potential to develop their capabilities.

Such opportunities should take into account the potential of each employee and be discussed with transparency. They will be based on defined possibilities, concentrate on the next career step and not on vague promises or remote hypotheses. The Company encourages its employees to express their objectives and expectations in an open dialogue.

The objective is to retain and motivate employees by offering attractive but realistic career moves allowing them to develop their skills over a long-term period within the framework of economic reality and a changing environment.

Whereas succession plans forecast the Company needs, they will be reconciled, inasmuch as possible, with individual development plans.

HR management provides the support for implementing the necessary planning tools, having in mind the necessary flexibility to cope with unforeseen situations. However, it is understood that each manager is co-responsible for preparing the resources necessary to the development of the Company as this is also part of his accountability.

Policy on prevention of sexual harassment at workplace

I. COMMITMENT: 7 Con is committed to providing work environment that ensures that every employee is treated with dignity and respect and afforded equitable treatment. The Company is also committed to promoting a work environment that is conducive to the professional growth of its employees and encourages equality of opportunity. The Company will not tolerate any form of sexual harassment and is committed to take all necessary steps to ensure that its employees are not subjected to any form of harassment.

II.    SCOPE:

This policy applies to all categories of employees of the Company, including permanent management and workmen, temporaries, trainees and employees on contract at their workplace or at client sites. The Company will not tolerate sexual harassment, if engaged in by clients or by suppliers or any other business associates.

The workplace includes:

1.    All offices or other premises where the Company's business is conducted.

2.    All company-related activities performed at any other site away from the Company's premises.

3.    Any social, business or other functions where the conduct or comments may Have an adverse impact on the workplace or workplace relations.

III.    DEFINITION OF SEXUAL HARASSMENT:

Sexual harassment may be one or a series of incidents involving unsolicited and unwelcome sexual advances, requests for sexual favours, or any other verbal or physical conduct of sexual nature.

Sexual Harassment at the workplace includes:

1.    Unwelcome sexual advances (verbal, written or physical),

2.    Demand or request for sexual favours,

3.    Any other type of sexually-oriented conduct,

4.    Verbal abuse or 'joking' that is sex-oriented,

5.    any conduct that has the purpose or the effect of interfering with an individual's work performance or creating an intimidating, hostile or offensive work environment and/or submission to such conduct is either an explicit or implicit term or condition of employment and /or submission or rejection of the conduct is used as a basis for making employment decisions.

IV.    RESPONSIBILITIES REGARDING SEXUAL HARASSMENT:

All employees of the Company have a personal responsibility to ensure that their behaviour is not contrary to this policy. All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.

V.    COMPLAINT MECHANISM:

An appropriate complaint mechanism in the form of "Complaints Committee" has been created in the Company for time-bound redressal of the complaint made by the victim.

VI.    COMPLAINTS COMMITTEE:

The Company has instituted a Complaints Committee for Redressal of sexual harassment complaint (made by the victim) and for ensuring time bound treatment of such complaints. Initially, and till further notice, the Complaints Committee will comprise of the following four members out of which at least two members will be of the same gender as that of the complainant:

1.    Head HR (Presiding Officer)

2.    Employee at the level of Manager or above from Personnel & Administration Department (Member)

3.    Team Leader of the Division from where the complaint has originated (Member)

4.    A Member Lawyer (Member)

The Complaints Committee is responsible for:

•    Investigating every formal written complaint of sexual harassment

•    Taking appropriate remedial measures to respond to any substantiated

•    allegations of sexual harassment

•    Discouraging and preventing employment-related sexual harassment

VII.    PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION or PROSECUTION OF ACT OF SEXUAL HARASSMENT:

The Company is committed to providing a supportive environment to resolve concerns of Sexual harassment as under:

A. Informal Resolution Options

When an incident of sexual harassment occurs, the victim of such conduct can communicate their disapproval and objections immediately to the harasser and request the harasser to behave decently. If the harassment does not stop or if victim is not comfortable with addressing the harasser directly, the victim can bring their concern to the attention of the Complaints Committee for redressal of their grievances. The Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.

B. Complaints:

1.    An employee with a harassment concern, who is not comfortable with the informal resolution options or has exhausted such options, may make a formal complaint to the Presiding Officer of the Complaints Committee constituted by The Management. The complaint shall have to be in writing and can be in form of a letter, preferably within 15 days from the date of occurrence of the alleged incident, sent in a sealed envelope. Alternately, the employee can send complaint through an email. The employee is required to disclose their name, department, division and location they are working in, to enable the Presiding Officer to contact them and take the matter forward.

2.    The Presiding Officer of the Complaints Committee will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the complaint fall under the purview of Sexual Harassment, preferably within 30 days from receipt of the complaint.

In the event, the allegation does not fall under the purview of Sexual Harassment or the allegation does not constitute an offence of Sexual Harassment, the Presiding Officer will record this finding with reasons and communicate the same to the complainant.

3.    If the Presiding Officer of the Complaints Committee determines that the allegations constitute an act of sexual harassment, he/ she will proceed to investigate the allegation with the assistance of the Complaints Committee.

4.    Where such conduct, on the part of the accused, amounts to a specific offence under the law, the Company shall initiate appropriate action in accordance with law by making a complaint with the appropriate authority.

5.    The Complaints Committee shall conduct such investigations in a timely manner and shall submit a written report containing the findings and recommendations to the Executive Director & Head-P&A as soon as practically possible and in any case, not later than 90 days from the date of receipt of the complaint. The Executive Director & Head-P&A will ensure corrective action on the recommendations of the Complaints Committee and keep the complainant informed of the same.

Corrective action may include any of the following:

a.    Formal apology

b.    Counseling

c.    Written warning to the perpetrator and a copy of it maintained in the employee's file.

d.    Change of work assignment / transfer for either the perpetrator or the victim.

e.    Suspension or termination of services of the employee found guilty of the offence

6.    In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management.

VIM. CONFIDENTIALITY:

The Company understands that it is difficult for the victim to come forward with a complaint of sexual harassment and recognizes the victim's interest in keeping the matter confidential. To protect the interests of the victim, the accused person and others who may report incidents of sexual harassment,

confidentiality will be maintained throughout the investigatory process to the extent practicable and appropriate under the circumstances.

IX.    ACCESS TO REPORTS AND DOCUMENTS:

All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Company except where disclosure is required under disciplinary or other remedial processes.

X.    PROTECTION TO COMPLAINT / VICTIM:

The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action. The Company will ensure that the victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment. However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action.

XI.    conclusion:

In conclusion, the Company reiterates its commitment to providing its employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.

Grievance Handling Policy

Grievance Redressal Committee

Grievance Redressal Committee of the Company consists of following members:

1.    Head HR (Presiding Officer)

2.    Employee at the level of Manager or above from Personnel & Administration Department (Member) preferably a women.

3.    Team Leader of the Division from where the complaint has originated (Member)

4.    A Lawyer nominated by the Board (Member)

The Committee is responsible for:

•    Investigating every formal written grievance relating to terms of employment

•    Taking appropriate remedial measures in the facts & circumstances of the issue, as per the company policy.

Procedures for resolution:

The Company is committed to providing a supportive environment to resolve concerns of its employees as under:

A.    Informal Resolution Options

When an issue is raised the Committee will proceed to resolve the matter. Committee shall resolve /decide the grievance within 45 days from the date of grievance being raised. However employee has to raise his grievance within 60 days and no such grievance shall be entertained if the same is made after the said period

B.    Appeal:

(1) The employee who is aggrieved of the decision of the Grievance Redressal Committee may prefer an appeal to the Board of Directors against the decision of Grievance Redressal Committee. The Board shall, within one month from the date of receipt of such appeal, and dispose off the same.

Anti Bribery / Corruption Policy

7 Con Technologies Pvt. Ltd values are integrity and transparency in business. In support of these principles, company has developed this policy for countering corruption and bribery.

Corruption is understood as the misuse of entrusted power for personal gain.

Bribery is understood as the offer or receipt of any gift, loan, fee, reward or other advantage to or from any person as an inducement to do something which is dishonest, illegal or breach of trust, in the conduct of the enterprise's business.

Scope

The policy covers:

All the employees of 7 Con Technologies Pvt. Ltd All our suppliers and contractors

All outside Authorities / Auditors / Inspectors coming for checking / auditing / inspecting

Objective

The purpose of this policy is to:

(i)    Set out business practices for countering corruption and bribery

(ii)    Give guidelines

To our employee while dealing with contractors, suppliers and outside inspection / auditing agencies To our contractors and suppliers while dealing with our employees

Commitment

7 Con Technologies Pvt. Ltd has ZERO TOLERANCE towards corruption and bribery. The company is committed to serving its clients with absolute honesty and integrity.

The company and its employees commit to this policy and to the pursuit of integrity and transparency.

The responsibility for the policy implementation, monitoring and questions regarding policy and principles rests with the Management.

Operational Guidelines For All Employees

Be honest and trustworthy. Make sure that your behavior complies with this policy and other rules of the company.

Use the company resources in the best interest of the company and avoid its misuse.

Make a clear distinction between the interest of the company and private interest and avoid possible conflicts

Do not pay or accept any bribe / gifts / other services which conflicts with this principle

If you find anyone trying to violate these principles, immediately report the matter to the Management

For Managers

Every Manager has an individual obligation to ensure that any interaction with public officials complies with all relevant laws and regulations, as well as this policy

It is the responsibility of every Manager to communicate this program and ensure that all employees and external parties working on behalf of 7 Con Technologies Pvt. Ltd within their area of responsibility, understand and comply with the objectives and guidelines of this policy

Contractors and Suppliers

7 Con Technologies Pvt. Ltd conducts its procurement / employment practices in a fair transparent manner and takes due care when evaluating major prospective contractors and suppliers. A Copy of our Anti-Corruption / Bribery Policy must be shared and signed by the suppliers. We reserve the right to terminate their services in the event (if found) offering bribes to our employees or in any other way that violates this policy.

7 Con Technologies Pvt. Ltd will avoid dealing with prospective contractors and suppliers who do not have a clean image in this regard.

Communication

7 Con Technologies Pvt. Ltd ensures that all its employees, contractors and suppliers are informed about and understand this program.

Corporate Disciplinary Measures and Procedures

The purpose of the Organization's Disciplinary Measures and Procedure is to help and encourage all employees to achieve and maintain required standards of conduct and work performance. The aim is also to ensure that the Organization's services are maintained effectively while all staff members are treated fairly and equitably.

This procedure sets out the action that will be taken in response to alleged misconduct or poor work performance.

Management must ensure that staff members are aware of general and specific rules, standards and procedures covering work and conduct. Employees must familiarize themselves with these standards and procedures and follow them.

In appropriate cases of minor misconduct or unacceptable performance or behavior, managers should use informal action before formal disciplinary action is taken. This may include setting clear targets and expectations, monitoring progress over a reasonable time period and providing additional coaching or training.

2. Who is authorized to take disciplinary action?

Informal action/First warning or Improvement note/Final warning: Line Manager

Dismissal: If same repetition immediate action may result in suspension from services or in extreme case termination from services by Director / HR Head

3. What is gross misconduct?

Gross misconduct is defined as misconduct serious enough to destroy the employment contract between the Organization and the employee which makes further working relationship and trust impossible. Gross misconduct is normally restricted to serious offences. The principal reasons for summary dismissal could include but are not limited to:

•    Criminal offence which affects the individual's ability to carry out his/her job;

•    Physical assault by an employee on any other person;

•    Theft, misappropriation or unlawful destruction of property: the Organizations', employees' or others';

•    Giving or receiving of bribes or unauthorized gifts;

•    Deliberate falsification of any documents or claims, including timesheets, overtime or expense forms;

•    Data theft or any breach of business confidentiality

•    Serious discrimination relating to a protected characteristic (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation);

•    Deliberately accessing internet sites containing pornographic, offensive or obscene material;

•    Persistent alcohol or drug abuse

•    Providing false information on a job application form including false information concerning immigration status

4. The procedure

If informal action fails to achieve the required improvement in performance or behavior, then this procedure is followed. This procedure applies to all employees, once their probationary period is completed. The procedure for probationary employees is described in Section 6 below.

I. Invitation to a Disciplinary Meeting

-    Following an investigation the employee should, without unavoidable delay, be given a letter detailing the allegation, the possible consequences and inviting them to a disciplinary meeting.

-    The meeting should ideally be arranged within five to ten working days of the alleged misconduct or poor performance issue, allowing reasonable time for the employee to prepare their case.

-    This will also state that they have the right to be accompanied by a trade union representative or work colleague at the meeting.

-    You should also consider whether any reasonable adjustments are required for disabled employees, such as allowing a support worker or sign language interpreter to attend the meeting.

-    At the same time the employee will be provided with copies of all documentation and supporting evidence to be presented at the meeting.

-    The employee should receive details about the problem in advance of any formal meeting to give her/him time to read and digest the information. To suddenly produce new information or allegations about an employee at a disciplinary meeting is likely to be seen as unreasonable.

-    It will be unusual for witnesses to give oral evidence at a disciplinary hearing but if witnesses are to be called the employee should be notified in advance.

II. Disciplinary Meeting

-    Where possible, a note-taker, who must be uninvolved in the case, will take down a record of the meeting.

-    If there are any witnesses, they should not be present throughout the meeting. They should be called in, one by one, to give their evidence and asked to leave once they have done so.

-    The Manager (Director / HR Head or Chairperson Disciplinary Committee) will open the meeting with an explanation of its purpose and will read aloud the allegations.

-    The employee and her/his representative can ask questions including of any witnesses called.

-    The Manager/Chair will then ask the employee if s/he wishes to take the opportunity to respond to the allegations or concerns or if there are any mitigating circumstances to be taken into account. The Manager/Chair may question the employee and any witnesses called.

-    The Manager (or Chair) will summaries the main points of the discussion and ask the employee if they have anything further to say.

-    The Manager (or Chair) will then consider the details heard in private. S/he must decide whether the case against the employee has been established on the balance of probabilities, i.e. whether misconduct is confirmed or the employee's performance is found to be unsatisfactory.

-    If this is the case, when they are considering appropriate disciplinary action, s/he should also consider any special, mitigating circumstances, the employee's previous disciplinary or performance record, how the Organization has dealt with similar cases in the past and whether the proposed action is reasonable in view of all the circumstances.

-    The Manager (or Chair) shall give the employee written confirmation of the decision normally within five working days of the meeting. This will include notifying the employee of her/his right of appeal and the procedure to be followed.

-    The employee should be informed in writing of any decision on whether disciplinary action is appropriate and how long the penalty will last, the improvement expected, the time period for improvement, and the procedure and time limits for appeal.

-    If the decision is to be dismissal, the employee should be notified as quickly as possible, explaining the reasons for the dismissal and the date when the employment will end.

-    The employee should be informed in writing of any decision on whether disciplinary action is appropriate and how long the penalty will last, the improvement expected, the time period for improvement, and the procedure and time limits for appeal.

III. Disciplinary Action

If following the disciplinary meeting it is decided to take action, one of the sanctions below may be applied.

Stage 1 - Written Warning

If conduct does not meet acceptable standards the employee will normally be given a written warning by his/her supervisor/line manager. S/he will be advised of the reason for the warning, that it is the first stage of the disciplinary procedure and of their right of appeal. A copy of this written warning detailing the complaint; the change in behavior required; and dates for review will be kept in the employee's personal file but will be disregarded for disciplinary purposes after a specified period.

Or

Improvement Note for Unsatisfactory Performance

If performance does not meet acceptable standards the employee will normally be given an improvement note by his/her supervisor/line manager. S/he will be advised of the reason for the note and of their right of appeal. A copy of this note detailing the performance problem; the improvement required; the set timescale for improvement; and dates for review will be kept in the employee's personal file but will be considered spent after a specified period - subject to achieving and sustaining satisfactory performance.

Stage 2 - Final Written Warning

If performance is still unsatisfactory or if a further misconduct occurs, or if the misconduct is sufficiently serious to warrant only one written warning but insufficiently serious to justify dismissal (in effect both first and final written warnings), the employee will be given a final written warning. This will give details of the complaint; the improvement required; the set timescale for improvement; and dates for review. It will warn that dismissal may result if there is no satisfactory improvement and will advise of the right of appeal. A copy of this final written warning will be kept on file but will be disregarded for disciplinary purposes after 12 months (in exceptional cases duration may be longer) subject to achieving and sustaining satisfactory conduct or performance.

Stage 3 - Dismissal

If conduct or performance is still unsatisfactory and the employee fails to reach the prescribed standards, or if the offence constitutes gross misconduct, dismissal will normally result. The employee will be provided as soon as reasonably practicable with written reasons for dismissal, the date on which his/her employment will terminate and be advised of the right of appeal.

IV. Appeal

An employee may appeal against the decisions of the disciplinary meeting taken under this procedure to the Director, HR Head, Chairperson of Disciplinary Committee or if the Chair has already been involved in an earlier stage of the procedure

The employee wishing to appeal against a disciplinary decision, must do so in writing within five working days of receiving written notification of the disciplinary action, stating the reasons for the appeal. Any documents submitted in support of the appeal must be attached.

5. Suspension

Suspension without pay is regarded as a form of penalty once a disciplinary decision has been made. It can only be used if it is expressly mentioned in the employee's contract of employment otherwise the employee could take action for breach of contract.

6. Probationary employees

This full procedure does not apply to probationary employees. However, they can be given warning for minor misconduct or terminated for gross misconduct.

Employee Code of Conduct and Business Ethics Policy

At 7 CON we strive to work through transparency, accountability so that we at all times are able to justify the trust reposed in us by our stakeholder.

Scope and applicability

All policies, practices, processes and business dealings at 7 CON are governed by the code including employees, vendors, consultants as well as customers. All relationships - with employees, customers, partners, stakeholders, suppliers etc., need to be built on the foundations of trust and transparency.

7 CON realises that its operations must be aligned with the spirit of the code besides the applicable legal framework.

Our core values:

•    To uphold individual dignity: At 7 CON we believe that the company is as good as its employees and deserve respect and dignity. Employees are encouraged to innovation, transforming client engagements and constantly raising the bar for client satisfaction.

•    Commitments counts : The sole focus of our operations is to honour our commitments with every Stakeholder, quality, innovation and growth in every endeavour.

•    Responsible corporate citizens: We believe in encouraging a sense of social responsibility and to give back to society. Our commitment includes the efforts to make a positive difference to the community and the environment in which we operate.

Recruitment:

Our recruitment and promotion policies are based on meritocracy and ability to learn, adapt and assimilate change. We ensure equal opportunities irrespective of gender, nationality, disability, sexual orientation, religion or ethnicity in hiring, pay and/or career advancement.

Privacy

The Company respects the privacy of all its employees, business partners and customers. We handle data whether personal or third party, responsibly and in compliance with all applicable privacy laws. Employees who handle the data of others act in accordance with applicable laws and relevant contractual obligations

Employees are expected to avoid conflicts of interest between their personal interests and those of 7 CON.

An employee's outside activities should not be conducted on 7 CONT property and not involve the use of any 7 CON assets, materials, property or the services of other 7 CON employees or involve the

Employee's activities during 7 CONT work hours

Employees should not use 7 CON prestige or influence, directly or indirectly, for personal gain or benefit. In this regard, an employee, while on the job or as an 7 CONT representative, should not solicit customers to hire or contract with him/her for outside work of any kind.

Workplace and sexual harassment: We have a strong, clear and documented stand against any form of harassment at the workplace. Harassment as a result of discrimination or which is sexual in nature and has the effect of creating an intimidating, hostile or offensive work environment is not allowed at 7 CON.

Drugs and weapons: The Company strictly prohibits any person entering the Company premises under the influence of or in possession of any intoxicating substance (including alcohol) or any other drugs. Further, any person in possession of unauthorized weapons, illegal firearms, weapons or explosives will not be permitted to enter the Company premises. However, trained security personnel may possess authorized weapons as mandated.

Intellectual property

We have entered into Non Disclosure Agreements and a PIIA with our employees. Any unauthorized receipt or use of the intellectual property of others may expose 7 CON to civil & criminal liabilities and employees are advised to strictly adhere by all 7 CON policies and procedures, including those governing the appropriate handling of unsolicited intellectual property.

Employees are advised to refer to guidelines as issued by the Information Security, Risk management and Information Technology Departments from time to time.

Environmental protection

Our Environmental commitments are documented in the Environment Policy. The policy implementation and regulatory compliance are interwoven into every level and every activity of 7 CON. The Company is committed to environmental protection. Employees are expected to comply with environmental regulations and maintain the Company's standards. 7 CON and its customers 7 CONT believes in helping its customers to shift paradigms and start revolutions. We seek to understand our clients' expectations and strive to meet and exceed them. We collaborate with our clients to shape exceptional opportunities of value that can be predicted, measured and repeated.

7 CON and its suppliers

7 CONTs relationships with suppliers are based on lawful, efficient and fair practices. We expect our suppliers to obey the laws that require them to treat employees fairly, provide a safe and healthy work environment and protect the quality of the environment. Comply with applicable laws and government regulations covering supplier relationships do business only with suppliers that comply with local and other applicable legal requirements. 7 CON believes in meritocracy requirement (no discrimination) visa-vis vendor selection. We Safeguard our confidential and proprietary information with a confidentiality agreement and safeguard any supplier-provided information protected by any confidentiality agreement.

Discipline:

We have disciplinary policy in place. Since these standards are very important to our basic existence, the response to a deviation from them can lead to (including and upto) termination of employment.

The following action(s) may be taken depending on the severity of the situation:

-    Reprimand

-    Verbal warning

-    Written warning

-    Probation

-    Suspension/ blacklisting

-    Termination of employment/ business contract

-    Litigation (civil and/or criminal)

-    Imposition of damages

Any other penal remedy that may be available to the Company under the applicable law of the country where the act has been committed or any other such actions as may be warranted depending on the circumstances of the case

Waiver and amendment of the COBEC

We are committed to continuously reviewing and updating our policies and procedures. Therefore, this document is subject to modification from time to time. Any amendment or waiver of any provision of the COBEC must be approved in writing by the Company's Board of Directors.

Amendments need to be posted on all applicable regulatory filings or other areas with the nature of amendments.

No Smoking Policy

General Principles:

Under the Health and Safety at work place, employees have duties to take reasonable care for the health and safety of themselves and others and to cooperate with the employer to comply with the requirements of the Health, Safety & Environment at Work Place.

The Management of Health and Safety at work:

This smoking policy seeks to guarantee all employees that right to work in smoke free environment i.e. tobacco smoke etc. Premises will be designated smoke-free with adequate signage to inform all employees and visitors of the smoke-free status of the building.

Common Areas:

Smoking is not permitted in the following areas:

•    Corridors

•    Stairways

•    Canteen

•    Meeting Rooms

•    Toilets

•    Reception Area

•    Entrances

•    Parking

Work Area:

Smoking is not permitted in any work area. This applies to all offices and work areas, whether occupied by one person or shared by two or more.

Vehicles:

Smoking is not permitted in company vehicles. The policy of "No Smoking" will apply to the parking areas as well.

Implementation and enforcement of the policy:

• Managers will be responsible for the promotion and implementation of the policy by their respective team members

•    Employees should report the appropriate managers of anyone who fails to comply with the policy

•    Visitors not adhering to the policy will be asked to comply or leave the premises.

•    No Smoking Board are displayed in all common areas, operation floors, and offices

•    Breach of this policy will be subject to the normal disciplinary procedure.

Social Compliance Policy

Our Social Compliance Policy aims to improve both our social and environmental impact in the communities that we do business with throughout the world. Our policy applies to all facilities that provide services to 7 Con or any of its divisions, or affiliates. While 7 Con recognizes that there are different legal and cultural environments in which companies operate throughout the world. 7 Con Social Compliance Policy sets forth the basic requirements to be met in order to do business with us. Accordingly, it is the responsibility of all 7 Con business partners, suppliers, agents, and designated third parties to act in accordance with the 7 Con Code of Conduct. 7 Con strongly encourages contractors, agents, and suppliers to exceed the Code of Conduct requirements and to promote best practices and continuous improvement throughout all of their factories. Our goal is to use the Code of Conduct and audit results as an integral part of our supply chain strategy, influencing how we rate, select and build vendor partnerships now and in the future.

At 7 con, our approach is to work closely with our clients/customers designing a customised agenda to achieve the highest quality and satisfaction. We stand behind every commitment made to exceed expectations in providing world class products and services.

We are committed towards:

•    Working with dedication and innovation, with total focus on our customer.

•    Integrity, honesty and sincerity by following ethical and moral standards.

•    Promoting a work culture that provides individual growth, team spirit and creativity to overcome challenges and attain goals.

•    Achieving growth along with our customers, staff and suppliers.

In 7 con, we believe that our success is built on a foundation of personal and professional integrity. We understand the challenge of ensuring high social, ethical and environmental standards within our business and are committed to working collaboratively with our suppliers to ensure that that these standards are continually improving. In order to achieve this, 7 con has developed this Social Compliance policy based on the internationally acknowledged ETI base code. This Policy defines 7 con's minimum standards, along with the basic principles we expect from all our Suppliers and Contractors. We are committed to ensuring that the standards outlined in the policy are effectively implemented, measured and monitored throughout our global supply chain and we require the support of our suppliers to achieve this goal.

1.0    SCOPE

7 con's management define this policy as relevant to the organisation itself, its contractors, subcontractors, suppliers and other parties engaged through the chain.

2.0    GENERAL PROVISIONS

Business Partners (including but not limited to agents, vendors, manufacturers, factories, suppliers, and subcontractors) must comply fully with all legal requirements relevant to the conduct of their businesses. This policy communicates our values and expectations and emphasises the importance of responsible workplace policies and practices, which generally comply, at a minimum, with applicable occupational H&S, environmental and labour laws and regulations. The standards outlined below reflect the values we uphold in our own policies, and we expect our suppliers to follow these standards and requirements:

2.1    Employment is freely chosen there is no forced, bonded, indentured or involuntary prison labour. Employees are not required to pay fees or lodge "deposits" or original identity papers with their employer and are free to leave their employer after reasonable notice.

2.2    Working Conditions

A safe and hygienic working environment is and continued to be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Applicable occupational Health and Safety regulations are adhered to, and a working environment which is safe and conducive to good health shall be provided. Employees shall receive regular and recorded health and safety training and such training shall be repeated for new or reassigned employees. Access to clean toilet facilities, potable water and sanitary facilities for food storage shall be provided.

2.3    Child Labour - 7 Con does not engage in or support the use of child labour. Suppliers and Contractors must not recruit child labour.

2.5    Fair wages are paid Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards. All employees shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. Wages shall be paid directly to the employees, at the agreed intervals and in full. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

2.6    Working Hours - Working hours comply with national laws and benchmark industry standards, whichever affords greater protection. Comply with applicable hour and benefits laws relative to the industry and/or local labour market.

2.7    No Discrimination is Practised Suppliers and Contractors must comply fully with local laws regarding equality of employment opportunities. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, nationality, origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

2.8    Regular Employment is provided to every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

2.9    Accident Compensation Policy As a measure of Social Security to our employees and to lend them helping hand, 7 Con Technologies Pvt. Ltd. Has put in place a mechanism where adequate financial assistance is provided to them in case of an accident

In doing so, we ensure that the provision of Employee Compensation Act is complied with, in case of death / injury to an employee, which has arisen during course of and out of the employment with 7 Con Technologies Pvt. Ltd. In cases of injury or death of an employee a policy has been put in place to ensure that immediate financial assistance is provided to the concerned employee or his / her dependents in terms of the mandate of Employee Compensation Act.

2.10    No Harsh or Inhumane Treatment is Allowed: Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. All disciplinary actions must be recorded and be fair, proportionate and fully compliant with local laws. Suppliers and contractors will ensure access to confidential means of reporting inhumane treatment and workplace grievances.

2.11    Protect the Environment - Conduct business in compliance with all applicable environmental laws, rules and regulations. Waste is minimised and items recycled wherever this is practicable. Effective controls of waste in respect of ground, air and water pollution are adopted. In the case of hazardous materials, emergency response plans are in place. In respect of packaging and paper, undue and unnecessary use of materials is avoided, and recycled materials are used whenever appropriate In respect of energy use, all production and delivery processes, including the use of heating, ventilation, lighting, IT systems and transportation, are based on the need to maximise efficient energy use and to minimise harmful emissions.

2.12    Business Integrity - Strive to provide a workplace free of bribery and corruption by complying with all applicable laws relating to bribery, money laundering and/or corruption as well as prohibiting the exchange of money or anything else of value to or from anyone, including government officials, to influence actions or obtain an improper advantage.

3.0 IMPLEMENTATION OF THE SOCIAL COMPLIANCE POLICY

7 Con is committed not only to comply with this Policy within its own business, but to working collaboratively with its Suppliers and Contractors to drive compliance of the same. We will support our Suppliers and Contractors in achieving this objective and will abide by the following principles in order to drive this improvement in ethical performance.

7 Con is Commits To:-

•    Allocate the required resources in order to fully implement the Policy, including an internal system to record and monitor compliance.

•    Assign responsibility for the implementation of this Policy to an appropriately trained management representative who will provide the Board, suppliers and other stakeholders with compliance updates and implementation performance as required.

•    Work collaboratively with our suppliers, supporting them in the improvement of social, ethical and environmental standards where required and appropriate.

•    Full compliance with this Policy within our own business and to ensuring that all relevant employees are aware of the Social compliance Policy.

•    Acknowledge specific national, regional and cultural challenges that may affect compliance. Recognise suppliers' own standards where they are comparable to our own.

•    Communicate this Policy to all suppliers and contractors and seek formal acceptance and commitment to its implementation.

•    Report level of compliance to each supplier and request a comprehensive corrective action plan be developed, complete with relevant targets and timescales.

•    7 Con will support suppliers through any remediation process and will monitor progress. Communicate periodically to 7 con employees, management, suppliers the progress towards compliance with this Policy.

•    Periodically review this policy in order to continually improve, taking into consideration changes in legislation, and any other requirements to which the Company subscribes, and in order to ensure the adequacy, suitability and continuing effectiveness of the policy.

•    Cease trading with suppliers demonstrating a persistent disregard for this Policy while giving appropriate consideration to the impact this may have on the supplier and community in which they operate.

7 Con Requires its Suppliers to:-

•    Comply with this Policy and all applicable laws in the countries in which they operate. Where standards differ, the standard which offers the greater degree of protection to employees shall apply.

•    Allocate the relevant resource for full implementation of the Social compliance Policy. Communicate the Policy to all employees, suppliers, sub-contractors, home employees and temporary and contract employees engaged in their supply chain.

•    7 con will recognise suppliers' own Policy and standards where they are comparable with our own). Communicate openly and honestly with 7 con and allow access to documentation and sites as required to determine performance against this Policy.

•    The conduct of our suppliers should not violate the basic rights of 7 con.

4.0 CONTINUOUS IMPROVEMENT

The Company commits to periodically review this policy in order to continually improve, taking into consideration changes in legislation, and any other requirements to which the Company subscribes, and in order to ensure the adequacy, suitability and continuing effectiveness of the policy. Specifically, the policy will be routinely reviewed at the Company's Management Review Meetings and will be integrated into its QMS.

5.0 QUERIES ON SOCIAL COMPLIANCE

If you have any questions or would like to discuss our supplier social responsibility requirements in more details, please email shoeb@7con.com or please visit our website at www.7con.com The section below to be signed by the supplier/contractor and a copy of this page to be returned to 7 Con Technologies Pvt. Ltd.

Responsibility Chart: Social Compliance Policy

Vendors / Suppliers

Ensuring Compliance with labour, environment & working condition rules. Taking variance remedial action vis-a-vis vendors & Suppliers

To ensure that migrant employees work as per the applicable rules and they are not exploited by Supplier / Contractors


Remedial Action vis-a-vis co mpliance as reported by the Team Leader in respect of 7 Con Employees'


<=i


Managers


A




V



Implementing guidelines for compliance    with Social

Com pliance Policy and Code of Business Ethics and conduct


Ensuring Compliance with labour, environment & working condition rules. Reporting variance to Manager for remedial action vis-a-vis 7 Con Employees




To ensure that the migrant employees at 7 Con work as per the applicable rules and they are not exploited. Report variance to the Manager.


V

Employees


i=>


To Work as per the guidelines issued by the Team Leader for compliance with Social Compliance Policy / Code of Business Ethics and conduct.



SOP - Procedure for Evaluation and Selection of Suppliers or Sub-contractors

At 7 Con we have established and laid down well defined procedure for the purpose of evaluation and selection of sub-contractors / suppliers / vendors. The focus of the procedure remains on performance of the suppliers / sub-contractors / vendors towards their background and the present set-up for ensuring compliance with our social compliance policy. Special attention is given to see if there is any

risk of human trafficking or slavery in the functioning of the sub-contractors / suppliers / vendors. The

procedure involves following steps:

1    Floating of Tender / Request for Quotations: The tender document contains a questionnaire in which the prospective contractors are asked about status of their compliance with laws relating to wages, working hours, child labour, use of hazardous substances, harassment, social security etc.

2    Acceptance of quotation

3    Undertaking / Affidavit from suppliers / sub-contractors / vendors showing their commitment towards compliance with labour and environment legislations

4    Undertaking / Affidavit from suppliers / sub-contractors / vendors to the effect that they are not involved in human trafficking and slavery in their functioning

5    Yearly Assessment of performance of suppliers / sub-contractors / vendors regarding the compliance with Social Compliance Policy.

6    Action including suspension / termination (black listing) of contract in case of violation.

Fire Protection Program and Policy

1.    Policy Statement:

The responsibility of compliance with this policy to safeguard the employees and assets of the Company, in case of fire, lies with each and every employee. The overall responsibility of putting in place an effective fire protection regime lies with Safety Committee of the Company.

2.    Agency:

Safety Committee shall appoint an efficient and trustworthy Agency as Fire fighting agency to conduct evaluation & processes for 7 Con at regular intervals. Number and nature of fir fighting equipments shall be determined by the safety committee as suggested by the said agency. The agency so hired shall be responsible for the fire protection program Issues like inspection and assessment of functionality of the equipments shall be dealt with by the safety committee at regular intervals preferably once in three months.

3.    Administration:

Safety Committee shall designate a safety Co-ordinator and an alternate safety coordinator for protection from fire. The coordinator shall coordinate with the agency to arrange and hold training programmes, escape procedure & route, Employee Alarm system etc.

Business Integrity Policy

Introduction:

Our business integrity policy lays out strict data security requirements and ensures compliance with the principles of national and international data protection laws. The policy sets a globally applicable data protection and security standard for our company. The guiding principles of our policies are transparency, data economy and data security. Our managers and employees are obligated to adhere to the Corporate Data Protection Policy.

Our Data Protection Policy ensures the adequate level of data protection as per national and international standards.

Definitions:

Authorized Individuals - Those individuals who have a current, signed confidentiality statement and statement of acknowledgement and agreement of confidentiality and security policies in their files, whose current duties require them to have access to data, and who are authorized by the System Administrator to have access to data.

Breach - Infraction or violation of a standard, obligation or law. A breach in data security would include any unauthorized use of data, even data without names. A breach, in its broadest sense, may be caused by an act of God, a person, or an application/system and may be malicious in nature or purely unintended.

A breach does not necessarily mean that sensitive information was released to the public or that any one person was harmed. A minor infraction, like forgetting to lock a file drawer containing sensitive information - even if inside the secured area - constitutes a breach of security protocol as compared to a breach of confidentiality.

Breach of Confidentiality - A security infraction that result in the release of client information with or without harm to one or more individuals.

Confidentiality - Disclosure of company or client information and data in a relationship of trust and with the expectation that it will not be divulged to others in ways that are inconsistent with the original disclosure

User - Any agency staff member who will have access to client level data for the purposes of collecting, processing or analyzing the data

Portable electronic client level data records - Any records containing client level data that are stored on portable electronic devices (laptop, blackberry etc.) or on removable storage media (diskette, CD).

Secured area - The physical confinement limiting where client level data are stored or where communications involving client level data are permissible. A secured area consists of a room that has floor to ceiling walls and a door with a lock. For the purpose of storing paper records and portable electronic records, a secured area consists of a locked file cabinet or other locked receptacle within a locked room. Access to any receptacle (including a computer) storing client level data must be restricted to authorized individuals.

Overall Responsible Party (ORP) - The official who accepts overall responsibility for implementing and enforcing these security standards and may be liable for breach of confidentiality. The ORP should be a high ranking official not below the rank of manager.

Confidentiality and Security Policies and Procedures For Client Level Data

Physical Security:

System Administrator Roles

The System Administrator will be responsible for the security of the client level data. This person will be responsible for ensuring ongoing staff training and compliance, and reviewing this policy on an annual basis and making changes as is necessary. This person will also be responsible for receiving complaints concerning this policy and client level data confidentiality and security compliance issues (including computer use violations).

Access to Client level Data:

Only staff whose role it is to collect, process or analyze client level data shall have access to the data. Persons granted access to client level data or the database will have that access restricted by the roles that correspond to the duties they need to perform.

The process by which a new staff member can gain access to the system or to client level data will be as follows. The supervisor of the staff member will first submit a Request for Access to Client Level Data form to the System Administrator. This request includes a description of what the person's duties will be related to The System Administrator will next assure that the person completes training on this policy and signs both a confidentiality statement and a statement of acknowledgement and agreement of the confidentiality and security policies.

Work Site Security

Users shall be individually responsible for protecting their own workstations. This responsibility includes protecting keys, passwords, codes and electronic devices that would allow access to client level data or the database.

Leaving the work area

Paper or portable electronic records containing client level data shall not be in the work area unless authorized individuals are working with them. Otherwise, records shall be stored in locked file cabinets or other locked receptacles.

When a user leaves his/her work area for short periods of time (less than 30 minutes), computers containing client level data must be locked so that they will require use of a password to reopen. The monitor must also be turned off if it is still possible to see the screen. In addition, all paper records shall be turned face down on desks and office surfaces.

When a user leaves his/her work area for periods of 30 minutes or more, computers must be locked (and monitors turned off if it is still possible to see the screen) and all paper or portable electronic records must be returned to their locked receptacles.

Users who utilize client level data throughout the workday will be located in low traffic areas and will appropriately store data when away from the workstation for 30 minutes or more (as is described above).

All paper or portable electronic client level data records will be returned to a locked receptacle when office hours are concluded.

All computers with access to the database or storing client level data will be locked when office hours are concluded.

If the client level data is being removed from secured areas for analysis, it should be de-identified first. If a portable electronic record is removed from a secured area, it must be encrypted.

Storing Data

Paper Records

When not in use, completed client level data forms and other paper records containing client level data (including but not limited to counselor notes, client files, data printouts) shall be stored in secured areas.

Electronic Records

When not in use, any portable electronic client level data records shall be stored in secured areas.

Computers storing client level data must conform to policies mentioned in Section II: Computer Security.

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If client level data is stored on a laptop, the hard drive or diskette, whichever the data is stored on, must be separated from the computer when not in use and stored in a secured area. All storage media shall be clearly labeled to reflect what data they contain.

Diskettes and other storage media that contain client level data should have only the minimum data necessary to perform a given task.

Record Retention and Disposal Policy

Portable electronic records will be maintained for the length of time necessary for task completion.

Breach of Security /Confidentiality User Responsibilities

Users are responsible for adhering to the policies and procedures in this document in order to ensure the confidentiality of client level data records to which they have access. users are prohibited from accessing client level data which is unnecessary for the fulfillment of their responsibilities. Users are prohibited from disclosing or divulging any client level data to unauthorized persons in any manner whatsoever.

Penalties

Any person failing to adhere to these responsibilities is subject to the following penalties.

•    Reprimands

•    Suspension of system privileges / data access privileges

•    Suspension from duty

•    Civil penalties

•    Criminal prosecution

Portable Electronic Records

Portable electronic client level data records must be encrypted if they will be used or transported outside of a secured area.

Data Integrity

Persons who have access to client level data are prohibited from altering the data for misrepresentation or falsification purposes.

Computer Security:

For computers used for (having access to or storing client level data)

Login/Password/Challenge Phrase

If a challenge phrase for a digital certificate or a login or password for software access is written down, it shall be kept in a locked drawer or other locked location. Passwords for software access shall be at least 8 characters long, contain a mix of at least three of the four types of keyboard elements (uppercase, lowercase, numbers, symbols), and cannot be the individual's name. Passwords should be changed at least every 90 days (this should be required by the system) and shall not be divulged to others. If it is discovered that a challenge phrase or password has been stolen or become known to someone else, staff will immediately notify their direct supervisor who will notify the System Administrator (as this would be considered a breach of security protocol).

Non-Discloser Agreement:

Company shall enter into Non-Discloser Agreement with all such employee, who may have access to client data

Data Integrity Policy

The following policies define data security issues that specifically relate to Data Integrity. The policies address the authorization, validation, modification controls, and consistency of data

Awareness of Integrity Status

Systems should be designed in a way that encourages compliance with the principles of data integrity. Examples include:

•    Access to clocks for recording timed events

•    Accessibility of batch records at locations where activities take place so that ad hoc data recording and later transcription to official records is not necessary

•    User access rights which prevent (or audit trail) data amendments

•    Proximity of printers to relevant activities

•    Access to raw data for staff performing data checking activities

Integrity of Information Sources

•    Authorization Required for All Production System Input

•    Methods must be in place to ensure that all input to production computer systems, which has been submitted for processing has been properly authorized. This requires that an access control system be in place to ensure the submitter has rights for the action requested.

Input Data Validation and Rejected Item Handling

All input data to a multi-user computer system must first be subjected to reasonableness checks, edit checks and/or validation checks. Transactions, which fail such checks, must either be (a) rejected with a notification of the rejection sent to the submitter (b) corrected and resubmitted or (c) suspended pending further investigation.

Modification Control

Management must establish and maintain sufficient controls to ensure that information is free from a significant risk of undetected changes. The intention of this policy is to clearly guide systems designers, network specialists, and others to implement adequate control measures to prevent undetected information alteration.

Handling of Rejected Batch Input Transactions via Suspense Files

All rejected batch input transactions must be placed in a suspense file and listed in exception reports until such time as they are successfully resubmitted for processing or otherwise handled

Input Validation Procedures for Rejected or Suspended Input

Input transactions which are corrected for resubmission, or which are suspended and later approved for resubmission, must be subjected to the same validation procedures that original input transactions receive

Consistent Representation of Data

Misrepresenting, obscuring, suppressing, or replacing a user's identity on an electronic communications system is forbidden. The user name, electronic mail address, organizational affiliation, and related information included with messages or postings must reflect the originator of the messages or postings

New Information Types Must Be Reflected in Master Data Dictionary

All new types of information that are created and / or stored by core administrative applications must be promptly reflected in the master data dictionary

Data Integrity Definition and Guidance

Term

Definition

Expectation / Guidance

Data

Information derived or obtained from raw data (e.g. a reported analytical result)

Data must be:

-    attributable to the person generating the data

-    legible and permanent

-    contemporaneous

-    original record (or 'true copy')

-    accurate

Raw Data

Original records and documentation, retained in the format in which they were originally generated. Raw data must be contemporaneously and accurately recorded by permanent means.

Raw data must:

-    Be legible and accessible throughout the data lifecycle.

-    Permit the full reconstruction of the activities resulting in the generation of the data

Data Integrity

The extent to which all data are complete, consistent and accurate throughout the data lifecycle.

Data integrity arrangements must ensure that the accuracy, completeness, content and meaning of data is retained throughout the data lifecycle.

Data Governance

The sum total of arrangements to ensure that data, irrespective of the format in which it is generated, is recorded, processed, retained and used to ensure a complete, consistent and accurate record throughout the data lifecycle

Data governance should address data ownership throughout the lifecycle, and consider the design, operation and monitoring of processes / systems in order to comply with the principles of data integrity including control over intentional and unintentional changes to information.

Data Governance systems should include staff training in the importance of data integrity principles and the creation of a working environment that encourages an open reporting culture for errors, omissions and aberrant results.

Senior management is responsible for the

implementation of systems

and procedures to minimize the potential

risk to data integrity, and for identifying the residual risk

STANDARD OPERATING PROCEDURE DATA INTEGRITY

PURPOSE

The purpose of the Data Integrity Standard Operating Procedure (SOP) is four-fold:

(a)    To describe the 7 Con's data integrity system,

(b)    To emphasize the paramount importance of propriety laws and ethics in the performance of our work,

(c)    To obtain the commitment of staff to the principle that all processes shall be performed in a controlled and documented manner, and

(d)    To ensure that employees consistently meet the specific requirements defined in the data integrity policies and plans.

SCOPE

This procedure applies to all activities performed within the 7 Con's scope of accreditation.

RESPONSIBILITIES

Head of Departments/Senior managers support and provide initial data integrity training and on-going annual training to managers and staff. Senior managers ensure that employees sign the appropriate agreements e.g. NDA, PIIA, Compliance & Ethics Code etc., pertaining to their area of work. ,

A data integrity Coordinator shall be appointed by senior management to advise of any need for detailed investigations. Confidential records shall be maintained by the data integrity coordinator for these discussions.

The Quality Assurance Officer (QAO) shall perform in-depth review and shall prepare a summary of plan updates, on-going ethics/data integrity training and data integrity investigations.

Procedure

4.1 Ethics Training

Ethics training is a required part of new employee orientation and is provided on an annual basis for all managers and staff by senior management. Initial training during orientation includes the overall organizational mission and its relationship to the absolute need for honesty and full disclosure in all analytical reporting and record-keeping. Resources where applicable ethics policy and law can be found are made available and copies are distributed.

The initial orientation is immediately followed-up by senior management with the specifics of the 7 Con's data integrity plan. Examples are described that illustrate unethical behavior and ethical behavior related to data manipulation. Standard operating procedures are reviewed with respect to proper procedure, data qualifiers, and adequacy of record keeping. Management will disclose that reports and the data generated to support them are subject to routine in-depth review.

The organizations response to infractions of the data integrity plan will be discussed and the trainee shall understand that infractions will be investigated in a detailed way. The consequences to an employee found to be in violation of the data integrity plan may result in immediate termination, debarment, and/or civil/criminal prosecution. Confidentiality is assured during this process.

Employee attendance or participation is documented.

4.2 Ethics Agreement

Following initial ethics training and on-going annual training for laboratory managers and staff, trainees shall sign a written ethics agreement. Senior managers who provide the training shall also sign the agreement. The agreement states that the signers will not engage in any unethical practices with respect to data integrity nor will they tolerate improper behavior in others if it is observed or suspected. By signing, senior managers acknowledge their duties in upholding the spirit and intent of the data integrity system and in effectively implementing the specific requirements of the plan.

4.3 Monitoring

Reports and the data used to support them are randomly selected by the QAO for auditing. Each calendar quarter the QAO audits 5 % or 5 data packages, whichever is more. The purpose of the review is to verify that all data integrity requirements are met.

4.4 Documentation

Confidentiality is critical and maintained by use of locked filing cabinets and password protected electronic files. All data integrity incidents must be documented, including investigative findings and disciplinary actions. Corrective actions are recorded. If client disclosure is determined to be necessary by senior laboratory management then such disclosures and outcomes are recorded. Criteria for client notification should be detailed in the Quality Assurance Manual or this SOP.

All data integrity documents, plans, SOPs, personal records and records of investigations shall be maintained for a period of five years. Documents are subject to the document control system and records are subject to the records management system as described in the 7 Con's quality manual and related SOPs.

Data Security Policy

We at 7 Con Technologies Pvt. Ltd. are committed to provide fool proof Data Security to our clients. We have evolved and implemented our DATA SECURITY POLICY and every member of 7 Con family is committed to comply with these set of rules.

Our specifically designed Data Security Policy is a clear statement and practically implemented across the organization with zero defect tolerance mode. It states:

Essential Elements of a Data Security Policy

Safeguard Data Privacy: Employees must understand that your privacy policy is a pledge to your customers that you will protect their information. Data should only be used in ways that will keep customer identity and the confidentiality of information secure. Of course, your employees and organizations must conform to all applicable laws and regulations.

Establish Password Management: A password policy should be established for all employees or temporary workers who will access corporate resources. In general, password complexity should be established according to the job functions and data security requirements. Passwords should never be shared.

Govern Internet Usage: Most people use the internet without a thought to the harm that can ensue. Employee misuse of the internet can place your company in an awkward, or even illegal, position. Establishing limits on employee internet usage in the workplace may help avoid these situations. Every organization should decide how employees can and should access the web. You want employees to be productive, and this may be the main concern for limiting internet usage, but security concerns should also dictate how internet guidelines are formulated.

Manage Email Usage: Many data breaches are a result of employee misuse of email that can result in the loss or theft of data and the accidental downloading of viruses or other malware. Clear standards should be established regarding use of emails, message content, encryption and file retention.

Govern and Manage Company-Owned Mobile Devices: When organizations provide mobile devices for their employees to use, a formal process should be implemented to help ensure that mobile devices are secure and used appropriately. Requiring employees to be responsible for protecting their devices from theft and requiring password protection in accordance with your password policy should be minimum requirements.

Establish an Approval Process for Employee-Owned Mobile Devices: With the increased capabilities of consumer devices, such as smart phones and tablets, it has become easy to interconnect these devices to company applications and infrastructure. Use of these devices to interconnect to company email, calendaring and other services can blur the lines between company controls and consumer controls. Employees who request and are approved to have access to company information via their personal devices should understand and accept the limitations and controls imposed by the company.

Govern Social Media: All users of social media need to be aware of the risks associated with social media networking. A strong social media policy is crucial for any business that seeks to use social networking to promote its activities and communicate with its customers. Active governance can help ensure employees speak within the parameters set by their company and follow data privacy best practices.

Oversee Software Copyright and Licensing: There are many good reasons for employees to comply with software copyright and licensing agreements. Organizations are obliged to adhere to the terms of software usage agreements and employees should be made aware of any usage restrictions. Also, employees should not download and use software that has not been reviewed and approved by the company.

Report Security Incidents: A procedure should be in place for employees or contractors to report malicious malware in the event it is inadvertently imported. All employees should know how to report incidents of malware and what steps to take to help mitigate damage.

Database Security Considerations

Physical Security (including back-up and restoration plan

Data Storage Access (Server or PC)


Network

(LAN/WAN) Security

IT~

Application Security User Level


Web Security


£


Application Security


User Level


£


User Level

Corporate Social Responsibilities/Community Involvement

"Corporate social responsibility is the commitment of businesses to contribute to sustainable economic development by working with employees, their families, the local community and society at large, to improve their lives in ways that are good for business and for development"

--World Bank Group 7 Con aims to inspire and facilitate our people to contribute positively to our society and create a sustainable business future. We recognize our responsibility for the social impact we have on communities, and our corporate social responsibility program is integral to what we do. We strive to ensure that the communities engaged through our CSR initiatives also experience certainty in their lives

Corporate Social Responsibility Program

The most significant first step has been the introduction of our Corporate Social Responsibility (CSR) Program - focused on the following four key areas.

Responsible Business

CSR is already deeply embedded in our everyday business, and over the past 12 months our staff have delivered financial, pro-bono and in-kind support for a range of community activities, including:

-    Wellness Camp

-    Food bank - Feeding the hungry

-    Environmental Clean-up drive

-    Green Earth - Planting Trees

-    Medicine Donation

Community Engagement

Every permanent member of staff is entitled to take one day of fully-paid leave per year to donate their time to an approved Community Volunteering Day activity. Each year, this translates to more than 500 man hours to support the work of organisations

Wellbeing

A range of free wellbeing services and initiatives, specifically designed to benefit staff and their families, are also an integral part of our business - from annual flu shots, to encouraging family participation in a number of community events.

Diversity and Inclusion

Recognising the importance of diversity in the workplace, our Diversity and Inclusion Project is in a process of rolling out several initiatives designed to encourage greater diversity at an organisational level.

Our vision is to create workplace environment which is rich in diverse people, talent and ideas. Our focus is to maximize the power of Diversity & Inclusion to drive superior business results and sustainable competitive advantage in a dynamic global marketplace

Additional practices include:

= Operating on a personal basis founded on teamwork and first-name relationships = Promotion from within = Practicing objective, careful hiring methods

= Encouraging and assisting employee development by communicating regularly with employees = Providing training opportunities and recognizing accomplishments = Compensating employees fairly and maintaining a safe work environment = Shunning favouritism = Respecting each employee's point of view

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