ENVIRONMENT,

HEALTH
AND SAFETY
E.H.S POLICY MANUAL
© COPYRIGHTS 2023 ECLERX
Agenda

Environment, Health EHS Policies and Environment or Prevention from

and Safety (EHS) Objectives Practices Green Practices Accidents
Policy

Control points Employee Well Being, Contact Operational objectives

and precautionary Morale and Information and allocation of
measures during Satisfaction responsibilities
pandemic

CONFIDENTIAL 2
Environment, Health and Safety (EHS) Policy

eClerx Services Ltd. is committed
to achieving high standards of
occupational health and safety
throughout the organization and
become an environmentally
responsible organization.
The Company aims to achieve
constant improvement by taking all
reasonably practical steps to prevent,
control or guard against health and
safety related risks and the resulting
likely effects and consequences.
The company recognizes its joint responsibility with
the Government, NGOs, private agencies and the
Public to protect the environment and is committed
to regulate all its activities so as to follow best
practicable means for minimizing adverse
environmental impact arising out of its operations.

eClerx will endeavor to ensure that all employees
receive appropriate health and safety training. eClerx
aims to ensure that the EHS Policy and related
information is brought to the attention of all employees
and that all reasonably practical steps will be taken to
ensure adherence to this policy by all employees and
other persons undertaking work on behalf of eClerx.
eClerx recognizes that a number of activities undertaken directly by the
Company, or which are undertaken on its behalf, could involve risk to
the health and safety of its employees and others. eClerx therefore
fully endorses the EHS Policy, which details the Company's
occupational health and safety objectives, environmental
responsibilities and arrangements and the procedures for
implementation, coupled with the goal of continuous improvement as a
result of best practices and corporeal experiences.

CONFIDENTIAL 3
Environment, Health and Safety (EHS) Policy
(Contd.)

This policy will be reviewed periodically as required.

When does the

Safety and Health At work (our employees, Travel between home and
policy apply? contractors and visitors) work of our employees

Business All Company organized business

related travel events, i.e. training programs,
conferences, business-related
get-togethers, annual sports, etc.

CONFIDENTIAL 4
EHS Objectives

The overall objectives of the EHS policy are to help eClerx to:

Implement cohesive and
complementary health and
safety and environmental
protection strategies and
standards for all activities
Monitor occupational health and safety
standards and methods of work
through hazard spotting, workplace
inspections, periodic audits and
assessment of eClerx operated offices
Gradually eliminate known hazards and Reduce waste, conserve
control events that may pose a risk to energy, and explore
employees, vendors, contractors, opportunities for reuse
Clients and the public, equipment, and recycle
property, reputation or services

Develop, introduce, and maintain
environmental management
systems across the company to
meet the generally accepted
standards as well as statutory
requirements for the environment.
Verify compliance with these
standards through regular auditing
Develop, introduce, and maintain
environmental management
systems across the company to
meet the generally accepted
standards as well as statutory
requirements for the environment.
Verify compliance with these
standards through regular auditing
Develop and maintain effective
communication systems that inform,
instruct, and train employees on
relevant occupational health and safety
matters to ensure employees can work
safely and effectively
Educate the employees so that
they can be aware of their own
safety, health and well-being as
well as their responsibility
towards the environment

The Company is committed to the protection of all employees and people who work for it, whether temporary or permanent or contractors and as
such, the EHS Policy applies equally to all, unless specifically stated otherwise.

CONFIDENTIAL 5
EHS Forum

EHS Core Committee

This forum is made up of the Head – Administration, Head – IIS, Head – RMG, one Associate Principal each from Digital, Market, CO, CF and IIS / SS.

EHS Forum Name of the Leads

EHS Forum Head Devidas Iyer
Head – IIS Sanjay Kukreja
Head – RMG Amir Bharwani
Associate Principal – Financial Market Sneha Saxena
Associate Principal – Digital Sandeep Srivastava
Associate Principal – CO Vikram Chandrasekharan
Associate Principal – CF Manoj Shelar
Associate Principal – IIS Manish Mittal

CONFIDENTIAL 6
EHS Forum
(Contd.)

EHS Working Committee

This forum is made up of Program Managers from Digital, Market, CO, CF, IIS, Admin (Location Leads) and RMG.

EHS Working Committee Name of the Leads

Associate Prinicpal – IIS Vijay Kamath
Associate Principal – Admin Harinder Singh (Site Lead)
Associate Principal – HR Sachin Chavan
Program Manager – CO Saurav Bansal
Program Manager – CO Harneet Singh
Program Manager – FM Harpreet Chadah
Program Manager – Digital Jyoti Sahay
Program Manager – HR (Gurugram) Santoshi Kothari
Program Manager – Graphics Operations (Coimbatore) Yesudass Maria Prakasam
Program Manager – CF Pratik Bhanushali

CONFIDENTIAL 7
EHS Forum
(Contd.)

EHS Working Committee

This forum is made up of Program Managers from Digital, Market, CO, CF, IIS, Admin (Location Leads) and RMG.

EHS Working Committee Name of the Leads

Program Manager – CF Jay Samant
Program Manager – TFM Kailas Deshpande
Process Manager – Admin (Manila) Richie Latayan
Program Manager – HR Kamal Mehta
Senior Process Manager – IIS Milan Gautam
Associate Process Manager – HR Anju Pinto
Pourushaspa Karkaria (Site Lead)
Manish Kr Jaiswal (Site Lead)
Sachin Gaikwad
Program Manager / APGM – Admin
Avinash Dubey
Amit Pendke
Nishant Jha

CONFIDENTIAL 8
EHS Forum
(Contd.)
The EHS Working Committee
representatives are at varying levels /
operating units within eClerx and
must include a minimum of one
women employee in the working
committee at all times.
The EHS Working Committee members The EHS Core Committee members should meet
should meet periodically to asses the action once every semester. The appointed EHS Core
plan ahead. The appointed EHS working Committee members and invited members of the
committee members and invited members of management should attend these meetings. Any
the management should attend these health and safety related issues or concerns
meetings. Any health and safety related reported in EHS Working Committee meeting to be
issues or concerns regarding employees evaluated and approved. EHS core committee
should be brought to the attention of the EHS contact details are displayed on the Intranet.
working committee. EHS working committee
contact details are displayed on the Intranet
along with the next scheduled meeting and
venue details. Any employee is free to walk-in
into these scheduled meetings to discuss any
EHS related issue or post queries / concerns
to EHS Working Committee
(EHS_Working@eclerx.com) distro.
CONFIDENTIAL 9
Responsibilities
EHS Forum
The EHS Forum’s role under the EHS Policy is to
Advise the Company
on health, safety and
environment policy
development and
implementation
Monitor the
implementation of the
occupational health,
safety and environment
standards as far as
reasonably practical
Develop, monitor and Advise the Company Coordinate, monitor,
review the occupational and employees on and review eClerx’s
health, safety and matters relating to EHS risk assessment
environment management occupational health program
system of the Company and safety
Perform functions for Identify employee Ensure that all
the purposes of the occupational health and appropriate EHS policy
health and safety safety training needs and related information is
management at work organize and assist with available on the Intranet
its delivery to all staff and is regularly updated
including new joiners
CONFIDENTIAL 10
Responsibilities

Employees
Employees must take reasonable care for their own health and safety and for that of others who may be affected by their actions. They must inform
their managers in case they contract any contagious diseases (e.g. Swine flu) or observe the same amongst their team members

Employees are required under this Health and Safety Policy to

Promptly report health and
safety risks and issues
including all accidents and
near misses to the either the
EHS Forum, their location EHS
lead, or immediate manager
Comply with eClerx’s
EHS Policy guidelines
and procedures
Carry out work in
accordance with safe
systems of work,
training, and instructions
Not intentionally or
recklessly interfere with, or
misuse anything provided
in the interests of health,
safety or services

CONFIDENTIAL 11
Responsibilities

EHS Inspections
EHS forum members will ensure that inspections are organized at periodic intervals. It will also:

Conduct regular and periodic
facility, vendor and contractor
site inspections at a frequency
not less than once a year
Establish daily work Develop and Provide a reliable system for
area inspection use a checklist employees, without fear of
procedures reprisal, to notify
management about apparent
hazardous conditions and to
receive timely and
appropriate responses

CONFIDENTIAL 12
Policies and Practices

Alcohol and Substance Use

Employees should not be under the influence of alcohol or illegal substances during working hours. The company does not promote excessive consumption
of alcohol at after-hours gatherings or social functions.

Electrical Safety
The repair of electrical circuits and components, together with the removal of any access covers which may expose employees to the hazard of ‘live’
electrical circuits or components is strictly prohibited. The removal of access covers may result in the risk of electrocution or death.

No work shall be done in
close proximity to electric
supply line and operations
without the approval of
components authority
The use of No one except a person duly Useful life of wires Use of Green Monitoring of
defective plugs, authorized by electrical used shall be electrical appliances electrical appliances
sockets and section shall operate any established for each (LED / CFL lights, for effective power
flexible cable switch gear or other electric facility and wiring HVAC, MPCB management
shall be avoided equipment except for routine change shall be approved DG etc)
starting and stopping motors completed before as far as possible
and switching on or such end of life
switching off lights, fans etc.

CONFIDENTIAL 13
Policies and Practices
(Contd.)

Emergency Procedures

Bomb Threat Emergency Alert Fire Safety

Please be vigilant about unusual packages In the event of an emergency alert, employees Awareness is created at regular intervals by
and report anything suspicious to the will be advised by the Business Continuity training employees on generic dos and don’ts
immediate managers, Facility EHS lead, or Management (BCM) team, Location Admin in- that are applicable to any type of disaster /
the EHS Forum. charge or Security of what action should be crisis. It also includes Crisis Warden Roles
taken; their instructions must be followed. and Responsibilities and Chief Crisis Warden
If a bomb threat is received by an employee, Roles and Responsibilities in the event of fire.
then that employee should gain as much
information from the caller as is possible, e.g.
location of the bomb, time that it has been set
to detonate, any code given, any background
noises, male or female, and their accent. This
information should be immediately provided to
immediate managers, Facility EHS lead or the
EHS Forum, who will in turn contact Business
Continuity Management (BCM) team.

CONFIDENTIAL 14
Policies and Practices
(Contd.)

Fire Safety
Discovering a Fire Fire precautions, alarm testing and fire drills

Sound the fire alarm Do not attempt Employees should Employees should Fire drills will Fire alarms The same
by breaking the glass to extinguish not put themselves, familiarize themselves be conducted are tested procedures must be
on any red manual fire any fires or their colleagues, at with fire safety at each location weekly in followed during a
alarm call point personal risk of injury information (escape is conducted each location. fire drill as though a
routes, assembly points) bi-annually. real evacuation.
provided on fire action The Fire Evacuation
notices / notice boards Plan is displayed at
all facilities.

Hearing a Fire Evacuation Alarm

Evacuate the building Assemble at Do not re-enter Follow the If employees have Do not stop to
immediately by using the nearest fire the building Fire Warden's visitors with them, collect coats, bags
the nearest available assembly point unless advised it instructions at advise those or other personal
exit. Do not use the is safe to do so all times individuals of what possessions
lifts – use the stairs action to take

CONFIDENTIAL 15
Policies and Practices
(Contd.)

Event Management
Generally there are 3 categories of events

Meetings & Events – Team Building / Fun / Charity / Sports Events – these are generally eClerx Offsites – These are generally
these are generally considered to be medium risk activities and can comprise any of the following: considered to be medium to high risk
considered to be low activities especially in cases where the
 All team building activities are to be booked with preferred suppliers who
risk activities involving offsite has outdoor activities such as
have the appropriate public liability insurance cover and may provide onsite
the use of meeting mountain climbing, white water rafting, etc.
first aiders / paramedics.
rooms, board rooms,
hotels, etc.  Charity / Sports events – These are activities such as the Standard
Chartered Mumbai Marathon etc.

First-aid Hazardous Housekeeping

Boxes Substances
First-aid boxes shall Employees are not Workplace and On completion of an Waste oily material Slipping substance Suitable warning or
be provided at the permitted to handle surrounding assigned job, all the and other intermediate such as grease or notices should be
reception at all hazardous substances area shall be tools, equipment’s and material shall be oil spilled on floor, displayed while
locations. without appropriate kept clean and left over material shall be removed and kept in shall be wiped and cleaning or
training and risk free from collected at designated covered cleaned maintenance work is
assessment. obstructions storage place metallic containers immediately in progress

CONFIDENTIAL 16
Policies and Practices
(Contd.)

Handling of Microwave

Admin would ensure that the
microwave oven is always
directly plugged into an outlet.
An extension cord would
never be used for a
microwave as it can overload
the circuit and cause a fire
Employees would be advised to:
 Use only microwave-safe containers to
heat food. Paper products other than
microwave popcorn bags would not be
considered microwave safe
 Never use aluminum foil or metal objects in
a microwave oven. They can cause a fire or
burn hazard and damage the oven
If there is a fire in the
microwave, it would be turned
off immediately and the door
would be left closed until the
fire is completely out

Induction Manual Handling of Heavy Equipment

All new joiners to the Company should receive a copy of Manual handling should be avoided where reasonably practicable, and employees must
the Induction Pack from Human Resources. They should not move, drag, push, and lift, etc., any items that are beyond their own capabilities.
be made aware of the EHS Policy and the guidelines and Employees are not permitted to undertake manual handling that involves a risk of injury
instructions on the policy. without having first undertaken appropriate training and risk assessment.

CONFIDENTIAL 17
Policies and Practices
(Contd.)

Health Check-ups

The organization provides all employees an opportunity to undergo Health Risk Assessment (HRA), the participation to which is voluntary. The results from
the HRA may be used to arrive at the aggregate health profile of the organization. The organization may also at regular intervals organize health camps in
office premises which may cover parameters:
 BMI
 Blood Pressure
 Blood Sugar, etc.
The organization allows employees sufficient time-off to take care of events including health issues with appropriate approvals from the management.

Commitment to a Smoke-Free Environment

All premises managed by the Company will normally be designated ‘No Smoking’ areas. The exception to this general rule is that this policy does not apply
to staff residences; however smoking is not permitted within communal areas of these facilities.
Essentially, any area designated as a smoking area will not be within an enclosed premise and will be positioned so that tobacco smoke or its odors do not
permeate to other internal areas.

CONFIDENTIAL 18
Policies and Practices
(Contd.)

For employees with disabilities

ACCOMMODATION OF INDIVIDUALS WITH DISABILITIES

eClerx complies with applicable local laws providing for nondiscrimination in employment against qualified individuals with disabilities. The Company is
committed to providing equal employment opportunities to all individuals, including those with disabilities. The Company is committed to engaging in an
interactive process to determine the availability of a reasonable accommodation to any qualified individual who requests an accommodation to enable him or
her to perform essential functions of the job, gain access to Company facilities, or otherwise enjoy equal benefits and privileges of employment.

CONFIDENTIAL 19
Policies and Practices
(Contd.)

For transgender employees

FACILITIES AND AMENITIES

In accordance with the TP Act, the Company will make every reasonable effort to ensure that all parts and facilities of the Company’s office space are safe
and gender neutral. Some of the specific facilities and amenities that the Company has endeavored to put in place, and will continue to do so going forward,
are:
 Maintenance of unisex (gender neutral) restrooms at all its establishments. Wherever possible, the Company shall make available single stall restrooms
for increased safety and privacy of transgender persons, if requested. Separately, the employees may be allowed to access any restroom consistent with
their asserted gender identity;
 Making hygiene products available at all unisex restrooms, including any product specifically requested by transgender employees;
 Making available safe transportation facilities specifically for the transgender employees, if such employees are not comfortable in using the other modes
of transportation and have raised a request in this regard;
 Ensure that any form of violence is not perpetrated against any of the employees, including transgender employees, by providing adequate security
guards on the premises; and
 Ensure safety by installing CCTV cameras at common places within the establishment.

CONFIDENTIAL 20
Environment or Green Practices

Our values put into daily practice can be expressed through four areas: Energy, Health, Resources and Respect.
Energy Health

 Purchase Energy Star® rated equipment and appliances  Use products that don’t off-gas toxic chemicals into
 Give higher preference to premises with LEED certification or “green” practices the work space
 Use low energy lighting (T5 or LED lights)  Use cleaning products that are biodegradable and not
 Use electric lighting only when necessary in favor of natural lighting tested on animals
 Turn off all non-essential equipment when not in use  Procurement of biodegradable materials
 Auto switch off of computers when not used  Discard toxic materials and products that contain
them properly
 Energy efficient settings on laptops
 Cut power to appliances when not in use with a power strip
 Use public transportation or walk before using a car
 Purchase of computing assets with green technology (Use of Virtualization,
Thin clients, TFT’s which are power efficient and emits lesser heat etc.)
 Use appropriate technology for Power Management (Power Management via
AD policies on IT assets)
 Work from home policy
 Reduce air-conditioning consumption by taking optimal plans from builders and
allocating multiple units for separate areas
 Maintaining temperature at energy efficient level

CONFIDENTIAL 21
Environment or Green Practices
(Contd.)

Our values put into daily practice can be expressed through four areas: Energy, Health, Resources and Respect.
Resources

 Purchase supplies made with recycled content as practical
 Purchase products and supplies that can be used more than once and /
or recycled
 Encourage reduction of water consumption and develop water conservation plans
 Focusing on transport efficiency to emphasize energy conservation
 Continuing to include improvements in construction / fit outs and energy standards in all new fit out
/ renovation projects, evaluate environmental standards and building standards, while satisfying all
applicable standards and codes. Implement the “Green Leases” approach for newly leased facilities
and renewal of
existing leases
 Group large vehicle transport facility to reduce carbon footprint
 Focus on hiring from nearby areas and flexibility to choose nearest facility
 Waste Paper recycling
 Printer Ink-toner and UPS / laptop battery handling
 Making office paper less by allotting printing rights to limited number of
people with quotas.
 Reduction of paper by using electronic communication
and e-payments
 Laboratory testing of food provided in canteen.

 Purchase and deployment of energy efficient IT assets (Servers / TFTs / Thin Clients) and
associated Technologies
 Focusing on proper collection, reception, storage, transport and disposal of computing waste
through authorized vendors
 Continuing identification of potential accidental and emergency situations and respond to accidents
and emergency situations
 Continuing to prevent and mitigate the associated environmental impacts.
 Food waste handling from pantry
 Recycling drives under CARE initiative by promoting donation of paper,
clothes, utensils etc.
 Use of tele and video conferencing for interoffice communication instead of
travel
 Early adoption of all e-initiatives by government, such as virtual board
meetings, paperless communication with investors etc.

 Continuing to test the effectiveness of the emergency preparedness and response procedure by
conducting periodic drill

CONFIDENTIAL 22
Prevention from Accidents

Vehicles Road safety

 All vehicles shall comply with traffic regulations within the office
compounds and they shall not exceed the speed limits
 Riding on a running vehicle or any part of the vehicle except on a
proper seat is strictly prohibited
 Sitting on the side laps or standing in a company vehicle while in
motion is strictly prohibited
 Vehicle vendor will be compliant and will have met all the
requirements under acts as prescribed by the Government of India
 The vehicle vendor will have provided all the registration certificates
/ licenses pertaining to government bodies
 The vehicle vendor will be compliant with ESIC / PF registration
 While travelling by company vehicle, ensure that driver is driving
safely, else, report to the Admin authorities
 Pollution under control check (PUC) certificates to be submitted by
each contractor for each vehicle used for transportation
 Drive safely
 Follow traffic rules
 No speeding (adhere to speed limits)
 Use seat belt in four wheelers
 Wear helmet while riding a two-wheeler
 Do not use a mobile phone while driving or walking on the road
 Do not drive under the influence of alcohol
 Do not listen to music on I-pod or any other mobile instruments while
riding a two wheeler
 Driver wake up routine and test for night shift transportation
 Security deployment in each of the night shift vehicles carrying women

CONFIDENTIAL 23
Control Points and Precautionary Measures
During Pandemic
 Facemasks compulsory to all employees, visitors and vendors.
 Revised seating plan will be followed to maintain social-distancing measures on the
work floor and in common areas.
 Sanitization of all commonly touched surfaces such as door handles, elevator buttons,
railings etc. and of all essential products such as packed material, water jars etc.
 Aarogya Setu app/similar apps as per the prevailing guidelines is mandatory for all
visitors and employees to encourage self-monitoring of health status.
 Thermal body checks through IR thermometers at all entry points
 Common recreation areas / gyms / creches will be accessible as per prescribed
guidelines
 Access for candidate, visitors and food delivery personnel will be governed as
per the prescribed guidelines by the authorities during the pandemic period
 Provisioning for containment area / isolation room
 Limited pedestrian movement at podium levels and club house lawns
 Demarcation in elevators with presence of security guard in building lobbies. Liftman
available where feasible
 Timely cleaning of all the common areas with an alcohol-based disinfectant
 Periodic cleaning of commonly touched surfaces such as elevator buttons, grab bars
on staircases, door handles, access control devices etc.
 Touchless attendance system as management recommendations
 Medical screening via self-declaration of all employees, visitors, vendors and
individuals accessing our premises – Assessment and temperature checks with touch
free IR devices.
 Timely and frequent sanitization of touch free thermometers
 Guidance for employees to avoid physical contact with objects and other people,
ensuring COVID protocols are followed at all times.
 A team of 24*7 trained medical attendants / nurses / security staff will be available
 A 24*7 on-call emergency ambulance service will be available which shall take the
employee to the nearest treatment centre / hospital in case immediate medication /
hospitalization is required
 List of all COVID centres and hospitals will be available with the ADMIN team /
security desk
 Demarcation at common areas such as café cash and service counter, locker rooms,
turnstiles to access work floor, office entrance for thermal body check
 All meeting rooms and board rooms will be locked until further notice. Use of phone,
Skype, Zoom, VC etc. to be promoted
 Digitalization of internal communications with virtual meetings through tele/ audio-
conferencing that brings down meeting-related travel, minimizing potential risk of infection
further
 Installation of UVGI, special filters in our HVAC
 Campaigns on social-distancing, wearing masks and precautionary measures to be
followed through various channels such as emails, WhatsApp, SMS and posters
 Use of wellness room will be through registration at the security desk to ensure 100%
linen turnover and cleaning of the beds post every usage
 Vaccination administration drives organized across all
CONFIDENTIAL 24
Employee Well Being, Morale and Satisfaction

eClerx is dedicated to the health and safety of its employees. This includes, but not limited to, providing safe and healthy work environment to prevent injury
and minimize risks, maintaining the well-being and morale of employees, complying with health and safety standards and guidelines, as well as essential
training and equipment to ensure the health and safety of employees. We encourage employees to undergo annual health check-ups and provide medical
services to all our employees including mental health counseling and health insurance. We strive to prioritize the preventive rather than corrective measures
through identifying potential accidents and emergencies before they occur through proper risk assessment, feedback forums and audits. Sachin, can we add
– in EHS policy, there is a mention of morale and satisfaction of employees pertaining to work environment, is added in scope

CONFIDENTIAL 25
Contact Information

Primary Contacts Secondary Contacts

Name Location Mobile Name Mobile

Avinash Dubey Airoli +91 9987 991 675 Devidas Iyer +91 9004 016 949
Sachin Gaikwad Express Towers - Mumbai +91 9987 996 485 Amir Bharwani +91 9820 219 662
Parveen Kumar Chandigarh +91 9780 009 663 Vikay Kamath +91 9167 546 868
Amit Pendke Pune +91 9967 783 346 Pourushaspa Karkaria +91 9004 094 552
Kailas Deshpande Airoli +91 9820 433 581 Harinder Singh +91 9780 009 660
Milan Gautam Chandigarh +919465 447 883 Manish Kr. Jaiswal +91 9890 904 442
Anju Pinto Airoli +919769 399 389

CONFIDENTIAL 26
Operational Objectives and
Allocation of Responsibilities
Our values put into daily practice can be expressed through four areas: Energy, Health, Resources and Respect.

Key Stakeholder Admin Admin TFM

Category Water Consumption and Per Capita Consumption GHG emission and Per Capita emission Energy Consumption and Per Capita Consumption

CONFIDENTIAL 27
Thank
You

For any queries, please contact EHS_Working@eclerx.com

CONFIDENTIAL 28