Employee Code of Conduct

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EMPLOYEE POLICY HANDBOOK - 2021

Nippon India Mutual Fund
Great vision
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Employee Policy Handbook 2021 02

Dear Colleague,
My heartiest congratulations on joining NAM India!
You are now part of the exciting, fun-filled and ever- growing Nippon Life
organisation which has been recognised as “AON Best Employer”, multiple times
in the last few years. As a member of our team, we are sure, you will not only have
an enriching time working with us, but also build a promising career for yourself.
At NAM India, it has been our constant and focused endeavour to be a globally
respected organisation that always strives towards making a positive impact on
all the lives we touch. As a socially conscious organisation, we take pride in being
the long-term wealth creator for our investors with the highest degree of
customer centricity, great corporate governance and the highest level of
employee care.
As an organisation, all our colleagues, at every level, are part of the organisation's
growth-strategy and are empowered enough to take business decisions. We take
care of them much beyond salary, pay and perks, and ensure that they all get the
best-in-class learning and career advancement opportunities.
We are dedicated and committed to provide a great workplace that is inclusive

and “equal-for-all” in all aspects, as our colleagues and customers form the core of
any and every business decision!
It's my pleasure to welcome you to NAM India. We have a whole lot of excitement
in store for you. This is a place where you can expect from us, plentiful career
opportunities and challenges. All we need is the willingness to accept and
accomplish them by walking that extra mile.
Looking forward to an exciting journey together!
Sundeep Sikka
Executive Director & CEO

Dear Colleague,
We are delighted to present to you our New Employee Policy Handbook.
This handbook is an initiative to reach out to our employees spread across

the length and breadth of the country and to make you aware of our best-
in-class policies and benefits, across Nippon Life India Asset Management
Limited and all its subsidiaries and affiliate companies in India.
We take pride in being an organization that listens and constantly evolves

our polices, basis your feedback, from time to time, to ensure they are
future-looking, forward-thinking and leading with innovation and
disruption. I will, therefore, urge all of you to continue sharing your ideas
and feedback on these, regularly.
This document will be available on the company intranet for your easy
access and reference. Please feel free to reach out to the HR team for any
queries.
Best wishes,
Rajesh Derhgawen
Chief Human Resources Officer

AMENDMENTS
E XC E P T I O N S
INTERPRETATION
All the policies and procedures
mentioned in this handbook are subject
to modification from time to time at the
discretion of the management.
Exceptions, if any, will need the
approval of the CHRO. The decision of
the CHRO shall be final and conclusive
in the event of an interpretation of a
provision of the policy.
APPLICABILITY
For ease of reference, in this handbook,
Nippon Life India Asset Management
Ltd., its affiliate Associate companies
and all subsidiary companies (including
Nippon Life India AIF management Ltd.,
Reliance Capital Pension Fund Ltd. and
Nippon Life India Trustee Company
Ltd.) will be termed as “NAM India”.
All policies mentioned in this handbook

are applicable to employees of NAM
India.

TABLE OF CONTENT
Governance & Code of Conduct I
Code of Conduct 8-29
Prevention, Prohibition & Redressal of Sexual Harassment at workplace (POSH) 30-34
Ombudspersons & Whistle Blower Mechanism 35-40
Dress Code Policy 41-42
Information Security Policy 43-50
Social Media Policy 51-56
Employment Rules I
Organizational Structure 58
Working Hours 58
Leave Policy 59-63
Probation & Confirmation 63
Employee Separation Policy 64
Flexi Work Policy 65-69
Total Rewards Policy I

Total Rewards Policy 71-72
Fixed CTC 72-75
Variable Pay 76
Employee Benefits 77
Mobile Policy 78
Young Achievers 79
Tenure Completion Policy 80
Crèche Allowance Policy 80
Policy for Children with Special Needs 81
Employee Experience 82-84
Company Provided Car Usage Facility 85-88
Business Enablers I
Business Travel Policy 90-95
Local Conveyance Policy 95-97
Relocation Assistance 97-100
Guidelines on Salary Advances/Loan to Employees 101
Career & Opportunities I

Employee Referral Programme 103-104
Internal Job Posting Policy 105-106
Professional Development Policy 107
Employee Transfer and Job Rotation Policy 108

GOVERNANCE &
CODE OF CONDUCT

CODE OF CONDUCT
At NAM India, the issue of ethics is simple: it is a process that involves defining what is right or wrong, and
then doing the right thing. Ethics Management at NAM India is about values and associated behaviors. It is
a process of defining values and ensuring that corporate and individual employee behaviors epitomize
those values. We at NAM India believe that any business conduct can be ethical only when it rests on the
nine core values of Honesty, Integrity, Respect, Fairness, Purposefulness, Trust, Responsibility,
Citizenship and Caring. Strong commitments to these high values have long been building principles for
NAM INDIA.
These values are not to be lost sight of, by anyone at NAM India under any circumstances, irrespective of
the goals that are intended to be achieved. To us, means are as important as the ends. Though, the deeper
significance of these values for us cannot be captured in words, a brief description of what we really feel
about these virtues is outlined below:
Honesty
We are committed to be truthful in all our actions. We strive to be honest and forthright with one another
and with all our stakeholders.
Integrity
NAM India insists on honesty, integrity and fairness in all aspects of its business and expects the same in
its relationships with all those with whom it does business.
There exists a clear vision and picture of integrity throughout NAM INDIA. Our reward and promotion
systems are aligned with this vision of integrity.
Upholding the NAM India reputation is paramount. We are judged by how we act. Our reputation will be
upheld if we act with integrity in all our dealings, even at a personal level, and we always do what we think
is right at all times. We say what we mean, deliver what we promise, and promise to stand for what is right.
We always honor all our commitments. We stand for loyalty and trustworthiness.
Respect
We are committed to treating everyone fairly and with respect and dignity. We appreciate and value the
skills, strengths and perspectives of our diverse workforce. We respect the uniqueness of each employee.
We believe that each employee makes a meaningful contribution to our organization's success.
Fairness
NAM India is firmly committed to fairness and objectivity in all its actions and interactions. Justice and
fairness imbued in the organization's fabric, ensure procedural fairness, impartiality and consistency in
NAM India's operations.

Purposefulness
NAM India sees its activities in terms of higher purposes and ideals. This purposefulness is a way of
operating, that ties NAM India to its environment at a mutually beneficial dimension.
Trust
We endeavor to foster a participatory work environment where trust and confidence between team
members is spontaneous. We always encourage teamwork with open, candid and speedy communication.
Responsibility
Our employees are expected to demonstrate the highest levels of personal responsibility and continually
affirm that they are responsible to themselves for the pursuit of excellence. At NAM INDIA,
accountability is individual rather than collective. Our employees are committed and enthusiastic to
assume responsibility for actions for the organization.
Citizenship
We are a fiercely patriotic company, fully committed to achieving and participating in every conceivable
way in the progress and integrity of India. We are committed to obeying all the laws of India and the
countries in which we do business and to do our part to make the communities in which we live better.
Caring
Compassion, sharing and kindness are values that we try to inculcate in our decision-making process to
achieve fairness. It is imperative that each one of us gets intensely driven from the heart towards
upholding these values in our day-to-day conduct. This initiative will further stimulate the creation and
maintenance of a highly ethical work environment.
Commitments Background
A firm belief that every NAM India team member holds is that the other person's interests count as much
as his/her own. It is not surprising that NAM India has always been able to strike a mutually profitable
equilibrium with ease while interacting with diverse internal and external stakeholder groups. NAM India
strives to make the good of these diverse stakeholder groups a part of its good.
NAM India recognizes that maintaining the trust and confidence of all its stakeholders is crucial to its
continued growth and success. We are aware that a company must be an integral part of the society in
which it operates; that it must fulfill a number of different expectations – financial, social and
environmental; and that there is no substitute to being right. We seek success by being sensitive and alive
to the interests and concerns of others in society, and by working constructively with them to find
solutions of mutual benefit. In pursuit of the values outlined above, we are committed to the ethical
treatment of all our stakeholders.

Commitment to Skakeholders
In all our relationships, we demonstrate our steadfast commitment to all our stakeholders:
OUR EMPLOYEES
NAM India recognizes that its commercial success depends on the full commitment of all employees. We
are committed to respecting the human rights of our employees. We strive to treat our employees with
honesty, just management, due dignity and fairness. We are committed to providing our employees with
a good, safe and healthy environment, and competitive terms and conditions of service.
NAM India promotes the development and best use of human talent. It encourages the involvement of
employees in the planning, direction and fair appraisal of their work. The employees are also encouraged
to participate in the application of these ethics and values within the company.
OUR CUSTOMERS
We are committed to producing reliable, world-class quality products and services, delivered on time, at a
fair price. NAM India strives to win and maintain customers by developing and providing products and
services that offer value in terms of price, quality, safety and environmental impact, which are supported
by the requisite technological, environmental and commercial expertise.
OUR ENVIRONMENT
NAM India is committed to acting as a concerned and responsible community participant, reflecting all
aspects of good corporate citizenship. We are committed to achieving the global standards of health,
safety and environment. NAM India works with its community by volunteering and supporting education,
medical welfare and other worthy causes that lead to sustainable development.
OUR SHAREHOLDERS
We are committed to pursuing sound growth and earnings objectives and to exercising prudence in the
use of our assets and resources. Enhancing shareholder value remains the prime driving force of our
business and financial decisions. We ensure our success by satisfying our customers and increasing
shareholder value.
OUR LENDERS AND OTHER INVESTORS

We are committed to truthful disclosure of all material facts and the regular and timely payment of all our
debt service obligations.
OUR SUPPLIERS AND OTHER SERVICE PROVIDERS

We are committed to fair competition and the sense of responsibility required for a good customer.
THE GOVERNMENT
NAM India is a fiercely patriotic company and is enthused and proud to be a homegrown enterprise. We
are committed to the payment of all applicable taxes and duties, and adherence to all applicable laws and
regulations.

POLICY ON CONFLICT OF INTERESTS

What is a 'Conflict of Interest'?
A conflict of interest may exist when an employee is involved in an activity or has a personal (direct or
indirect, by himself or through any relative) interest that in the opinion of the company can interfere with
the employee's objectivity in performing company duties and responsibilities.
An actual conflict of interest need not be present. Also, a direct loss or disadvantage to the company need
not be present/evident. Activities that create the appearance of a conflict of interest are also
automatically deemed to be covered by this policy in order not to reflect negatively on the reputation of
NAM India and/or its employees.
Any 'indirect' interest, held by an employee, in any property, proprietorship, concern, partnership,
investment, arrangement, agreement or transaction that creates or can create direct or indirect personal
advantage or gains can lead to a conflict of interest.
A conflict of interest can arise when an employee is involved in a transaction/arrangement with any
person acting on his/her behalf or at his/her behest for the employee's direct or indirect personal
advantage or gains. Such activities, arrangements, transactions and agreements are not allowed and
must be discontinued by the employee immediately, failing which the company will commence the
contract termination process and disciplinary action.
In situations where a conflict arises, the employee's first responsibility is to disclose the conflict of
interest and seek express approval from his/her Manager or the Ombudsperson. The
Manager/Ombudsperson will assess the nature of the conflict and recommend either the employee not
participating in the decision-making process or approve the same with appropriate safeguards to
minimize the conflicts. In cases where the above safeguards are not feasible/have not been implemented,
the suggestion of discontinuance would apply.
What is the essence of this code on conflict of interest?

Any activity or personal (direct or indirect) interest of the employee, including those of the employee's
relatives, that leads to or can lead to a conflict of interest, is prohibited.
Employees are expected to provide truthful, accurate and complete information about certain facts,
transactions, and relationships that may have a bearing on issues related to conflicts of interest. They are
expected to provide details about these facts, transactions and relationships, irrespective of their
assessment of whether a conflict of interest exists. Disclosure forms seeking such information will be
made available to employees for submitting details in a confidential manner to the compliance office.
This is a key element of the plan to implement and enforce the policy on conflict of interest as it promotes
self-regulation and is built on the pillars of trust and self-responsibility. Employees are expected to
identify conflicts of interest that involve them and are further expected to discontinue activities that
result in or can result in conflicts of interest.

What should employees do to avoid a conflict of interest?

Employees should steer clear of any situation that involves or may involve a conflict between their
personal interest and the interest of the company.
Employees should avoid any relationship, influence or activity that might impair, or even appear to impair,
their ability to make objective and fair decisions when performing their job.
Employees dealing with customers, suppliers, contractors, competitors or any person doing or seeking to
do business with the company are to act in the best interest of the company to the exclusion of
considerations of direct or indirect personal preference or advantage.
Employees are obliged to place NAM India's interest in any business transactions ahead of any direct or
indirect personal interest or personal gain to the individual employee or to the employee's spouse, family
member, friend or other individual.
Employees should not have an outside employment or be involved in an outside activity that is in
direct/indirect conflict with their official duties. Employees are also prohibited from using their
position/title/authority associated with their office or coerce or induce a benefit for themselves or
others.
Any non-compliance with the above policy guidelines will be treated as a serious violation of the
company's Code of Conduct and will invite strict disciplinary actions, including any appropriate legal
recourse, against the employee, as deemed fit by the management.
What actions are to be avoided by the employees at all times?

Any person to whom this policy is made applicable, cannot undertake any of the following activities:
Undertaking full-time employment or significant and active managerial or decision-making role in any
business enterprise other than NAM India.
Undertaking Part-time Employment: Setting up, operating, advising, representing or getting involved
in any manner whatsoever with a business enterprise that competes with NAM India in any of our
businesses.
Holding an investment interest (either directly or indirectly through any relative*) or any kind of
financial involvement, or acting as an officer, member, director, partner, consultant, representative,
agent, advisor, broker, intermediary or employee in any other capacity in any outside business
enterprise would not be allowed if the outside interest does or proposes to do business with NAM
India (as a supplier, customer, consultant, advisor, agent, broker, intermediary, representative or in
any other way). Employees are encouraged to check with the Ombudsperson in case there is a conflict
of interest on this. Relatives include the following: Spouse, Father, Mother, Sons, Son's Wife,
Daughters, Daughters' Husband, Father's Father, Father's Mother, Mother's Father, Mother's Mother,
Son's Son, Son's Wife, Son's Daughter, Son's Daughter's Husband, Daughter's Son, Daughter's Son's
Wife, Daughter's Daughter, Daughter's Husband, Brother (including Step-Brother), Brother's Wife,
Sister (including Step-Sister), Sister's Husband and Members of HUF.

Undertaking any activity that might lead to, or give the appearance of unapproved disclosures of
proprietary information or proprietary information owned by others who have entrusted such
information to NAM India.
Using their corporate official title or position to promote a book, seminar or any other similar activity.
All employees may accept honoraria for an appearance, speech or article, provided that the activity
does not relate to the employee's official duties.
Getting involved or engaged in any other activity that could create the appearance of a conflict of
interest and thereby impair NAM India's reputation.
The Company would like to reiterate on one very important and salient aspect of the policy, with
regards to having an ARN code in your or your immediate family members' or relatives' name who are
dependent on you.
Please note that as employees of NAM India, you are not supposed to have any active ARN code in your
or your family members' and relatives' name and not do any business movement though such ARN
code that might bring profit to other business entities.
You are required to report any such instance of yourself or your family members' and relatives' having
an existing ARN code and/or business being done on that ARN code. Effective immediately, you are
required to surrender all such ARN codes and confirm to the company on the same.
Any non-compliance with regards to non-reporting of the existing ARN code, acquisition of new ARN
code or any NAM India business movement via the existing ARN code, in your name or immediate
dependent family member's or relatives' name will be treated as serious violation of company code of
conduct and will invite deemed disciplinary actions, as deemed fit.
The details on the definition of family members and relatives are mentioned in the policy document
and can be accessed on RPULSE or at: https://bit.ly/2I9FhZZ
Please feel free to reach out to your HR SPOC in case of any clarification or assistance.
Employees dealing with customers, investors, distributors, suppliers, contractors, competitors or any
person doing, or seeking to do business with the company, are to act always in the best interest of the
company and should not have dealings or considerations of direct or indirect personal preference or
advantage, for themselves, or for their family members.
Employees are not allowed to have any personal dealings, for themselves or for their family
members, with any service provider of the organization where the organization is paying any
consideration, monetary or non-monetary.
Employees are not allowed to have any personal dealings or any dealing in favor of any investors,
distributors, brokers or any individual working in direct consideration with the organization and/or
empaneled with the organization.

Employees who are part of the decision-making team, directly or indirectly for the company's
investment decisions in external entities, are required to report and take prior sign-off from
the Management, for any dealing in personal capacity with such entities, even if that dealing is at
arm's length.
Please note that as employees of NAM, you are not supposed to have any active ARN code in your
or your family members' or relatives' name. In case any employee already has an ARN code in his/her
name or family members' or relatives' name, the same needs to be reported immediately to the HR
team.
Employees are not allowed to share any company confidential information with anyone who is not
authorized to receive such information and does not have access to such information.
Employees are required to report receipt of any gifts, consideration, services, goods, holdings or any
other item of monetary value of more than INR 2000/- and for things which are outside the
preview of normal and acceptable business courtesy and are not associated with customary
business practices.
What are the exceptions to the above policy?

An employee can accept an office in a non-profit organization if he/she obtains prior approval from the
Management. An employee can accept an office or hold an investment in any outside entity (which is
doing or proposes to do business with NAM India, e.g. Joint Venture) if he/she has obtained approval from
the Management or such investment/office is held on behalf of or as a nominee of the company.

POLICY ON PAYMENTS AND GIFTING

What are the general principles that NAM India employees
are expected to bear in mind before accepting any gifts or
business courtesies?
All business courtesies offered to and accepted by NAM India employees are courtesies that belong
to NAM India. Employees do not have a right to keep a business courtesy for personal use.
When offered a business courtesy, employees should determine whether it is appropriate to accept the
courtesy on behalf of NAM India after considering why it is being extended and possible repercussions
of acceptance.
Acceptance and disposal of any gift/business courtesy has to be in line with the requirements of this
code.
What business courtesies can NAM India employees accept?

An employee can keep a business courtesy when acceptance of the courtesy:
Is usually associated with customary business practices.
Promotes successful working relationships and goodwill with persons or firms with whom NAM India
maintains or may establish a business relationship. Such courtesies include business meals and
entertainment that are shared with the person who has offered to pay for the meal or entertainment.
However, employees should use good judgement and decline invitations for meals and
entertainment that are inappropriately lavish or excessive and are of such nature or magnitude that
cannot be reciprocated.
Conforms to the reasonable and ethical practices of the marketplace, such as flowers, fruit baskets
and other modest presents that commemorate a special occasion.
Does not create conflict of interest of divided loyalty, such as placing the interests of the person or
firm that offered the courtesy above the interests of NAM India, including the company's interest in
conducting business fairly and impartially.
Does not create the appearance of an improper attempt to influence business decisions, such as
accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
Novelty, advertising, or promotional items of nominal value, such as calendars, pens and mugs may
generally be retained.
When local customs or practices make it inappropriate to decline the business courtesy at the time it is
offered, employees should accept the courtesy and follow the guidelines for disposition.

What gifts or business courtesies should NAM India

employees not accept?
Employees shall neither seek nor accept for themselves or others any gifts, favors, business courtesies or
entertainment without a legitimate business purpose, nor seek or accept loans (other than conventional
loans at market rates from lending institutions) from any person or business organization that does or
seeks to do business with, or is a competitor of the company.
Employees who award contracts or who can influence the allocation of business, who create
specifications that result in the placement of business, or who participate in negotiating contracts must
be particularly careful to avoid actions that create the appearance of favoritism or that may adversely
affect the company's reputation.
Employees should avoid a pattern of accepting frequent courtesies from the same persons or companies.
The following actions by employees would be completely unacceptable
Asking for a business courtesy.
Accepting a business courtesy when:
An attempt is being made by the donor to offer the courtesy in exchange

for or to influence, favorable action by NAM India.
An attempt is being made to motivate an employee to do anything that is

prohibited by law, regulations, or NAM India or donor policy.
An attempt is being made to gain an unfair competitive advantage by improperly

influencing an employee's discretionary decisions.
Using a company position as a means of obtaining business courtesies, such as personal discounts (on
products, services or other items). Employees may accept NAM India-approved discounts or discounts
available to all NAM India employees.
Accepting offers of expense-paid trips for pleasure from persons or firms with whom NAM India
maintains or may establish a business relationship.
Accepting a gift in cash or cash equivalents of any amount.
What should a NAM India employee do when the business

courtesy or the gift is inappropriate or unacceptable?
If it is not appropriate to accept or retain a courtesy, the employee should either politely refuse the
business courtesy at the time it is offered or follow the guidelines for disposition.
All employees are mandatorily required to report receipt of any gifts, consideration, goods, services,

or any other item of monetary value greater than INR 2000/- and for things which are outside the
preview of normal and acceptable business courtesy and are not associated with customary
business practices.
What actions should be taken in case gifts have been

accepted but are inappropriate?
Whenever an employee has accepted a courtesy that does not meet the criteria for acceptance in this
procedure, he or she should use one of the following alternatives:
Return it to the donor with a polite explanation that NAM India policy prohibits retention of the
business courtesy.
Promptly forward the courtesy to the department dealing with community welfare and charity for
appropriate disposition.
Retain the courtesy for displaying with prior approval.
Retain the courtesy for personal use after prior approval or after paying NAM India an amount equal
to the fair value of the business courtesy.
If the employee is ultimately permitted to retain such gifts, the Head of Department shall record
his/her approval in writing and the employee will retain the approval on file for potential audit review.
POLICY ON PURCHASES THROUGH

SUPPLIERS AND OTHER SERVICE PROVIDERS
What are the general principles of the purchase policy?

Purchase decisions must be made purely on the basis of quality, service, price, delivery, best value or
other similar factors.
Extraneous or personal interest/advantage should never be the criteria for arriving at purchase decisions.
Objective, fair, transparent, and responsible criteria must be used while evaluating, passing or rejecting
the quality of the goods/services supplied.
If such criteria are being followed, employees should not have any apprehension and fear about taking
any procurement decisions.
Care must be taken to avoid actual/potential conflicts of interest and the appearance of partiality
regarding all business transactions with suppliers and other service providers.

What actions should be avoided by NAM India employees

while dealing with suppliers and other service providers?
Business and personal activities must be kept separate. Having both a personal and business involvement
with a supplier or potential supplier/other service providers may create a conflict of interest or
appearance of partiality. Please refer to the Policy on Conflict of Interest given in this code.
What additional responsibilities are levied on NAM India

employees under this Code?
Employees are responsible for complying with supplier-imposed limitations governing the use of supplier
information, including such items as documents and computer software.
All company employees, contract labor, consultants, representatives, agents and others acting for the
company, are prohibited from the following actions:
Soliciting, accepting or attempting to accept any kickback, including, directly or indirectly, the amount of
any kickback in the price charged under a contract, either as prime contractor or sub-contractor.
The term 'kickback' includes any money, fee, commission, credit, gift, gratuity, thing of value or
compensation of any type, whether in cash or in kind that is provided directly or indirectly to anyone for
the purpose of inappropriately or improperly obtaining or rewarding favorable treatment.
It should be noted that any action that even appears to be in violation of the above principles would be
severely dealt with.
What are the responsibilities that are levied on the

suppliers/other service providers as per this policy?
It is important for employees to be aware of the responsibilities of suppliers/service providers and create
awareness about the same.
Suppliers/other service providers are required to ensure that their actions in no way contravene any
provisions of NAM India's Code of Ethics.
They must take special care in respect of specific requirements of the policy on Conflict of Interest,
payments and gifts, and receipt of gifts. These specific requirements will be incorporated as additional
terms of all existing and new contracts with all suppliers and vendors.
The overarching principle that suppliers ought to keep in mind is that their actions should not result in any
direct or indirect personal advantage or gains for any NAM India employee or his/her relatives. It is not
relevant for the purpose of this policy whether such actions were performed at the behest of the NAM
India employee or were suo motu actions on the part of the supplier.
Any supplier or vendor found to be violating any of these requirements will be subject to the possibility of
termination of his contract and the payment of liquidated damages.

POLICY REGARDING FULL-TIME CONSULTANTS,

AGENTS, REPRESENTATIVES AND OTHERS
What are the general principles regarding consultants,
agents and representatives?
We are committed to maintaining the integrity of our full-time consultants, advisors, agents,
intermediaries, contractors, brokers and representatives. Business integrity is a key criterion for the
selection and retention of those who represent NAM India.
Appointment of consultants, advisors, agents, intermediaries, brokers and representatives must not
result in the creation of a conflict of interest. For example, when a relative of an employee acts as a
consultant, advisor, agent, intermediary, broker, or a representative of NAM India, a conflict of interest
may arise. Such instances should be discontinued. In this context, reference should be made to the
company policy on Conflict of Interest. Individuals should never be appointed as consultants, advisors,
agents, intermediaries, brokers or representatives with a view to circumvent NAM India's ethics and
values. Full-time agents, representatives, or consultants who expressly represent or propose to represent
NAM India must certify their willingness to comply with the company's policies and procedures.
POLICY ON FINANCIAL AND

ACCOUNTING INTEGRITY
The company is committed to the maintenance of accurate and complete corporate records.
The company relies on its business records for making business decisions, for making representations to
the regulators, government, investors, media and other stakeholders concerning the company, and for
exercising its legal rights. Hence, it is critical that these records be accurate and complete. It is
everybody's responsibility to see that any company records generated are properly safeguarded.
Company policies require the company to keep books and records that accurately and fairly reflect its
transactions and the dispositions of its assets. Failure to meet such requirements may constitute a
violation of law or regulatory requirements.
What is expected of employees?

All the transactions entered into, on behalf of NAM India must be promptly and accurately entered in our
books and systems in accordance with generally accepted accounting practices and principles.

What actions on the part of employees are considered

unacceptable?
Rationalizing or even considering misrepresentation of facts or falsification of records is completely
unacceptable. It is illegal, will not be tolerated, and will result in disciplinary action.
What is the specific policy to ensure financial and

accounting integrity?
All accounts and records shall be documented and governed by the following cardinal principles:
The transactions accounting clearly describes and identifies the true nature of business transactions,
assets, liability, income and expenditure. Proper recording of entries on the books of account in conformity
with generally accepted accounting practices and principles.
All the entries are recorded in the books of account on time as they were entered into, without any
intentional delay or disarrangement or improper sequencing.
All the transactions are entered into, and recorded without any omission either in part or whole. No
undisclosed funds or assets may be established or maintained. No record or entry or document shall be
false, distorted, misleading, misdirected and deliberately left incomplete or suppressed.
All the established internal control standards and procedures are strictly adhered to, while recording the
transactions. Employees also share the responsibility for maintaining and complying with required internal
controls. Improper accounting and documentation and fraudulent financial reporting are not only contrary
to company policy, but also may be in violation of laws and regulations.
All transactions entered into are backed by proper management approvals, as may be delegated to each
authority.
Each employee shall promptly report to his/her supervisor/reporting authority any significant and unusual
event or occurrence, both positive and negative, that arises in the course of discharging his/her duties and
responsibilities in the matter of financial accounting.
The company adopted the system of disclosure controls to assure that all the important information
regarding the business and prospects of the company are properly gathered and reported in accordance
with the applicable laws. All employees should comply with these requirements.
Each employee must be candid in discussing matters concerning financial accounting and recording,
internal controls and business disclosures with the company management and auditors and regulators.
There shall be no intentional concealment, misdirection, misleading statements, falsification of documents

and records or making a statement which they do not prima facie believe to be true while dealing with all
stakeholders.

Errors or possible errors in the company's books and records shall be brought to the attention of the CFO
promptly for necessary corrections. Employees shall promptly report to the CFO or Compliance Officer or
Ombudsperson if in place, any actual/suspected breaches or violations, questionable activities or activities
of fraudulent nature relating to financial accounting and recording. They should also render all the
necessary cooperation for any investigation carried out by the authorities in this regard.
The company shall extend all the necessary protection as per its policies and shall adopt a non-retaliation
policy approach towards the whistle blowers who had flagged matters relating to non-compliance with
financial integrity.
The employees shall keep the data and other records processed by them while accounting and recording the
transaction as confidential and these should be used only for company purposes. The same should not be
used for ulterior motives, or for any personal gains.
No employee should be misguided by any sense of loyalty to the company or a desire for higher profitability
that might cause him or her to disobey any applicable law or company policy causing damage to the
reputation of the company.
All the necessary efforts should be made by each employee to ensure the records, papers, documents,
vouchers, bills, etc. supporting the transactions entered into and accounted for are properly arranged,
safeguarded and retained for the necessary period as may be prescribed under company policy/legal
requirements/regulatory guidelines.
POLICY ON FAIR MARKET PRACTICES

What is the essence of the fair market practices adopted
by NAM India?
NAM India believes that the welfare of consumers is best served by economic competition.
We believe in, and strive to protect the free enterprise system. We are committed to the maintenance of
an efficient, free and competitive market structure. We compete fairly and ethically for all business
opportunities.
What actions should NAM India employees refrain from

performing?
Employees should refrain from entering into agreements and practices that unreasonably restrict
competition and are in restraint of free trade, such as price fixing and boycotting suppliers or customers.
Any commercial strategy based on the intention to run a competitor out of business through unfair
pricing or otherwise, cannot be followed.

Disparaging, misrepresenting or harassing a competitor; stealing trade secrets; bribery and kickbacks are
strongly discouraged.
Organizational conflicts in which one business unit's activities may preclude or impede the pursuit of a
related activity by another business unit should be avoided.
POLICY ON POLITICAL CONTRIBUTION
What are the general principles regarding political

contribution?
Employees should not make any contribution of company funds to any political party or committee,
domestic or foreign, or to any candidate for, or any office of any government – National, State, local or
foreign unless it is legally permissible and is appropriately authorized.
NAM India employees should not make illegal political contributions, either directly or indirectly, through
the use of expense accounts or through payments to a third party or on their own account.
POLICY ON WORK ETHICS INCLUDING PREVENTION OF

WORKPLACE HARASSMENT/THREATENING BEHAVIOR
A. Business Confidentiality
All Directors and employees shall strive to protect the confidential information acquired, generated,
gathered or otherwise come into possession during the course of business. All information should be
maintained in strict confidence, except when disclosure is authorized by the company or required by law.
Confidential information includes all non-public information, Intellectual Property Rights such as trade
secrets, business research, new products, new projects and plans, business strategies, salary and benefits
data, customer, employee and suppliers' lists and any unpublished financial or pricing information.
B. Favoritism in the Workplace

All Departmental/Business Heads must treat each and every employee in their department equally. The
underlying principle is that each one of us at NAM India is expected to work to create an environment
where people are valued as individuals and treated with respect, dignity, fairness and equality.
Thus, leaving no room for displays of favoritism.

C. Compliance with Laws, Rules and Regulations

All Directors and employees shall keep themselves updated with laws/statutory compliances applicable
to their scope of work. They should endeavor to keep themselves abreast with the developments in laws
and regulations, and comply with the same. If anyone gets to know of any non-compliance of any of the
laws in his or her colleagues' area of operation in the company, the same should be brought to his/her
immediate notice, as well as to the notice of his/her Head of Department. In case the said non-compliance
continues, the same should be brought to the notice of the Ombudsperson.
All Directors and employees of the company shall conduct business affairs with honesty and integrity, and
in full compliance with all applicable laws, rules and regulations, and shall not commit any illegal or
unethical act or instruct others to do so, for any reason.
D. Information Security and Protecting Company Assets

NAM India recognizes that information is a critical business asset, and that our ability to operate
effectively and succeed in a competitive market with several legislative and regulatory requirements,
depends on our ability to ensure that business information is protected adequately through appropriate
controls and proactive measures. Accordingly, NAM India is committed to the implementation of
Information Security by establishing comprehensive management processes throughout the
organization and every employee is governed by the Information Security Policy of the company.
Also, it is the responsibility of the employees to ensure that the assets of NAM India shall not be misused,
but shall be employed for the purpose of conducting the business for which they are duly authorized.
These include tangible assets such as equipment and machinery, systems, facilities, materials and
resources, as well as intangible assets such as proprietary information, relationships with customers and
suppliers, etc.
E. Policy on Personal Conduct

In their official as well as personal capacity, employees at no times should indulge in any action/behavior
that:
· Violates any law,
· Is indicative of personal indiscretion,
· Is socially unacceptable
NAM India employees are expected to ensure that their conduct at all times is such that the company's
reputation is upheld.
F. Prevention of Workplace Harassment/Threatening Behavior

NAM India is committed to providing a work environment that fosters cooperation and teamwork among
co-workers. The company requires that every employee will respect the rights and dignity of all
employees, without regard to race, colour, religion, national origin, sex, age, disability or other
characteristics protected by law.

GENERAL GUIDELINES
In accordance with the Code of Ethics, among the types of behavior that will not be tolerated is the making
of unwelcome sexual advances or comments of a sexual nature to another employee, or any other conduct
with sexual overtones. Sexual harassment is illegal and offensive.
Harassment of any kind is strictly prohibited. Such harassment may be based on but not restricted to race,
sex, age, national origin, religion, political beliefs and sexual orientation, physical or mental disability.
Threats, threatening behavior or acts of violence against associates, visitors, guests or other individuals by
anyone on company premises will not be tolerated.
Any person who makes threats, exhibits threatening behavior or engages in violent acts on company
premises, may be removed from the premises as quickly as safety permits, and may be required to remain
away from company premises pending the outcome of an investigation.
RESPONSIBILITIES OF EMPLOYEES
All employees have the responsibility to promote a culture of mutual respect, free of harassment
and hostility, and to maintain a professional attitude and standard of behavior.
All employees are responsible for immediately notifying a Human Resources Manager or their
immediate Manager, of any harassment or threats which they have witnessed, received or have been
told that another person has witnessed or received. In the event that an individual is uncomfortable
speaking with a Human Resources Manager or the immediate Manager, he or she may contact the
Ombudsperson.
All employees are required to cooperate fully and truthfully in any investigation.
Unauthorized discussion of investigations related to workplace harassment or threatening

behavior is prohibited.
All Management personnel have the responsibility to ensure the workplace is free of any form of
discrimination including sexual harassment, and should make all efforts towards providing a safe
and healthy work environment.
Managers must set an example by always using appropriate behavior.
Managers are expected to be open to discussing issues, be alert for and listen seriously to all
employee complaints about harassment of any kind, as they relate to this Workplace Policy.
Managers are responsible to report any concerns or complaints about harassment of any kind to
Human Resources.

Ombudspersons are responsible for conducting appropriate investigation of complaints of any type
of harassment, threats or acts of violence in the workplace and for promptly taking appropriate
remedial action.
Every effort will be made to protect the confidentiality of all parties involved.
The conclusion of each investigation will be judged on the facts and merit of the complaint.
CORRECTIVE ACTION
Any violation of this policy is subject to corrective action up to and including termination of employment.
POLICY ON EXTERNAL COMMUNICATION

NAM India is deeply committed to the highest levels of Corporate Governance and the welfare of all its
stakeholders, and realizes the critical role played by media in this regard. Hence, it is necessary to engage
with media in a fair and professional manner, so as to uphold the company's corporate image and
safeguard its business interests.
The External Communication Policy outlines our philosophy and provides a broad media engagement
framework for officials who would be required to engage with media as part of their professional
responsibilities.
What is the objective of this External Communication

Policy?
The objectives are clearly as follows:
To put in place a robust framework for NAM India (and group companies) to deal and engage
effectively with the media as part of overall business strategy.
To define guidelines and norms for dealing with the media for various situations and purposes.
What is the scope of this policy?

The scope of this policy includes NAM India, all subsidiary and group companies, joint venture and partner
companies, and other companies.
The policy will be applicable to all formal external communications including Press Releases, Corporate
Presentations, Management Profiles, Corporate Backgrounders and Fact Sheets.
All media formats including Electronic, Print, Radio and Internet-based/Online Media – including blogs
and social networking – will form part of this policy.

What are the cardinal principles followed by this policy?

NAM India and its group companies shall endeavor to be seen as a business group that is strictly apolitical
and without any bias or prejudice towards any region or religion. The company shall always be seen as a
business group that respects and abides by the law of the land, and resorts to and trusts the legal, judicial
and legislative framework of the nation for addressing and managing its business challenges. The
company shall always be recognized as a business group that fosters supports and participates in healthy
market competition and conducts its businesses with the highest standards of ethical practices and
corporate governance. The company regards the fourth estate as the voice of the nation and shall always
endeavor to co-operate, support and participate in media's role for the betterment of society and the
nation at large.
What is the broad media interaction philosophy?

The company will engage with media in a professional manner and through its designated spokes
persons only. These spokespersons will be nominated at the Group, Business and Operations level.
The company is committed to meeting its obligation regarding information disclosures and in sharing
accurate and timely information with the media.
The company is committed to safeguarding the interest of its businesses and all its stakeholders while
sharing information with the media.
The CEO and its members are expected to ensure that the information being shared is approved and does
not violate any norms and/or harms its businesses
The company will refrain from commenting on issues that are inaccurate, speculative, competitive,
untrue, and can be misleading or can misrepresent facts, and/or can pose any damage to its operations
and business relationships regionally or globally.
Who is authorized to interact with the media? What is the

process to be followed while sharing information with the
media?
The Management shall identify and approve individuals, from time to time and on a case-to-case basis.
Only such Spokesperson shall be authorized to interact with the Media on behalf of the Organization.
This may be reviewed and revised as required.
The Authorized Spokesperson shall seek appropriate guidelines from the Company when dealing with
the Media for any specific issue.
All Nippon Life India Asset Management Ltd. companies and officials shall necessarily consult the
Company before or while interacting / responding / addressing to the media and / or implementing media
activities.
All other employees, in case approached by the media, will direct these queries to appropriate
spokespersons in the Company and immediately inform the Public Relations representative.
All media queries to be directed to the following:

Bhushan Parab ‐ Lead - Public Relations | bhushan.parab@nipponindiaim.com

No official, other than a designated spokesperson, will interact with the media. All designated
spokespersons will also restrict their media interaction to their respective subjects / domains only in a
manner advised by the Public Relations Team.
The Public Relations team will provide necessary support through guidance, training, and
implementation assistance to Group companies and their designated spokespersons for handling routine
media queries, crisis management and in enhancing their media handling skills.
The Public Relations team will help businesses draft responses to media queries in line with the overall
Group's communication strategy. Similarly, all responses drafted by businesses shall be verified for
overall consistency.
POLICY ON HEALTH,
SAFETY AND ENVIRONMENT
What is NAM India's policy on Health,

Safety and Environment?
“Safety of individuals and environment, overrides all the financial and physical targets” – is the
Environment, Health and Safety (EHS) philosophy of the Company.
The Company shall demonstrate, within its business processes, care for the environment, health and
occupational safety to create brighter lives for current and future generations.
Purpose
The purpose of the policy is to exhibit NAM India Nippon Life Asset Management Co. Ltd.'s commitment
to the conservation of the environment and safeguarding health and safety of its employees, contractors,
customers and visitors on its premises.
Scope
The policy covers all employees, products, processes and infrastructure within NAM India Nippon Life
Asset Management Co. Ltd. and its subsidiaries and affiliates.
The policy will be read in conjunction with Legal statutes, state proclamations and notices, and
procedures & alerts issued from time to time by authorized company personnel.
Application
The Company is committed to the effective management of health and safety of its employees,
contractors, customers and visitors on the company premises.
The Company is also committed to prevent the wastage of natural resources and minimize hazardous
impact of any of its products or services on the ecological environment.
Accordingly, to ensure effective delivery and continual improvement of environment, health and
safety, the Company will:
Comply with regulatory requirements

Identify key risks through risk assessment.

Impart necessary education and training to enable employees to take ownership and avoid
unnecessary risks.
Set out clear roles and responsibilities for all stakeholders.
Consult with employees on environmental impact and health and safety arrangements, as
appropriate.
Within the spirit of this policy, the Company shall abide by the following principles to minimize the
impact on environment, health and safety.
Environment
Integrate the considerations of environment and pollution concerns and impact into all decision-
making and activities.
Monitor, control and upgrade technology to prevent pollution and conserve natural resources.
Use sustainable practices in property design and property management.
Prevent wastage of water and use treated water within the premises wherever feasible.
Make optimum use of energy through installation of energy efficient machines.
Health
First-aid equipment maintained and made available at appropriate places.
Allow sufficient paid time-off to employees to take care of health exigencies.
Extend affordable medical check-ups to employees.
Monitor food quality in the cafeteria to ensure high standards are maintained at all times.
Provide for insurance cover (health, accident and life) to all employees to take care of medical events.
Conduct health and wellness programs regularly, including vaccination administration.
Discourage any kind of substance abuse and run de-addiction programs if necessary.
Provide professional counselling services wherever possible.
Safety
Proactively train and build awareness of road safety and extend support during exigent events of
natural calamity and, civil strife in life beyond work.
Prepare on-site emergency plans and conduct regular mock drills and evacuation programs
Deploy sufficient physical and electronic security within office premises.
Install portable fire extinguishers of required type and capacity at appropriate places and impart
training to operate firefighting equipment.
Use state-of-the-art electrical equipment and procedures.
Conduct detailed investigation of all incidents including the minor ones and near-miss incidents
followed by recommendations to avoid recurrence.
Analyze the findings of investigations of accidents in similar organizations and taking steps to prevent
such accidents in the plants/premises/workplaces.
Prohibit smoking within company premises

Roles and Responsibilities
Roles Responsibilities
Ÿ Integrate EHS aspects within respective functions and their implementation.

Leadership Team Ÿ Ensure compliance with applicable legal and other requirements and excel
beyond them.
Ÿ Continuously evaluate and improve practices, processes and products to

Business Teams make them safe and acceptable to employees, the customers, the public and
the environment.
Ÿ Develop appropriate management procedures and consultative

arrangements to monitor the EHS policy.
Ÿ Protect the safety and health of all employees, contractors and other third
parties working within Company premises, always, in close collaboration with
HR and Admin Teams them.
Ÿ Appoint Fire Wardens to help evacuate the office building during crisis.
Ÿ Create awareness on EHS and develop the required level of knowledge and
skills in all employees, including contractors, through need based training
and internal communication.
Ÿ Adhere to safe work practices and principles laid down in this policy.
Employees Ÿ Ensure personal belongings are stored safely.
Ÿ Actively participate in recognizing and mitigating EHS risks at workplace.

PREVENTION, PROHIBITION & REDRESSAL OF

SEXUAL HARASSMENT AT WORKPLACE (POSH)
NAM India believes that all employees, including other persons who have been dealing with the company,
have the right to be treated with respect and dignity. Sexual harassment in any form is an offence and is
therefore punishable.
NAM India is committed to creating a safe and conducive work environment that enables employees to
work without fear of prejudice, gender bias and sexual harassment. Sexual harassment is a form of
workplace harassment of a sexual nature that affects the dignity of Women/Men at work.
This Policy has been framed with the intention of preventing sexual harassment at the workplace, and it
includes redressal of sexual harassment, should it occur.
This policy is to be read in conjunction with “The Sexual Harassment of Women at Work Place (Prevention,
Prohibition and Redressal) Act, 2013 which got the assent of the President on April 22, 2013 (hereafter
referred to as 2013 Act) or as may be amended from time to time.
All employees are expected to uphold the highest standards of ethical conduct at the workplace and in all
their interactions with business stakeholders. It is mandatory for all employees to follow this Policy and
the guidelines formulated herein. Sexual harassment at the workplace will be deemed to be a
violation/breach of the terms of employment. This means that employees have a responsibility to:
Treat each other with dignity and respect.

Follow the letter and spirit of law.
Refrain from any unwelcome behavior that has sexual connotation (of sexual nature).
Refrain from creating a hostile atmosphere at the workplace via sexual harassment.
Report sexual harassment experienced and/or witnessed by the Employee Protection Committee
formulated under this Policy and abide by the complaint handling procedure prescribed herein.
General Clauses
The terms appearing in the Policy shall have the meaning assigned to them in the Definition Clause of this
Policy. In the event, any term used in the Policy is not defined in the Definition Clause, it shall have the
meaning as assigned to it under the Sexual Harassment of Women at Workplace (Prevention, Prohibition
and Redressal) Act, 2013 and the Sexual Harassment of Women at Workplace (Prevention, Prohibition
and Redressal) Rules, 2013.
In case of a conflict between the definitions of the terms as set out in the Definition Clause of this Policy
and the definition of such terms as laid down under the Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Act, 2013 and the Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Rules, 2013, the provisions of the Act and the Rules shall prevail.

Scope/Coverage
This Policy is applicable to all employees of NAM India. Local country laws will take precedence over this
Policy in other geographies, if applicable. The Policy is not in derogation of any other legal rights of the
affected employees.
This Policy takes complete cognizance of the latest legislation by the Government of India including The
Sexual Harassment at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and its rules
notification published on 9th December 2013, ESG Guideline of SEBI Guidelines for submission of BR
Reports, etc. This Act is to provide protection against sexual harassment of women at the workplace and
for the prevention and redressal of complaints of sexual harassment. and for the matters connected
herewith or incidental thereto.
Objective/Purpose
Provide a work environment free from victimization, discrimination and harassment of sexual nature.
Issuing a policy statement to define sexual harassment to prevent, prohibit and deter sexual
harassment at the workplace.
Address issues related to sexual harassment by providing an informal and formal mechanism for
redressal of complaints of sexual harassment.
Define implications and consequences resulting from violation of this Policy and ensure compliance
with the NAM India Code of Conduct.
Not to tolerate verbal or physical conduct of a sexual nature by any employee, advisor and business
partner that harasses, disrupts, or interferes with any Woman's work performance or that creates an
intimidating, offensive, or hostile environment to them.
Harassment that is unchecked has the potential to hurt the employer's operations through decreased
productivity and increased employee turnover.
Definitions
ACT means the “Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act
2013”.
AGGRIEVED INDIVIDUAL means any individual who alleges to have been subjected to any act of
sexual harassment by an employee of the company.
COMPANY means NAM India.
COMPLAINANT means the Aggrieved Individual or any relative or colleague of the Aggrieved
Individual (if the Aggrieved Individual is unable to make a complaint on account of his/her physical or
mental incapacity or death or otherwise) who makes a complaint alleging sexual harassment under this
Policy.

EMPLOYEE means a person employed at a workplace for any work on permanent, temporary, part time,
ad hoc or daily wage basis, either directly or through an agent, including a contractor, with or without the
knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or
otherwise, whether the terms of employment are express or implied and includes a co-worker, a contract
worker, probationer, trainee, apprentice or called by any other such name.
INTERNAL COMPLAINTS COMMITTEE (ICC) means the committee constituted to discharge the
functions of an Internal Complaints Committee (ICC) as defined under the Act.
MANAGER means any person responsible for the management, supervision and control of the workplace
including the HR Manager, Circle/Plant/Region/Division/Site/Zone Office Head and Head of any business,
entity or function.
RESPONDENT means the person against whom the Complainant has made a complaint.
RULES means the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act,
2013 and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules,
2013.
SEXUAL HARASSMENT includes any one or more of the following unwelcome acts or behavior
(whether directly or by implication) namely:
Physical contacts and advances; or

A demand or request for sexual favors; or
Making sexually colored remarks; or
Showing pornography; or
Any other unwelcome physical, verbal or non-verbal conduct of sexual nature
The following circumstances, amongst other circumstances mentioned above,
may constitute sexual harassment if it occurs or is present in relation to, or
connected with any act or behavior of sexual harassment:
1. Quid Pro Quo (something for something) Harassment

A form of sexual harassment resulting in a situation where an employee is required to choose between
submitting to sexual advances set out above, and losing a tangible benefit, or even the job. This form of
harassment leads to conditioning employment benefits on submission to sexual advances. This may
include:
Direct and/or indirect promise of preferential (special) treatment in employment.
Direct and/or indirect threat of detrimental (harmful/damaging) treatment in employment.
Direct and/or indirect threat about present or future employment status.

2. Hostile Work Environment Harassment:

Employment discrimination consisting of unwelcome verbal or physical conduct that has the effect of
interfering with an Aggrieved Individual's work performance or of creating an intimidating, hostile,
offensive or humiliating environment. This may include:
Creation of conditions and situations that interfere with work or creation of an intimidating
offensive or hostile work environment.
Humiliating treatment likely to affect health and/or safety of the Aggrieved Individual.
WORKPLACE means and includes:

Any department, organization, undertaking, establishment, enterprise, institution, office or branch
unit of the company.
All such places or locations where acts of sexual harassment are committed in the context of working
relationships, or whilst fulfilling professional duties, or which may be visited by the employees during
the course of employment.
Prevention of Sexual Harassment – Preventive Measures

The EPC suggests that the Aggrieved Individual should tell the Respondent that his/her behavior is
unwelcome and ask him/her to stop immediately.
The Aggrieved Individual is advised to keep a record of the incidents (date, time, location, possible
witnesses and details of incident(s) and response of such Aggrieved Individual).
It is not mandatory to have records of the events to file a complaint. However, a record can strengthen the
case.
A complaint should be filed as soon as possible. In the event that, after asking the Respondent to stop
his/her behavior, the harassment continues, the conduct must be reported to the EPC.
Internal Complaints Committee (ICC)

The ICC shall be created at the Company level, and will function as the Internal Complaints Committee (ICC)
as defined under the Sexual Harassment at Workplace (Prevention, Prohibition and Redressal) Act, 2013. It
will be committed to redressal of complaints of sexual harassment, as well as issues related and incidental
thereto.
The Chief Human Resource Officer of the Company will appoint the ICC by nomination of the presiding
officer and other members of the ICC.
Third Party Harassment

Where sexual harassment occurs as a result of an act or omission by any third party or an outsider, the ICC
may carry out an ex-parte investigation. Based on the conclusion of such ex-parte inquiry, the ICC may
recommend internal corrective actions for avoidance of further occurrence of the incidents of sexual
harassment.

Punishment for sexual harassment and for false or malicious complaint and false evidence on completion of
the enquiry, the ICC by way of a written report may:
Dismiss the complaint of sexual harassment as being malicious or false; or

Dismiss the complaint of sexual harassment in cases where the ICC arrives at a conclusion that the
allegations against the Respondent have not been proved; or
Find the complaint of sexual harassment proven and give a finding to that effect.
Where the ICC finds and arrives at a conclusion that the allegations against the Respondent are
substantiated and proved, the ICC shall make recommendations to the management of the
company, which may include:
To take action for sexual harassment as a misconduct and take action as follows: Where the ICC
arrives at a conclusion that the allegations made in the complaint of sexual harassment against the
Respondent are substantiated and proved, the ICC shall recommend to the management of the
company to take disciplinary action, up to and including termination of services of such employee.
Deduct salary or wages of the Respondent in such sum as may be considered appropriate, to be paid to the
Aggrieved Individual as compensation. The recommendation for deduction of salary is not mandatory and
any such deductions may only be made at the discretion of the ICC. While determining the sum to be paid (if
any) to the Aggrieved Individual, the ICC shall be guided by the existing statutory guidelines.
Where the ICC arrives at a conclusion that the complaint against the Respondent is malicious, or the
Aggrieved Individual or Complainant making the complaint has made the complaint knowing it to be false,
or the Aggrieved Individual or Complainant making the complaint has produced any forged or misleading
document, it may recommend to the employer, as the case may be, to take action against such Aggrieved
Individual or Complainant in accordance with the provisions of the employment contract applicable to her
or him, or where no such employment contract exists, in such manner as may be prescribed by the President
and Group Head of Human Resources.
Provided that a mere inability to substantiate a complaint or provide adequate proof should not attract
action against the Complainant.
Amendments & Interpretation

This Policy is subject to modification, amendment and alterations, in part or whole, by the Management
without assigning any reasons or without giving any prior intimation.
This Policy is subject to any law for the time being in force relating to Sexual Harassment at the Workplace.
Singular shall also mean plural and vice versa.
Feminine gender shall also mean masculine gender and vice versa.
Appeal
Any person aggrieved from the recommendation of the inquiry Committee or non-implementation of such
recommendation may prefer an appeal to the court or tribunal in accordance with the services rule within 90
days from the date of recommendation. For this purpose, the CEO may appoint an Appellate Committee.

OMBUDSPERSONS &
WHISTLE BLOWER MECHANISM
Objective
1. Promote a non-threatening environment and a culture of “Speak-up” on matters relating to Code of
Ethics, leak of unpublished price sensitive information or suspected leak of unpublished price
sensitive information, violation of insider trading laws or suspected violation of insider trading laws.
2. ‘Insider Trading Laws’ means the following provisions of securities laws:
Section 15G of Securities and Exchange Board of India Act 1992;
regulation 3 of SEBI (Prohibition of Insider Trading) Regulations 2015;
regulation 4 of SEBI (Prohibition of Insider Trading) Regulations 2015;
regulation 5 of SEBI (Prohibition of Insider Trading) Regulations 2015; and
regulation 9 or regulation 9A of SEBI (Prohibition of Insider Trading) Regulations 2015, in so
far as they pertain to trading or communication of unpublished price sensitive information.
3. Sustain & strengthen our culture of Integrity & Compliance.
4. To provide necessary safeguards for protection of complainants. against any discharge, termination,
demotion, suspension, threats, harassment, directly or indirectly, for whistle blowing in good faith as
we strictly follow No Retaliation, No Harassment and No Victimization Policy.
5 To provide an assurance to external stakeholders that there is internal cordiality and transparency.
Scope
All stakeholders of Nippon Life India Asset Management Limited, Nippon India Mutual Fund &
Portfolio Management Division.
Who is a Complainant?
Any stakeholder making a disclosure under this process is commonly referred to, as a complainant. The
complainant’s role is as a reporting party; he/she is not an investigator. Although the complainant is
not expected to prove the truth of an allegation, the complainant needs to demonstrate to the
Ombudsperson, that there are sufficient grounds for concern and expected to
provide the complete details/evidences in his possession.
Safeguards
Protection Against Retaliation, Harassment and Victimization
Retaliation, Harassment and victimization of the complainant will not be tolerated and could
constitute sufficient grounds for any punitive action including dismissal of the concerned person, who
indulge in such harassment/victimization.
Complainant's identity
Every effort will be made to protect the complainant’s identity, subject to legal constraints.

Complaints
The complaints need to be precise and specific, and the complainant should not indulge in general or
“in general” forms and should always identify the person against whom such allegations are made.
It is desirable that the complainant should approach the Ombudsperson or the CEO in case the complaint
is against the Ombudsperson or the Chairman of the Audit Committee if the complaint is against the CEO.
Who is an Ombudsperson?
The Ombudsperson will be a person, including a full-time senior employee, well respected for
his/her integrity, independence and fairness. She/he would be the authorized person for the purpose
of receiving all complaints under this policy and ensuring appropriate action.
Who do you contact an Ombudsperson?

Code of Ethics, leak of unpublished price sensitive information or suspected leak of unpublished
price sensitive information.
To raise a complaint/concern pertaining to Code of Ethics, leak of unpublished price sensitive
information or suspected leak of unpublished price sensitive information.
To notify if they discover a potential violation of Code of Ethics, leak of unpublished price
sensitive information or suspected leak of unpublished price sensitive information.
In making a report of a violation of the Code of Ethics, leak of unpublished price sensitive information or
suspected leak of unpublished price sensitive information, the complainant should exercise due & utmost
care to provide as much details on the concern/complaint & ensure the accuracy of the information.
In case the complaints received do not pertain to matters related to Code of Ethics, leak of unpublished
price sensitive information or suspected leak of unpublished price sensitive information, then the same
should be forwarded to the appropriate authorities for disposal.
Annexure I provide the necessary contact details.
Confidentiality
On receipt of complaint, the ombudsperson must not forward the mail or share it with any other
person.
Ombudsperson must carry out the investigation either directly or, through engaging services of
other official's assistance, maintaining utmost confidentiality.
Investigation
All complaints received, will be recorded and looked into. If initial enquiries by the Ombudsperson
indicate that the concern/complaint has no basis, or it is not a matter to be pursued under this process, it
may be dismissed at this stage and the decision documented. Where initial enquiries indicate that further
investigation is necessary, this will be carried through, either by the Ombudsperson alone, or by a
Committee nominated by the Ombudsperson for this purpose. The investigation would be conducted in a
fair manner, as a neutral fact-finding process and without presumption of guilt. A written report of the
findings would be made.

Investigation Result
Based on a thorough examination of the findings, the committee (or Ombudsperson) would recommend
an appropriate course of action to the ED & CEO. Where an improper practice is proved, this would cover
suggested disciplinary action, including dismissal, if applicable, as well as preventive measures for the
future. All discussions would be minuted and the final report will be prepared.
In case of any complaints against the Ombudspersons, the same would be reviewed and acted upon by
the ED & CEO & if the complaint is against the ED & CEO, the same would be reviewed by the Chairman of
the Audit Committe.
Information relating to such complaints, inquiries and results of such inquiries shall be provided to the
Board.
Communication to Complainant
The complainant will receive acknowledgement on receipt of the concern.
The amount of contact between the complainant and the body investigating the concern will depend
on the nature of the issue and the clarity of the information provided. Further information may be
sought from him/her.
Subject to legal constraints, she/he will receive information about the outcome of any investigations..
Changes to process
This process can be changed, modified, rescinded or abrogated at any time, by Nippon Life India Asset
Management Limited.
Responsibilities of Complainant
Bring to early attention of the company any improper practice they become aware of. Although they
are not required to provide proof, they must have sufficient cause for concern.
Co-operate with investigating authorities, maintaining full confidentiality.
The intent of the policy is to bring genuine and serious issues to the fore.
A complainant has the right to protection from retaliation, harassment and victimization.
Maintain strict confidentiality.
In making a report of a violation of the Code of Ethics, leak of unpublished price sensitive information
or suspected leak of unpublished price sensitive information, the complainant should exercise
utmost care to provide as much detail on the concern/complaint and ensure the accuracy of the
information.
Be objective while making complaints and allegations.
Responsibilities of Ombudspersons
An Ombudsperson is expected to manage the sensitivities of the person seeking clarifications or
reporting a concern. Nippon Life India Asset Management Limited follows a "No Retaliation, No
Harassment and No Victimization Policy" on matters relating to the Code of Ethics, leak of
unpublished price sensitive information or suspected leak of unpublished price sensitive information,
violation of insider trading laws or suspected violation of insider trading laws, which means that the
company will make sure that the complainant will not be discharged, terminated, demoted,

suspended, threatened, harassed, directly or indirectly just because he voices a concern or reports a
violation.
Promote the “speak up” culture
Execute the job of the ombudsperson diligently in a manner which shall uphold the spirit of the
process.
Ensure that necessary safeguards are provided to the complainant.
Ascertain prima facie the credibility of the charge. If initial enquiry indicates further investigation is
not required, close the issue.
Where further investigation is indicated carry this through, appointing a Committee if necessary.
Ensure the complaints recorded are actioned upon within reasonable time frame.
Conduct the enquiry in a fair, unbiased manner.
Ensure complete fact-finding.
Maintain strict confidentiality.
Decide on the outcome of the investigation, whether an improper practice has been
committed and if so by whom.
Recommend an appropriate course of action suggested disciplinary action, including
dismissal, and preventive measures.
Minute Committee deliberations and document the final report.
Appeal
If the complainant is dissatisfied with the outcome of the investigation and the judgement of the
Ombudsperson she/he can appeal to the Chief Executive Officer (CEO).
The decision of the CEO/Chairman of the Audit Committee will be final and binding.
(Refer Annexure II for details)
Maintenance of logs / Documentation

Log of all cases will be maintained by the Ombudsperson.
The Ombudsperson shall be responsible for keeping the record of all Reports and complaints and the
investigation reports for a period of 2 years.

ANNEXURE I - OMBUDSPERSON NETWORK

Mutual Fund (Asset Management)
MR. MUNEESH SUD MR. SUNDEEP SIKKA
Chief Legal and Compliance Officer Executive Director & CEO
022 - 6808 7229 / 9320980341 022 - 6808 7110
muneesh.sud@nipponindiaim.com sundeep.sikka@nipponindiaim.com
MS. ASHVIN PAREKH

Chairman of Audit Committee.
022 - 4303 1000
ashvin_parekh@AP-AS.com
ANNEXURE II
Appeal Process
Any appeal against awards, in cases involving/relating to Ombudspersons, or CEO, would be heard by
the Chairman of the Audit Committee as may be formed whenever required.
Time Limit of Filing of Appeal

Every appeal must be filed within “30 days from the date of communication of the ombudsperson's
decision.”
If the CEO / Chairman of the Audit Committee is satisfied that the appellant was prevented by
sufficient cause from filing the appeal, the appeal may be admitted after 30 days also.
Commencing the Appeal

An aggrieved person may seek the right to appeal to the CEO / Chairman of the Audit Committee
against the decision of the Ombudspersons or any penalty imposed by them.
Where an aggrieved person is pursuing the Appeals procedure, any penalty imposed by the
Ombudspersons shall not immediately take effect. However, the CEO/Chairman of the Audit
Committee shall have the authority to temporarily suspend, or exclude such person in the interests of
. the Organization.
Disposal of Appeal
The appeal should be disposed off within 30 days of receipt of the appeal. In exception cases, the
Appellate Authority may take 45 days for its disposal.
Appeals only against the decision of the Ombudspersons are maintainable before the CEO, no other
appeal / direct complaint shall be entertained.
The decision of the CEO / Chairman of the Audit Committee shall be final and binding.

Matters to be referred to the Chairman of the Audit Committee

The primary function of the Chairman of the Audit Committee is the disposal of appeals against the
decision of the CEO or against the CEO, through a formal process of screening of complaints and
conducting enquiries.
The aim of the committee is to address appeals in order to safeguard and expand the culture of
“speak up” in the company.
The Chairman of the Audit Committee shall accept for review only those cases where the aggrieved
person can:
Present new or additional evidence; and/or
Present additional information about her/his personal circumstances; and/or
Present evidence of procedural irregularity; and/or
Demonstrate that a penalty imposed is disproportionate to the breach; and/or
Demonstrate that a restitutional financial penalty is based on an inaccurate valuation.
The Chairman of the Audit Committee shall be entitled to question the aggrieved person on the
content of the statement or any documents presented before them.
If the aggrieved person fails to make an appearance without just cause at a meeting called by the
Chairman of the Audit Committee, the members may, at their discretion, dismiss the request for an
appeal or they may deal with the case.

DRESS CODE POLICY

The way in which NAM India employees dress and present themselves, plays an important part in the
image that NAM India portrays to its clients, business associates, etc.
The policy is not exhaustive in defining acceptable and unacceptable standards of dress and appearance,
and employees should use their common understanding and discretion in adhering to the principles
underpinning the policy.
The Company allows employees in non-client facing roles to wear Business Casuals on all working days.
Those in client or customer facing roles must be dressed in Business Formals.
Following is an indicative list of acceptable and unacceptable attire
MEN
Acceptable Attire
Business Formals – Formal Shirts, Trousers, Leather Shoes
Business Casuals – Denims, Corduroys, Chinos, Casual Shirts, T-shirts, Smart casual shoes, Sneakers, or
any other closed shoes
Others - Head Covers that are required for religious purposes or to honor cultural tradition
Unacceptable Attire
Low waist, torn, distressed or shredded jeans,
T-shirts that are body-fit, sleeveless, or with printed slogans, messages and graphics that are loud or
offensive.
Bermudas, shorts, three-fourth capris, track pants or any sportswear
Any transparent or revealing clothes
Hats, caps and any kind of fancy head gear
Slippers, Floaters, Open Shoes, etc.
WOMEN
Acceptable Attire
Business Formals – Formal Shirts, Trousers, Knee length skirt, Indian attire like sarees and
salwar/churidaar kurtas
Business Casuals – Denims, Corduroys, Chinos, Palazzos, Casual Shirts, T-shirts, Smart Casual Shoes,
Sneakers, Heels, Sandals, Flats or Bellies.
Others - Jewelry, make-up, perfume and cologne. Head Covers that are required for religious
purposes or to honor cultural tradition.

Unacceptable Attire
Low waist, torn, distressed or shredder jeans,
Backless blouse, tops, Dresses that are made of lyra or hosiery material
Noodle straps, spaghetti tops, tube tops
Tops with printed slogans, messages and graphics that are loud or offensive
Bermuda, shorts, three-fourth capris, track pants or any sportswear
Any transparent or revealing clothes
Hats, caps and any kind of fancy head gear
Slippers or Floaters
Please remember that we portray our organization's image through what we wear to work. Let's ensure
that we display the highest standards of professionalism on behalf of the company.
VIOLATION OF THE POLICY

Violation of provisions in this document will be treated as breach of the Company's Code of Conduct. The
HR team is authorized to refuse admission to an employee found violating the policy. Repeated violation
may call upon the management to take strict action to be taken against the employee

INFORMATION SECURITY POLICY

The objective of this Policy is to make users aware of their security responsibilities, in order to ensure
security of the information and information resources they interact with. This Policy documents the
responsibilities of the employees of NAM India and its businesses which are users of information
resources. Compliance with this Policy is essential in creating an environment that is conducive to sound
information security practices. This Policy applies to all the users, including NAM India employees and the
employees of temporary employment agencies, vendors, business partners and contractor personnel
they manage.
1. Usage of NAM India Information Systems

a. Users are only authorized to utilize NAM India information resources for the business purposes for
which they have been authorized.
b. Users must avoid accessing areas on the company networks for which they do not have a valid
business need.
c. Usage of NAM India information systems to store, process, download or transmit data that can be
construed as biased (politically, religiously, racially, ethnically, etc.) or supportive of harassment is
strictly prohibited.
d. Downloading, redistribution and printing of copyrighted articles, documents or other copyrighted
materials to NAM India information systems are strictly prohibited.
e. Receiving, printing, transmitting or otherwise disseminating proprietary data, company secrets or
other confidential information in violation of company policy or proprietary agreements is strictly
prohibited.
f. Downloading inappropriate material such as picture files, music files or video files for personal use is
strictly prohibited.
g. Users should terminate active sessions when finished, unless they can be secured by an appropriate
locking mechanism, e.g. a password protected screen saver.
h. Users are prohibited from changing the configuration of, removing, de-activating or otherwise
tampering with any Virus and Malicious Software and software that has been installed on systems
used by them.
I. Users must follow a clear desk policy for papers or information assets, and a clear screen policy for
information processing facilities in order to reduce the risks of unauthorized access, loss of, and
damage to information during and outside normal working hours.
j. NAM India's resources must not be used for commercial or personal use. Resources include but are
not restricted to faxes, telephones, printers, scanners, EPABX, copiers, hardcopy, or electronic media.
2. Introduction of unauthorized copies of Licensed Software

& Hardware
a. Introduction of unauthorized copies of licensed software and hardware (piracy/copyright and patent
infringement) to NAM India information resources and the copying of such material is prohibited.

b. The storage, processing or transmission of unauthorized copies of licensed software and hardware
(piracy/copyright and patent infringement) by NAM India personnel associates is strictly prohibited.
3. Introduction of Open-source, Freeware and Shareware

Applications
a. Introduction of open-source, freeware and shareware applications whether downloaded from the
Internet or obtained through any other media to NAM India information systems will be subject to a
formal evaluation and approval process.
b. Open-source, freeware and shareware applications should be evaluated and tested by the CISO (Chief
Information Security Officer) and System Administrators before installation on NAM India
information resources. They must verify the legal implications of using the same in NAM India
information systems.
Open-source systems shall be used for monitoring and reviewing any production systems after
c.
evaluation and approval of the same by the CISO.
4. Introduction of Pornographic Material

Introduction of pornographic material into any NAM India information systems environment is strictly
prohibited. The storage, viewing, processing or transmission of pornographic material on NAM India
information systems by NAM India employees, contractors or associates is strictly prohibited.
5. Due Diligence
Introduction of pornographic material into any NAM India information systems environment is strictly
prohibited. The storage, viewing, processing or transmission of pornographic material on NAM India
information systems by NAM India employees, contractors or associates is strictly prohibited.
a. Unauthorized access to network, telecommunications or computer systems;
b. The apparent presence of a virus/malwares on a PC;
c. The apparent presence of any information resource prohibited by this policy;
d. Apparent tampering with any file for which the user established restrictive discretionary access
controls; and
e. Violation of this Policy or any other Information Security Policy or procedure by another user,
employee, contractor or third-party service provider.
Each user has the responsibility to prevent unauthorized access, installation of unlicensed/open source
softwares, notifying suspicious events on the system and violation of Information security policies of
NAM India.
6. Computer Games
Playing computer games in NAM India premises is prohibited. Users should not install any computer
games in NAM India information resources.

7. Introduction of Destructive Programmes

Introduction of destructive programmes (e.g., viruses, self-replicating code) in order to cause intentional
damage, interfere with others, gain unauthorized access or inhibit production to NAM India's information
systems, is strictly prohibited.
8. External Services
a. All users should limit their usage of external services (e.g., bulletin board, online service provider,
Internet site and commercial database) to authorized business purposes only.
b. All users should further comply with the policies, standards and procedures of the external service
(e.g., bulletin board, online service provider, Internet site and commercial database) that they are
using.
9. Reporting Incidents
a. Incident is defined as the occurrence of any exceptional situation that could compromise the
confidentiality, integrity or availability of information and information systems of NAM India. It is
related to exceptional situations or a situation that warrants intervention of senior management,
which has the potential to cause injury or significant property damage. Violations of NAM India's
security policies and procedures shall also be considered an incident.
b. If any user comes across any exceptional situation as mentioned above, he/she should immediately
inform the Chief Information Security Officer (CISO). Any exceptions against the information security
policy shall be approved by CISO.
c. Users should not try and test the weaknesses, since it might be interpreted as misuse of the system.
10. Password Use

Passwords provide a means of validating a user's identity and thus, to establish access rights to
information processing facilities or services. All users should:
a. Keep their passwords confidential;
b. Avoid keeping a paper record of passwords, unless this can be stored securely;
c. Change passwords whenever there is any indication of possible system or password compromise;
d. Select quality passwords with a minimum length of 8 characters, which are difficult to guess and are
complex by nature (contains at least alphabets upper and lower case, numeric value and one special
character);
e. Change passwords at regular intervals;
f. Do not include passwords in any automated log-on process, e.g. stored in a macro or function key;
g. Do not share individual user IDs/passwords;
h. Five successive login failures will result in a user's account being locked; they should not be able to
login until their account is unlocked and the password reset. The user should contact the System
Engineers/Administrators for getting the account unlocked or use ServiceDesk portal .
Refer Password Management in the Information Security Policy for more details.

11. Virus Protection

a. Users should not open any files attached to an email from an unknown, suspicious or untrustworthy
source.
b. Users should not open attachments that are from an unknown or non-trusted source.
c. Users should not open any files attached to an email whose subject line is questionable or
unexpected. If there is a need to do so, they should always save the file to the hard drive before doing
so.
d. Users should delete chain/junk emails and not forward or reply to any of the chain/junk mails. These
types of email are considered Spam, which is unsolicited, intrusive and clogs up the network.
e. Users should exercise caution when downloading files from the Internet and should download only
from a legitimate and reputable source. Verify that an anti-virus program checks the files on the
download site. If you are uncertain, don't download the file at all or download the file to a floppy and
test it with your own anti-virus software.
f. Users should back up their files on a regular basis.
g. When in doubt, always err on the side of caution and do not open, download or execute any files or
email attachments.
12. E-Mail
a. Each employee is responsible for the contents of his/her e-mail and all actions performed using
his/her e-mail login credentials.
b. E-mail should be used only for business purposes. Personal or non-business use of the systems is not
permitted.
c. Users should use only their own NAM India e-mail account and should not allow anyone else to access
their account.
d. Users should not provide other unauthorized persons with their e-mail ID and password.
e. Users should not send confidential or restrictive information via e-mail, unless the information is
encrypted using approved encryption techniques.
f. E-mail should not be used to transmit or receive statements that contain any material that is offensive,
defamatory or threatening to others.
g. Employees may either communicate with the originator of offensive e-mails, asking him/her to stop
sending such messages, or report such offensive e-mails directly to the CISO.
h. Users who cannot access their e-mail for long periods (due to vacation, outstation work, etc.) should
use the "Out of Office" feature in NAM India's email system to make the sender aware that the
recipient is out of office.
i. Users must not employ a scanned version of a hand-rendered signature to give the impression that the
sender signed an e-mail message or other electronic communications, as another person could misuse
the signature.
j. Users should not send unsolicited bulk mail messages (also known as "junk mail" or "spam").
k. At any time, with or without notice, this information may be monitored, searched, reviewed, disclosed
or intercepted by NAM India for any legitimate purpose.

13. Physical Security

a. Users should not enter NAM India without ID badges and they should always display their ID badges
within NAM India.
b. Users should not take in or out any equipment from NAM India, without authorization.
c. Users should adhere to all physical security standards to be followed in NAM India.
14. Handling Confidential Information

a. Confidential/restricted information transmitted over any communication network should be sent in
an encrypted form.
b. Confidential information not being actively used, when stored or transported in computer-readable
storage media (such as magnetic tapes, floppy disks or CDs), should be in encrypted form.
c. To prevent unauthorized disclosure of data when computers are sent out for repair or used by others
within or outside NAM India, and data cannot be deleted, all data stored on hard disks should be
encrypted via user-transparent processes.
d. Confidential/Restricted data should not be shared through public mailing sites (Hotmail, Gmail, etc.)
or on file sharing zones hosted on the Internet.
e. Data being shared with third parties (vendors, auditors, etc.) should be secured with encryption.
15. Use of Office Equipment

Telephone
a. The staff should not reveal sensitive or classified information over the telephone unless the
telephone lines have been specifically secured for this purpose – for example, through the use of
encryption.
b. The staff should not enter into the conversation or reveal any information over the telephone where
the identity of the caller cannot be determined.
c. Staff should not discuss confidential matters or reveal confidential/classified information in public
places and/or outside NAM India premises.
Fax Machines
a. Sensitive or confidential information should be faxed only, when a more secure means of
communication is not available.
b. Users who are responsible for receiving confidential fax messages should co-ordinate with the
sender to ensure that they are present at the fax machine at the time of delivery.
Modem
a. Modems should not be attached to workstations without authorization from the Information Security
Team.
b. Laptop users should not connect to the public domain using the internal modems in laptops and be
connected to the NAM India network at the same time. The internal network connectivity has to be
disconnected before the modem is enabled.
c. No data transfer should take place by way of a modem when connected to NAM India networks.

Desktops and Laptops

a. Confidential data should not be stored on laptops or desktops. In events where confidential or
restricted data needs to be stored on laptops, the data on the laptop hard disks should be kept
encrypted using at least 128 bit encryption application. All confidential data being copied to
removable media should be encrypted.
b. Laptops should not be left unattended.
c. The folders or disk drives in individual PCs or laptops should not be shared unless authorized.
d. Use of CDs, DVDs, USB drives, floppies and other removable media on laptops and desktops should be
disallowed by default and enabled only on authorization from the CISO.
e. The virus definition files on all desktops and laptops should be kept updated.
f. Users will need to return the desktop/laptop and all related IT accessories to the IT or HR department
only after their release/leaving the organization and should not hand it over to anyone else within the
department/organization.
g. All data on desktops or laptops should be erased in the event of change of desktop or laptop
custodian, unless authorized by the Head of Department.
16. Internet User Code of Conduct

Internet "inappropriate" use
The use or attempt to initiate such activities using NAM India's computing facilities or equipment leading
to abusive, unethical or "inappropriate" use of the Internet is considered grounds for disciplinary, legal
and/or punitive action, including termination of employment. Detailed examples of prohibited Internet
use are available in the Information Security Policy.
Implied restrictions on Internet

Users using NAM India's computers on discovering that they have connected with a web site that contains
potentially offensive material should immediately disconnect from that site.
a. Users should be aware that NAM India accepts no liability for the exposure to offensive material that
they may access via the Internet.
b. The ability to connect with a specific web site does not in itself imply that users of NAM India's systems
are permitted to visit that site.
17. Management Review

At any time and without prior notice, NAM India's management reserves the right to examine electronic
mail messages and, files on personal computers, web browser cache files, web browser bookmarks and
other information stored on or passing through the company's computers. All transactions done over the
Internet will be logged. These logged transactions will be used for analysis and can be audited.
18. Restrictions on posting NAM India's material

a. Users should not place the company's information or material (software, internal memos, data files,
etc.) on any publicly accessible Internet computer, which supports anonymous FTP or similar

services, unless the Head – IT/CTO has first approved the posting of these materials.
b. Your Internet postings (Facebook, YouTube, Orkut, blogs, wikis, etc.) should not disclose any
information that is confidential or proprietary to the company or to any third party that has disclosed
information to NAM India.
Reporting of violation
All users shall adhere to their security responsibilities as outlined in this document and IT Security policies
and procedures. They are expected to make themselves familiar with the policies, procedures, standards
and guidelines that are applicable to them. All violations of any policy shall be reported to the CISO. He
shall classify the violation, coordinate with appropriate personnel and take necessary action on the
concerned person.
Violation Classification
Violations shall be categorized into three levels:
High Severity: The security violations that can compromise the security of critical IT/non-IT equipment or
confidential information assets or, to the extent that they can cause devastating impact to the operations
of the organization, are classified as High Severity violations.
Medium Severity: The security violations that can compromise the security of critical IT/non-IT equipment
or restricted information assets or, to the extent that they can cause significant impact to the operations
of the organization, are classified as Medium Severity violations.
Low Severity: The security violations that can compromise the security of non-critical IT/non-IT equipment
or internal information assets or, to the extent that they can cause nuisance impact to the operations of
the organization, are classified as Low Severity violations.
20. Disciplinary Action

A staggered approach shall be followed in taking disciplinary action against the employee on compliance.
Employees may initially be let off with a lighter penalty (e.g., a reprimand) till the security culture is
established in NAM India. Implementation may thus be done in the following three steps:
a. Step 1 (1st 6 months): Counseling
b. Step 2 (Next 3 months): Verbal Reprimand & Written Memo
c. Step 3 (Subsequently): Any of the punitive actions mentioned below
Punitive actions will be laid down for each category of the violation. The punitive action may be decided on
a case-to-case basis depending on the impact of the violation on the information systems resources of
NAM India. A few possible punitive actions for each level of violation are listed below:
Severity Category Possible Punitive Action
High Suspension of Service/Termination of

Employment/Cancellation of Contract
Medium Severe Reprimand/Suspension of Service
Low Reprimand

The high and medium severity violations may directly result in the execution of Step 3, bypassing Steps 1
and 2. Categories of violations and their associated severity have been detailed in the "Punitive action for
violation of policy”.
21. Execution Responsibility

Employees of NAM India who use information resources are responsible for implementing the policies
and guidelines mentioned in this document.
The Information Security Policy and procedures are available in detail at the Information Security web site
http://intranet.NAM Indiacapital.co.in:8080
All users are encouraged to read the Policy and ensure adherence during their tenure in NAM India.

SOCIAL MEDIA POLICY

Being a part of the financial services Industry, NAM India, Its subsidiaries and affiliates have to maintain
public image by upholding brand values and acting as guarding to all confidential data pertaining to its
customers and stakeholders.
The Company and its employees have a responsibility towards these stakeholders and are committed to
act in a manner that does not cause any loss to our stakeholders and customers; not make any statements
that violate regulatory or judicial laws; not participate or make any comment in a way that damages the
brand image of NAM India or any other Nippon Life group companies.
With the evolution of Social Media, the way employees of organizations communicate internally,
externally as well as online is evolving. Social Media is fast becoming an important part of overall
communication across companies around the world. While this medium is opening up new avenues of
engagement and interactions, it is also creating larger responsibilities for all involved
Also, with the distinction between offline and online medium diminishing fast – whatever trends
sometimes gets reported and whatever gets reported sometime trends on social media – it is becoming
increasingly important to understand the nuances of comments made on social media.
With a view to embrace this new medium and use to its full potential, it is important that the employees
adhere to some basic framework of rules and conduct, both in their professional and personal sphere,
which will help in creating a positive impact on the reputation of the Company
Need for Social Media guidelines

Given the speed, reach and scope of the Social Media platforms, and the “permanency” of all statements
made on social media, it is important for any organization to form a basic set of rules to monitor its “Digital
Personality” - presence, engagement and messaging on social media – with regards to their stakeholders
and regulators.
With general awareness of social media growing exponentially and regulators also keeping a watch on
the content posted by Companies online, employees need to be aware of the following risk that are
getting associated with communication on social media:
Data Leaks Privacy breaches
Cyber security breach Reputational damage
Violation of Regulatory norms
Some of these risks may lead to financial and other penalties causing a dent to the brand image and
perception.
Definition of Social Media

Social Media has been broadly defined to refer to 'the many relatively inexpensive and widely accessible
electronic tools that enable anyone to publish and access information, collaborate on a common effort, or
build relationships.

Online platforms and applications on the internet that allow users to interact with each other by sharing
information, pictures, opinions, knowledge and interests – all form part of this Social Media policy
including building of communities/networks, participation and engagement on internet.
Facebook, YouTube, LinkedIn, Google+, Twitter, Instagram, Whatsapp etc. discussion forums like Yahoo!
and Google Banks, web logs and sites where information can be posted freely such as Wikipedia are all a
few examples of Social Media.
For the purpose of this policy we would also like to include online mediums – like websites - and comments
made thereof as part of Social Media.
All employees of NAM India, its subsidiaries and Associates, will be covered by this policy.
Social Media Guidelines for Employees

NAM India encourages its employees to have a social presence on their chosen platforms.
As a Company, we respect our employee's personal space and their freedom to express opinions.
After all, as a young organization, which is part of a young country, we truly believe that every opinion
counts.
We are also well aware that in online social networks, the lines between public and private, personal and
professional are blurred.
Just by identifying yourself as an NAM India employee, one creates a perception about one's expertise,
and about the Company, to our shareholders, customers, and the general public. Over time, this evolves
into Digital Personality which also has a rub-off on the Brand's image and perception.
The purpose of this policy is to evolve a broader framework that will help our employees work
constructively towards creating greater value for our stakeholders on Social media platforms, while
safeguarding their freedom of expression and speech.
In order to help our employees be our greatest brand ambassadors, we are suggesting some basic best-
case rules for social media presence. These rules are applicable to all personal handles/pages/presence
on social media platforms.
Personal Presentation
Identify yourself :
Employees should create their profile on social media and online channels in their true self /real
name and must not create any fake profiles. Be clear of who you are and while expressing personal or
private views or opinions, avoid any attribution to NAM India, or its Executives.
However, do identify NAM India as your employer on LinkedIn.
Speak in the first person and Use a disclaimer: Whether employees publish or use any form
of social media. they must do it in first person. While expressing anything on a social media platform it
should be made clear that what you say represents your views and not of the Company
or Group or its Executives.

Opinions personal: “The postings on the site are my own/personal views and are not of my
employer, who will not be liable for any action that may result as a consequence of my views and
opinions”. This disclaimer is mandatory at all places wherein NAM India name is mentioned in the
profile/employment record. ((It is not convenient to write a long sentences on some platforms. In such
a case,’views personal’ could be conveyed in a shorter format).
Respect your audience: Employees should avoid using any objectionable language, avoid
making remarks that can be construed as personal insults or obscenity in any communication. Show
consideration for privacy of co-workers and of customers and clients, and avoid views and opinions
that may be considered objectionable or inflammatory.
Provide worthwhile information and perspective: Nippon Life brand is best represented
by its people, and what you publish may reflect on Nippon Life as a brand. Employees should avoid
making any false, misleading or defamatory statements concerning the Company, Group or its
Executives in their posts/tweets/updates/opinions.
Information Sharing
Protect confidential and proprietary information: Any information, data or other
proprietary materials that can be used to cause loss of business, opportunity or brand image and
acquired in course of business interactions with reference to any client, business partners or other
organizations, will be treated as confidential information. Such information should not be disclosed
or revealed to any outsider in any manner.
Protect clients, business partners and suppliers: Any confidential information regarding
any clients, partners or suppliers should not be quoted, referred or disclosed on Social Media.
Employees should ensure that they do not disparage NAM India/Nippon Life/Executives, competitors
and all other stakeholders including customers/potential customers/agents/vendors/etc.
Respect intellectual property rights: As a company and Group, we respect the intellectual
property rights and right to privacy of all persons. We expect the employees to do the same and avoid
any transgression of any other persons' rights.
Do not share the information available on the internal network: Just because
information is on the internal network, it may not be for external use and should not be made public. If
an item features the sentence "for internal use only", then it is absolutely not meant for anyone who is
not employed by Nippon Life.
Best Practices
Be an ambassador of NAM India on social media: Regularly like, share &/or retweet
content posted on company handles.
Follow the company’s Code of Conduct: Our company's core values are trust and
responsibility, in all dealings as a company, NAM India expects its employees to exercise personal
responsibility to build trust whenever they participate in any form of Social Media.

Summary of Dos and Don'ts for employees – Best Practices

Do's
Clearly state that views are personal and do not represent the employee's/company's.
It is advisable to use real names on social media profiles.
Create your profile in personal capacity and be thoughtful and responsible while carrying out any
social media activity.
Ensure that all individuals/employees are sensitized not to spread rumors or share any speculative
news about listed companies.
Be aware of the NAM India's Code of Conduct and Business Ethics. Any violation by your colleagues,
subordinates and/or any other employee/individual should be brought in notice of the Corporate
Communications/HR.
Be a Brand Ambassador of the company and regularly like, share &/or retweet content posted on
company’s social handle.
Don'ts
Do not participate online anonymously using fictitious profiles.
Avoid making any false, derogatory or misleading statements concerning your work or the
organization.
Avoid public debate on sensitive issues.
Avoid breach/infringement of any other person's rights.
Do not use objectionable language, personal insults or obscenity in any communication.
Do not cite any information related to clients or projects.
Do not share any official reports on public sites and avoid exchanging such information through
personal mail IDs, text messages and on social media.
Avoid discussions about stock movement of the company on social media. Do not send or forward
emails, blogs or text messages etc. with unauthenticated information received from others about
listed scrips.
Do not accept any invitation from any outside entity to interact or to contribute any article for
publication on any aspect relating to our business/strategy, without prior permission from the Chief
Communications Officer.
Don't respond to queries on messaging services/chats. All media queries would be responded to, in
accordance to the Media Policy available on the intranet.
Guidelines for handling Social Media Profiles of official handles of NAM India and
Group Companies
Only designated personnel – approved by the CEO of each business – would be allowed make/
upload/tweet approved comments from official handles.
All communication/tweets/updates etc. through official handles will be restricted to customer centric
initiatives and business-related updates only and duly approved by the CEO.
All company sponsored/affiliated/campaigns participation – with regards to marketing – needs to be

approved by the CEO.
All other posts, including for publication/communication, need to be approved by the designated
Corporate Communication team and CEO of the respective company.

Be thoughtful: If you're about to publish something that makes you even the slightest bit
uncomfortable, please refer to these guidelines. If you're still unsure, you might want to discuss it
with your manager, legal or Corporate Communications team. Ultimately, what you publish is your
opinion and responsibility.
Avoid using official email id for personal use: Don't use you're the NAM India email for
personal affairs. Use official email for work related purpose only. Avoid using your NAM India email
address on your personal blog or when posting on social network sites.
Do not comment on legal matters: Please avoid saying anything related to legal matters,
litigation, or any parties (Companies) that the Company may be in litigation with.
Speculating on Rumors: Refrain from speculating on anything that NAM India / Nippon Life has
not officially announced, even if anyone insists you for a personal opinion. Information leaks can
potentially damage interests of the Nippon Life, and NAM India has zero tolerance for those who leak
information.
Do not participate in Social Media in crisis situations: Never participate in any discussions
or comment on social media when the topic being discussed may be considered a crisis situation. Even
anonymous comments may be traced back to your or the company's IP address. Refer all Social Media
activity around crisis topics to the CEO, Corporate Communications and / or the Legal team.
Avoid Political Comments: As individuals, we are free to express views on political issues and
chosen religious beliefs. However, Employees should express these views as individuals only, and not
on behalf of the company or Group. As a policy, the Company or the Group does not make any
comments in this regard.
Complement the organizational effort: As stated earlier, we encourage Employees to use

this powerful medium of Social Media to business advantage and amplify the organizational effort of
reaching out to a larger audience. However, Employees should ensure that such engagement does not
interfere or hamper their job or organizational commitments.
Additionally, employees of the company are not supposed to express their personal grievances in public,
especially when the company has provided for adequate internal grievance mechanisms. Be sure that all
content associated with you is consistent with your work, with NAM India values and highest professional
standards.
Breach of SM Guidelines
Any violation of these guidelines may result in disciplinary action in accordance with the employee code
of conduct and business ethics or as per applicable laws.

In all cases, Copyright regulations have to be adhered to and due credit given to content owners.
The designated officials responsible for interacting on behalf

of the company must:
Be knowledgeable of various legal terms, and what they mean in your business environment, such as
defamation, endorsements, intellectual property, and any form of wrongful disclosure.
Be aware of global implications of your online communication.
Avoid inappropriate comments about competitors, government, regulators or others online.
Should cultivate relationships and build communities on your social media profiles.
Should not post anything political, controversial and pertaining to any legal matters.
Should route any crisis communication to the designated Public relations officer with a CC to the CEO
of the company for advice.
We believe that this policy will serve as a broad framework that will help all of us maximize the use of
Social and Online media for our collective advantage and help the business gain from this powerful
medium going forward.

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EMPLOYEE POLICY HANDBOOK - 2021

Employee Policy Handbook 2021 02

We are dedicated and committed to provide a great workplace that is inclusive

Looking forward to an exciting journey together!

Employee Policy Handbook 2021 03

This handbook is an initiative to reach out to our employees spread across

We take pride in being an organization that listens and constantly evolves

Employee Policy Handbook 2021 04

All policies mentioned in this handbook

Employee Policy Handbook 2021 05

Total Rewards Policy I

Career & Opportunities I

Employee Policy Handbook 2021 06

Employee Policy Handbook 2021 07

Employee Policy Handbook 2021 08

Employee Policy Handbook 2021 09

OUR LENDERS AND OTHER INVESTORS

OUR SUPPLIERS AND OTHER SERVICE PROVIDERS

Employee Policy Handbook 2021 10

POLICY ON CONFLICT OF INTERESTS

What is the essence of this code on conﬂict of interest?

Employee Policy Handbook 2021 11

What should employees do to avoid a conﬂict of interest?

What actions are to be avoided by the employees at all times?

Employee Policy Handbook 2021 12

Employee Policy Handbook 2021 13

What are the exceptions to the above policy?

Employee Policy Handbook 2021 14

POLICY ON PAYMENTS AND GIFTING

What business courtesies can NAM India employees accept?

Is usually associated with customary business practices.

Employee Policy Handbook 2021 15

What gifts or business courtesies should NAM India

Asking for a business courtesy.

Accepting a business courtesy when:

An attempt is being made by the donor to oﬀer the courtesy in exchange

An attempt is being made to motivate an employee to do anything that is

An attempt is being made to gain an unfair competitive advantage by improperly

Accepting a gift in cash or cash equivalents of any amount.

What should a NAM India employee do when the business

Employee Policy Handbook 2021 16

What actions should be taken in case gifts have been

Retain the courtesy for displaying with prior approval.

POLICY ON PURCHASES THROUGH

What are the general principles of the purchase policy?

Employee Policy Handbook 2021 17

What actions should be avoided by NAM India employees

What additional responsibilities are levied on NAM India

What are the responsibilities that are levied on the

Employee Policy Handbook 2021 18

POLICY REGARDING FULL-TIME CONSULTANTS,

POLICY ON FINANCIAL AND

What is expected of employees?

Employee Policy Handbook 2021 19

What actions on the part of employees are considered

What is the speciﬁc policy to ensure ﬁnancial and

There shall be no intentional concealment, misdirection, misleading statements, falsiﬁcation of documents

Employee Policy Handbook 2021 20

POLICY ON FAIR MARKET PRACTICES

What actions should NAM India employees refrain from