Employee Handbook v 1.2

Sterling Information Resources India Pvt. Ltd.-confidential Page 1

Sterling Information Resources (I) Pvt. Ltd.

2011

EMPLOYEE HANDBOOK Human Resources

V 1.2

November, 2011


Sr no: Particulars Page No.

1 Introduction 6

2 Welcome from William Greenblatt 7

3 Welcome from Vikas Vig 8

4 Welcome from Human Resources 9

5 Organization Chart 10

6 About Sterling InfoSystems, Inc 11

7 History of Sterling InfoSystems, Inc 11

8 SIRs Values, Vision & Mission 11

9 Our Values 12

10 Our Vision 12

11 Our Mission Statement 12

12 Quality Standard 13

13 Customer Focused Philosophy – “Thrilling the Customer” 13

14 Sterling’s Employment ethics 14

15 Equal Opportunity 14

16 Teamwork 15

17 Sterling’s Commitment to Diversity 15

18 Working for Sterling Information Resources India Pvt. Ltd. 15

19 Employment “At Will” 16

20 Employee Classifications 16

21 Full-Time Employees 16

22 Contract and Temporary Employees 16

23 Safe harbor Policy for Employees 17

24 Employment of Relatives 17

25 Recruitment Policy 18

26 Employee Referral Policy 19

27 Induction Policy 20

28 Open door Policy 21


29 Communications Boards 22

30 Statement to the Media 22

31 Rehiring Policy 23

32 Whistle Blower Policy 23

33 Relocation Policy 25

34 International Travel Policy 27

35 Compensation 29

36 Hours of Operation and Workweek 29

37 Lunch Breaks 30

38 Pay Day 30

40 Employee Benefit Information 30

41 Workers’ Compensation Insurance 30

42 Employee Insurance 30

43 Group Personal Accident Insurance Plan 35

44 Charity 37

45 Employee Recognition Programs 37

46 Attendance & Leave 38

47 Absence and Tardiness 38

48 Excessive Lateness 38

49 Leave Policy 40

50 Performance Reviews 44

51 Performance Improvement Plan 45

52 Probationary period , Confirmation Policy 46

53 Advancing with the company: Promotions 47

54 Internal Job Posting Policy 48

55 Internal Transfer Policy 49

56 Disciplinary Policy 51

57 Organization Development 52

58 Health & Safety 54

59 Employee Safety 54


60 Reporting On-the-Job Injuries 54

61 Fire Extinguishers, First Aid Kits and Emergency Exits 54

62 Cellular phone safety while driving 54

63 Smoking Policy 55

64 Anti-Tobacco Chewing 55

65 Alcohol and Drug Policy 55

66 Work Place conduct 56

67 Staff Identity Card 56

68 Ethical Code of Conduct 56

69 Workplace Violence 57

70 Personal Calls/Cell Phone Use 58

71 Good Housekeeping 58

72 Office etiquette 58

73 Phones 58

74 Talking 58

75 General Noise 59

76 Work place visitors 59

77 Accepting & Giving Gifts 59

78 Theft Attempted 59

79 Dress Code Policy 59

80 Non-Solicitation Policy 60

81 Non-Disclosure & Proprietary Rights Agreement 60

82 Conflicts Of Interests 63

83 Computer, E-Mail and Internet Usage Policies 64

84 Help Desk 65

85 E-mail 65

86 Internet 67

87 Prohibited Conduct 68

88 Non-Harassment Policy 68

89 Sexual Harassment Policy 69


90 Grievance Procedure 70

91 Employee Separation policy 73

92 Return Of Company Property 76

93 Security 76

94 Office – Security 76

95 Additional Access 76

96 Employee Property 77

97 Inspections 77

98 Shredding and Document Handling/Destruction 77

99 Situations where company is to be indemnified 77

100 Company right to recover amount against employee benefit schemes 78

101 Employee Handbook Revisions 78


Introduction

This is your employee handbook. It has been prepared for you to help

you better understand what you can generally expect from Sterling information

Resources India Pvt. Ltd. The information in this handbook is important to all of our employees.

Naturally, you won’t find answers to all your questions in the handbook. No

written statement, no matter how complete, can be a substitute for direct daily

contact with your immediate supervisor. You are urged to check with your supervisor or anyone from the Human Resources

Department for complete information on employee policies and benefits. If your

supervisor doesn’t have an immediate response to your question, he or she will

get the information you seek and pass it along to you promptly. The company reserves the right to amend, modify, rescind, delete, supplement or

add to the provisions of this handbook as it deems appropriate from time to time

in its sole and absolute discretion.

The company will attempt to provide you with notification of any other changes as

they occur. In all instances where the terms “Company” or “SIRs” are used

in this Handbook, it should be interpreted as Sterling Information Resources

India Pvt. Ltd. Should a statement in this Handbook conflict with current

applicable Plan Documents, the Plan Document will prevail. This document is for

internal distribution only. It has been developed and is distributed solely for the

use of SIRs employees.


Welcome

William Greenblatt, CEO I am pleased to welcome you to Sterling Family. You have chosen to join a company that enjoys a reputation for being a leader in its field. We are justifiably proud of our record of service, as well as for the success the company has achieved in its history. Sterling is a pre-employment screening company where each employee is relied upon to do his or her job correctly and promptly. With that in mind, I urge you not to lose sight of the significance of your job to the overall effectiveness of the Corporation. A client’s decision to continue to do business with us depends on the manner in which you and your fellow employees do your work. The Human Resources Department has designed this handbook to help you adapt to your new surroundings as quickly and easily as possible. Please read it carefully as it contains information of general interest such as company benefits, as well as a set of guidelines we all must observe if we are to successfully work together as a team. It is our goal to create an atmosphere in which productivity, job satisfaction, and career opportunity combine to make Sterling a rewarding place to work.

Again, I am pleased that you have decided to join us, and I hope our association will be a mutually beneficial one.

Sincerely,

William Greenblatt (CEO)


Welcome

Vikas Vig, CEO Let me begin by expressing warm welcome to all of you.

Why Sterling Infosystems? Your friends might ask you. For the un-initiated, that may seem to be a valid question, but for me and for all those working here, we are hard pressed to come up with reasons why we wouldn’t want to move here!

As a team, we’re in a great position to move forward. We are in a field that requires foresight and creativity. All of our employees accept these challenges and are committed to continue delivering breakthrough solutions and superlative services. We continue to build on the special cultural tradition of Sterling Information Resources limited. We think ahead and focus on the future in everything we do. What we are today is because of the incredible quality of the people who work here, because it’s you who ultimately makes the difference. I depend upon your expertise, your ideas and your experience to help identify where and how we can improve. We build upon our tradition and at the same time embrace innovation. Sterling Information Resources India Pvt. Ltd has an exciting future in store for those with passion towards work.

Sincerely

Vikas Vig (CEO-India)


Welcome

From the HR Team at Sterling India.

Congratulations!!! And welcome aboard

Together we will work to ensure your career with us is a success.

You can make a difference - In our world – the Sterling world – innovation thrives, where diversity, creativity and personal responsibility is combined to generate business advantage. Sterling is a global company.

In Sterling, united behind our company’s vision and values, you will discover an enabling environment, an energetic culture and a customer – focused organization that inspires and motivates all of us to perform our best. Joining Sterling translates into continual opportunities to expand on what you can do. The broader our employees’ experience, education and background, the more diverse their opinions and insights, the deeper Sterling collective understanding grows. The result is a collaborative environment that respects individual needs and promotes ongoing development. Sterling Information Resources India Pvt. Ltd. (SIRs), believes in promoting an atmosphere of open communication and co-operation among all of our people. This Handbook reflects that thinking, and has been prepared to provide you with general information and an overview of SIRs. It summarizes present programs, benefits, policies, and is intended to serve as a guideline for you.


Organization chart

Vikas VigCEO India

Sridhar VFinance

Controller

Deepesh SainiAVP - Client

Relations

Karan Arora VP - EBT

Hiro PunjabiDirector

Application Services

Additional reporting to Andrew Reiben

Additional reporting to Steve Elko

Drug Rebilling

India GAAP

Client Care

Training

Quality

SDC

SE & SW Verifications

Manila

Shreejith GopiAVP - SUK

SE Special Operations

Manoj ShahSr. Manager

Bishops

Alla SchayCOO

Additional reporting to Mark Morgenfruh

Process Improvement

Additional reporting to Dan Agee

Additional reporting to Jessica Eason

Manish Kotwani

VP – Human Resources

Talent Acquisition

Employee Engagement

Employee Relations

BRM Team

US GAAP

Bipin GedamVP – SE, SW

and SVA

Aliasger Bohari

VP - GTO

Pramod ParavAVP GTO

Additional reporting toAsif Ahmed

Nitesh MishraAssistant Manager,

Client Care

Business Intelligence

Sales Support

IDG

OrganizationalDevelopment

Amit KotakSr. Manager,

Admin

Vimal KotakAVP

SE & SW Crim

SE & SW OHS

SE & SW Order Creation

SV Crim

SV Order Creation

Additional reporting toTom Christensen

SUK - Verifications

SUK - OC

Procurement

Yunus ShaikhDM – Admin

Administration


About Sterling Infosystems, Inc

HISTORY OF STERLING INFOSYSTEMS, INC

Sterling Infosystems, Inc. was originally founded in 1975. Sterling Inc. of New York City quickly became the vendor of choice in testing employees of client companies. Using the technology of the time, Sterling Inc. was able to create an operational model of providing the client with a quality product coupled with the highest level of customer service. By making use of Sterling’s years of experience providing screening services, William Greenblatt established the blueprint of what the pre-employment background industry has become today. Building on its history of offering superior customer service, quality product offerings and technology advancements, Sterling InfoSystems, Inc has built a vibrant organization which remains a leader in its field. SIRs started its India operations on Dec 1 2006

SIRs Values, Vision & Mission

Our Values

Sterling believes in these core values and uses them to define who we are and how we Work as a company. These values have sustained us for over 30 years and will continue To support our success as a company that delivers exceptional service to our customers and provides a satisfying and challenging work environment for our employees. • Integrity

• Honesty


• Commitment to Excellence

• Innovation

• Set the Benchmark

• Be a Part of Something Special

• Passion

Our Vision

To create a growth-oriented enterprise that will be a market leader while being an employer of choice

Our Mission Statement

By employing the best people, practices, and technology, we position ourselves as trusted advisors to our clients, ensuring the highest probability of success in hiring and retaining human capital.

Quality Standard

For all of us at Sterling, quality means meeting or exceeding the requirements and expectations of both external and internal customers, the first time and every time. At Sterling, we recognize that the closer we come to achieving sustained Quality, the closer we will come to achieving total customer satisfaction.

Customer Focused Philosophy – “Thrilling the Customer”


Our clients deserve spectacular after-sales support. It is said that the quality of service will be remembered long after the cost has been forgotten. That is the reason for our customers to insist on receiving exceptional support from their vendors throughout the service duration. In the end, it all comes down to the service that is provided to the customers. It's the responsibility of Sterling Information Resources India Pvt. Ltd. employees to keep customers satisfied and loyal. Personal attention to the customer, empathy and understanding of customer needs - these are some of the traits that we must cultivate. Our employees must not be so attached to systems, processes and structure that they cannot offer flexibility and a personal touch to the customer. After-sales support falls into two categories:

Discrepancies: If errors arise, we must take prompt and responsive corrective Measures. Our employees should capitalize on such “moments-of-truth" to make the customer happy & satisfied by resolving the matter efficiently. Continual Support and Assistance: All of our customers should know who to call and should receive prompt, courteous, and knowledgeable replies. We should be familiar with our customer’s needs and requirements, which the primary contacts are, and how frequently contact, should be made. We should respond to quality evaluations with corrective action in areas of noted weakness. These actions should reflect a true commitment to quality, not just a sudden delegated exercise to satisfy the customer. Sterling Information Resources India Pvt. Ltd. must anticipate our customers' future needs and suggest solutions to satisfy them. In short, we want our customers to know we’re in it for the long haul. We will work with them towards complete customer satisfaction and unprecedented standards of performance excellence as Partners in Quality.

STERLING’S EMPLOYMENT ETHICS

Sterling Information Resources India Pvt. Ltd. relies upon the accuracy of information contained in the employment application, as well as the accuracy of other data presented throughout both the hiring process and duration of employment. You will undergo a pre-employment background check. You will cease to be in our employment if there is any misinformation detected during verification check. You are expected to maintain this same level of integrity throughout your employment at Sterling. We act with integrity in all of our employment decisions. We respect everyone communicating openly and honestly. Any misrepresentations, falsifications, or material omissions in any of the employment information or data may result in Sterling Information Resources India Pvt. Ltd. exclusion of the individual from further employment, if the person has been hired, it would result in termination of employment.

.


Equal Opportunity

The company prohibits discrimination on any basis of race, color, religion, sex, national origin or ancestry, age, disability, or sexual orientation as well as any other classification protected by applicable law. Sterling Information Resources India Pvt. Ltd. Intends to fully comply with this policy and in all aspects relating to its employees. Any employees with questions or concerns about any type of discrimination in the workplace are encouraged to bring these issues to the attention of their immediate Supervisor or Human Resources. Employees can raise concerns and make reports without fear of reprisal. Anyone found to be engaging in any type of discrimination will be subject to disciplinary action, up to and including termination of employment.

Teamwork

Sterling encourages teamwork on every level – both formally and informally – because the nature of all of our businesses requires the collective best efforts of many individuals. We encourage a collaborative environment that takes advantage of our diverse Sterling Family resources to provide the best-in-class solutions and services needed by our customers.


Sterling’s Commitment to Diversity

Sterling’s employee population is diverse on a broad spectrum. This spectrum includes the diversity dimensions of age, race, religion, gender, sexual orientation, physical capacity, political beliefs, work-style, socio-economic and marital status. These diversity dimensions become our strength. By honoring Sterling’s value of integrity and respect and behaving as the Sterling Family, we establish a diverse culture, which fosters “an environment that encourages and supports every employee to strive and reach their maximum potential in pursuit of Sterling’s business objectives.”

Working for Sterling Information Resources India Pvt. Ltd.

Employment “At Will”

This handbook is not an employment contract and does not create any obligations, contractual or otherwise. The policies and procedures stated in this book may be modified by the company at anytime. Your employment is “At Will” and may be terminated by you or the company at any time.

Employee Classifications

It is the intent of Sterling Information Resources India Pvt. Ltd. to clarify the definitions of employment classifications so that employees understand their employment status and benefit eligibility. These classifications do not guarantee employment for any specified period of time. Accordingly, the right to terminate the employment


relationship at will at any time is retained by both the employee and Sterling Information Resources India Pvt. Ltd.

Full-Time Employees

Full-time employees are those who have been hired for a permanent schedule averaging a minimum of 40 hours or more work per week.

Contract and Temporary Employees

Contract and temporary employees are those who are hired as interim replacements, to temporarily supplement the workforce, or to assist in the completion of a specific project. Employment assignments in this category are of limited duration. Employment beyond any initially stated period does not in anyway imply a change in employment status. Contract and temporary employees retain that status unless and until notified of a change. Contract and temporary employees are ineligible for Sterling Information Resources India Pvt. Ltd. benefit programs.

SAFE HARBOR POLICY FOR EMPLOYEES

It is our policy and practice to accurately compensate employees and to do so in compliance with all applicable laws. To ensure that you are paid properly and that no improper deductions are made, you must review your salary slips promptly to identify and to report all errors within 7days of receipt. If you believe a mistake has occurred or if you have any questions, please use the reporting procedure outlined below. As per guidelines, your salary is subject to certain deductions. For example, unless the law requires otherwise, your salary can be reduced for the following reasons: Full / partial day absences for personal reasons Full / partial day absences for sickness or disability Full / partial day disciplinary suspensions for infractions of our written policies and procedures Full / partial day Family and Medical Leave absences Your salary may also be reduced for certain types of deductions such as your portion of Income tax, Professional Tax and any other deduction as applicable by law. In any work month in which you performed any work, your salary will not be reduced for any of the following reasons:


Your absence because the facility is closed on a scheduled work day If you believe you have been subject to any improper deductions, you should immediately report the matter to your immediate Supervisor. If the Supervisor is unavailable or if you believe it would be inappropriate to contact that person (or if you have not received a prompt and fully acceptable reply), you should immediately contact Human Resources or any other Management team member in the company with whom you feel comfortable.

Employment of Relatives

Immediate family members (including parents, spouses, children and siblings) are eligible for employment at SIRs, provided they possess all qualifications for employment and their employment would not create a direct or indirect conflict of interest. Family members may not work under the direct or indirect supervision of another family member and if possible, it is preferred that they work in separate departments. The same conditions will apply for employees who marry or become members of the same household. Should a conflict arise, SIRs will attempt to find a suitable position within the Company to which one of the employees may transfer. If this is not feasible, the employees will be permitted to determine which of them will resign. If they are unable to make the decision themselves, SIRs will make the decision based on a number of factors including seniority, overall performance records, and operational needs.

Recruitment Policy Objective:

The objective of the recruitment Process is to enable HR to recruit the right person for the right profile.

Scope: The Recruitment Process will be applicable to all employees, directly or indirectly are involved and effect the final selection of the candidate.

Policy Details:

General Rules:

Each candidate who comes for interview will fill the Pre – Screening Form. Each Interviewer should mention his/her comments and signature in the Interview Feedback Form.


Sourcing hierarchy to be followed would be Job Portals, Employee Referrals and Recruitment Consultants.

Recruitment Process:

Process owner to discuss and finalize manpower requirements in his/her process with CEO and VP – Human Resources. Duly filled MRF along with the Job Description to be emailed to HR (in case of a new business line or vertical). (MRF format attached herewith) Talent Acquisition team initiates sourcing of candidates. Prime sourcing channel to be Job Portals, Recruitment Consultants, Direct Walk In & Employee Referrals. Profiles received from various sourcing channel to be shortlisted by TA. TA to call the shortlisted candidates and conduct initial screening of profiles & Sterling Introduction Sheet provided. Candidates shortlisted through initial screening to be intimated about the time and place for further interview rounds. TA to coordinate the interview schedule with respective Process Owners. TA to negotiate and finalize remuneration and Date of Joining with final list of shortlisted candidates. Checklist of relevant Documents to be issued post selection and Letter of Employment are issued on or before Date of Joining. Predictive Index survey to be conducted on the date of joining & filed in employee P File. TA to maintain shortlisted candidate’s resume along with Pre–Screening form, Interview Feedback Form, Predictive Index report and signed copy of Letter of Employment & handover the same to HR Operations team for filing on or before the date of Joining. TA to mail the Final list of joiners along with their joining details to concern departments. Joiner’s compensation details are emailed to HR Operations team for payroll. Exceptions:

The VP – Human Resources depending on the exigencies of the business may redefine the Recruitment Process, in conjunction with the CEO & Sr. VP - Ops.

EMPLOYEE REFERRAL POLICY

Objective: To set protocol for referral payout to employees.

Scope: The Referral Policy is applicable to all full time employees of the company. However, the below mentioned are not eligible for referral bonus: Members of the Senior Management Team – including department heads and their direct reports. Employees at or above Manager Level. Members of the Human

Resources Department. Anyone else who is involved in the recruitment process


Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources Policy Details: General Rules: The Employee is paid the referral amount after completion of 3 months from the Date of Joining of the reference. Referral amount is paid along with salary. The same will be paid after deduction of applicable Income Tax. The amount is paid only if none of the two parties (referrer & the referral) have resigned and/or are serving notice period. To avoid dual submission of resume for a particular candidate; we ensure cooling period of 3 months. (i.e.: If an employee has referred a particular candidate, the candidate remains his/her reference for the next 3 months.) Employees at or above Managerial Level & members from Human Resources Department are not eligible for Referral Bonus. Human Resources Team may release special Referral Programs over and above this standard program to reward employees & cater to Business needs. Such programs will be valid only for a pre defined time frame. Employee can not refer his/her spouse for the same Department/Process. Incase of any dispute, decision taken by Human Resources will be final and binding on all parties. Referral Process: The HR will email the details of open positions to the Mumbai Users inviting the employees to send references for the open positions. The candidate has to mention the name and contact number of the employee on the Pre-screening Form by whom he/she has been referred. The TA Team provides salary & employee source details to HR Operations team & they in turn maintain Referral Payout data month-wise [as a part of payroll data]. Referral Payout

Referral amounts for Operations:

Up to Sr. Verifier / Verification Specialist

/ QA / CCR

Team Coach – Dy. Manager

Manager – Sr. Manager AVP & above

5,000/-

10,000/-

20,000/-

40,000/-

Referral limits for Software Development Team:


Up to Sr. Software Developer Team / Tech Lead / Software Analyst

Project Manager & above

20,000/-

30,000/-

40,000/-

Exceptions: The VP – Human Resources depending on the exigencies of the business may redefine the Referral Policy, in conjunction with the CEO and Sr. VP Operations

INDUCTION POLICY

Objective: The objective of the Induction process is to educate new joiners’ on company history, growth, policies, events, activities, etc. Scope: The Induction Process is applicable to all employees, who directly or indirectly are

involved in implementing the Induction process. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources JAF being referred as Job Application Form NEO being referred as New Employee Orientation

TES being referred as Talent Engagement Specialist SEA being referred as Standard Employee Agreement NDA being referred as Non Disclosure Agreement Policy Details: General Rules: Induction Feedback form will be filled by all joiners. Lunch/snacks expenses for new joiners on first day to be borne by company Induction Process: Recruitment Team will share the New Joiners List with concerned parties HR operations team will conduct the initial introduction round. Organization joining kit to be provided to all new joiners. New joiners to be provided with various forms to be filled. (format of JAF attached) Relevant documents to be collected along with duly filled JAF. SEA, NDA, IT Form, Form 11 & India Consent Form are signed & filed in personal file. HR Generalist to present the NEO program.


Bank Account Opening formalities to be completed. New Joiners are provided with Transport details Department Business Head/Managers to meet the Induction batch. FCRA & ISO awareness training conducted by the EBT representative. HR Operations team to coordinate with IT department for issuing access card. New Joiners will be introduced to respective trainers/reporting supervisor as per requirements. The Induction Feedback form to be filled up by the employee after the completion of Induction. HR Ops team to mail induction attendance & report to concerned functions.

P.S.: SEA, NDA, India Consent Form and Form 11 can be filled separately as per requirement.

Exceptions: The VP – Human Resources depending on the exigencies of the business may redefine the Induction Process, in conjunction with the CEO.

Open door policy

Sterling infosystems has adopted an open door policy for all its employees. This means literally that every manager’s door is open to every employee. The purpose of an open door policy is to encourage open communication, feedback and discussion about any matter of importance to the company. Our open door policy means that employees are free to talk to any manager at any time.

Responsibility under open door policy

If any of your work is causing you concern, you have the responsibility to address your concern with a manager. Whether you have a problem, complaint or an observation, your company managers want to hear it from you.

Before you pursue an open door policy

Most problems can and should be solved in discussion with your immediate supervisor. This is encouraged as your first effort in solving the problem, But an open door policy means that you may also discuss your concerns with the next level of management and /or the HR staff members. No matter how you approach your problems you will find managers at all levels of organization willing to listen and help.

Communications Boards


The employee bulletin boards display, SIRs announcements, job and similar Material. These bulletin boards are provided to keep employees informed of events important to everyone. All employees should examine the boards frequently. If the notices appearing on the boards are not clear, or if an employee requires further Information about them, the appropriate supervisor, and/or manager should be contacted. The bulletin boards are reserved for Company business, and no one, other than Management, or other authorized personnel is permitted to post or remove any material From them. All bulletin board notices must receive appropriate “Supervisory Authorization”. This policy also applies to electronic (e-mail) postings. Please refrain from using the “All Sterling Users”/Mumbai users e-mail group for personal announcements or commentary.

Publicity/Statement to the Media

All media inquiries regarding the Company and its operation must be referred to Vikas Vig, CEO. Only the CEO is authorized to make or approve public statements pertaining to the Company or its operations. No employee, unless specifically designated by the CEO, is authorized to make those statements. Any employee wishing to write and/or publish an article, paper, or other publication on behalf of the Company must first obtain approval from the CEO.

REHIRING POLICY

Objective: To rehire the ex-employees of sterling infosystems Scope: All ex employees of Sterling infosystems,who have completed a cooling period of 3 months and have neither quit without notice nor been terminated due to process error or disciplinary issues are eligible for rehire. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources RT being referred as Recruitment Team Policy Details: Steps to be followed: Whenever an ex employee comes for interview, Talent Acquisition team will check the

attrition sheet for the below mentioned details: Previous Date Of Leaving Previous reason for leaving


Previous tenure Full and Final settlement status Previous Reporting Managers Feedback Important Notes:

An ex employee can be rehired only after a cooling period of 3 months Ex Employee who has quit without notice (absconded cases), terminated due to process

error or disciplinary issues may not be considered for rehiring After the ex employee is rehired, Talent Acquisition Team will fill the rehire form and the

same will be attached to his interview feedback form Ex-Employee will undergo the interview rounds & hired if he/she meets required criteria

Exceptions: The VP – Human Resources depending business exigencies may redefine the Rehiring Policy in conjunction with the CEO & Sr. VP Operations.

WHISTLE BLOWER POLICY

Objective: To enable the employees to report any non routine activity where the company integrity and ethical standards are being compromised. Scope: The Whistle Blower policy will be applicable to all full time employees of the company Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre.

HR being referred as Human Resources WBP being referred to Whistle Blower Policy Policy Details: Utilization Limits The Whistle Blower Policy is anonymous incident reporting method designed to enable the reporting of non- routine events and activities that call into question compliance with ethical standards. General Rules: An employee can report the below mentioned non routine activities:

Accounting or audit complaints or concerns Unfair Labor practice Discrimination Harassment Customer Mistreatment Unsafe work conditions Embezzlement


Waste of time and/or resources Compliance and regulation Violations Auditing Matters Corporate Scandals Other Ethical Violations

Procedure to blow the whistle:

In such scenarios, report the event to respective supervisor, if not resolved/ confident then, report it at email ID [email protected]

Steps to be followed:

Whenever the DL receives an e - mail or direct grievance/s from employees, the same needs to be escalated to the concerned department.

Follow up is done with the concerned department and the employee is informed on the resolution.(Turn Around Time to respond/follow up – 5 to 10 Days)

Any deviation from the process or the TAT is subject to VP-HR approval. Exceptions: The VP – Human Resources depending business exigencies may redefine the Whistle Blower Policy in conjunction with the CEO & Sr. VP Operations.

RELOCATION POLICY

Objective: To compensate an employee on whatever expenses he/she has incurred while relocating to Sterling Information Resources India Pvt Ltd and the reimbursement is subject to applicable laws. Scope: The Relocation Policy is applicable to all full time employees of the company who relocate from various parts of India to Sterling Information Resources India Pvt. Ltd. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre.

HR being referred as Human Resources. Policy Details:

General Rules:

Relocation may be due to either of the following reasons: Whenever an employee is transferred (whether such transfer is initiated by the

Company or by the employee). Whenever an outstation candidate is joining the Company.


Tickets fare for self, spouse and two kids. (Train or Air will be as per level and at the sole discretion of the Company.)

Transportation charges of households, furniture to the present location. Temporary lodging expenses are subject to a maximum room rent of Rs. 1000/- per day.

(Only hotel/motel room rent charges) The candidate/employee may make relocation arrangements prior to relocating his

family. In such a scenario, employee will be paid to and fro charges for two such visits. Mode of transport for which such reimbursement would be payable would be bus (Volvo) or train (III Tier A/C or A/C Chair car).

Relocation reimbursement would exclude deposit paid for the house and/or rent paid.

Relocation Eligibility Process:

Employees on relocation are eligible for Travel expenses as per the following table:

Note:

This is applicable to Company-initiated relocation as well as Employee initiated relocation. In case the travel is for a distance less than 400 km, the mode of travel will be Train and

entitlement will be II AC, AC Chair Car, AC Bus or AC vehicle. Employees on company-initiated relocation are eligible for reimbursement of

expenses incurred for transportation of household effects. The reimbursement as

shown in the table below:

Note:

Grade Mode Class of Travel Family

Executive to Assistant Manager Train Second Class AC χ

Manager & Sr. Manager Train Second Class AC

Associate Director & above Air Economy Class

Grade Amount

Executive to Assistant Manager Rs. 10,000 or Actual whichever is less

Manager & Sr. Manager Rs.15,000 or Actual whichever is less

Associate Director & above On Actual


The reimbursement amount indicated above includes incidental expenses like Insurance, Packaging, Loading and unloading charges.

The reimbursement claims must be supported by original bills (Lorry / Rail receipts). Such reimbursement is not applicable to employee-initiated relocation.

3. In case of cash advance, the employees needs to take an approval from Finance Team

4. In case of reimbursement, the employee needs to submit the documents as per below checklist.

Previous address proof (rent agreement/bill/passport)

Current address proof (rent agreement/bill/passport)

Photocopy of employment letter Family members proof (Ration Card) Photocopy of approved quotation for

cargo Original bills for the expenses

incurred Original tickets for the travel

undertaken Temporary lodging receipt

5. In the event of a voluntary resignation of the employee within six months of relocation, the employee will be responsible for repayment of all the relocation expenses. In the event of resignation by the employee between six to twelve months of relocation, 50% of the relocation expenses will need to be paid back by the employee.

Exceptions:

The VP – Human Resources depending on the exigencies of the business may redefine the Relocation policy, in conjunction with the CEO & Sr. VP - Operations.

INTERNATIONAL TRAVEL POLICY

Objective: The objective of this policy is meant to serve as the reference for expenses to be

incurred by employees while traveling abroad in case of Business Exigency. Adequate care has been taken to ensure that employees’ comfort is not compromised while not giving in to extravagance. Scope: The International Travel policy will be applicable to all full time employees of the company as per their grade and level.


Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources FIN being referred as Finance SDT being referred as Software Development Team Policy Details: Entitlement To ensure that expenses are not incurred above prescribed RBI limits for foreign exchange, tickets for all travel between countries must be booked through Fin before leaving the country. Exception will require specific approval of the VP – HR and the CEO. The Company will not assist individuals traveling abroad on business in acquiring a passport. The cost of making the passport and subsequent renewals, additional booklets, etc. will be borne by the employee. Utilization Limits: As per Management Discretion and Business Exigency. General Rules: An employee will continue to get his / her full Salary. This will be credited to his/her bank account in India. The per diem rates are USD 65 per day. This is calculated from next day of travel till the day of boarding the aircraft from US If any leave is availed during this period of travel, those days will not be accounted for the per diem allowance and lodging expenses. Accommodation to be taken care by US. It is possible that the client with whom the employee is allocated would have provisions for Internet / telephones /Fax etc. facilities. One has to be extremely judicious and careful in utilizing these facilities and under no circumstances should they be misused. The employee should be aware that clients routinely check on the usage of these facilities. Any misuse of the facilities would mean instant recall to India, and the employee would face severe disciplinary action. Plan for medical / travel insurance Forex arrangement is made USD 65 per day as per diem from the next day of travel till the day of boarding the aircraft from US We pay USD 200 in currency and rest in Travel Card (Axis Bank) Travel expense settlement form. Our office in the US will arrange for accommodation Visa Validity/Extension: The employee must return to India before his/her visa and period of stay expires. He /she must ensure that the employee's passport is stamped with a proper validity date upon arrival in the destination. Any variation in this must be brought to the notice of the concerned authority, since an extension would be needed to apply before the date of expiration.


Medical Insurance

All employees on overseas travel are covered under the overseas Medical Insurance for the period of their stay. If their stay gets extended they should intimate the HR/FIN department in India to have their medical insurance extended for that period.

Procedure for International Travel:

After the process owner gets business buy in for travel to the US, continued below process is followed;

The process owner gets permission from their reporting authority for travel to the US Visa fees paid with HDFC Employee fill up the form online D-160, and avail their interview date with VISA Officer. Invitation letter handed over to employee. Letter to visa office handed over to employee. Once stamping done, we take the copy of visa for insurance purpose Travel date will be fixed with ops head with their counter part in US and the employee is

informed on Travel Date Exceptions: The VP – Human Resources depending on the business exigency may redefine the International Travel Policy in conjunction with company’s CEO & Finance Controller.

Compensation

Sterling Information Resources India Pvt. Ltd. strives to remain on the cutting edge of our industry. In order to do so we hire qualified employees and are determined to compensate them. Accordingly several factors may influence your rate of pay. Some of the factors the company considers are the nature and scope of your job, what other employers pay their employees for comparable jobs what the company pays their employees in comparable positions and individual as well as company performance.

Hours of Operation and Workweek

Work schedules for employees vary throughout our organization. Staffing needs and operational demands may necessitate variations in the total hours that may be scheduled each day and week. Supervisors will advise employees of their individual work schedules.


Lunch Breaks

Lunch breaks are mandatory and should be scheduled to accommodate the demands of the department. Individual lunch/Dinner breaks may change over time as department demands change. Cafeteria has been provided for the convenience of the employees to enjoy their lunch indoors. Lunch and dinner are available in cafeteria for the employees at subsidized rates.

* Updating Attendance on a daily basis is the respective Reporting Managers / Trainers responsibility.

Pay Day

The scheduled pay day for employees will be on the 7th of every month, unless intimated otherwise. In the event that a regularly scheduled payday falls on a day off; (e.g. weekend or holiday), employees will be paid on the work day prior to the regularly scheduled payday. Employee Benefit Information

It is important that each employee’s name, address, and telephone number be kept accurate and current in the Company records. Therefore, it is each employee’s responsibility to report changes in his or her name, address, telephone number, and emergency contact information to the Human Resources Department. For benefits related information, it is critical to keep the Company informed of any changes that may affect benefits (e.g., marriage, divorce, birth, death, etc.) This information must be provided to the Human Resources Department within 30 days of the event. Workers’ Compensation Insurance Under this insurance, employees may receive benefits. The amount of benefit is based on the nature of the injury/illness and the amount of the employee’s wages. All work related injuries or accidents, no matter how slight, must be reported to the Human Resources immediately. Eligible employees will be covered under the ESIC Act as per the terms and conditions.


Employee Insurance

Mediclaim Policy Eligibility: All full time employees of the Sterling India Family. Mediclaim Coverage: The coverage would be in the following ranges based on level 1. INR 1,00,000/- 2. INR 1,50,000/- 3. INR 2,00,000/- Policy Highlights

1. Special Benefits 1. Pre-existing Diseases Cover Including Congenital Internal Diseases (Clause 4.1) –

Covered from Day One. 2. Waiver of 1,2,3,4 year exclusion (Clause 4.3). 3. Waiver of 30 Days Waiting Period (Clause 4.2). 4. Hospitalization due to Terrorism Effect is covered. 5. Pre Hospitalization Expenses (Excluding maternity) to be covered for 30 days. 6. Post Hospitalization Expenses (Excluding maternity) to be covered for 60 days. 2. Special Limits

1. Maternity Benefit Covered from Day One with the limit of 25 K for Normal and 35K for Caesarean. ( This benefit is not there in previous years policy)

2. Insurance covers first 2 deliveries only. 3. Room Rent Per Day Restrictions – 1% of Sum Insured. 4. ICU Rent per Day Restrictions for room rent – 2% of Sum Insured. Standard Exclusions 1. HIV and AIDS 2. Intentional Self-Injury, Use of intoxicating drugs/alcohol, Venereal Diseases,

Naturopathy, unproven procedure/treatment, experimental or alternative medicine/treatment including acupuncture, acupressure, magneto-therapy etc

3. All psychiatric & psychosomatic disorders 4. Injury or Disease caused directly or indirectly by nuclear weapons 5. Naturopathy 6. Expenses on Vitamins/Tonics unless forming part of treatment 7. Cost of Spectacles or Contact Lenses, Correction of eye sight, Hearing Aid etc. 8. Any cosmetic or plastic surgery except for correction of injury 9. War, Invasion, Act of foreign enemy, War like operations, Nuclear weapons, Ionising

Radiation, contamination by Radioactive material nuclear fuel or nuclear waste 10. Any hospitalization for Diagnostic tests only 11. Infertility treatment 12. Any hospitalization less than 24 hours except for specific treatments like Dialysis,

Chemotherapy, Radiotherapy, Cataract Surgery, Lithotripsy, Tonsillectomy etc. 13. Any Non Medical Expenses like Registration Fees, Admission Fees, Charges for Medical

Records, Cafeteria Charges, Telephone Charges, Service Charges etc. 14. Any dental treatment or surgery which is corrective – filling of cavity, root canal etc.


15. Expenses incurred for investigation or treatment or irrelevant to the diagnosed during hospitalization, private nursing charges, referral fee to family physician, outstation Doctor/Surgeon/ consultants’ fees etc.

16. Vaccination & Inoculation 17. Treatment which is continued before & after hospitalization for an ailment / disease /

injury different from one for which hospitalization was necessary 18. Voluntary Termination of Pregnancy during first 12 weeks from the date of conception. 19. Treatment arising from or traceable to pregnancy/ childbirth including caesarean section,

miscarriage, abortion or complications thereof including changes in chronic conditions arising out of pregnancy

20. Out patient Diagnostic, Medical or Surgical procedures or treatments, non-prescribed drugs & Hormone replacement Therapy, Sex Change

21. Any treatment received in convalescent home, convalescent hospital, health hydro, nature care clinic

22. Doctor’s home visit charges, Attendant/Nursing Charges during pre & post Hospitalization 23. External/ durable medical/Non-medical equipments of any kind used for

diagnosis/treatment including CPAP, CAPD, infusion Pump etc., ambulatory devices like walker/ crutches/ belts/ collars/caps/ splints/ slings/ braces/ stockings/ diabetic foot-wear/ glucometer/ thermometer & similar related items & any medical equipment which could be used at home subsequently.

24. Non-medical expenses including personal comfort/ convenience items/ services such as telephone/ television/ aya/ barber/ beauty services/ diet charges/ baby food/ cosmetics/napkins/ toiletries/ guest services etc.

25. Treatment which the insured was on before hospitalization and required to be on after discharge for the ailment/disease/injury different from the one for which hospitalization was necessary.

How to use Medimanage Portal

1. Log-on to your account by using the alternate e-mail id as log-in id and your DOB in DDMMYYYY as the password.

2. You will view the main Dashboard “Member Central” of the application. 3. Please click on the “My Communication” tab to proceed further. 4. Select a category of support request. 5. Enter a “Subject” of your request & then enter the Message describing your request. 6. Attach documents if any and then submit the Support Request. 7. A Ticket No. will be generated and will be reflected in the History of all your requests. 8. Immediately after you submit a request, you will receive an acknowledgement e-mail on

the registered e-mail ids. 9. When Medimanage representative responds to your Message, you will get an alert about

the same on the registered e-mail ids. 10. To check the response from Medimanage, pick the particular Message from the History or

Search with Ticket no. Or Subject of your Message. Enrollment 1. Enroll yourself & family members with Medimanage on www.medimanage.com 2. Update status changes in the family within 30 days 3. If Married, provide info about spouse (Name/DOB/Relationship) 4. Had a baby, provide info about baby (Name/DOB/Relationship) 5. If any member covered under plan Expires, Please inform.


6. Please note that you cannot change your dependents during the currency of the policy except for the events like New Child Birth & Marriage. The details given by you at commencement of policy would be FINAL.

TPA ID Cards for Hospitalization 1. Identifies you as Sterling Health Plan member 2. If hospital insists on photo identification, can be produced along with any other Photo ID

like Sterling I.D Card. 3. Each Health Plan member gets separate card. 4. Non-Transferable 5. Provides you Emergency admission at Network hospital

How to avail Basic Insurance Services?

HOSPITALISATION AT NETWORK HOSPITAL: If the hospitalization is in the Network Hospital of Mediassist you need to fill up Cashless Request Form & follow process of Cashless Route HOSPITALISATION AT NON NETWORK HOSPITAL: If the hospitalization is in the Non-network Hospital, you complete your hospitalization, pay the bill & follow process of Reimbursement of expenses. In case of Planned Hospitalization 1. Obtain the Pre-Authorization Form from Mediclaim Desk of Network Hospital

a. Fill by yourself the details like

1. Name of the person to be hospitalized 2. Mediassist ID & Employee ID No. 3. Relationship (Self/Spouse/Son etc.)

b. To be filled by Treating Doctor

1. Proposed date of admission 2. History of illness / ailment 3. Approximate duration of hospitalization 4. Approximate Expenses (to be filled in by Hospital Administration)

2. Hospital Administration would fax the Pre-authorization Form to Mediassist 3. The Mediassist Staff would scrutinize the form 4. Mediassist will fax the Authorization Letter to the concerned hospital within 24 hours. 5. You can get hospitalized & the treatment can start. 6. On discharge, Sign the bills, claims form & pay the non-medical charges only. In case of Emergency Hospitalization 1. Get the patient hospitalized at the desired / nearest network hospital 2. In case, if the hospital insists for deposit, pay the same & get it returned once Mediassist

settles the claim with Hospital. 3. Let the patient stabilize 4. Follow up the standard Pre-Authorization process 5. Follow the standard discharge process


Cashless Hospitalization Mediassist will only pay for the Medical Expenses You need not make any payment for any of the medical expenses. You must pay for the non-medical expenses on discharge or whenever asked by

hospital The bills for medical expenses would be sent to Mediassist by the hospital & they

would directly settle the same with hospital

Non Network Hospitalization 1. You get hospitalized in any hospital registered with local municipal authority or a

hospital having minimum 15-beds. 2. Get Discharge after making all the necessary payments. 3. Also obtain the Hospital Registration No. 4. Submit all the necessary documents (in original) along with Claims Form within 30

days from the date of discharge to the Claims Collection arranged by Medimanage at your worksite.

Documents for Reimbursement Claims All documents mentioned herein should be submitted in ORIGINAL

1. Discharge Card 2. Detailed Hospital Bill 3. Pre-numbered Cash Paid Receipts for payments made to hospital 4. Prescriptions, Reports & Bills for all Diagnostics Tests 5. Prescriptions & Bills for all Medicines purchased 6. Gravida Status (No. of Living Children) in case of Maternity 7. All Main Hospitalization bills should be submitted for claim within 30 days from Date of

Discharge.

Reimbursement Claims 1. All Pre-Hospitalization bills should be submitted for claim along with the main bills

only within 60 days. (Pre Hospitalization Expenses (Excluding Maternity to be covered for 30 days)

2. All Post-Hospitalization bills should be submitted for claim within 90 days from Date of Discharge.

Function Contact Person

Contact Details

Enrollments

Ms. Kajal Shinde

Login to the web site www.medimanage.com Raise a ticket by logging in through Ms Kajal’s Communication module.

Reimbursement claim

Mrs. Apurva Vedak

Login to the web site www.medimanage.com Raise a ticket by logging in through my Claims module.


Cashless Claim

Ms. Kousar Zari

+91 98200 46961

[email protected]

First Level Escalation Contact

Enrollment

Ms. Anjali Powar

[email protected]

Cashless and Reimbursement Claim

Mrs. Apurva Vedak

[email protected]

( Final Escalation)

Mr. Amar Maskey [email protected]

Group Personal Accident Insurance Plan Eligibility: 1) All full time employees of the Sterling India Family. 2) Individual Sum Insured of INR 10,00,000, INR 30,00,000, INR 50,00,000 as per HR Policy 3) Cover for only Employees Provides you benefits in case of Loss due to Accident…

1) In case of DEATH 2) In case of Physical Disability (PTD/PPD) 3) In case of Inability to attend work due to accident-induced disability (TTD) Maximum

up to 104 Weeks 4) The Maximum benefit is up to Sum Insured. 5) Cover is for 24/7 hours and on a worldwide basis. 6) Terrorism Cover. 7) Medical extension = 10% of CSI or 50% of admissible claim amount or actual whichever

is lower. In Case of Accidental Death

1. Your family will receive the total sum insured as benefit. In case of Loss of Two Limbs OR Two Eyes OR One Limb & One Eye due to an Accident

1. You will receive100% sum insured as benefit. In Case of Loss of One Limb OR One Eye due to an accident

You will receive 50% sum insured as benefit In case of loss of any other organ (Permanent Partial Disablement) due to an accident You will receive 1% – 50% of the sum insured as benefit.


In Case, you can not attend the office because of Temporary Total Disablement due to an accident

- You will receive weekly compensation @ 1% of Sum Insured or 5000/- Max up to 104 Weeks.

You can avail benefits. 1. If you are already in employment before 15th April 2010, then immediately 2. If you have joined after 15th April 2010, then w.e.f. your Date of Joining The Insurance cover ends on…..

1) Standard Termination of the Policy i.e. 14th April 2011 at 12:00 midnight 2) Separation from Sterling.

Standard Exclusions

1) Self exposure to needless peril (except in an attempt to save human life). 2) Congenital anomalies or any complications or conditions arising there from. 3) Participation in an actual or attempted felony, riot, crime, misdemeanor, or civil

commotion. Victims of riots are covered. 4) Participation in winter sports, skydiving/parachuting, hang gliding, bungee jumping,

scuba diving, mountain climbing (where ropes or guides are customarily used), riding or driving in races or rallies using a motorized vehicle or bicycle, caving or pot holing, hunting or equestrian activities, skin diving or other underwater activity, rafting or canoeing involving white water rapids, yachting or boating outside coastal waters (2 miles), participation in any Professional Sports, any bodily contact sport or any other hazardous or potentially dangerous sport for which You are untrained.

5) Suicide, attempted suicide (whether sane or insane) or intentionally self-inflicted Injury or Illness, or sexually transmitted conditions, mental or nervous disorder, anxiety, stress or depression, Acquired Immune Deficiency Syndrome (AIDS), Human Immune deficiency Virus (HIV) infection.

6) Being under the influence of drugs, alcohol, or other intoxicants or hallucinogens unless properly prescribed by a Physician and taken as prescribed.

7) Participation in an actual or attempted felony, riot, crime, misdemeanor, or civil commotion. Victims of riots are covered.

8) Operating or learning to operate any aircraft, or performing duties as a member of the crew on any aircraft, or schedules Airlines.

9) War, civil War, invasion, insurrection, revolution, act of foreign enemy, hostilities (whether War be declared or not), rebellion, mutiny, use of military power or usurpation of government or military power.

10) Ionizing radiation or contamination by radioactivity from any nuclear fuel or from any nuclear waste from burning nuclear fuel.

11) Any Pre-existing Condition or any complication arising from it. Claims Procedure

1. You or your family MUST intimate your HR within 24 hours of Accident occurrence. 2. In case of Accident involving a Motor Vehicle, a FIR (First Information Report) with

Local Police Station is MUST. 3. A Certificate from treating doctor certifying the condition of the patient should be

submitted to HR. 4. HR, in turn, will certify the absence record & submit the complete claim documents to

the insurance co. 5. Insurance co. may ask for additional documents, if needed & upon satisfaction, will

pay the claim. Documents to be submitted


Duly completed claim form by Claimant & Medical Practitioner Death certificate, in case of death claims Post mortem Report, in case of death claims Proof of employment and designation (Salary slip etc) Doctor’s Certificate confirming the percentage of disability in case of PPD and PTD Police Panchnama report, copy of FIR, wherever necessary Investigation Reports like Laboratory test, X-rays, and reports essential for confirmation

of type and percentage of disability. Copy of Driving License & R C Book in case of RTA Leave Records from the employer, if absent due to injury (TTD).

Cha

rity

Sterling Information Resources India Pvt. Ltd. recognizes the importance of charitable non-profit organizations. We believe in sharing and in serving the society. we currently have a tie –up with “Ma-Niketan” and encourage our employees to contribute in any way possible in helping their cause.

Contact Person Contact Details

Ms. Kajal Shinde

[email protected]

+ 91 22 67282916

First Level Escalation Contact

Mrs. Anjali Powar

[email protected]

+ 91 22 67282905

Final Escalation

Mr. Amar Maskey

[email protected]

+ 9820184094


Employee Recognition Programs

Sterling recognizes that employees are a major contributing factor to the Company’s success. To show appreciation, Sterling has established a whole range of unique programs like the Employee Of The Month, Appreciation slips, Etc.

ATTENDANCE AND LEAVE

Punctuality and regular attendance is essential to efficient operation of the company. Sterling Infosystems would like you to be ready for work at the beginning of your assigned daily work hours, and to reasonably complete your projects by the end of your assigned work hours. Employees are expected to report to work as scheduled, on time and be prepared to start work. You are also expected to remain at work for your entire work Schedule, except for meal periods or when required leaving on authorized company Business. Late arrival, early departure or other absences from scheduled hours are disruptive and must be avoided. Failure to report to work and/or repeated failures to notify the supervisor or manager prior to the shift starting time regarding absence or tardiness may be considered grounds for disciplinary action. Proper call-in procedures will be provided by the supervisor at the time of hire and may be updated periodically. It is essential that these procedures be followed. 10 hours (9 hours of login time and 1 hour of break) constitute a working day.

Absence and Tardiness

To maintain a safe and productive work environment, Sterling Information Resources India Pvt. Ltd. expects employees to be reliable and to be punctual in reporting for Scheduled work. Absenteeism and tardiness place a burden on other employees and on Sterling Information Resources India Pvt. Ltd. In the rare instances when employees cannot avoid being late to work or are unable to work as scheduled, they should notify


their supervisor as soon as possible in advance of the anticipated tardiness or absence. Poor attendance and excessive tardiness are disruptive. Excessive unexcused absences may lead to disciplinary action, up to and including termination of employment. Management, in conjunction with Human Resources will determine if an employee’s absences constitute excessiveness. If for any reason you have an unplanned absence, call your supervisor as soon a possible to report the nature of your absence and when you expect to return to work. seven consecutive days of no-call/no-show will constitute job abandonment and will be Considered a voluntary resignation.

Excessive Lateness

Employees are expected to arrive for work on time according to the schedule provided by their manager or supervisor. Employees are expected to inform their manager or supervisor of an anticipated late arrival. Failing to inform a manager or Supervisor of a late arrival will result in the recording of an unexcused late arrival. In any 180 day period unexcused late arrivals will be treated as follows: 1. First unexcused late arrival – unexcused late arrival will be noted; no other action will be taken. 2. Second unexcused late arrival - employee will receive a verbal warning and a note regarding the warning will be included in the employee’s record.

LEAVE POLICY

Objective: To enable the employees to meet their social commitments, personal exigencies, sickness and leisure. It is therefore necessary that employees avail leave during the course of the year. The processes pertaining to Paternity Leave, Unauthorized Absence and Maternity Leave covered under Maternity Benefit Act, 1961 will be provided in this process.


Scope: The Leave Policy will be applicable to all full time employees of the company. The maternity benefits policy will be applicable for all female employees covered under the Maternity Benefit Act, 1961. Paternity Leave will be applicable to all male employee of the company. All employees in the Sterling Infosystems India Pvt Limited are eligible for the following categories of leaves: 1. Comprehensive Earned Leave (CEL) 2. Maternity Leave (ML) 3. Paternity Leave (PL) Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources Policy Details:

Entitlement Bombay Shops and Establishment Act, 1948 shall govern leave entitlements. Employees will be eligible for a total of 24 working days of leave for each completed year of service. Utilization Limits

Leave Type

Eligibility (In Days)

Entitlement Utilization Limit

(in Days) – Confirmed Employee

Utilization Limit (in Days) – Probationers

Approval Required

CEL 24 >= 6 months Available Balance 05 Reporting Manager

ML 84 >= 80 Days 84 84 Reporting Manager & Human Resources

PL 5 >= 6 months 05 NA Reporting Manager & Human Resources

Deductions Applicable


Snapshot of Leave Categories and Impact

Deductions / Impact basis Type of Leave availed

Leave Type

Abbreviation

for

Attendance

Updation

No. of Days

applied

Minimum

Intimation

Time to

Supervisor

[Business

days/hrs]

Leave

Balance Salary

Attendance

Incentive

Performance

Incentive *

DAP

Applicability IJP Impact

Scheduled

Leave SL => 5 Days

>= 5 Days

Notice Yes No No No No No

Scheduled

Leave SL 1 ‐ 4 Days

>= 3 Days

Notice Yes No No No No No

Unscheduled

Leave Approved USLA 1‐2 Days >= 2 Hrs Notice Yes No No No No No

Unscheduled

Leave not

approved yet

availed * USLN Any NA No Yes Yes

50% on 1st

Instance &

100% on 2nd

Instance

On 2nd

Instance No

Half Day

approved HDA.

>= 5 hrs < 10

hrs work >= 2 Hrs Notice Yes No No No No No

Half Day

Unapproved yet

availed * HDN Any NA No Yes

on 2nd

Instance in 1

Month No

on 4th

Instance In case of a DAP

No Call No

Show NCNS Any Uninformed No Yes Yes

50% on 1st

Instance &

100% on 2nd

Instance

On 2nd

Instance Yes

Maternity

Leave ML 84 Days

1 Calendar

Month No No Yes Yes No No

Paternity Leave PL 5 Days >= 2 Hrs Notice No No No No No No

The above mentioned grid is a subset of Leave policy and rest of the clauses remain unaltered.

* Reason for denying leave must be recorded by the respective reporting Manager/Supervisor.

‐ To qualify for Performance Incentives each employee must have attendance for at least 15 business days in that month.

Compensatory Off Clause:

‐ Managerial levels & above are not eligible for compensatory offs & Over time allowance.

‐ Employees below Managerial levels may be paid out as Over Time / allowed to avail Compensatory Off at the Function Heads discretion.

‐ Functional Heads/SPOC will need to maintain the records for Compensatory Offs and/or Over Time approved for timely reconciliation & payouts

with Finance & HR Team.

* Unless it is unapproved or if there is no leave balance available


Accumulation of Leave:

Leaves shall be accumulated up to a maximum of 45 days. Any leave exceeding this limit as on December 31st will be en-cashed on the basis of Gross pay in the January Payroll.

Important Notes:

- Employee who joins post the 10th of the month will be eligible for 1 day leave for that particular month

- Employee who joins on or prior to the 10th of the month shall get 2 days of leave for that particular month

- During Probation an employee cannot avail beyond 5 days of leave. - Employee will not be permitted to take Leaves during the training period. - If unscheduled leave is not approved by the reporting manager it may lead to loss of

pay. - CEL cannot be clubbed with ML unless approved by the Functional Head & Head HR. - Sanction of leave of any kind is subject to work exigency & Managerial approval. - Approved leaves can be denied on grounds of Business needs with prior intimation of

3 working days to the employee. Maternity Leave Applicability: Maternity Benefit Act, 1961, shall govern female Employees not covered under ESI Scheme. Quantum of leave: For Female Employees covered under the Maternity Benefit Act, a total of 12 weeks i.e. 84 days. Any period of absence, which is greater than 12 weeks, shall not be treated as Maternity Leave. The female employee is paid the full salary while on Maternity leave with an exception of attendance/performance incentive for this period (if applicable as per her offer). Procedure Expectant Female employee should apply for maternity leave at least a month in advance of commencement of leave. A medical certificate should accompany such leave application from a registered Medical Practitioner indicating the expected date of delivery.


ML is given only for the first 2 deliveries. ML can be availed only 6 weeks prior to the expected date of delivery In case of miscarriage, employee can avail leave up to 6 weeks from date of miscarriage. Paternity Leave (PL)

1. Employees should have worked for 180 days (6 months) at least to be entitled for PL. 2. PL is given only for the first 2 children only

Others

1. Employee who joins post the 10th of the month will be eligible for 1 day leave for that particular month

2. Employee who joins on or prior to the 10th of the month shall get 2 days of leave for that particular month

3. During Probation an employee cannot avail beyond 5 days of leave. 4. Employee will not be permitted to take Leaves during the training period. 5. If unscheduled leave is not approved by the reporting manager it may lead to loss of pay. 6. CEL cannot be clubbed with ML unless approved by the Functional Head & Head HR. 7. Sanction of leave of any kind is subject to work exigency & Managerial approval. 8. Approved leaves can be denied on grounds of Business needs with prior intimation of 3

working days to the employee. Unauthorized Absence 1) Any absence without prior approval or intimation to superiors will be termed as

unauthorized absence. 2) Any unauthorized absence will be considered as a misconduct and be liable for

disciplinary action on the employee 3) Any unauthorized absence of 3 days or more will result in disciplinary action to be taken

on that employee. Following procedure will be followed for the same.

1. First Warning Letter mentioning the period of unauthorized absence will be sent on the fourth day asking the employee to report to the office within 3 Working days from date of the letter.

2. In case the employee does not join on the stipulated date, the second and final letter will be sent on the presumption of abandonment of service.

3. The cases of unauthorized absence can be tracked through the HRIS, based on which HR sends the letters for long absenteeism.

Exceptions: The VP – Human Resources depending on the business exigency may redefine the leave policy and unauthorized absence policies, in conjunction with the CEO & Sr. VP

Operations. Since maternity leave is a statutory compliance, provisions as framed by the Govt. of India from time to time will be applicable.


Performance Reviews

When an employee joins the Company, his or her personnel record begins. Depending on job classification and skill level, periodic evaluations will be made to determine each employee’s individual progress, training needs, and wage or salary. Performance evaluations are important tools to be used to encourage efforts that drive the strategic business direction of the company. The performance appraisal process is carried out as per the performance management system policy described below: Objective: To create career growth through the process of obtaining, analyzing and recording information about the relative worth of an employee to the organization. The purpose of such evaluations is to provide you and your manager with opportunities to discuss your job tasks, encourage and recognize strengths, identify and correct weakness and discuss methods for improving your performance. Scope: The policy is applicable to all full time employees of company who fall in the appraisal cycle. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), team leaders, and quality control specialists and other employees under management cadre HR being referred as Human Resources DAP being referred as Disciplinary Action Plan CAP being referred as Corrective Action Plan MLT being referred as Mumbai Leadership Team PD being referred as Performance Development

Policy Details: General Rules:

Revised appraisal letters will be issued only after HR team receives ratings from respective Process Head.

Bi Annual appraisal process is followed. (January and July). DAP/CAP issued in last 3 months before the appraisal will be taken into

consideration. Immediate supervisor will be Appraiser and Process Head will be Final

Reviewer. Employees who have been rated “Below Average” would be put under PIP

plan by default.


Performance Appraisal Process: Corporate Goals to be discussed & decided at the start of the year for all functions. Departmental goals discussed & decided upon post finalization of corporate Goals. Individual KRAs decided & communicated to all by the process owners post the

departmental goals being discussed & finalized. PMS eligible list rolled out by HR team to department heads during the PMS cycles

[January & July]. Functional managers to communicate ratings to Function Head. Normalization & forced ranking process to be carried out. Final rating & forced raking communicated to HR for hygiene check. Final ratings shared with Managers & concerned employees. PMS documentation Promotion/Increment finalized in consultation with stakeholders & letters are issued

accordingly. Exceptions The VP – Human Resources depending Business Exigency may redefine the Performance Appraisal policy in conjunction with the CEO.

PERFORMANCE IMPROVEMENT PLAN (PIP)

Steps to be followed:

In scenarios where the employee performance is traced and is not up to the expectations, the below mentioned steps to be followed:

Employee Performance is tracked & measured as per the benchmarks set. Employee commits errors and/or has severe performance issues; he/she is placed under

the Performance Improvement Plan [PIP] for a period of 30 days. PIP Form to be filled & duly signed Acknowledgement copy to be handed over to HR for

filing. Refresher Training/Coaching & Mentoring required meeting the target set. Performance needs to be reviewed constantly and periodic documented feedback to be

given. Post PIP phase; One on One Performance Review with the employee to discuss the

outcome of the program. Favorable/Acceptable Improvement Shown - Employee is taken out of PIP with

communication to HR. No Improvement Shown - Employee is referred to HR for Redeployment or Employee

Separation. Decision of the process owner and HR is final and binding on all parties. Organizational Record updated & relevant documents to be filed in Employee Personal File.


PROBATIONARY PERIOD

The probationary period is intended to give new employees the opportunity to demonstrate their ability to achieve a satisfactory level of performance and to determine whether the new position meets their expectations. Sterling Information Resources India Pvt. Ltd. uses this period to evaluate employee capabilities, work habits, and overall performance. Either the employee or Sterling Information Resources India Pvt. Ltd. may end the employment relationship “at will” at any time during or after the probationary period, with or without cause. It is advised that employees, who wish to terminate their employment with Sterling Information Resources India Pvt. Ltd. give notice to their

supervisor, 21 working days in advance. All new employees work on a probationary basis for the first 180 calendar days after the date of hire. Any significant absence will automatically extend the probationary period by the length of the absence. Upon satisfactory completion of the probationary period, employees enter the permanent employment classification. After the initial 180 days probationary period, permanent employment will be offered or the probationary period will be extended. Likewise nevertheless, at all times, the Employee’s status will remain “at-will”. On

completion of probation, employees are eligible to use their Leave as per the leave policy in the following months. During the tenure of probation the employees are eligible only for five days as leave. Probationary employees depending on the department may be eligible for a 6 month review which will occur on completion of 6 months from their date of hire. Subsequent reviews will be conducted as per our performance management program.

CONFIRMATION POLICY

Objective: To conduct the Confirmation Process for all employees who have completed their probation period.

Scope: The Confirmation Policy is applicable to all employees who spend stipulated time frame within the organization.


Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources Policy Details: General Rules Confirmation can be extended only by one month. After a month the Employee either has

to be confirmed or terminated from the system. In any case a non confirmed employee cannot be transferred to any other team or

process. Confirmation Letters will be issued if Manager does not raise a concern or object to a

particular employees’ confirmation. Confirmation can be delayed on account of performance issues or behavioral issues. 1. The performance issues arise when the individual gets not more than rating of 1 2. Behavioral issues arise in cases of integrity issues like theft, manhandling, customer

SLA’s, drug abuse, sexual misconduct, etc. Delayed cases of confirmation - are not allowed to apply for an IJP for a period of 3 months from the actual date of confirmation. The reason for extending Confirmation along with performance improvement action plan

needs to be shared with the concerned employee by the reporting manager/supervisor basis which employee’s performance will be reviewed at the end of extension period.

Confirmation Process:

Auto Confirmation process introduced w.e.f. August 2010. List of employees due for their confirmation is emailed to the respective

Managers by the 10th of each month Reporting Managers/Supervisors to revert within 5 working days in

case they want an employee’s probation to be extended due to non-performance, CAP/DAP, NCNS issues, etc.

Incase of extension, Performance Improvement Action Plan needs to be handed over to the employee basis which his/her performance will be reviewed towards the end of extension period.

Incase of No Objection/ No Communication within 5 working days from immediate Supervisor/Manager, the employee is considered Confirmed & confirmation letter is issued by 20th of the month.

Letter of confirmation is issued to the employee and the acknowledgement copy is retained by HR for their respective personal files.

Discrepancy or PIP cases are forwarded to HR Generalist team. Exceptions: Depending on the business exigency the VP – Human Resources may redefine the Confirmation policy, in conjunction with the CEO & Sr. VP Operations.

ADVANCING WITH THE COMPANY: PROMOTIONS


The opportunity to advance is important to everyone. When job openings occur, the Company is interested in obtaining the best-qualified personnel available, consistent with the requirements of the job. It is SIRs general preference to promote from within whenever present employees are qualified to support both the Company’s short and long-range needs and growth goals. By promoting from within the organization, the Company attempts to offer as many opportunities for advancement as possible. Promotional opportunities are generally awarded to the individual who has personally achieved the skills and experience necessary for an advanced position. Promotions do not correspond only to the length of one’s employment (Employees are eligible for transfer or promotion after 3 months in a position). However, employees are not eligible for promotion for three months following the receipt of a warning or other adverse employment action. Most open positions are posted on the Company’s communications boards or emails. Because SIRs continues to be a rapidly growing organization and is at times in need of specialized skills, our human resources strategy also includes outside hiring to fulfill the Company’s needs. Sterling infosystems is dedicated to assisting employees to reach their professional goals through internal promotion and transfer opportunities. One of the tools the company makes available to employees in managing their careers is Internal Job Postings.

INTERNAL JOB POSTING POLICY

Objective: To create Career growth through Lateral and Promotional movement. This policy provides the process of any movement within the system, be it lateral or vertical. Scope: The Internal Job Posting Policy is applicable to all confirmed employees of the company. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources SIRIPL being referred as Sterling Information Resources India Pvt. Ltd. PI being referred as Personal Interview IJP being referred as Internal Job Posting TES being referred as Talent Engagement Specialist

Policy Details: General Rules:

Minimum of 3 nominations is required for any IJP to be processed Salary hike is applicable for promotions only & not for Lateral movements Promotion Effective Cycle: January 1, April 1, July 1 & October 1 only during the year


In case of withdrawal post selection the concerned employee will be barred from applying for next 6 months

Any mid-year increment owning to IJP may lead to possible change in regular increment cycle for that individual.

Any policy exceptions should be approved by VP – Human Resources IJP released will be closed within 10 working days (incase where an IJP cannot be

closed within the same vertical and we need to release another IJP across verticals the TAT for the same will be 15 working days).

USL, NCNS & CAP, DAP would impact applicants eligibility for IJP In case of withdrawal post selection the concerned employee will be barred from

applying for any internal opening for next 6 months. Any policy exceptions should be approved by VP – Human Resources.

Internal Job Posting Process:

IJP Details mailed by Process Owner to HR [JD needs to be mailed to HR in case of New Position]

IJP Open Position Broadcast mailed by HR inviting Applications in Generic Resume Format

Shortlisted candidates appear for Pre-Selection Process Final short listed candidates to go through Personal Interview with IJP Panel

[Functional Head + HR] Compensation decided by HR & shared in accordance with Organization Parity &

Budgets & shared with Functional Head IJP Promotion broadcast mailed to all publishing the final selects Revised Salary & Designation updated in the Payroll Database & Letter issued

accordingly Organization Record updated [R Directory, IJP Tracker, etc.] post the 45 days

probation phase A 45 days probation phase clause introduced:

All promotions via IJP’s will now attract a 45 day probation period. In case an employee fails to come up the learning curve during that period then he /

she is liable to resume the same role & function where he / she came from. All Increment letters will be rolled out only post they have cleared this phase and

arrears effective the date of Promotion will be paid to the employees. Candidates will be informed of this clause at the Interview stage itself to avoid any

confusion and mutual agreement in order to proceed. Functional Managers will need to provide objective data supporting their decision for

its action thereon. Any deviation from the process or the TAT is subject to VP-HR approval Exceptions: The VP – Human Resources depending on the exigencies of the business may redefine the IJP policy, in conjunction with the CEO and Sr. VP Operations.


INTERNAL TRANSFER POLICY

Objective: To define rules and regulations to be followed during Inter Departmental Transfer at Sterling Information Resources India Pvt. Ltd. Scope: The Internal transfer Policy is applicable to all full time employees of the company. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources Policy Details: This policy provides the process to be followed during Internal Transfer.

Transfer would be effective only post submission of necessary information & duly signed Transfer form to the Human Resources team at least 48 hours / 2 working days in advance.

Internal transfer process doesn’t attract any salary increment & change in grade or level of the employee.

Both Managers take ownership of necessary communication [Department, Job role & clarity around Point 2 as stated above] about the transfer to the respective employee/s involved.

Internal Transfer Process:

Functional Head to email his requirement along with business justification to his counter part & HR

Counter Part to revert with the Employee Relieving Date & Details Final Transfer Communication along with details in Internal Transfer Format needs to

be emailed to HR 2 working days in advance on [email protected] Details as per attached format.

Organizational Records updated accordingly.

Special Allowance process (Subset of Internal Transfer Policy)

Purpose: To provide a standard special allowance or deduction to the concerned employee for being permanently transferred from a Non US shift to a US shift based role and similarly deduction in compensation owing to a self proposed transfer from a US shift to a Non US shift.

Applicability: - Special Allowance is payable to an employee basis of the below mentioned qualifying parameters:


Approval of transfer from the Reporting Manager, Functional Head & VP – Human Resources.

Employees up to Sr. Verifier / Specialist level in Operational function only. Employee is being transferred “permanently” from a Non US process (Shift- 1:30 PM –

11:30 PM IST) to a US Process (Shift- 6:00 PM – 4:00 AM IST). Employees transferred to US Process at Company’s discretion (Due to Business Purpose)

or employee’s request (under exceptional cases, if approved by Functional Head & VP – Human Resources).

- Deductions are applicable in the following cases:

If an employee working in US shifts requests for a permanent transfer to a Non US process voluntarily and the same is approved by the Functional Head & VP – Human Resources.

Calculation for Payable / Deductible: Payable / Deductible - Rs. 100/- per day worked / maximum of Rs. 2200/- per month

Payment Head: Any additional amount payable owing to a transfer under this policy shall be paid as Special Allowance and shall be paid out to an employee on a monthly basis.

Note: Special Allowance shall be paid out post deduction of applicable taxes. If an employee is transferred from US Process to a UK Process where the shift will change

to the UK Shift timing (1:30 PM – 11:30 PM IST); employee will no longer be eligible for Shift Allowance effective from the Date of Transfer.

Incase of USL, NCNS; employee will lose out on Shift Allowance for that particular day Special Allowance does not apply to Temporary Transfer cases such as:

Employees temporarily transferred from UK to US shift for a short period for any reason and vice versa

Special Allowance payout is subject to approval from Functional Head & VP – Human Resources Any exceptions to the policy shall require prior approval of VP – Human Resources.

Exceptions: The VP – Human Resources depending on the exigencies of the business may redefine the Internal Transfer policy, in conjunction with the CEO and Sr. VP Operations.

Disciplinary Policy

Objective: To define rules and regulations to be followed when any non adherence of process/policy occurs at Sterling Information Resources India Pvt. Ltd.


Scope: The Disciplinary Policy is applicable to all confirmed employees of the company. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources DAP being referred as Disciplinary Action Plan CAP being referred as Corrective Action Plan NCNS being referred as NO Call No Show Policy Details: General Rules:

Any warning letter or action under this Policy shall be issued only after a right to fair hearing is given to the concerned employee.

Any warning letter issued is valid for 3 months from the Date of Issue. Warning letter issued will be considered during Performance Appraisal, Internal Job

posting and Confirmation Process. Employee would lose out on Performance Incentive for the month in which they have

received a DAP. Employee services can be terminated with immediate effect depending upon the severity

of the situation. In case of a dispute, decision taken by Vice President – Human Resources will be final and

binding on all parties. Decision taken by VP – Human Resources will be final and binding on all parties.

DAP tracker to be maintained up to date. Disciplinary Process:

CAP – Corrective Action Plan

Ownership lies with the Quality Team (EBT) to Issue CAP; however, they share data with us for our records. This is issued with reference to the quality of work, errors committed etc.

DAP – Disciplinary Action Plan

Ownership lies with the HR Team and it’s given on Disciplinary grounds

Attached is the break up on the CAP & DAP Severity levels & the consequence of the same.

CAP & DAP Severity Matrix v 1.0.pdf

Exceptions: The VP – Human Resources depending on the exigencies of the business may redefine the Disciplinary policy, in conjunction with the CEO and Sr. VP Operations.


Organization DEVELOPMENT

S.O.U.L. [Sterling Opportunities for Unlimited Learning] is conceptualized to aid Scientific Grooming & Development of employees and the Organization at large through a series of independent & customized Learning & Developmental Programs.

First Initiative:

The Mentor – Mentee Program [MMP]:

The MMP will involve a series of participative, experiential & simulative coaching and learning approaches aimed at carving out future leaders. With MMP sterling sets out on its Endeavour towards providing continuous learning & organization wide development.

MMP Selection:

Participants are selected post nominations received from the SLT team & upon discussion with function heads.

MMP Process:


HEALTH AND SAFETY

Employee Safety

For an employee’s own protection, and for the protection of fellow employees, SIRs requires that everyone work safely. Safety is everyone’s business. Each employee is encouraged to

do his or her bit to make our workplaces a safe place to work. Any unsafe working conditions should be reported to your supervisor immediately. Nobody gains from an accident, and nobody likes to work under conditions that present hazards to life and property. Everybody loses when accidents occur. The Company has a safety program in compliance with applicable laws, but its ultimate success will depend on the safety consciousness of all employees.

Reporting On-the-Job Injuries

In the event of injury, regardless of how slight, an employee must report it immediately to his or her supervisor or Human Resources for First Aid and/or medical attention. Medical services for on-the-job injuries are available through local emergency medical services and supervisors will refer employees to Human Resources for appropriate treatment. If an employee prefers to see his/her own doctor for treatment in the event of

any on-the- job injury, the employee must present a written request (including his/ her doctor’s name and phone number) to his/her manager immediately.


Fire Extinguishers, First Aid Kits and Emergency Exits

Fire Extinguishers, First Aid Kits and Emergency Exits are strategically located through out the Company. First Aid Kits are also available in Human Resources.

Cellular Phone Safety While Driving

Where appropriate, some SIRs employees use cellular phones for company business. It is SIRs endeavor that employees ensure driving safety when making calls on cellular phones and comply with all applicable laws. This is for your safety and the safety of those around you.

Smoking Policy

Sterling Infosystems is committed to providing a healthy and safe work place for all its employees, customers, contractors and vendors. In keeping with this commitment, the smoking of cigarettes in the office is prohibited. If you wish to smoke, do so only in the designated smoking areas. Excessive breaks, whether for smoking or other reasons, may lead to disciplinary action, up to and including termination of employment.

Anti-Tobacco Chewing

In accordance with the company policy, no chewing of tobacco (in whatever shape, manner or form) is permitted on the premises. Disciplinary action may be initiated against offenders up to and including warning/ termination of employment.


Alcohol and Drug Policy

Sterling Information Resources India Pvt. Ltd. has a long-existing commitment to protect the health and safety of its employees. As part of this commitment, the Company seeks to maintain a workforce and environment that is free from the harmful effects of alcohol and drug abuse. The Company has established the following rules regarding illegal drugs, controlled substances, and alcohol abuse. The obligations set forth in these rules constitute a condition of employment. The unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance (drugs or alcohol) is prohibited in the SIRs workplace and may constitute grounds for immediate dismissal (with the exception of Company-sponsored after hours events where alcohol may be served and good judgment is expected). Involvement with the sale of illegal drugs or controlled substances off Company premises constitutes grounds for dismissal. Any employee who is convicted of violations of criminal drug statutes must notify the company within five days after receiving notice of the conviction. A failure to give required notice will be grounds for dismissal.

WORK PLACE CONDUCT

STAFF IDENTITY CARD

For security reasons, all staff members are issued a staff identity card with a photograph of the holder which acts as an access card as well. These cards must be carried at all times while on Company premises and presented for identification at the request of authorized personnel. Access to Company premises outside normal working hours will be denied to anyone not in possession of the cards. The cards should by no means be lent to others. Missing cards should be reported immediately to the attention of Administration Department so that replacements could be arranged and issued.

Ethical Code of Conduct

We seek to take a constructive approach to employee relations. Employees are expected to properly perform their duties and responsibilities and to conduct themselves in accordance with appropriate standards of ethical behavior. SIRs discusses employee performance so that employees have the opportunity to understand job standards, to receive recognition for positive performance, and have the opportunity to improve their performance where needed. When an employee’s performance or conduct is deficient, SIRs


may use training, corrective or disciplinary action in an attempt to remedy the problem. Corrective or disciplinary action may include one or more of the following: a documented verbal warning, a written warning, demotion, suspension without pay, or termination from employment. Which of these steps is taken will depend upon the circumstances; it is impossible to establish a precise formula for the application of corrective action or discipline. Under no circumstances should an employee expect to receive more than one corrective or disciplinary action in the first 180 days of employment and continue to be employed by the Company. In some cases, SIRs may determine that an employee’s performance or misconduct warrants immediate termination. SIRs therefore reserves its right to take any corrective and disciplinary action, including immediate termination of employment, which the Company deems to be appropriate in a particular situation and reiterates that its employment relationship with its employees is at-will and subject to termination at any time. It is not possible to list all the forms of behavior that are considered unacceptable in the workplace. The following are examples of infractions of rules of conduct that may result in disciplinary action, up to and including termination of employment:

Unexcused or excessive absence from work Frequent tardiness Failure to follow established call-in procedures to promptly notify the Company of an

intended absence or tardiness prior to shift starting time Leaving work before the employee’s scheduled hours are completed or Unauthorized or

excessive visiting of areas away from one’s work place. Failure to properly perform assigned work Use of profane or abusive language Willful damage, theft or removal of Company equipment or property. Deliberate or willful destruction of Company’s, or another employee’s equipment or

property Violation of any Company Policy, i.e., Non-Harassment, Alcohol and Drug, Non-

Disclosure, Conflict of Interest, etc. The possession, sale or use of knives, explosives, firearms, or other dangerous

weapons on Company property or while engaged in any assignment Fighting, threatening, or attempting bodily or other injury to another. Falsification of Company records, including employment application, time cards, and/or

production work records. Insubordination, including but not limited to, refusal to do lawful assigned work. Inability or refusal to work in harmony or cooperation with fellow employees so

as to cause friction, conflict or lowering of group morale, including deliberate spreading of false rumors adversely affecting the operation of the Company.

Horseplay, throwing objects, or practical joking Disorderly or immoral conduct on Company premises Sleeping while on duty Harassment of fellow employees, clients, or other parties including, but not limited to

instances of sexual or other unlawful harassment and/or Unwanted social advances. Any other conduct or behavior not specifically listed above that reflects adversely on

SIRs or on the Company’s relationship with its clients.

Workplace Violence


SIRs is strongly committed to providing a safe workplace. The purpose of this policy is to minimize the risk of personal injury to employees and damage to Company and personal property. We do not expect you to become an expert in psychology or to physically subdue a threatening or violent individual. Indeed, we specifically discourage you from

engaging in any physical confrontation with a violent or potentially violent individual. However, we do expect and encourage you to exercise reasonable judgment in identifying potentially dangerous situations. Experts in the mental health profession state that prior to engaging in acts of violence troubled individuals often exhibit one or more of the following behaviors or signs: over resentment, anger and hostility; extreme agitation; making ominous threats such as bad things will happen to a

particular person, or a catastrophic event will occur; sudden and significant decline in work performance; irresponsible, irrational, intimidating, aggressive or otherwise inappropriate behavior; reacting to questions with an antagonistic or overtly negative attitude; discussing weapons and their use, and/or brandishing weapons in the workplace; overreacting or reacting harshly to changes in Company policies and procedures; personality conflicts with co-workers; obsession or preoccupation with a coworker or Supervisor; attempts to sabotage the work or equipment of a co-worker; blaming others for mistakes and circumstances; demonstrating a propensity to behave and react irrationally.

Personal Calls/Cell Phone Use

Employees are not allowed to carry cell phones with cameras on the production floor without written approval from department heads. All employees must deposit cell phones with cameras at the Security Desk. Employees using cell phones without cameras are expected to keep the cell phones switched OFF or on silent at all times in work areas. They can use these only during breaks at the cafeteria or office compound.

Good Housekeeping

While Sterling Information Resources India Pvt. Ltd. would like its employees to feel comfortable and at home in their work environment, the company intends to keep the office clean and neat. This also applies to each workstation. Each employee can help to reach this goal by keeping his or her working area neat and clean and by making use of the services and facilities provided. Every employee should limit décor to business appropriate furnishings. No explicit material or expressions of vulgarity will be permitted at an individual’s workstation. Additionally, any oversized and unnecessary pictures or decoration are prohibited. Please decorate your workstation to your liking while remaining within the confines of the policy set forth. The Company reserves the right to inspect all desks and any other property of the Company.

Office Etiquette


Phones Set the ringer volume to low and try to answer your phone after the first or second ring. Schedule to use a conference room for conference calls. Watch your volume when talking on the phone. A headset can help keep your voice low. With personal or sensitive calls, be aware that your neighbors can hear your end of the conversation Headsets need to be taken good care of by the individual user. The individual user will have to bear the cost of damages for breakages. Talking Don’t talk through cube/desk walls or congregate outside someone’s cube/desk. For impromptu meetings, go to a conference or break room. Use an office or schedule to use a conference room to meet clients/vendors. Do not schedule meetings in your work pod. General Noise To communicate with your co-workers, never yell. Use e-mail or phones. Set PC volume to a low level and turn off all sound effects. Work Place Visitors Sterling Infosystems prohibits unescorted or unauthorized visitors in our facilities. If you are expecting visitors, please notify your HR manager. You are expected to abide by these rules at all times. Failure to do so will lead to disciplinary action. All visitors must sign the Visitor Log (located at the security desk), where they will receive a Visitor slip which must be available at all times. A Visitor is defined as anyone who requests entry into the office and is not a Sterling employee. Visitors include all applicants, vendors, and non-Sterling employees. It will remain the responsibility of the party or parties that receive the visitor(s), to escort them back to the reception area when finished. At this point the visitor will sign out and return the Visitor slip. Accepting & Giving Gifts SIRs is committed to ensuring all business relationships with suppliers and clients are legal and based on professional integrity. Advance approval from the management is required before an employee may accept or solicit gifts of any kind from customers, suppliers and vendor representatives. Also, the presence or absence of gifts should not bias his/her decisions Provided that an advantage is not offered to influence the proper discharge of their duties, staff members may accept the gifts: • Advertising or promotional gifts. • Non cash gifts presented to staff members attending functions on behalf of the Company. • Commercial discounts that is equally available to the general public. Should a staff member have doubts as to whether the acceptance could affect their proper discharge of duties or place them under an obligation to act against the interests of the company, they should refer the matter to their Manager and Function Head. Any benefits that employees may receive in the course of performing duties must be declared within 3 working days upon receipt of the same. The staff members will then be advised whether the item may be accepted, returned or disposed of in some other ways. Theft Attempted Any theft, attempted theft, or unauthorized removal of Company property, irrespective of value, shall constitute a serious offence, lead to a summary dismissal and be reported to the police. If any such activity comes to the attention of a member of staff, the staff member


must immediately report the same to his or her Department Head, who shall arrange for appropriate follow-up action to be taken.

DRESS CODE POLICY

Objective: To follow the set protocol for Dress Code within the organization. Scope: The Dress Code Policy is applicable to all full time employees of the company. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources Policy Details:

Job Title Monday – Thursday Fridays

Up to Sr. Verifier/ Software Developer Levels Business Casuals Business Casuals

Team Coach/Sr. Software Developer & Above Levels Business Formals Business Casuals

Description

Attire Men Women

Business Formals Formal Shirt, Trousers, formal

leather Shoes, Belt and/or neck tie.

Salwar Kameez, Sarees, Business Suits (Up to

Knee length formal skirts, formal shirt), formal

shoes/sandals/ Stilettos

Business Casuals Collared T‐Shirt/Shirt, Denims,

Shoes and/or Belt.

Formal Top, Kurti, Formal shirts, Jeans, codroir,

Full leggings, sandals, up to Knee length skirts.

Not Permitted

Men Round neck t‐shirts, t‐shirts/shirts with any bold and obscene statement / pictures /


logo of any other Company, Torn and stained clothing and Chappals, Floaters, etc.

Women Revealing outfits [Eg. – Tube tops, Halter neck tops, Spaghetti tops, Off Shoulders top,

Mini skirts, Micro‐Mini Skirts etc.], Transparent and torn clothing, 3/4ths not permitted.

t‐shirts/shirts with any bold and obscene statement / pictures / logo of any other

Company, Chappals, Floaters, etc.

Important Notes:

In the eventuality of a Client visit, employees may be asked to come formally attired and it would be the manager’s responsibility to ensure adherence.

In case of violation, the HR team reserves the right to issue a Disciplinary Action Plan to the respective employee.

Exceptions: The VP – Human Resources depending on the exigencies of the business may redefine the Dress Code policy, in conjunction with the CEO and Sr. VP Operations. Non-Solicitation Policy

In an effort to assure a productive and harmonious work environment, persons not employed by Sterling Information Resources India Pvt. Ltd. may not solicit or distribute literature in the workplace at any time for any purpose. Sterling Information Resources India Pvt. Ltd. recognizes that employees may have interests in events and organizations outside the workplace. However, employees may not solicit or distribute literature concerning these activities while on Sterling Information Resources India Pvt. Ltd. premises. In addition, the posting of written solicitations on company bulletin boards is prohibited except with approval from Human Resources. Bulletin boards are reserved for official organization communications. Violation of these rules may result in disciplinary action.

Non-Disclosure and Proprietary Rights Agreement

In consideration of employment with Sterling Information Resources India Pvt. Ltd. with its main office located at 1, Mohan Mill Compound, Next to Global Gallerie, (Mahindra), Ghodbunder Road, Thane- 400 607 (hereinafter referred to as "Employer"), each employee is expected to agree to the following: 1. Avoidance of Conflict of Interest: While employed by Employer, Employee will not engage in any other business activity which conflicts with Employee's duties to Employer. Under no circumstances will Employee work for any competitor or have any financial interest in any competitor of Employer; provided, however, that this Agreement does not prohibit investment of a reasonable part of Employee's assets in the stock or securities of any competitor whose stock or securities are publicly traded. 2. Confidentiality: Employee recognizes and acknowledges that the systems and software which Employer owns, plans or develops, or acquires from third parties, whether for its own use of for use by its clients, are developed as a result of an expenditure of time and expense, are


confidential in nature and are the trade secrets, proprietary to and the property of the Employer. Employee further recognizes and acknowledges that in order to enable Employer to perform services for its clients, such clients may furnish to Employer confidential information concerning their business affairs, property, methods of operation or other data and that the good will afforded to Employer depends upon, among other things, Employer and its Employees keeping such services and information confidential. For the purposes of this Agreement, a "Trade Secret" is any scientific or technical information, design, process, procedure, formula or improvement that is valuable and not generally known to competitors of Employer including but not limited to computer software programs. Examples are the specialized information and technology relating to Employer's business. "Confidential Information” is any data or information, other than Trade Secrets, that is competitively sensitive, and not generally known to the public, including but not limited to Employer's customer lists, prospect list, training manuals, and product development plans, marketing strategies and internal performance statistics. Employee shall not, for the duration of this Agreement, nor any time thereafter, without the prior written consent of Employer, disclose any trade secret or confidential information of Employer or its clients to its clients or any third parties, or permit or cause any personal organization:

To copy or duplicate any physical form of Employer's trade secrets or confidential information to or from any medium except for archival, security or other regular business purposes; or Create or recreate, or attempt to create or recreate, the source programs, object code or any other aspect of the trade secrets of confidential information of Employer, in all or in part; or To place such trade secrets into the public domain.

Employee shall limit access to all media containing Employer's and or its client's trade secrets or confidential information to its employees and agents necessary to permit Employee to perform tasks required pursuant to this Agreement. Employee further agrees to store all media and documentation upon which Employer's and or Its clients' trade secrets and confidential information are recorded in a secure place, except when being used, and will exercise all other reasonable precautions to prevent unauthorized access, whether direct or indirect. Employee agrees that he/she shall not disclose, transfer, use, copy or allow to any such trade secrets or confidential information to any unauthorized employees or third parties. Upon the request of Employer and, in any event, upon the termination of Employee's employment, Employee will leave with the Employer and or its clients' all computer programs, documentation, code, memoranda, notes, records, drawings,

manuals, flow charts, or other documents pertaining to Employer's business or Employee's employment (including all copies thereof). Employee will also leave with Employer and or its client's all materials involving any Trade Secrets of Confidential Information of Employer or Employer's clients.

During the course of employment, Employee agrees to treat all Trade Secrets and Confidential Information of Employer and its clients as confidential and to take all necessary precautions against disclosure of such information to hird parties during and after the term of this Agreement. 3. Restrictions on Competition and Solicitation: Employee agrees that during the term of this Agreement Employee shall not

compete with Employer by soliciting, accepting employment as an employee, contractor, consultant, or independent contractor with any competitor or client of Employer for whom Employee has worked on behalf of Employer.


Employee further agrees that during the term of this Agreement, Employee shall not attempt to sell any competing goods or services to any client whom Employer Introduces Employee, nor shall Employee do any work for or contract with any competitor or client to whom Employer introduces Employee.

During employment with Employer, Employee will not solicit, entice or persuade any other Employee of Employer or Employer's clients to leave the services of their Employer for any reason.

Employee agrees that the foregoing restrictions are fair and reasonable considering the scope of Employee's employment, salary and benefits provided by Employer and Employee further agrees that such restrictions will not unduly restrict or prohibit Employee from obtaining gainful employment in his or her chosen profession.

4. Ownership: Employee agrees that all developments made and works created by Employee or under Employee's direction in connection with Employer's assignments or in connection with the assignments of other Employees of Employer whether or not made exclusively at Employer’s premises and whether or not created exclusively with Employer's computers or other equipment, shall be the sole and complete property of Employer and that all title, ownership, copyrights and other proprietary interest therein shall belong to Employer and that all other provisions of this Agreement shall fully apply to all such developments and works created by Employee shall be considered "works made for hire" and Employee assigns to Employer the ownership and title to all such materials and copyrights on such materials. 5. Injunctive Relief: Employee acknowledges that disclosure of any Trade Secrets or disclosure of any confidential Information or any breach of any noncompetitive covenants or agreements contained herein will give rise to irreparable injury to Employer or clients of Employer, inadequately compensable in damages. Accordingly, Employer or, where appropriate, a client of Employer, may seek and obtain injunctive relief against the breach or threatened breach of the foregoing undertakings, in addition to any other legal remedies which may be available. The Employee further acknowledges and agrees that in the event of the termination of employment with Employer, the Employee's experience and capabilities are such that the Employee can obtain employment in business activities as an Employee of Employer, and that enforcement of a remedy hereunder by way of injunction shall not prevent the Employee from earning a reasonable livelihood. The Employee further acknowledges and agrees that covenants contained herein are necessary for the protection of Employer's legitimate business interests and are reasonable in scope and content. 6. Miscellaneous: This Agreement shall inure to the benefit of and be binding upon, Employer and its subsidiaries and affiliates, together with their successors and assigns, and Employee, together with Employee's executor, administrator, personal representative, heirs and legatees. This Agreement merges and supersedes all prior and contemporaneous Agreements, undertaking, covenants or conditions (including specifically all prior confidentiality and non-competition agreements Employee has entered into with Employer), whether oral or written, express or implied, to the extent they contradict and conflict with the provisions hereof. This Agreement is non-assignable by Employee.


The failure of Employer to enforce any rights granted hereunder or take any action

against employee in the event of any breach of this Agreement shall not be deemed a waiver to any subsequent rights or actions in the event of future breaches. If any provision of this Agreement is determined to be invalid or unenforceable by a decision of a Court of competent jurisdiction, it shall not affect the remainder of the Agreement, which shall survive and remain in full force and effect. All obligations of Employee relating to ownership of work products and protection of trade secrets and confidential information shall survive the termination of this Agreement. Applicable Law: This Agreement shall be constructed in accordance with the Applicable Laws. Employee is specifically unauthorized to execute any agreement or contract on behalf of Company unless specifically authorized to do so, in writing, by Board of Directors. Employee further agrees to indemnify and hold harmless Company from any and all damages, including reasonable attorney's fees, incurred by Company as a result of a breach of this Section.

Conflicts of Interest

Any improper transfer of material or disclosure of information, even though it is not apparent that an employee has personally gained by such action, constitutes unacceptable conduct. Any employee who participates in such a practice will be subject to disciplinary action, up to and including possible termination of employment and legal action. Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Sterling Information Resources India Pvt. Ltd. wishes the business to operate. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation. Transactions with outside firms must be conducted within a framework established and controlled by the executive level of Sterling Information Resources India Pvt. Ltd. Business dealings with outside firms should not result in unusual gains for those firms. Unusual gains include bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, employee, or both. Promotional plans that could be interpreted to involve unusual gain require specific executive level approval. An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative as a result of Sterling Information Resources India Pvt. Ltd. business dealings. For the purpose of this policy, a relative is any person who is related


by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage. No "presumption of guilt" is created by the mere existence of a relationship with outside firms. However, if an employee has any influence on transactions involving purchases, contracts, or leases, it is imperative that he or she discloses the existence of any actual or potential conflict of interest to an officer of Sterling Information Resources India Pvt.Ltd. as soon as possible so safeguards can be established to protect all parties. Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which Sterling Information Systems India Pvt. Ltd. does business but also when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Sterling Information Resources India Pvt. Ltd. The materials, products, designs, plans, ideas and data of Sterling Information Resources India Pvt. Ltd. is the property of Sterling Information Resources India Pvt. Ltd. and should never be given to an outside firm or individual except through normal channels and with appropriate authorization.

Computer, E-Mail and Internet Usage Policies

Computer Security/Use of Systems

The security of the hardware and software of our computers, as well as the intellectual properties contained therein, are very important to Sterling Information Resources India Pvt. Ltd. We ask that all of our employees be vigilant and exercise care in the use of this property. Computer security is of special concern and all employees are asked to strictly adhere to computer security guidelines, making sure that unauthorized people do not have access. If you have a need to access files or functions to which you do not currently have access, see your supervisor to request a change in your access parameters. DO NOT share your password with others or seek to "borrow" another's. The information systems owned and operated by Sterling Information Resources India Pvt. Ltd. As such, management reserves the right to monitor and/or access all files, including e-mail and voice mail. Infractions of these security guidelines may result in disciplinary action, up to and including termination of employment. In addition, employees are required to sign a Security Agreement in order to protect Sterling Information Resources India Pvt. Ltd. from the unlawful use of its systems. In the course of their jobs, employees may use the Computer System to communicate internally with coworkers or externally with clients, consultants, vendors, and other business acquaintances. Sterling Information Resources India Pvt. Ltd. provides its employees with computer use to facilitate business communications and enhance their productivity. As with the telephone, there may be occasion to use the computer for personal purposes. Under no circumstance should the Sterling Computer System be used for personal financial gain, or to solicit others for activities unrelated to Sterling business, or in connection with political campaigns or lobbying. Sterling reserves the right to review all computer files and communications, and to monitor its employees’ use of the Internet, to maintain system integrity and ensure the proper and responsible use of the computer in accordance with Sterling policies and procedures.


Help Desk

Should any problems arise with your computer or phone systems, the Sterling IT team can be notified. The Help Desk will acknowledge your request/query immediately and begin to rectify any problems you are encountering.

E-mail

Sterling Information Resources India Pvt. Ltd. has established a policy with regard to the access and the disclosure of electronic mail messages created, sent, and received by company employees using the electronic mail system. Sterling Information Resources India Pvt. Ltd. intends to honor the policies set forth below and reserves the right to change them at any time as may be required. Sterling Information Resources India Pvt. Ltd. maintains an electronic mail system to assist in conducting business within the company. The electronic mail system hardware is company property. Additionally, all messages composed, sent, or received on the electronic mail system are and remain the property of the company and are not the private property of any employee. Sterling Information Resources India Pvt. Ltd. has the capability to access, intercept, monitor, audit, review, copy, delete, and disclose any messages sent, received, or stored on the e-mail system. Sterling also has the ability to access deleted messages in certain circumstances, and as necessary. Sterling Information Resources India Pvt. Ltd. reserves and intends to exercise the right to review, audit, intercept, access and disclose any messages created, received or sent over the electronic mail system for any purpose. The contents of electronic mail properly obtained for legitimate business purposes may be disclosed within the company without the permission of the employer. The confidentiality of any message should not be assumed. Even when a message is erased, it is still possible to retrieve and read that message. Further, the use of passwords for security does not guarantee confidentiality. Notwithstanding the company's right to retrieve and read any electronic mail message, such messages should be treated as confidential by other employees and accessed only by the intended recipient. Employees are not authorized to retrieve or read any e-mail messages that are not sent to them. Any exception to this policy must receive prior approval by the Company.


The electronic mail system may not be used to solicit or recruit for commercial ventures, religious or political causes, outside organizations, or other non-job related solicitations. Should an employee make use of the email system to transmit personal messages, such messages will be treated in the same way as business-related messages. In other words, Sterling reserves the right to access, intercept, monitor, and audit, review, copy, delete, or disclose personal messages for any purpose. Excessive personal use of email warrants disciplinary actions.

E-mail Etiquette: Please remember that your email messages may be read by someone other than the person to whom you send them and may even someday have to be disclosed to outside parties or a court in connection with litigation. Accordingly, please take care to ensure that your messages are courteous, professional and business like. Remember that email messages once sent, are usually not retrievable. Be sensitive to the fact that, in the absence of an explanation, email messages may be unclear and can be misinterpreted. This is of specific concern when a message is being forwarded to multiple recipients. Rather than quickly sending essages without adequate review, you should consider printing and proofreading them prior to distribution. This should ensure that their content is completely appropriate. The electronic mail system is not to be used to create any offensive or disruptive messages. Among those which are considered offensive include, but are not limited to, any messages which contain sexual implications, racial slurs, gender-specific comments, or any other comment that offensively addresses someone's age, sexual orientation, religious or political beliefs, national origin, or disability. Emails that are threatening, sexually suggestive, contains obscenities or adult content are also prohibited. The electronic mail system shall not be used to send (upload) or receive (download) copyrighted materials, trade secrets, proprietary financial information, or similar materials without prior authorization. Employees shall not use a code, access a file, or retrieve any stored information, unless authorized to do so. Employees should not attempt to gain access to another employee's messages without the latter's permission Any employee who discovers a violation of this policy should notify Human Resources. Any employee who violates this policy or uses the electronic mail system improperly shall be subject to discipline up to and including termination. Personal emails should not be accessed. Also, sending emails from Sterling ID to personal ID’s are not allowed.

Internet


Conduct: Access to the Internet has been provided to most of our employees for the benefit of the organization and its customers . It allows employees to connect to information and resources around the world. Every staff member has a responsibility to maintain and enhance the company's public image, and to use the Internet in a productive manner. To ensure that all employees are responsible, productive Internet users and are protecting the Company's public image, the following guidelines have been established for using the Internet.

Acceptable Use Of Internet:

Employees accessing the internet are representing the company. All communication should be professional and business related. Employees are responsible for seeing that the Internet is used in an effective, ethical and lawful manner. Internet Relay Chat channels may be used to conduct official company business, or to gain technical or analytical advice. The World Wide Web may be accessed to search for information. News channels may be used to read industry wide developments or to solicit customer feedback. The file transfer protocol may be used when necessary to download files. Unacceptable Use of the Internet: The Internet should not be used for personal gain or advancement of individual views. Solicitation of non-company business, or any use of the internet for personal gain is strictly prohibited. Use of the Internet must not disrupt the operation of the company network or the networks of other users. It must not interfere with your productivity. Communications: Each employee is responsible for the content of all text, audio or images that they place or send over the Internet. Fraudulent, harassing, obscene

messages or messages expressing personal opinions are prohibited. All messages communicated on the Internet should have your name attached. No messages may be transmitted under an assumed name. Users may not attempt to obscure the origin of any message. Information published on the Internet should not violate or infringe upon the rights of others. No abusive, profane or offensive language can be transmitted through the system. Security: All messages created, sent or retrieved over the Internet are the property of the company, and should be considered public information. The company reserves the

right to access and monitor all messages and files on the computer system as deemed necessary and appropriate. Internet messages are public communication and are not private. All communications including text and images can be disclosed to law enforcement or other third parties without prior consent of the sender or receiver. Harassment: Harassment of any kind is prohibited. No messages with derogatory or inflammatory remarks about an individual or group’s race, religion, national origin, physical attributes, or sexual preference can be transmitted. Violations: Violations of any guidelines listed above may result in disciplinary action up to and including termination. If necessary the company will advise appropriate legal authorities


of any illegal violations. Any installation or downloading of non-approved software or programs is a violation of Sterling policy. This includes Yahoo and Hotmail tool bars, emotion icons, instant messaging software, alternate web browsers, MP3 players, music, etc. Anything that is not installed by or approved by IT and sanctioned by Sterling is in violation of company policy. All employees are expected to fully comply with these policies. Prohibited Conduct

Threats, threatening language or any other acts of aggression or violence made towards or by any Company employee WILL NOT BE TOLERATED. For purposes of this policy, a threat includes any verbal or physical harassment or abuse, any attempt at intimidating or instilling fear in others, menacing gestures, flashing of weapons, stalking or any other hostile, aggressive, injurious or destructive action undertaken for the purpose of domination or intimidation. To the extent permitted by law, employees and visitors are prohibited from carrying weapons on to Company premises.

Procedures for Reporting a Threat

All potentially dangerous situations, including threats by co-workers, should be reported immediately to any member of management with whom you feel comfortable. Reports of threats may be maintained confidential to the extent maintaining confidentiality does not

impede our ability to investigate and respond to the complaints. All threats will be promptly investigated. No employee will be subjected to retaliation, intimidation or disciplinary action as a result of reporting a threat in good faith under this policy. If an investigation confirms that threat of a violent act or violence itself has occurred, the Company will take swift and appropriate corrective action. If you are the recipient of a threat made by an outside party, please follow the steps detailed in this section. It is important for us to be aware of any potential danger in our offices. Indeed, we want to take effective measures to protect everyone from the threat of a violent act by an

employee or by anyone else. Non-Harassment Policy

It is SIRS’s policy to prohibit harassment / discrimination of any employee by any employee, client or visitor on the basis of sex, race, color, religion, class, national origin or ancestry, age, sexual orientation, or disability as well as any other classification protected by applicable law. Sterling Information Resources India Pvt. Ltd. will not tolerate harassment / discrimination not only because it violates company policy, but because it is personally offensive, fails to respect the rights of others, and interferes with work performance. All employees’ visitors , managers and non-managers, must comply with this policy and take appropriate measures to ensure that such conduct does not occur and maintain a harassment free workplace. Depending upon the circumstances,


prohibited conduct can also include unwelcome sexual joking, vulgar or offensive conversation or jokes, commenting about an employee's physical appearance, conversation about your own or someone else's sex life, teasing or other unwelcome conduct directed toward a person because of his or her gender which is sufficiently severe or pervasive to create an unprofessional and hostile working environment. Anyone who feels that he or she has been subjected to conduct which violates this policy should immediately report the matter to his/her supervisor, any other supervisor/manager, or a Human Resources representative. After receipt of such a complaint, the Company will ensure that an investigation is conducted immediately. very report of perceived harassment will be fully investigated and corrective action will be taken where appropriate. Violation of this policy will result in disciplinary action, up to and including termination of employment. In addition, Sterling Information Resources India Pvt. Ltd. will not allow any form of retaliation against individuals who report unwelcome conduct to management or who Co-operate in the investigation of such report in accordance with this policy

Sexual Harassment Policy

Objective: To create a Healthy, Safe and Exploitation free environment to all employees. Scope: The Sexual Harassment Policy is applicable to all full-time employees of the company. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre HR being referred as Human Resources Policy Details: Definition of Sexual Harassment:

Sexual inappropriate gestures and propositions for dates or sexual favors

Leering, Pinching, Grabbing, Hugging, Patting, Brushing against, Touching, Physical contact or advances; Sexually colored remarks

Sexual comments or inappropriate references to gender

Sexually explicit statements, questions, jokes, SMS’s or anecdotes regardless of the means of communication (oral, written, electronic, etc.).

The display of inappropriate sexually oriented materials in a location where others can view them

Inquiries and commentaries about sexual activity, experience or orientation..


* Requesting / demanding sexual favors as a term or condition to provide promotion or employment to an individual would be treated as a serious offence. * Pre-Defined committee would investigate the matter & strict action up to termination can be taken against the guilty party basis the facts found during investigation. General Rules:

Not more than 3 employees shall investigate a particular case Team will involve at least 1 female employee as a part of any investigating committee to ensure fair and just decision making.

Sexual Harassment Policy Process:

The employee has to immediately complaint about such issues/matter to any of the [email protected] email ID.

The committee members will ensure prompt and immediate investigation of the matter. The investigating team will make every reasonable effort to conduct all proceedings in a

manner that will protect the confidentiality of all parties. Every report of perceived harassment will be fully investigated and correct action will be

taken where appropriate. Once it has been determined that sexual harassment has occurred, steps will be taken to

ensure the harassment is stopped immediately. The violation of this policy by any employee will result in disciplinary action and

depending on the severity of the action it would lead to termination of services. Exceptions: The VP – Human Resources depending on business exigencies may redefine the Sexual Harassment Policy in conjunction with the CEO and Sr. VP Operations.

Skip Level/Complaint Handling Process

Skip Level Process


Purpose: Ensures clarity and two way employee communication within the organization. Helps working towards feedbacks and improvement areas based on these feedbacks from time to time. Skip level Interview Definition: A “skip” means skipping one level of reporting or meeting up with an independent non biased department like Human Resources for a discussion. Skips can be conducted as One – on – One session or Focus Groups which are conducted across the organization to get to know problem areas or work environment and employee sentiments in specific verticals of business. Frequency: 1 Team of One – on – One session and 1 Team for Focus Group every month. Population Covered: Minimum of 30% of the team strength or all members in a team depending on team dynamics Mode: Generally an interview either with specific skip questions on Supervisor, team, work, organization at large related or a group discussion and brainstorming on a particular problem faced at workplace and resolution by involving the concerned department head. ESAT Survey Definition: An ESAT survey is a survey conducted across the organization with a more structured approach either by an independent third party organization or internal by the Human Resources team. Frequency: Once or twice in a year Population Covered: Aimed at covering the feedback of the entire organization across the globe. Mode: Either a paper and pencil survey or to be filled online through a detailed survey questionnaire shared with all employees across the globe.

Skip Process Flow:


Exception for SKIP: Exceptions to skip process occurs when the stipulated skips for the month are not met due to business related exigencies. As a preventive step towards this a timely track of the skips conducted with feedback is saved & we ensure we complete that particular department/functions skip level within the next 3 months.

There could be deviations from the skip calendar depending upon any business exigency, functional heads request, attrition analysis report etc. VP-HR is to be kept informed on any deviations made.

Complaint Handling Process: Incase of a specific complaint raised by any employee, there is an investigation at large is carried out wherein HR representative takes feedback from the complainer and the complainant and other employees either directly or indirectly impacting due to the case or complaint. An investigation or incident report is prepared duly for each of such cases and saved in repository for future reference. The complaint raised has to be investigated and closed within 2 weeks from the complaint registered.


EMPLOYEE SEPARATION POLICY

Objective: To enable smooth exit of the employee from the company. Scope: The Employee Separation policy will be applicable to all full time employees of the company. Definition: For the purpose of this process all staff here implies Agents (varies from process to process), Team Leaders, and Quality Control Specialists and other employees covered under Management cadre. HR being referred as Human Resources FIN being referred as Finance NCNS being referred as No Call No Show DAP being referred as Disciplinary Action Plan CAP being referred as Corrective Action Plan V&N being referred as Voice and Accent

Policy Details: Entitlement Bombay Shops and Establishment Act, 1948 shall govern Employee Separation entitlements. General Rule:

1) The Employee has to email resignation to his respective manager and copy [email protected]

2) In absconded cases, the employee is not due for any dues or letters. 3) In all scenarios of termination, Employee will receive pay for the number of days he

has been in the system. 4) In case of an absconded employee, respective supervisor has to inform

[email protected] on the status 5) Resignation Intimation needs to be sent by the Process Owner [Respective

Manager/Trainer] to HR on [email protected] within 24 hours of employee resigning.

Notice Period Clause:

Functions Operations & Process Training Software Development, Business Analysis & GTO

functions

Enabler Functions - HR, Finance, EBT, CS, Administration, etc.

Employee Levels Up to Team Leaders

Assistant Managers & Above

All Staff Up to Sr. Execs / Mgt. Trainees

Assistant Managers & Above

In Probation 15 Days 2 months 2 months 1 month 2 months

Post Confirmation 1 month 2 months 2 months 1 month 2 months


Either party [Employer or the Employee] may terminate the employment agreement by serving the notice period as may be prescribed in writing to that employee in his Letter of Employment or payment at Basic pay / day * no. of days that fall short of the notice period due] in lieu of notice period on exit.

Common Employee Separation Procedure: Resignation emailed to [email protected] with CC to Reporting Manager. HR Generalist to meet the employee within 3 days of resignation received Exit process explained & LWD confirmed [As per the revised Notice Period Clause] Supervisor to ensure Employee meets HR Generalist on LWD between 5:00 PM – 7:00 PM

for exit formalities HR Generalist to handover the Employee Clearance Form to concerned employee to

complete Sign-Off process Employee to revert to HR Generalist for final Sign–off & Exit Interview to conclude the

Exit Formality Duly filled & signed forms to be filed in Employee P File & information passed onto Payroll

team for payroll processing Payroll Processed & Employee details moved from Current headcount data file to Attrition

data file. Employee is informed about the date for collecting the full and final dues. HR Operations team would update the attrition data sheet with the exit details [LWD,

Comments, Reason for leaving, notice Period status, Etc.] and would send the ex employee name to GTO for disabling their company ID’s.

Full and Final check is released after the 25th of each month. HR Operations team informs ex-employees to collect their FnF checks & experience Letter [if Experience Letter is not provided on LWD incase an employee had not served complete notice period].

Acknowledgement copy of the experience letter to be filed in personal files. The employee’s file to be moved from current employee database [Active sheet] to ex

employee database [inactive sheet].

Important Note: All respective Managers who are signing-off shall take ownership of the activities under their kitty as stated in the Clearance Form Sign-Off from the respective Managers denotes that HR can carry out the Exit formality successfully. Type of Employee Separation:


Employee Separation Description

Voluntary Resignation following Exit Protocol, Absconding

Involuntary Termination, Background Check Alert Cases, Downsizing

Resignation Scenarios of Full and Final calculation:

1. Employee resigns and serves full notice period. 2. Employee resigns and serves partial notice. 3. Employee resigns and notice period is waived off 4. Employee separation due to downsizing.

Employee resigns and serves full notice period: Final dues are calculated on the Gross salary, leave balance encashment and incentives till the date employee is eligible is added to final dues. The data is emailed to the FIN dept along with payroll data.

Employee resigns and serves partial notice period Final dues to be calculated on Gross salary, basic salary for short notice period to be deducted. Leave balance encashment and incentives till the date employee eligible to be added to final dues. The data is emailed to the FIN dept with payroll data.

An employee resigns and notice period is waived off. Final dues to be calculated on Gross salary, No notice period deduction to be done. Leave balance encashment and incentives till the date employee eligible to be added to final dues. The data is emailed to the FIN dept with payroll data.

Employee Separation due to downsizing Final dues to be calculated on Gross salary. If the employee is on probation, 15 days additional salary to be paid, other wise 1 additional month salary to be paid to permanent employees. Leave balance encashment and incentives till the date employee eligible to be added to final dues. The data to be mailed to FIN with payroll data.

Employee Termination Process:

Type of Termination

Employee can be terminated from his/her services with immediate effect under situations as mentioned below:

Employee separation due non-performance & / or critical errors. Employee’s services can be terminated due to misconduct. (Variations explained in details

here forth). Employee is terminated in training due to test failure. Background verification check failure


1) Employee has committed critical error more than once in the process: In this scenario a critical error has occurred (critical errors as described by operations and Quality Team).

1. Supervisor will keep a track of the employee’s performance. 2. No. of errors occurred during the tenure of the employee to be recorded and

documented. 3. Employee to be issued a CAP during the first instance. 4. If the errors continue and employee doesn’t improve within 15 days, it is followed by

the 2nd (TAT is 15 Days) and 3rd incident leads to Termination. 5. In case of ZERO Tolerance errors, employee is directly terminated in consultation with

Sr. VP – Ops.

2) Employee terminated due to misconduct (includes drug tests): In this scenario the employee has not followed the company’s code of conduct which

has led to his termination. 1. Supervisor will report the incident to HR with immediate effect. 2. HR to have one – one meet with the employee and issue the termination letter. 3. HR to complete exit formalities (collect ID). 4. Employee will be paid up to the last working day. Leave balance encashment to be

added to the Final dues. Employee will be issued a Termination letter.

3)Trainee terminated for not clearing VNA or Process Assessment:

This scenario occurs when the trainee has undergone the VNA/process training/Process Assessment, however, has not been able to score the passing percentage in the final assessment held.

Trainee should have gone through the entire training. Trainer has to maintain the assessment scores. If the trainee is eligible for reassessment, the same to be conducted and the best score to

be considered. Trainee has not cleared the second reassessment. Trainer to inform HR along with test results. NCNS Process:

If the employee has been on uniformed leave (NCNS) for 7 working days. His services are terminated on the 8th day. Scenarios of NCNS mentioned below: Case 1: Employee has taken leave without informing his supervisor: In this case, the below mentioned steps to be followed:

Supervisor will keep a track of employee’s attendance. Managers are requested to send out the NCNS notification on the DL –

[email protected] on the 3rd day of consecutive uninformed absence of an employee.


Managers will need to roll out a separate e-mail on the [email protected] DL confirming the termination of such cases if they don’t return to work by the end of Day 7.

If HR contacts or unable to contact, the information is cascaded to operations as well. If contacted, employee is asked to resume.

In case employee contacts his supervisor within 7 days of NCNS, supervisor informs HR.

On 8th working day, supervisor will inform HR on NCNS status. HR to send Termination Letter employee’s mailing address. Absconded employees are not entitled for any dues or experience letter.

Case 2: Employee has taken uniformed leave (NCNS) for 2- 3 days: Employee resumes duty and then again takes uniformed leave In this case, the below mentioned steps to be followed:

1. Supervisor will keep track of the employee’s attendance. 2. Supervisor to have one – one with the employee when employee resumes duty. 3. Supervisor to mail details of employee attendance and request for issuing DAP. 4. HR to issue a DAP to the employee. 5. If the employee has NCNS again then he can be terminated (since the warning letter

has already been issued). 6. For each NCNS, per day salary and attendance incentive for that month will be

deducted.

Case 3: Trainee has availed uniformed Leave:

1) Trainee in training will be terminated on the 4th Day of NCNS.

2) The concerned trainer will mail the trainee exit details to HR.

Exception:

The VP – Human Resources depending on the exigencies of the business may redefine the employee separation policy, compensatory in conjunction with the CEO & Sr. VP - Operations.

Leave adjustment against notice period is done post receiving approval from VP – HR.

Return of Company Property

Any SIRs property issued to you must be returned to SIRs at the time of your termination. You will be responsible for any lost or damaged items. The value of any property issued and not returned may be deducted from your pay check.

Security


Office Security

Unless employee has been otherwise notified, access to the office is restricted to their normal operation/shift hours. Upon leaving the office for the day, make sure all office equipment and lights are turned off, all windows are closed and locked, and all personal property is safely stored away. Employees must check the premises to make sure there is nobody else in the office if they are the last person to leave.

Additional Access

Additional access will have to be coordinated by each employee’s department manager. Department managers will compile and submit a list of approved employees for weekend access by end of business Thursday to Human Resources. Upon approval by Management, Human Resources will then setup employees for additional “weekend” access. No employee is to allow anyone not approved for weekend access onto company property. Further instructions and procedures can be obtained from the Human Resources department. Employee Property

Each employee is responsible for the safety of his or her own personal belongings. Since Sterling Information Resources India Pvt. Ltd. theft insurance does not cover your personal property, the Company will not be responsible for reimbursement for theft of personal items kept in the office. You should, therefore, exercise every precaution to protect your personal property. Inspections

SIRs reserves the right to require employees while on Company property, or on client property, to agree to the inspection of their persons, personal possessions and property, personal vehicles parked on Company or client property, and work areas. This includes lockers, vehicles, desks, cabinets, work stations, packages, handbags, briefcases and other personal possessions or places of concealment, as well as personal mail sent to the Company or to its clients. Employees are expected to cooperate in the conduct of any search or inspection.

Shredding and Document Handling/Destruction

SIRs maintains a secure and confidential environment in this manner, the printing of any information from a Sterling background check is strictly prohibited. In the event material is mistakenly printed; the document must be cross-cut shredded, burned or pulverized so that the information cannot be practicably read or reconstructed. All electronic media (including, but not limited to: flash Drives, data cards, computer hard drives, floppy disks, compact discs, PDAs, Blackberrys, etc.) containing consumer information must be destroyed or erased so that information cannot practicably be read or reconstructed. If you are currently in possession of Sterling documents containing consumer information, you must cross-cut shred, burn or pulverize the


material so that the information cannot practicably be read or reconstructed. Upon termination, all Sterling documents and electronic media (as defined above) containing consumer information must be cross-cut shredded, burned or pulverized so that the information cannot practicably be read or reconstructed. Company to be indemnified under certain situations

Employee shall indemnify and undertakes to pay to the Company an amount equivalent to, and hold the Company harmless against, all losses without limitation, damages, claims, demands, expenses and other liabilities incurred by the Company as a result of Any fraud, dishonesty, misconduct or any breach or non-observance of any of The terms and conditions of employment or Code of Conduct by employee, as may be prescribed by Company from time to time, Any neglect, failure, refusal, misrepresentation or un authorized representation made or act carried out by an employee in violation to the terms and conditions of employment or Code of Conduct, as may be prescribed by Company from time to time. Loss or damage to the Company property, as may be provided to employee during continuation of employment with company or otherwise, including company assets like laptops, mobile handsets, telephone instruments and data cards. Expenses or charges incurred or that may be incurred by the Company due to non compliance with Code of Conduct or terms and conditions of employment or negligence of employee during discharge of his official duty, including charges incurred by Company due to its customer premium cheques getting returned by the Bank as unpaid, due to any reasons whatsoever, when such cheques are collected by an employee from said customer towards payment to the Company during course of discharge of his official duty. Company right to recover amount against employee benefit schemes

The Company may offer from time to time various employee benefit schemes, which are optional in nature. Company reserves right to recover from employee such amount, as it may deem fit and necessary to recover the charges for offering such employee benefit schemes in case employee fails to comply with terms and conditions of such benefit schemes. Such recovery amount shall include, but not limited to, any such amount as the Company may deem fit towards such lapsed policies which were offered at discount to employee under employee benefit schemes

Employee Handbook Revisions

While it is difficult to cover all of the operational aspects of a large business, SIRs anticipates that this handbook answers most employee questions. It is intended that this handbook be revised and updated from time to time, as the need requires. Any suggestions for its improvement would be welcomed. Every SIRs employee should feel free to ask about any policy or procedure that is not fully understood. It is intended that this document reflect adequate understanding of an employee’s work situation. The dynamic nature of the industry and the times will undoubtedly require changes in this work situation. For this reason and because of employees’ suggestions, the contents of this handbook may be revised. Such revisions will be posted on the bulletin board on the floors or via email and will, as of that date, supersede any provisions herein to the contrary. Employees with ideas for improvements or additions to these practices are encouraged to discuss them with their supervisors or a member of the Human Resources staff. A current electronic copy of the Employee Handbook is available with the Human Resource Department.


_____Thank You_____