ANTINO LABS

VALUES THOURGHCONVERGENCE

Employee & HR Manual

Prepared By

HR/Admin Team & Legal Team

Reviewed & Approved By

Board & Leadership Team

Effective From 1st January 2024

 INDEX
S. Topics Page No
No
1 Introduction 3
2 About The Organization 3
3 Hours of Operation & Work Schedule 3
3.1, Meal & Tea Breaks 4
3.2
3.3 Attendance Policy 4
3.4 Late coming 4
3.5 Obtaining Approvals 5
3.6 Types of Leaves 5-6
3.7 Procedure of Availing Leaves 7
3.8 Late Return from Leaves & Other Conditions 7
4 Work From Home Policy 8
5 Pay & Compensation 9
5.1 Deductions 9
5.2 Salary Slip Distribution Procedure 10
5.3 Performance & Compensation Review 10
6 Crisis Suspension/Dismissal 11
7 Employee Code of Conduct 11
7.1 Dress Code 11-13
7.2 Cyber Security & Digital Devices 14
7.3 Internet Usage 14
7.4 Cell Phone Usage 14
7.5 Corporate Email 15
7.6 General Expectations 15
8 Social Media Policy 15-16
9 Discontinuation of Service 16
10 Conflict of Interest 16-17
11 Employee Relationships 17
11.1 Fraternization 17
11.2 Dating the Managers or Superiors 17
11.3 Friendships at work 17
12 Solicitation & Distribution 18
13 Prevention of Sexual Harassment Policy 18
(POSH)
13.1 Sexual Harassment 18
13.2 Scope 19
13.3 Sexual Harassment Inclusions 19
14 Cyber Security Policy 20
14.1 Policy Brief & Purpose 20
14.2 Scope 20
14.3 Policy Elements & Confidential Data 20
14.4 Transfer of Data 20-21
14.5 Disciplinary Action 21
15 Personnel Administration 21
16 Employee Maternity Benefits 22
16.1 In case of childbi rth 22
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 16.2 Availing the benefits 22
16.3 Statutory Maternity Pay 22
16.4 Employee Paternity Leave Benefits 22-23
17 Travel Policy 23-29
18 Retirement Policy 29
19 Asset Policy 29-32
20 IPR Policy 32-34
21 Control Of Documents 35
22 Reward & Recognition Policy 35-39
23 Grievance Policy & Procedure 40-41
24 Zero Tolerance Policy 42-44
25 Whistle blower policy 44-48
26 Policy on Performance Improvement Plan (PIP) 48-50

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1. Introduction
Welcome to the Company ANTINO LABS. This handbook was developed to provide you with an
information resource for common questions and concerns. If you have questions or concerns about
the policies outlined here, you should contact your manager or Human Resources Manager.

The policies stated in this handbook are subject to change at any time at the sole discretionof the
Company. From time to time, you may receive updated information about any changes in policy.

The contents of this handbook are not intended to create a contract or agreement between the
Company and you. For those employees in a position covered by a collective bargaining agreement,
you should refer to the agreement which governs your terms and conditions of employment.

There are specific procedures for many of the general policies stated in the handbook. Please direct
any questions to your manager, department head, or to Human Resources.

2. About the Organization

1. It was founded in September 2018 as a Technology Consulting Company to provide services

related to Digital Product Development & Custom Software Development. The Company was
incorporated with the purpose of providing a single-window solution for startups & enterprises while
ensuring that only the best business ethics and engineering are practiced. From modest beginnings,
ANTINO LABS has grown to be a professionally Digital Platforms Development solutions provider
with a multi-national client base.

ANTINO LABS is headed by a team of IT Professionals & IIT/IIM Alumni. In addition,

our people have a well-rounded exposure to the requirements of the IT Sector.

2.1 Over the years, ANTINO LABS has built a team of personnel with expertise in mixed
disciplines, using a mix of staff with long years of practical IT experience. ANTINO LABS also
provides Softwareservices and solutions.

2.2 ANTINO LABS has the capability to draw on a sizeable talent pool comprising IT, Software
& Admin staff. Through this wealth of experience and technical skill-sets, we are able to deliver
innovative solutions that exceed our client’s objectives and aspirations.

3. Hours of Operation/Work Schedules

Company’s general working days for all employees will be weekdays. Everyone is expected to
complete 8 hours for full day in Desktime or similar tool provided by company for employees working
from home. Employees working from office need to complete 9 hours (8 hours working
+ 1 hours total break time including lunch & snacks break). General hours for employees apply
the following schedule. Company reserves the right to change shift/schedule based on the job
function.

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 a) Working Days: Monday – Friday

b) Weekly off: Sunday (weekends), Saturday’s will remain off, except in case where a Project
demands us to put in the extra time the Company may require you to work longer hours should the
projects or work demand so.

c) Official Login Time: 9:30 AM (9:30 Hours IST)

d) Official Logout Time: 06:30 PM (18:30 Hours IST)

* Company provides 30 Min of flexibility in Login Time depend on the projects. If someone is starting
late then they will have to ensure to complete minimum login time of 8 Hours (in Desktime) and 9
Hours (in Office Attendance Punching Portal/Zimyo)

3.1 Meal Break

Between 13:00 hours to 14:00 hours (30 mins)

3.2 Tea Break

Tea Break (Morning) 11:30 AM, Tea Break (Evening) 4:30 PM

All staff needs to give prior leave requirement or information for venturing out of office formore than
30 minutes during office working hours.

3.3 Attendance Policy

Regular attendance is essential to the Company’s efficient operation and is a necessary condition of
employment. Employees are expected to report to work as scheduled and on time. Employees need to
ensure punching in/out in biometric machine in office and Zimyo. Employees working from home must
enter daily attendance in Zimyo Payroll portal (Ask HR if you don’t have access). Desktime will also
be used to cross verify attendance of 8 hours working.

The employee must refrain from manipulation/falsification of attendance records thatmay include but not
restricted to malpractices like proxy attendance, Script to manipulate Desktime input Data etc. Erring
employees will face strict disciplinary action if found guilty.

3.4 Late Coming (Late Login/Buffer)

Keeping the official decorum employees are required to arrive at office & login latest by 10:30 AM (1000
Hours IST daily). A grace period of 60 minutes will be allowed for any last- minute exigency.

Morning attendance after 10.30 AM will be marked as a late comer and will be considered half day as a
penalty.

Employees need to complete 8 working hours in Desktime or similar tracking application provided by
company. If Desktime is found less than 8 hours for consecutive days then it may be considered half
day. If your Desktime is less due to any technical issues then ensure to email HR &your reporting
manager within 24 hours.

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 3.5 Obtaining Approval
Staff members wishing to take annual leave should follow the procedure set out below.

- All requests for annual leave should be made as per the criteria set for leaves. .Annual leave
records should be passed to the appropriate manager for approval and copy to hr@antino.com at
the earliest opportunity. Employee also need to apply leave in Zimyo. Requests for annual leave
will not be unreasonably refused.

- Your Manager must approve all Annual leave in advance. To request sick for leave employees
must need to submit medical proof on Zimyo. Human Resources may be consulted before a final
decision is made.

- If your application for leave is refused, your Manager will notify you as soon as possible.

- Any staff member who takes annual leave which has not been previously approved may be subject
to disciplinary action.

- Early leaving from work, need your project manager’s approval and HR be kept in cc
(hr@antino.com). Please not that such requests should not be more than twice in a month.

3.6 Types of Leaves:

The following types of Leaves will be applicable to Employees

Privilege / Earn Leave: Every employee who has been in employment shall be entitled to earn leave for
not less than Fifteen days (15) for every calendar year. An employee can avail his/her leave or part of it
from the 1st of January of every year. However, in case of any employee separates from the Company
during the year for whatsoever reason, excess leave availed by him/her over and above the pro-rata
entitlement will be subject to adjustment against Leave and or deduction from the final dues.

Leave entitlement is on a Calendar Year basis i.e., from 1st, January to 31st, December of any year.
Any decimal places shall be rounded off to the next higher whole number. Privilege Leave can be
preceded or succeeded by a holiday / weekly off. At one time minimum of 3 privilege leave can be
taken and all Privilege Leave must be sanctioned at least a week in advance. Privilege Leave cannot
be taken during Probation and Training period. The employee may avail pro-rated Privilege Leave only
after his confirmation for carrying forward/accumulation of PL as per clause mentioned below for
carrying forward of leaves.

Casual Leave: Every employee shall, subject to conditions as may be prescribed, be entitled to Casual
Leave for not less than FIVE Days (5) in any one Calendar Year. Casual Leave may be taken for
emergency or unforeseen circumstances/events. All employees are entitled to avail 05 days of Casual
Leave in a Calendar Year. CL is restricted to a maximum of two days in a stretch. Casual Leave cannot
be carried forward to the next year and will lapse if not availed by the end of the year. CL cannot be
combined with any other types of leaves but can either succeed or precede a Weekly off/Company
Festival Holidays.

Casual Leave cannot be encashed and will lapse if not availed in the Calendar Year. CL should be
informed in advance as far as possible. However, in case it is not possible, the concerned employee
will have to inform within 24 hours about the same. Employees availing Casual Leave and if they have
not informed their line managers in advance need to convey the same on mail, marking copies to HR.

Sick Leave: Employee who is not covered under ESI Scheme and who has been in continuous
employment for a period of six month shall, subject to such conditions as may be prescribed, is further
entitled to Sickness Leave for not less than FIVE days (5) in a Calendar Year. As a rule, Sick Leave
cannot be combined with any other type of leave but it may be succeeded (not preceded) by a Privilege
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Leave in case the person is not able to recover during the course of Sick Leave. Sick Leave cannot be
encashed as per policy mentioned below. Sick leave will not be adjusted against notice period of
employee.

Marriage Leave: Marriage Leave may be availed by an Employee for self-marriage up to a maximum of
Five days (5) once in his/his employment with the Company. The Leave application for the same should
be supported with the Wedding Card or relevant documents. Marriage Leave may be combined with a
maximum of 10 days of Privilege Leaves. Marriage Leave is not applicable to employees in probation.

Maternity Leave: Women Employees will be eligible for 26 weeks of ML with wages for delivery, may
start 8 weeks prior to delivery, provided such an employee has worked for a period not less than 6
months in the organization, in the twelve months preceding the date of expected delivery. In case of
miscarriage six weeks leave from the date of miscarriage will be granted. This is subject to production
of medical certificate. PL may be added to Maternity Leave subject to approval of Reporting Manager
/HR Head. ML will be governed by Government Maternity Act.

Paternity Leave: Male employees will be entitled to Paternity Leave for a maximum period of SEVEN
days (7) (maximum for two children). They will have to produce birth certificate of their child to avail this
leave. To be availed within two months of child birth.

Bereavements Leave: Employees can avail a maximum of THREE days (3) days of Bereavement
Leave in case of demise of any close family relative. Family relative may include Parents/Spouse
/Children/ Others (for which permission from Reporting Manager / HR Head will have to be taken). PL
may be added to Bereavement Leave.

Festival Holidays: ANTINO Will allow Ten days (10) Festival Holidays in a year of which two holidays
will be on choice of the employee. Eight will be fixed paid holidays which will include Government
Notified National Holidays. Regions may have separate 8 festival holidays. List of the same is attached
in table below. However, employees can choose two optional holidays with total festival leaves not
exceeding 10 days in a calendar year.

Weekly Offs: Saturday and Sunday are weekly off as per job for Corporate Office Employees. Field
Operation Employees / Employees at Client sites will be governed by their leave rules.

Compensatory Off: Compensatory Off will be allowed to employees who work on holidays specified by
the company. Compensatory offs will have to be taken within 15 days of the leave subject to
management approval. Compensatory Off will be applicable only when employee works on Sundays or
on Festivals for more than 5 hours.

Birthday / Anniversary Leave: Employees will be entitled for One day (1) leave on either on their
Birthdays or Marriage Anniversary.

Office Timings (9:30 am – 6:30 pm): The Company provides Flexible working hours. Employees are
advised to login a minimum of 9 hours of work every day which includes an hour of break. However
employees have to reach office latest by 10:30 am which includes their buffer time.

Work from Home: WFH as per the company policy, employees will be allowed to take 2 WFH in a
month. However, the following rules will be applicable:

- It cannot be clubbed with any weekly offs, CL, PL,SL and festival holidays.

Accumulation of Leave: Privilege Leave may be carried forward up to a maximum of 10 days to the next
Calendar year subject to a maximum accumulation of 30 days. Any leave over and above the carry
forward or accumulation will be credited to the salary after necessary tax deductions at the end of the
Calendar Year.

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Procedure of Availing Leaves:

Employees are expected to communicate about their planned leaves at least one week in advance for
their managers to plan work / allocate tasks to others.

- All leaves to be availed by employees must be routed through Zimyo.

- All leave requests whenever possible should be submitted in advance. Reporting Manager should
be informed about employee availing leave.
- Manager reserves the right to approve PL or other leaves ensuring that business continuity is not
impacted.
- In exigencies, where prior approval cannot be obtained, reporting manager / CEO / Founder / Co-
Founder / HR Head must be informed over phone / mail followed by compliance of leave application
in system etc. within three days of employee joining duties.
- No leave would be accepted without a formal leave application being submitted on Zimyo to
Reporting Manager / HR.
- Employees cannot avail leave in excess of leave balance at the time of application.

Sanctioning Authority: Leave can be sanctioned by a person to whom the employee is reporting or
Founder / Co-Founder / HR Head. The entire Leave request should be routed through immediate
reporting manager for recommendation and or approval.

Leave Encashment: Automatic encashment of Privilege Leave will be done along with the salary for the
month of January every year for the PL leave balance of any employee in excess of 30 days. At the
time of separation owing to any reason, including termination employees can encash their accumulated
Privilege Leave up to the last working day on pro rata basis. If the NP is waived/shortened, the unused
NP will be deducted from accrued leave and remainder will be paid out.

3.7 Late Return from Leave & Other Conditions

- If, for any reason, staff members know that they will be late returning from leave, they must contact
their manager and notify them of their late return and reason for late return as soon as possible.
Failure to do so may render the staff member liable to disciplinary action for unauthorized absence.

- If an employee is reporting at client location, then working days and hours will be according to the
client policy (if any), else it will be according to Antino Labs policy only.

- In case if there are irregularities in office timings then it will affect the monthly remuneration/salary
compensation and its quantum will not be adjusted to any type of leave(s).

- In case if any leaves taken for 2 or more than 2 days including weekends without prior approval
then weekends will be included for the leave loss as well.

- In case if an employee is serving notice period with the company, then the leave policy will not be
applicable and any leave taken during that period will impact the extension of Notice period or
deduction of salary of that particular duration

- If candidate is serving under notice period, then the salary will be with-held till the time of full and
final settlement.

- Full and final settlement will be done on or before 45 days from last working days and employee
need to take clearance from Reporting manager (For Handover) and IT department/HR regarding
company laptop etc. submission before full and final settlement.

- Developers working directly with client should follow their office timings & holiday calendar.
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- Multiple short duration breaks in desk-time may lead to half day/absence.

- If anyone have desk-time issue during any working day should promptly email to hr@antino.com
and reporting manager.

- 1 month Notice period is for interns and 2 Month Notice Period is for full-time/trainees employees.

4. Work from Home Policy

Employees are entitled to “Work From Home” as per the tenets of this policy. The request for the
approval of WFH should be sent within 24 hours from official mail Id to the reporting/project
manager and cc to hr@antino.com. All confirmed Employees are entitled to avail two (2) days' work
from home (WFH) per month which will be added on Zimyo as WFH Balance on 1st of every month.
Anyone joining after 1st of the Month will receive WFH from next month. Please note that
unapproved WFH will be marked as absent/leave.
Note: This work from home policy is valid till 31st December 2024 and it may be further
increased/cancelled based on the productivity
The employees, in addition to the all-applicable code of conduct and Company Policies, shall also
adhere to the following rules and guidelines for WFH:
- All Employees will mandatorily need to clock attendance to their Desktime (Automatic) & Zimyo
(Manual Clock in)account.
- Active work hours of less than 8 hours will be considered as a half day leave and less than 04 hours
will be considered as a full day leave.
- Employees need to inform hr@antino.com and reporting manager within 24 hours in case of any
technical issue in laptop or short time in Desktime.
- Company will consider Total “Desktime Time”. In case if the employee is to attend a call or any
official meeting then the employee shall put in such a request to the manager as well as HR for
attending the same at least 24 hours in advance.
- The management reserves the right to deduct pay or mark as absent to work for continuous usage
of non-work-related activity, continued period of low activity and so on. Please ensure your active
hours are always productive without distraction.
- During work hours, all official communication will happen through Email or Microsoft Teams for
instant communication. Employees must be available on these channels during active work hours.
Any un-informed absence shall be considered as a leave(full or partial)as per the decision taken by
the supervisor/manager in consultation with HR.
- We follow a strict communication policy where any email/Team's communication that requires
attention needs to be responded to or redirected within a 12-hour period. Failing which it shall be
considered as a violation of work and relevant actions shall be initiated on such indiscretion.
- Company reserves the right to cancel work from home for non-compliance of above for individual
employee or respective team.
- Company reserves the right to modify work from home duration considering business needs from
time to time.
- Employee working from office can’t take work from home without prior approval from HR &
Reporting Manager both. This shall be limited to emergency only. Work from Home without approval
will be considered as leave of absence.

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5. Pay and Compensation
Employees are paid between 5th & 7th of each month and company will change the pay day
according to the public/bank holiday in India.

5.1 Deductions from Salary

ANTINO LABS is required by law to make certain deductions from your pay regarding income
tax and in future too may do the deductions as directed by government guidelines.

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5.2 Salary Slip Distribution Procedure
Pay details for every employee will be uploaded within 7 days in payroll portal after disbursement
of salaries.

For any kind of reimbursement like laptop repair/travel etc. you need to take prior approval to your
HR/Admin team according to the reimbursement policy of company.

5.3 Performance and Compensation Review

It will be carried out once twice a financial year, normally in March & September. Salary raises will
be directly linked with performance appraisal. Employee should complete minimum 5 months from
joining/appraisal to be eligible for subsequent appraisal perio d. Example: If your appraisal/joining in
December then you will be considered in Appraisal cycle of September.

Your manager is continuously evaluating your job performance. Day-to-day interaction between
you and your manager should give you a sense of how your manager perceives your performance.
Your manager will consider the following things, among others:

i) Attendance, Initiative and Effort

ii) Knowledge of your work
iii) Attitude and willingness
iv) The quality and quantity of your work
v) The conditions under which you work

Following would be the overall factors while considering:

Review from HR/Admin in terms of regularity/attendance/attitude: 20% Review from
Client/Reporting manager: 40%
Knowledge of work, dedication and improvement: 20% Project Success & completion of work
within timeline: 20%

Compensation Reviews
Wage and salary increases are based on merit alone, not length-of-service or the cost-of- living.
Having your compensation reviewed does not necessarily mean that you will be given an increase.

Normally, ANTINO LABS conducts compensation reviews annually. Any salary annual increases
will appear in the pay period ending after the dates they are granted.

There is a provision for special review for outstanding performers. This could be done as and when
considered necessary by the MD/Director/CEO/Management, mainly to meet the needs of
promotions, inter departmental postings and pay advancements.

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 6. Crisis Suspension/Dismissal
If your performance is unsatisfactory due to lack of ability, failure to abide by ANTINO LABS’ rules or
failure to fulfill the requirements of your job, you will be notified of the problem. If satisfactory change
does not occur, your services would be terminated. Some incidents may result in immediate
Dismissal/Discharge without notice period. These are:

1) Absence from duty, failure or refusal to report for duty when called upon to do so.
2) Doing personal work during office hours or doing any part time job/ freelancing or
any other work not related to the official work either in lieu of any monetary benefits
or otherwise.
3) Playing cards or games/sports at the work premises during working hours.
4) Downloading unethical or illegal data/picture from internet.
5) Using insulting words or abusive languages towards the colleagues.
6) Indulging in violence, instigation and abetment or sabotage during
participation in illegal strike.
7) Refusal to accept an order or letters or communications.
8) Sleeping during duty hours.
9) Strike in public utility services.
10) Molestation of co-workers. Voyeurism, & sexual advances towards co-
worker(s).
11) Teasing and making indecent jokes or making indecent remarks towards any
woman worker.
12) Threatening a superior or colleagues.
13) Sharing company internal working information with an ex-employee without
bringing the interaction to the notice of the management.
14) Divulging confidential information to outside party.

7. Employee Code of Conduct

As an employee, you are responsible to behave appropriately at work. We outline our expectations
here. We can’t cover every single case of conduct, but we trust you to always use your best judgment.
Reach out to your manager or HR if you face any issues or haveany questions.

7.1 Dress code

We value professionalism at our company and believe that how we present ourselves reflects our dedication
to the work we do. As a result, we have implemented a dress code policy for our male employees to ensure
that everyone dresses professionally and appropriately for the workplace. All male employees, regardless of
position or seniority, are subject to this policy. The goal of this dress code policy is to establish a professional,
respectful, and conducive to a productive work environment. By adhering to this policy, we hope to create a
workplace where everyone feels at ease and confident, and where our clients and customers are impressed
by our employees' professionalism. The policy includes:
· Formal attire: Employees are expected to dress in formal attire for client meetings, presentations, and other
official events. This includes a collared shirt, dress pants, and shoes.

· Casual business attire: For regular workdays, casual business attire is permitted. This includes collared
shirts, polo t-shirts, dress pants, and casual shoes.
· Business casual attire: On casual days, business casual attire is permitted. This includes collared shirts or
polo t-shirts, dress pants or khakis, and casual shoes.
· Appropriate Fit: Whatever clothing is worn should be clean, pressed, and fit appropriately. Clothes that are
too tight, too loose, or too short can look unprofessional.
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· Grooming: Good grooming is essential for a professional appearance. Males should be well-groomed and
neat. Hair should be clean and well-styled, facial hair should be trimmed, and nails should be clean and well-
manicured.
· Medical Reasons: In the event that an employee has a medical condition that renders them unable to adhere
to this policy, the policy then may be exempted for them.
· Shoes: Shoes should be clean and polished. Sneakers, sandals, or flip-flops are typically not acceptable in
a professional setting.
· Prohibited attire: Employees are not permitted to wear shorts, ripped or torn jeans, t-shirts, tank tops, and
athletic wear in the office.
· Cultural sensitivity: Employees are expected to be sensitive to cultural norms and customs when dressing
for work.
· Jewellery: Simple jewellery such as a watch, wedding ring, or simple chain necklace is acceptable. However,
flashy or distracting jewellery should be avoided.
· Exceptions: Exceptions to the dress code policy may be made for special events or occasions but must be
approved in advance by management or notified by an internal memo.
Note: This policy is applicable to every male employee of the company including the upper management, and
the company reserves the right to change this policy without any prior notice.
Employees must strictly adhere to the Dress- Code policy and the employees who are found not complying
with this policy will be asked to leave the workplace and return with modest clothing at their expense, including
penalties of late arrival or one day leave.

Dress-Code Policy (Females):

We value professionalism at our company and believe that how we present ourselves reflects our dedication
to the work we do. As a result, we have implemented a dress code policy for our female employees to ensure
that everyone dresses professionally and appropriately for the workplace. All female employees, regardless
of position or seniority, are subject to this policy. The goal of this dress code policy is to establish a
professional, respectful, and conducive productive work environment. By adhering to this policy, we hope to
create a workplace where everyone feels at ease and confident, and where our clients and customers are
impressed by our employees' professionalism.
The policy includes:

· Formal attire: Employees are expected to dress in formal attire for client meetings, presentations, and other
official events. This includes a collared shirt, skirts, dress pants, blazers, and shoes, further, Skirts or pants
are acceptable and must be of appropriate length (no shorter than knee-length).
· Casual business attire: For regular workdays, casual business attire is permitted. This includes modestly
presented Saris, Suits, Kurtas, and Overcoat to an extent that it is not considered obscene or too revealing.
· Avoid overly revealing clothing, such as short skirts, low-cut tops, or tight clothing. Clothing that is too tight
or revealing can be distracting and Prohibited.
· Avoid wearing anything with offensive language or graphics.
· Appropriate Fit: Whatever clothing is worn should be clean, pressed, and fit appropriately.
· Maternity: Expectant mothers are permitted to wear long, loose dresses to the office.
· Medical Reasons: In the event that an employee has a medical condition that renders them unable to adhere
to this policy, the policy then may be exempted for them.
· Prohibited attire: Employees are not permitted to wear shorts, flip-flops, ripped or torn jeans, t-shirts, tank
tops, and athletic wear in the office.
· Cultural sensitivity: Employees are expected to be sensitive to cultural norms and customs when dressing
for work.
· Jewellery: Simple jewellery such as a watch, wedding ring, or simple chain necklace is acceptable. However,
flashy or distracting jewellery should be avoided.
· Exceptions: Exceptions to the dress code policy may be made for special events or occasions but must be
approved in advance by management or notified by an internal memo.
Note: This policy is applicable to every female employee of the company including the upper management,
and the company reserves the right to change this policy without any prior notice.
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Employees must strictly adhere to the Dress- Code policy and the employees who are found not complying
with this policy will be asked to leave the workplace and return with modest clothing at their expense, including
penalties of late arrival or one day leave. It's important to remember that clothing can have a significant impact
on how people perceive you, so choose your attire wisely.

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 7.2 Cyber security and digital devices

This section deals with all things digital at work. We want to set some guidelines for using computers,
phones, our internet connection and social media to ensure security and protectour assets.

7.3 Internet usage

Our corporate internet connection is primarily for business. But, you can occasionally use our
connection for personal purposes (with prior approval from your superior/manager/management) as
long as they don’t interfere with your job responsibilities. Also, we expect you to temporarilyhalt
personal activities that slow down our internet connection (e.g. uploading photos) if you’re asked to.

The internet usage (during office hours) even during WFH will be considered Corporate Internet
Connection (if & when the charges are being paid by the company) & shall be governed by the
policies laid here.

You must not use our internet connection to:

● Download or upload obscene, offensive or illegal material.

● Send confidential information to unauthorized recipients.
● Invade another person’s privacy and gain access to sensitive information.
● Download or upload pirated movies, music, material or software.
● Visit potentially dangerous websites that can compromise our network and computers’
safety.
● Perform unauthorized or illegal actions, like hacking, fraud or buying/selling illegal
goods.

7.4 Cell phone usage

We allow use of cell phones at work. But, we also want to ensure that your devices won’t distract you
from your work or disrupt our workplace & its decorum. We ask you to follow a few simple rules:

● Use your cell phone in a manner that benefits your work (business calls, productivity
apps, calendars.)
● Keep personal calls brief and use an empty meeting room or common area so as not
to disturb your colleagues.
● Avoid playing games on your phone or texting excessively.
● Don't use your phone for any reason while driving a company vehicle.
● Don’t use your phone to record confidential information and private
information/pictures etc.
● Don’t download or upload inappropriate, illegal or obscene material using our corporate
internet connection.
● Clicking any pictures or recording any videos at office premise during office hours
should be done only with the consent of Management & people involved

Also, you must not use your phone in areas where cell phone use is explicitly prohibited.

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7.5 Corporate email
Email is essential to our work. You should use your company email primarily for work, but we allow
some uses of your company email for personal reasons.

● Work-related use. You can use your corporate email for work-related purposes without
limitations. For example, you can sign up for newsletters and online services that will help
you in your job or professional growth.
● Personal use. You can use your email for personal reasons as long as you keep it safe and
avoid spamming and disclosing confidential information. For example, you can send emails
to friends and family and download ebooks, guides and other safe content for your personal
use.

7.6 Our General Expectations

No matter how you use your corporate email, we expect you to avoid:

● Signing up for illegal, unreliable, disreputable, or suspect websites and services.

● Registering for a competitor’s services, unless authorized.
● Sending insulting or discriminatory messages and content.

In general, use strong passwords and be vigilant in catching emails that carry malware or phishing
attempts. If you are not sure that an email you received is safe.

8. Social Media Policy

We want to provide practical advice to prevent careless use of social media in our workplace. We
address two types of social media uses: using personal social media at work and representing our
company through social media.

Using personal social media at work

You are permitted to access your personal accounts at work. But, we expect you to act responsibly,
according to our policies and ensure that you stay productive. Specifically, we ask you to:

● Discipline yourself. Avoid getting sidetracked by your social platforms.

● Ensure others know that your personal account or statements don’t represent our company.
For example, use a disclaimer such as “opinions are my own.”
● Avoid sharing intellectual property (e.g. trademarks) or confidential information. Ask your
manager or PR or Management before you share company news that’s not officially
announced. Any un-solicited information related to work or business without proper
authorization may invite legal action not restricted to termination and monetary damages.
● Avoid any defamatory, offensive or derogatory content. You may violate our company’s anti-
harassment policy if you direct such content towards colleagues, clients or partners.

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Representing our company through social media
If you handle our social media accounts or speak on our company’s behalf, we expect you to protect
our company’s image and reputation. Specifically, you should:

● Be respectful, polite and patient.

● Avoid speaking on matters outside your field of expertise when possible.
● Avoid speaking on matters that have not been flagged by the company for the brief or
divulgence of information as such
● Follow our confidentiality and data protection policies and observe laws governing
copyrights, trademarks, plagiarism and fair use.
● Avoid deleting or ignoring comments for no reason.
● Correct or remove any misleading or false content as quickly as possible.

9. Discontinuation of Service

All employees are expected to follow and abide by the Retention & Notice period policy. By joining
the organization after reviewing the offer letter and appointment letter, it will be understood that
the Employee has agreed to all the terms & conditions laid out and that the employee does not have
any objection to the terms. The written acceptance or even absence of it (and the action of joining
the organization) will be construed as explicit consent of the employee to abide by the terms of the
organization. Employees (Including in Probation) need to serve 2 month of notice period. Interns &
Contractors need to serve 1 month Notice period. During Notice Period, Salary will be on hold, and
it will be given within 30 - 45 working days of last working day as Full and Final Settlement.
Employees need to submit company property like Laptop, Code, Data etc. within 7 days of last
working day and take clearance/NOC from HR/Admin/IT & Reporting Manager. Leave policy & other
benefits will remain suspended during Notice Period.

Employee needs to submit a written notice to the management for leaving the organization at
least 02 (two) months via official email Id to HR & Reporting manager before the date of leaving the
organization. During the notice period the employee will discharge his/her services as per the
guidelines of the company & management and will fully help & co- operate the organization in smooth
transition of work from him/her portfolio to his/her replacement.

Any breach of these conditions will not only invite legal action against the employee but would also
result in recovery of monetary damages from the employee in line with the loss/perceivedloss
to the organization due to such action of the employee.

10. Conflict of Interest

When you are experiencing a conflict of interest, your personal goals are no longer aligned with your
responsibilities towards us. In other cases, you may be faced with an ethical issue. For example,
accepting a bribe or any favor that may benefit you financially or in any other way, but it is illegal
and against our business code of ethics. If we become aware of such behavior, you will lose your job
and may face legal action.

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For this reason, conflicts of interest are a serious issue for all of us. We expect you to be vigilant to
spot circumstances that create conflicts of interest, either to yourself or for yourdirect reports.
Follow our policies and always act in our company’s best interests. Whenever possible, do not let
personal or financial interests get in the way of your job. If you are experiencing an ethical dilemma,
talk to your manager or HR and we will try to help you resolve it.

11. Employee Relationships

We want to ensure that relationships between employees are appropriate and harmonious. We
outline our guidelines, and we ask you to always behave professionally.

11.1 Fraternization
Fraternization refers to dating or being friends with your colleagues. In this policy, “dating” equals
consensual romantic relationships and sexual relations. Non-consensual relationships constitute
sexual violence and we prohibit them explicitly. The company PROHIBITS Dating or Romantic
Relationships or Sexual relationships between its employees. Any breach of this policy will invite
strict action including termination & other legal penalties.

11.2 Dating the Managers or Superiors

To avoid accusations of favoritism, abuse of authority and sexual harassment, supervisors must not
date their direct reports. This restriction extends to every manager above an employee.

Also, if you act as a hiring manager or supervising manager, you aren’t allowed to hire your partner
to your team. You can refer them for employment to other teams or departments where you don’t
have any managerial or hiring authority.

11.1 Friendships at Work

Employees who work together may naturally form friendships either in or outside of the workplace.
We encourage this relationship between peers, as it can help you communicate and collaborate. But
we expect you to focus on your work and keep personal disputes outside ofour workplace.
Interactions with any ex-employee needs to be strictly personal basis, and no company information
needs to be shared either verbally or via any other media with such ex- employee(s). In case such
indiscretion comes to the knowledge of the company then the employee & ex-employee both will
be liable to termination and other legal actions including criminal proceedings and monetary damage.

If any ex-employee gets in touch with you and solicits or attempts to solicit company information,
then you are expected to immediately bring such overtures to the notice of the Management.

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12. Solicitation and Distribution
Solicitation is any form of requesting money, support or participation for products, groups,
organizations or causes which are unrelated to our company (e.g. religious proselytism, asking for
petition signatures etc.) Distribution means disseminating literature or material for commercial or
political or religious purposes.

We don’t allow solicitation and distribution by non-employees in our workplace. As an employee,

you may solicit from your colleagues only when you want to:

● Ask colleagues to help organize events for another employee (e.g. adoption/birth of a
child, promotion, retiring.)
● Seek support for a cause, charity or fundraising event sponsored, funded, organized or
authorized by our company.
● Invite colleagues to employee activities for an authorized non-business purpose (e.g.
recreation, volunteering.)
● Ask colleagues to participate in employment-related activities or groups protected by
law (e.g. trade unions.)
● Any religious solicitation is strictly prohibited

In all cases, we ask that you do not disturb or distract colleagues from their work.

13. Prevention of Sexual Harassment (POSH) policy

This policy is in accordance with the provisions of The Sexual Harassment at Workplace (Prevention,
Prohibition, and Redressal) Act, 2013. The purpose of this policy is to prevent sexual harassment
against employees in the workplace and also to protect the managers. Every company aims to
provide a safe working environment for all people.

This policy is applicable to all the members of the company including employer and those
who are employed on regular, temporary, on contract or on a daily wage basis, etc. The
policy also extends to those who are not employees of the company such as customers, clients,
visitors, interns, contract workers, suppliers, etc.

This policy is restricted to the business locations of the company and any external location visited
by the employees during the course of employment whether inside or outside of India.

All the employees should have the personal responsibility to ensure that their behaviour is not
in contravention with the policy.

13.1 Sexual Harassment:

Any Act or behaviour which may be physical, psychological, graphical, emotional, verbal, written,
electronic, gestures which are offending, etc. is defined as inappropriate by the policy. Any act
of the person either intentional or not, should not offend the dignity of theother person. If done so,
then serious disciplinary action is/will be taken against the person who has performed such act.

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13.2 Scope:
This policy applies to all employees (full-time, part-time, trainees and those on contractual
assignments) of the Company including all subsidiaries and affiliated companies at their workplace
or at client sites. The Company will not tolerate sexual harassment, if engaged -in by clients or by
suppliers or any other business associates.

The workplace includes:

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

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

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

13.3 Sexual harassment (direct or by implication) Inclusion:

• Any kind of unusual and unwelcome sexual requests or demand for sexual favors in return
for employment, promotion, examination or evaluation of a person.
• Stalking, displaying indecent posters, showing pornography, sending jokes, comments,
messages which are inappropriate and sexual in nature, lurid stares, physical contact or
molestation, inappropriate sounds, signs, questioning about person’s private life or body,
insults or taunts based on sex or any kind of communication either verbal or non-verbal which
affects the performance of the individual.
• Physical confinement against one’s will and likely to interrupt the privacy of the person.
• Any act or conduct by a person who is in authority, which creates the environment at
workplace hostile or intimidating to a person belonging to the other sex or having alternate
sexual preference.
• Any conduct that has the purpose or the effect of interfering with an individual’s work
performance or creating an intimidating, hostile or offensive work enviro nment and/or
submission to such conduct is either an explicit or implicit term or condition of employment
and /or submission or rejection of the conduct is used as a basis for making employment
decisions.

Any breach of any clause/sub-clause outlined above shall invite strict and immediate action from the
management including termination and registering of complaint before the appropriate authority (ies)
as per the law.

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14. Cyber Security Policy

14.1 Policy Brief & Purpose

Our company cyber security policy outlines our guidelines and provisions for preserving thesecurity
of our data and technology infrastructure.

The more we rely on technology to collect, store and manage information, the more vulnerable we
become to severe security breaches. Human errors, hacker attacks, and system malfunctions could
cause great financial damage and may jeopardize our company’s reputation.

For this reason, we have implemented a number of security measures. We have also prepared
instructions that may help mitigate security risks. We have outlined both provisions in this policy.

14.2 Scope

This policy applies to all our employees, contractors, volunteers and anyone who has permanent or
temporary access to our systems and hardware.

14.3 Policy Elements & Confidential Data

Confidential data is secret and valuable. Common examples are:

● Unpublished financial information

● Transaction Details
● Data of customers/partners/vendors
● Company’s Operations
● Company’s modus operandi
● Company’s Admin and other related information which has not been given permission
for disbursal to the outside world
● Customer lists (existing and prospective)

All employees are obliged to protect this data.

14.1 Transfer of Data

Transferring data introduces security risk. Employees must:

● Avoid transferring sensitive data (e.g. customer information, employee records) to other
devices or accounts unless absolutely necessary. When mass transfer of such data is
needed, we request employees to ask for permission from Management/Manager/Director.

● Share confidential data over the company network/ system and not over public Wi-Fi or
private connection.

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 ● Ensure that the recipients of the data are properly authorized people or organizations and
have adequate security policies.

● Report scams, privacy breaches and hacking attempts

14.2 Disciplinary Action

We expect all our employees to always follow this policy and those who cause security breaches
may face disciplinary & Legal action:

● First-time, unintentional, small-scale security breach: We may issue a verbal warning and
train the employee on security.
● Intentional, repeated or large-scale breaches (which cause severe financial or other
damage): We will invoke more severe disciplinary action up to and including termination &
initiation of Legal Action not limiting to Monetary Damage & Criminal Prosecution under the
provision of law.
● We will examine each incident on a case-by-case basis.

Take Security Seriously

Everyone, from our customers and partners to our employees and contractors, should feelthat their
data is safe. The only way to gain their trust is to proactively protect our systems and databases. We
can all contribute to this by being vigilant and keeping cyber security top of mind.

15. Personnel Administration

Keeping your personnel file up to date can be important to you with regard to pay, deductions, and
other matters. If you have a change in any of the following, please be sure to notify your Manager
or the HR Manager within 48 hours of occurrence.

i) Legal Name
ii) Change in Looks
iii) Home Address
iv) Home Telephone Number
v) Person to call in case of Emergency

16. Employee Maternity Benefits

This policy is applicable to:

All Full- t i m e women associates, working in India for a period not less than eighty days in the twelve
months immediately preceding the date of their expected delivery. This policy is not applicable to
Academic Interns and Contract Consultants (Retainers).

ANTINO LABS provides maternity leave & benefits as per the Maternity Benefits Act, 2017. The
key provision of this act are as follows:

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16.1 In case of Childbirth
An employee is entitled to upto 26 weeks of paid maternity leave. Out of the 26 weeks of maternity
leave, up to 8 weeks may be availed before and including the date of delivery andthe remaining
may be availed after the date of delivery OR the entire 26 weeks may be availed after the birth of
the child, including the date of delivery.

16.2 Availing the Benefits

a. The leave may be prefixed and/or suffixed with other leave types/weekends/statutory holidays.
The other leave types/weekends/statutory holidays will be considered as leavesdays.

b. Maternity Leave should be planned well in advance i.e. at least 8 weeks before availing the
same (except in situations of a medical emergency wherein prior planning may not be possible).

c. An employee who avails maternity leave (for any maternity reason) should submit a medical
certificate substantiating the reason for leave to the Management/HR.

16.3 How much Statutory Maternity Pay will you get?

The amount of maternity pay may you get changed during your maternity leave.

This table shows how much you’ll get at each stage of maternity leave in the 2022 -23 tax year:

• Statutory • Statutory Maternity Pay

Maternity
Leave
• First 26 Weeks • 100% of your gross
monthly earnings before
tax excluding bonus &
allowances

• The next 26 Weeks • Unpaid

Just be aware, if you decide not to return to work after 52 weeks, you might have to pay back any
extra money paid by the organization to you in lieu of this policy. After joining back, Employee need
to complete minimum 1 year of service. If employee resign within 1 year of joining back then she may
need to return extra money paid during maternity leave.

16.4 Employee Paternity Leave Benefits

Employees can take up to 7 days paternity leaves, 15 days before the birth of child or within one
month of the birth of baby. This would be additional to leave balance available. Employees need to
apply this leave at least 1 month before.

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17.0 Travel Policy (For Official Business)
All employees must adhere to the Business Trip & Procedures when incurring travel and
associated expenditure on behalf of the Company.

Wherever possible, and subject to business needs, travel reservations should be ma de in time
to take advantage of cheaper fares or accommodation.

1. Objective: To provide guidelines and establish procedures for employees incurring business-
related travel expenses on behalf of Antino Labs.

2. Scope: The procedure and guidelines outlined in this policy cover all the activities involved in
the travel arrangements for approved company business purposes (e.g. conferences, visiting other
companies, research, generating company income, consulting, professional development, training,
etc.)

3. Procedure and Guidelines

3.1. Approval

3.1.1. The employee needs to share the completely filled Travel Requisition Form for making the
reservations for the travel conveyance and accommodation.

3.1.2. The employee needs to take approval from his/her Reporting Manager before 7 days of the
commencement of the trip.

3.1.3. If the request is made less than 7 days prior to the trip, then the employee needs to take
approval from both the Directors.

3.1.4. The selection of the conveyance and hotel will be done by Travel Team based on the lowest
fare, available. If the employee is not in agreement with the conveyance/hotel selected, He/she will
communicate his/her choice to HR, who in turn will put it up to the Directors for approval. Only with the
approval of the Directors, the changes will be made.

3.2. Arrangements

3.2.1. Hotel Arrangements

3.2.1.1. Lodging:

3.2.1.1.1. Employees travelling alone must stay in a single room with a private bath, as opposed to
a larger double room or suite if a larger room results in an additional cost to Antino Labs.

3.2.1.1.2. Employees will get breakfast at the hotel provided by the company while on a business
trip. Rest of the meals can be bought by using the daily allowance been allocated to each employee
as per their grades.

3.2.1.1.3. Employees are themselves responsible for checking out on-time and will not be
reimbursed for additional charges beyond the approved length of stay.

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3.2.1.1.4. In case an employee stays with a friend/relative, he/she will be paid 70% of the Lodging
Expense.

3.2.1.2. Hotel Upgrades:

3.2.1.2.1. Upgrades to suites or executive floor rooms are acceptable only if it creates no additional
cost to Antino Labs, such as when the rate for the upgraded room is the same as a single room
booked by Travel Team.

3.2.1.2.2. Wherever a guest house is made available by the company or the client, it is compulsory
to use the same.

3.2.1.2.3. Employees should prefer to share a room with a colleague while on travel.

3.2.2. Travel Arrangements:

3.2.2.1. Category and Guidelines: Employees need to request for conveyance 10 days before the
approximate departure & arrival time. The eligibility criteria for each conveyance will be defined by
the management team.

3.2.2.2. Travel within NCR

3.2.2.2.1. Metro should be used for business commuting purposes wherever possible.

3.2.2.2.2. The employee should use OLA (Pool/ Micro/ Mini) or UBER (Pool/ Go/ Premier)only
if metro connectivity isn’t available and should travel by the shortest route so that the expenses can
be minimized.

3.2.2.2.3. If the vendor is not authorized as OLA & UBER, then inform the Travel Team aboutit and
take the bill.

3.2.2.2.4. In the case of auto-rickshaw, it is up to the jurisdiction of the management for approval.

3.2.2.2.5. If less expensive and less time consuming than renting a car, taking a taxi, oralternate
transportation an employee may use his personal vehicle for short-distance travelfor business
purpose.

3.2.2.2.6. Employee’s personal car at Rs 8/- per Km & two wheelers at 4/- per km will be
reimbursed at actual. Bill should be around the amount claimed in the expense claim sheet by
the employee.

3.2.2.2.7. The toll and parking fees will be paid extra at actual on submission of original payment
receipts/bills.

3.2.2.2.8. An employee using a personal vehicle has to necessarily bear a legal Driving License.
In case he has a driver, the driver should be the valid license holder.

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3.2.2.2.9. It is recommended that employees using personal vehicles on company business have
adequate automobile coverage (Insurance, Road Tax, and Other necessary documents)

3.2.2.2.10. Employees will not be reimbursed for any repairs to their personal vehicle and/or
insurance deductibles even if the breakdown or accident occurs during business travel.

3.2.2.3. Air Travel

3.2.2.3.1. Air travel is allowed only if the distance of the destination is more than 600 km.

3.2.2.3.2. After the booking, the flight details will be given to the employee (via SMS
/phone/email). The ticket may be downloaded from the internet with the PNR number.

3.2.2.3.3. Overnight Delays / Layovers - Should airline scheduling delays necessitate an overnight
stay; the employee must first attempt to secure complimentary lodging from the airline. If
unsuccessful, the employee should find his/her own accommodation complying with the company
travel policy.

3.2.2.4. Rail Travel: Rail travel should be used when:

3.2.2.4.1. Less expensive than air travel

3.2.2.4.2. Adding no more than six hours to total travel time

3.2.2.4.3. Less time consuming than driving

3.2.2.4.4. Dictated by weather

3.2.2.5. Ground Transportation

3.2.2.5.1. If the distance is greater than 200 km or duration is more than 3 hours, then choose either
bus or train, whichever is available at a reasonable price.

3.2.2.5.2. To and from the Airport: The most economical mode of transportation should be used to
and from airports, bus and rail terminals. Employees are encouraged to use hotel and airport shuttle
services when available. Employees will be reimbursed for tolls, parking charges, taxis, subways,
and other modes of public transportation for assignments away from the employee’s primary work
location on submission of original payment receipts/bills.

3.2.3. Client Side/Travel Allowance

Monthly Client Side/Travelling Allowance

Distance from office 3-5 Days/week 1-2 days/week
<5 km 0 0
5 - 20 km ₹4000 ₹2500
20 - 50 km ₹5000 ₹3000
>50 km ₹9000 ₹5000
1. Distance will be considered minimum distance from Office to Client office as per Google Map
2. Employees should prefer taking Metro, Auto, Bike Taxi and other available public transport
3. The Above-mentioned allowance is monthly and will be paid along with salary,
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 4. Employees should prefer travelling by flight/train if distance is far more than 50 km.

Note: Travel allowance given above will be applicable if employee is working on the client’s
side and the employee needs to take approval from his/her Reporting Manager for such
reimbursement.

3.2.3.1. Method of Reimbursement:

3.2.3.1.1. Login to Employee Self Service Portal (ESS)

3.2.3.1.2. Click on Expenses Tab

3.2.3.1.3. Submit Expense Claim Sheet (Fill all the necessary details)

3.2.3.1.4. Make an entry in the Reimbursement sheet available on drive, mentioning the amount to
be reimbursed and its associated remarks/description by filling the Reimbursement Details table
attached as Annexure-III

3.2.3.1.5. Submit the hard copies of the bills to the HR

3.2.3.1.6. The reimbursement amount will be transferred to the employee’s bank account with the
salary.

3.2.1.1. Receipts:

3.2.1.1.1. Employees are required to attach the original receipts (that are collected for each and
every request for travel reimbursement) in the expense claim sheet on ESS

3.2.1.1.2. All the submitted expense claim sheets which do not have the required receiptswill be
rejected.

3.2.1.1.3. Employees are required to submit the hard copy of the same to the Travel Team.

3.2.1.1.4. Bank Account Statements will not be accepted.

3.2.2. Payable Reimbursement: Employees may only receive reimbursement for actual, reasonable
travel costs up to the limits prescribed in the annexure of this policy.

3.2.3. Expense Claim-Time Limit: Claims for reimbursement of the expenses for approved company
business travel (including conferences and official meetings) are to be made on ESS before 5th of
the very next month after returning from the trip.

4. General Guidelines

4.1. Employee Responsibility:

4.1.1. Complying with the Travel Policy

4.1.2. Accurate submission of original travel expenses receipts within policy guidelines

4.1.3. Completing expense sheets timely

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4.2. Audit: At the sole discretion of Antino Lab, all expense reports are subject to audit either before
or after reimbursement. The company assumes no such obligation to reimburse employees for travel
expenses that are not in compliance with the policy.

4.3. Non-Reimbursable Expenses

4.3.1. Expense claim requests that are incorrect or incomplete will be returned for corrective action
and if submitted late, or returning from the Client site on your own will then all the expenses during
your return will result in non-reimbursement of expenses.

4.3.2. Apart from Hotel Stay (including breakfast), no other luxuries taken at the business trip will
be reimbursed.

4.4. Extending Business Trips for Personal Travel: Employees may extend business trips for
personal travel, provided that:

4.4.1. An employee is eligible for and has accrued a sufficient leave balance.

4.4.2. Trip extensions do not interfere with business commitments and are approved in writing by
the employee's direct manager.

4.4.3. The employee must document with Travel Team when booking, which portions of the trip are
business and personal. The employee will be responsible for all expenses above the cost of an
equivalent business trip without a personal extension.

4.5. Spouse/Family Accompaniment: As a general rule, the company does not reimburse for
spouse/family accompaniment. A spouse or other individual may accompany an employee on a
business trip at the employee’s expense. Any arrangements for the spouse or companion will
be booked outside the Antino Lab travel program.

The following expenses are not reimbursable:

1. Additional travel insurance, travel accident insurance or trip cancellation premiums.

2. Alcoholic beverages consumed as part of meal or otherwise while traveling onCompany

business.

3. Additional expenses associated with the cost of first class or business class or any class
higher than economy class airfare.

4. Childcare and babysitting expenses.

5. Additional travel insurance, travel accident insurance or trip cancellation premiums.

6. Alcoholic beverages consumed as part of meal or otherwise while traveling onCompany

business.

7. Additional expenses associated with the cost of first class or business class or any class
higher than economy class airfare.

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8. Childcare and babysitting expenses.

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9. Corporate Travel Card delinquency assessments.

10. Costs for personal medications.

11. Costs incurred by your failure to cancel transportation or hotel reservations.

12. Costs incurred by your spouse or other dependents traveling with you.

13. Entertainment expenses, including movies in your hotel room.

14. Host/hostess gifts, in lieu of meals and lodging, when the cost exceeds what meal
and/or lodging expenses would have been.

15. Additional travel insurance, travel accident insurance or trip cancellation

premiums.

16. Alcoholic beverages consumed as part of meal or otherwise while traveling on

Company business.

17. Additional expenses associated with the cost of first class or business class or any
class higher than economy class airfare.

18. Childcare and babysitting expenses.

19. Corporate Travel Card delinquency assessments.

20. Costs for personal medications.

21. Costs incurred by your failure to cancel transportation or hotel reservations.

22. Costs incurred by your spouse or other dependents traveling with you.

23. Entertainment expenses, including movies in your hotel room.

24. Host/hostess gifts, in lieu of meals and lodging, when the cost exceeds what meal
and/or lodging expenses would have been.

25. Hairstyling and haircut, SPA or Massage expenses.

26. Kennel/boarding expenses for pets.

27. Laundry or dry-cleaning expenses.

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 28. Magazines or Newspaper expenses.

29. Other expenses not directly related to the business purpose of the travel assignment.

30. Parking or speeding tickets.

31. Personal telephone calls in excess of one per day.

32. Lost luggage and contents. Employees should work directly with the airline and credit
card insurance carrier to recover damages.

33. Personal gifts, Gift cards in any amount for employees or non-employees

34. Hands-free devices, i.e. Bluetooth headsets, not obtained through IT Support Services
or without company’s authorization.

35. Any technology equipment or supply purchased by an employee which is referenced

on the IT Hardware and Software Standards document.

18.0 Retirement Policy

You will automatically retire from the Company on attaining the age of [60] years. An extension may,
however, be given at the discretion of the Company.

19.0 Asset (Physical & Softcopy/Abstract) Policy

The employee, at times (in some cases) can be provided the following equipment (physical assets):
mobile phone, SIM card, laptop, power cord, dongle and carrying case or any other physical asset
that the company has procured or abstract/softcopy of programs, codes etc. developed and handed
it to employee for the temporary possession and for official (company’s business) use only. The
employee agrees that the equipment is in good working order at the time of taking possession of the
same. If the employee retires, resigns from the organization, or transfers to work at another location,
all equipment (or assets) must be returned to the company at the office/site listed below.

The employee is responsible for such assets & equipment at all times. The employee is responsible
for taking reasonable precautions to secure the assigned assets in such a manner that it will not
be subject to theft or damage. Loss, theft or damage to such equipment or assets including laptop
etc. must be reported to the employee’s Manager/supervisor. Employees are responsible for any loss,
theft or damage that occurs outside of the stated work location (office &/or work from home –
employee’s home).

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Employee may elect to provide a police report indicating the cause of the loss, theft ordamage
to the asset to company. If a police report is not provided, then the employee is liable for the full
replacement value of the asset as specified below.

• If an asset is damaged or in need of repair, the employee should submit a complaint ticket
to the company or follow other technology support request protocols established by the
company.
• If an asset has been lost or stolen, the staff member is directed to notify his/her
supervisor/manager of the loss or theft.

19.1 ACCEPTABLE USE OF TECHNOLOGY:

● The employee in whose name the asset is issued is responsible for its proper use at all times.
Employees shall keep account information, home addresses and telephone numbers & their
schedule of travel upto date with the company. They shall use the system only undertheir
own account identification & in line with the company policy.
● Employee shall use the system safely, responsibly and primarily for official work- related
purposes only.
● Employee shall conduct company’s business through safe communication systems.
Employees shall not use personal e-mail or social media accounts for official business.
● Employee shall not access, post, submit, publish or display harmful or inappropriate matter
that is threatening, obscene, disruptive, or sexually explicit, or that could be construed as
harassment or disparagement of others based on their race, ethnicity, national origin, sex,
gender, sexual orientation, age, disability, religion or political beliefs while working for the
company and using company’s assets.
● Employee shall not use the system to promote unethical practices, or any activity prohibited
by law
● Employee shall not use the system/company’s assets to engage in commercial or other for-
profit activities not related to the company's business and in case such usage is required
then only with explicit permission of the management.
● All Company property – including desks, storage areas, work areas, lockers, file cabinets,
credenzas, computer systems, office telephones, cellular telephones, modems,
facsimile machines, duplicating machines, copying machines and vehicles
– must be used properly and maintained in good working order. Employees who lose,
steal, or misuse Company property may be personally liable for replacing or repairing the
item.
● The Company reserves the right, at all times and without further notice, to inspect and search
all Company property for the purpose of determining whether this policyor any other policy
of the Company has been violated, or when an inspection and investigation is necessary for
purposes of promoting safety in the workplace or compliance with state and federal laws.
● These inspections may be conducted during or outside of business hours and in the presence
or absence of the affected employee.

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 ● To protect the Company’s legitimate business interests, the Company reserves the right to
question and inspect or search any employee or other individual entering or leaving Company
premises, with or without notice. The inspection or search may include any packages or items
that the individual may be carrying, including briefcases, handbags, knapsacks, shopping
bags, etcetera. The individual may be requested to display the contents of any packages
and/or turn out his or her pockets, etcetera, in the presence of a representative of the
Company, typically a management employee of the same gender.
● Whether information is entered or sent during or outside of working time, employees have no
right of privacy as to any information or file maintained in or on Company property or
transmitted or stored through Company computer systems, voice mail, e- mail or other
technical resources. If, during the course of your employment, you perform or transmit work
on Company computer systems or other technical resources, your work may be subject to
the investigation, search and review of others in accordance with this policy. In addition, any
electronically stored communications that you either send to or receive from others may be
retrieved and reviewed when doing so serves the legitimate business interests and
obligations of the Company.
● Employees should use the computer systems only for business purposes. Using e- mail or
the Internet for personal, non-business, purposes is prohibited during working time.
● Employees may access only electronic files or programs that they have permission to enter
or access. Unauthorized copying or use of computer software exposes both the Company
and the individual employee to substantial fines and/or imprisonment. Therefore, employees
may not load personal software onto the Company’s computer system, and may not copy
software from the Company for personal use. All employees must contact the Admin to install
any software on the Company’s computer system.
● Unauthorized review, duplication, dissemination, removal, installation, damage or alteration
of files, passwords, computer systems or programs, or other property of the Company, or
improper use of information obtained by unauthorized means, will not be tolerated.
● Messages stored and/or transmitted by voice mail or e-mail must not contain content that
may reasonably be considered offensive or disruptive to any employee. Offensive content
would include, but not be limited to, sexual comments or images, racial slurs, gender-specific
comments or any comments or images that would offend someone on the basis of his or her
age, sexual orientation, religious or political beliefs, national origin or disability.

19.2 COMPUTER AND SYSTEM SECURITY

● All computers and the data stored on them are and remain at all times the property ofthe
Company. As such, all messages created, sent or retrieved over the Internet or the
Company’s electronic mail system are the property of the Company, and should be
considered public information. The Company reserves the right to retrieve and read any
message composed, sent or received on the Company’s computer equipment and electronic
mail system. Employees should be aware that, even when a message is deleted or erased,
it is still possible to recreate the message; therefore, ultimate privacy of a message cannot
be ensured to anyone. Accordingly, Internet and electronic mail messages are public
communication and are not private.
● Furthermore, all communications, including text and images, can be disclosed to law
enforcement or other third parties without prior consent of, or notice to, the sender orthe
receiver.

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19.3 VIOLATIONS

Violations of any guidelines listed above may result in disciplinary action up to and including
termination. In addition, the Company may advise appropriate legal officials of any illegal violations.
This policy is in no way intended to modify the at-will nature of employment with the Company.

In case the asset is not returned by the employee at the end of his/her tenure with the company, the
company shall be entitled to

● With-hold all payment dues to be made to the employee

● With-hold salaries
● With-hold full and final settlement and other related formalities like issuing NOC, Leaving
Certificate or Experience certificate
● Initiate the legal proceeding against the employee for breach of contract and breach of
confidential information which is stored on the laptop & is proprietary asset/property of the
company
● The company will be under its rights to withhold the payment of dues to the employee till
the time the IT department of the company checks the submitted/surrendered assets for its
workability, security & other parameters like data safety & security. Once satisfied the
company may release the dues to the employee and if there is some damage or data missing
or some suspicious activity or deliberate activity to bring damage to the company or its assets
is recovered during such check & audit, the company will be under its rights to initiate
monetary recovery form the employee and also initiate appropriate legal action against the
employee under relevant sections of the Indian Law.

20.0 Intellectual Property Rights (IPR) Policy

The company has an efficient Intellectual Property Rights (IPR) Policy and Intellectual Property
Management guidelines (Collectively referred to as 'IP Policy' or ‘IPR Policy’, hereinafter) in place
basically to maintain absolute clarity on IPR related iss ues such as ownership, rights and obligation
of employees and Company, rights and obligation of customers and Company, disclosure of work/
invention, non-disclosure of confidential information, liabilitiesin case of misappropriation of IP or
resolution of IP related disputes strategically. Intellectual property (IP) is one of our most valuable
assets. We rely on various types of intellectual property (such as trademarks, patents, copyrights,
trade secrets, domain names, design rights) for our success in the market. IP helps us stay
competitive, allows usto fund future successes, and supports each of our jobs at the Company. The
Company has a consistent policy of identification of Company's intangible assets, prioritizing them
according to Company's business plans, registering, exploiting and safeguarding them in order
to benefit fully from IPin terms of revenue, reputation and market share. The Company's IP Policy
also envisages protection and management of its own IP assets, internally and with its business
partners. The company also respects the IP of others as it develops the products and services. This
IP Policy aims to provide a transparent administrative system for the ownership, control and transfer
of the IP created and owned by the Company. This IP Policy is applicable to all the employees,
representatives and agents of the Company including its Subsidiaries and Affiliates.

20.1 Policy & Procedure

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 1. Company shall respect intellectual property (IP) and conduct its business in compliancewith
the IP-related laws as applicable in the jurisdiction of Republic ofI ndia and its agreements
with other companies.
2. Company shall actively protect its own IP.
3. Company shall maintain an effective system of IP asset management, including maintaining
an inventory and records of IP-related assets and agreements.
4. Company shall not knowingly infringe a third party's intellectual property in its products,
services, or components, or disclose or use a third party's trade secrets without the express
or implied consent of the owner or as permitted by law.
5. Company shall not knowingly purchase or use counterfeit or other infringing goods and
services in running its business, including counterfeit trademark goods or infringing copyright
material (such as software, publications, video, audio, or other content).
6. Company shall document and maintain written records of all substantial transactions and
uses that involve the exercise of IP rights. (This includes, for example, licenses or
assignments of rights; manufacture, reproduction or distribution of patented, trademarked or
copyrighted items; and disclosure and use of trade secrets.)
7. Company shall require, through binding policies or agreements with employees and
contractors that its personnel comply with the applicable IP laws and the Company'sIP
policies and IP-related provisions in agreements with other companies.
8. Company shall develop and implement a management system to help ensure that all
personnel follow its IP policies. This management system shall encompass all IP- related
policies, procedures and adequate and accurate records necessary to implement, measure,
and improve Company's IP protection and compliance program.
9. Any IP developed by any employee while on active employment of the company (regular
employment, contractual employment, Trainee, Internship) will be the sole property of the
Company. The company shall be the only & complete, undisputed owner of such IP and its
rights to use (monetize, usage, licensing etc). Any employee will have no right (either
complete or partial) in the IP thus created and owned by the company.

20.2 Compliance Team

Company's IP protection and management shall be implemented through a cross -functional

compliance team, overseen by a Director of the Company or designated senior management.
The said compliance team may appoint or engage any advocate or expert from within and/or outside
the Company to seek their opinion in carrying out their responsibilities as stated under this IP Policy.

20.3 Security Management of IP

1. Company shall maintain physical security designed to effectively protect trade secrets (where
applicable) and other confidential information, and IP-related records, masters, tools, inventory
and related materials.
2. Company shall maintain computer and network security effective for protecting trade secrets,
other confidential and proprietary information, and IP related records, and for discouraging
violations of Company's IP policies on the Company's computers and networks.
3. Company and its personnel shall only make trade secrets and other proprietary information
available to third parties on a “need to know?? basis, and subject to

Page | 34
 company procedures and written agreements containing adequate confidentiality and other
protections.
4. Company shall execute written confidential or Non-disclosure agreements with third parties
prior to disclosure of any confidential information of the Company to any third party (ies).
5. Any IP generated, created or developed by any of the employees/representativesand
agents of the Company and/or consultants engaged by the Company, during the term of their
employment or engagement as the case may be, for and/or on behalf ofthe Company,
shall be “work made for hire” and shall be assigned by such persons to the Company. Further,
the Company shall have the sole and exclusive ownership to such IP generated, developed
or created unless otherwise agreed by the Company by way of a written contract or as may
be applicable by the relevant IP law.

20.4 IP Monitoring

1. Company shall establish and operate a system to monitor its performance in meetingt he
Company's relevant IP policies.
2. Company shall incorporate the information gained from the IP compliance team through the
monitoring system into the overall evaluation of its departments.

20.5 IP Violation & Action

1. Company shall develop and implement an annual or other regular improvement plan for IP
protection, management, and compliance.
2. In case of violation/infringement of any IPR such as trademark infringement by any
employee/representative or any third party infringing upon the IPR of the Company, the
Compliance Team of the Company would first investigate the matter in associationwith
its Advocates and make recommendations to the Director/Management for resolution of such
violation/infringement including need for any legal course of action.

20.6 IP Licensing:

1. The Company may license its IP to any of its Subsidiaries, Affiliates or a third party (ies)
through various modes of licensing strategy such as: Exclusive licensing, Sole licensing,
Non-Exclusive Licensing, Sub-licensing and licensing in general. The Company shall
document such IP licensing through a license Agreement where each such license
agreement shall define the terms and conditions for the proper use of IP of the Company.
2. The Company may transfer its IP to any of its Subsidiaries, Affiliates or a third party (ies)
through a signed IP transfer agreement on the conditions as may be deemed to be fit and
proper to the Company.
3. This Policy shall be governed by the laws of Republic of India and the courts at Gurugram,
Haryana shall have the jurisdiction to the same.

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21.0 Control of Documents

All the internal documents shall be under the purview of the confidentiality & IPR clauses. Documents
(physical or softcopy) shall include (& mean) information, emails, data, codes, algorithms, programs
etc.

All such documents shall be under the control of certain authority/manager/executive and thus their
disbursal (authorized only) shall be his/her responsibility. The documents which are to be updated
and renewed in any sense shall carry ‘version number’, ‘updation date’, ‘created by’ & ‘approved by’
information as per the company nomenclature and numbering system.

Any access to such documents shall ONLY BE through authorized approval by the personnel in-
charge of such document. For e.g. Offer Letter, Appointment Letter, HR/Employee Manual shall be
the responsibility of HR and any unauthorized access to such documents shall mean liability lying at
the feet of HR.

22.0 Reward & Recognition Policy

PURPOSE:

To reduce Attrition Rate and improve Employee Loyalty & Motivation.

OBJECTIVES:

To provide guidelines to recognize specific, unique, value added and critical performance
incidents within or beyond expected & predefined performance objectives.

To align employee performance and achievements in line with Company’s Value Charters &
Mission Objectives.

To reward the performance incidents in monetary or non-monetary terms indicating

organizational recognition and appreciation towards the employees.

22.1 SCOPE APPLICABILITY:

Whole of employees / divisions / functions or regions (define as it suits and organization needs

it)

22.2 GENERAL RULES:

22.2.1 NOMINATION: (INDIVIDUALS / TEAMS / GROUPS):

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All Managers/Department Heads (along with inputs from immediate Superiors/Reporting Authorities
wherever applicable) can nominate employees/teams who have shown reward- worthy performance,
behavior, skills or competence.

22.2.2 General Guiding Principles for R&R Programs:

Award Frequen Parameters Nature of

cy Award

“Achiever of Monthly The “Achiever of the Month” Token of Gratitude

the
Month” Award- (Best Employee) is along with a
Award for
work or a good deed done Certificate of
within
(Best
Employee) The employee’s job Appreciation.
description,
such as taking extra care,
making
sure everything is done
promptly
and correctly, helping
others
Within their department, or

Willingly filling in when

someone
is absent.

Evaluation Criteria:

• 70% for the Punctuality

(Based on the total Desktime

of the month).

• 30% for Work Ethics &

Behavior

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“Ace of Monthly The “Ace of Initiative”Award- Token of

Initiative” (Best Manager) Gratitude along

Award (Best with a

A good manager follows the
Manager) Certificate of
threeships of management:
Appreciation.
Leadership, Mentorship,

Ambassadorship.

- Leadership involves creating

decisions such as which

projects to choose.

- Mentorship is an efficient way

to grow a team in ways that

are mutually beneficial.

- Ambassadorship

meansrepresenting the team

within the broader socio-

political context of your

organization.

Evaluation Criteria:

• 60% to the Results

• 20% to the Impact on

otherssuccess

20% for Work Ethics & behavior.

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“Go to the Mont The “Go to that Extra Mile (GEM)” Token of Gratitude
hly
Extra Mile Award- (A person who did along with a

(GEM)” Exceptional) is for employees who Certificate of

Award do exceptional work. It is for

employees who have been

observed doing more than their job

requires or doing the job

exceptionally well, going out of their

way or taking extra steps to

complete their job, for

enhancing/encouraging/supporting

teamwork or for doing things

outside of their job description.

This award is for something that

requires extra time and effort.

Evaluation Criteria:

• 60% for the Goes above and

beyond expectations.

• 20% for the Quality of

workperformed.

20% for the Excel as a teamplayer.

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3. General Guidelines

3.1. The company may decide to reward or recognize any other extraordinary
efforts/behaviors/results that are not mentioned in this manual. The management would be the final
authority to decide on such matters.

3.2. Reward programs will be carried out on Monthly basis.

3.3. In case of any dispute or any complaints about the Rewards & Recognition programs employees
can inform the HR who will look into the matter.

22.2.3 PERIODICITY:

Assessments and recommendations can be done on monthly basis and one employee can be
nominated multiple times in different months. Further spot achievement awards can be
recommended during shorter terms of monthly basis. For ongoing performance achievements
these awards can be assessed monthly basis.

BENCHMARKING REWARD-WORTHY: PERFORMANCE/BEHAVIOR/COMPETENCE

In order to align employee performance to Company’s Values & Mission Objectives, the standards
can be set against the 4 value & mission objectives. Employee showcasing exceptional examples
of following up these values can be considered for Rewards & Recognition Program.

THE 4 VALUES ARE

a) Leadership

b) Innovation

c) Openness

d) Teamwork

22.2.4 CRITERIA:

● Cost Effectiveness.

● Discipline & punctuality at work.

● Behavior at work with his peers, subordinate & immediate supervisors

● Contribution towards Process Objective or Company's Values/Mission

● Attitude, Initiatives, Knowledge of work, Willingness to learn, Achievement

● Anything that goes above and beyond the normal work expectation and benefits the

company
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23.0 Grievance Policy & Procedure
23.1 Introduction

Although we at Antino Lab seek to provide a workplace in which all employees feel that they are an
important part of Antino Lab and where employees feel fairly treated, there may be times when you
have a dispute with a supervisor or the Company which can best be resolved through a formal
procedure for dispute resolution. All disputes between any employee and the Company are to be
resolved by in accordance with the following procedure. Please note, however, that the Company
reserves the right to modify this procedure at any time and nothing in this procedure should be
construed to constitute a contract between you and the Company or to constitute any part of a
contract between you and the Company. We define grievance as any complaint, problem or concern
of an employee regarding their workplace, job or coworker relationships.

Employees can file grievances for any of the following reasons:

● Workplace harassment

● Health and safety

● Supervisor behavior

● Adverse changes in employment conditions

This list is not exhaustive. However, employees should try to resolve less important issues informally
before they resort to a formal grievance.

Any dispute between you and the Company may be resolved using this grievance procedure, except
for oral reprimands which are not recorded in your personnel file.

A grievance is a complaint by an employee concerning any matter related to the employee’s

employment with the Company. All grievances must be in writing. Using the form provided by the
Company, you must state clearly and concisely all the known facts related to your grievance,
including “who, what, where, when and the why.” Clearly explain why you disagree with an act
or omission that forms the basis for the grievance. Also explain what remedy you are requesting. You
must sign and date the grievance. The form needs to be shared with the designated authorities (as
mentioned below) and a copy of the same to besent on hr@antino.com

23.2 Grievance Procedure

Preliminary Step

You must first address your grievance with your immediate supervisor. This may be done orally
in informal discussion. If your informal attempts to resolve the matter are not successful, you may
implement the formal grievance process.

Step 1

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You must first submit your grievance in writing to your immediate supervisor. Grievances must be
submitted within 15 calendar days following the date you first knew or should have known of the
grievance. If you do not submit the grievance within the 15 days period, youwaive your right to assert
it. Your supervisor will respond in writing within ten (10) days following receipt of your grievance. All
grievances and replies in Step 1 must be in writing. If the grievance is not settled in Step 1, then you
may proceed to Step 2.

Step 2

Within ten (10) days following your receipt of the written answer to your Step 1 grievance from your
supervisor, you may appeal the disposition of your grievance by your supervisor toHR. The HR Head
will then undertake an investigation of your grievance and the underlying facts. Within
10 business days following receipt of your grievance the HR Head will meet with you in person
to discuss your grievance. The HR Head will then provide a written response to your grievance within
10 business days following the date of your meeting.

Step 3

If you are not satisfied with the response of the HR Head at Step 2, you may submit your grievance
to the Director of the Company or the Director’s designee for review within five (5) days following
receipt of the written response from your HR Head. The Director or his designee will review the
grievance and provide a written response within 15 business days following receipt of the Step 3
grievance.

The grievant bears the burden of proof as to the validity of the grievance.

Employees who face allegation have the right to:

● Receive a copy of the allegations against them

● Respond to the allegations

● Appeal on any formal decision

The company is obliged to:

● Have a formal grievance procedure in place

● Communicate the procedure
● Investigate all grievances promptly
● Treat all employees who file grievances equally
● Preserve confidentiality at any stage of the process
● Resolve all grievances when possible
● Respect its no-retaliation policy when employees file grievances with the company or
external agencies

The decision of the Director(s)/Management shall be in writing and the decision will be deemed final
and binding. Henceforth, you waive your right to bring any action in court.

# Grievance Form is available with HR

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24. ZERO TOLERANCE POLICY

24.1. The intent of this policy:

Zero Tolerance Policy is part of our commitment to providing a safe and dignified work
environment for all employees, regardless of gender, race, ethnicity, sexual orientation,
disability, religion, or any other aspect of their identity. All employees are responsible for
conducting themselves in a professional and inclusive manner, and disciplinary action will be
taken in situations where an employee’s behavior violates this expectation. The Policy covers
harassment, bullying, data breach and discrimination both in and out of the office and provides a
standard for addressing allegations of inappropriate behaviour, ensuring fairness and equal
treatment.

24.2. Scope

All company employees, volunteers, contractors, and vendors regardless of employment

agreement or rank.

24.3. Policy

Any employee who is found to have been involved in harassment, bullying, data breach or
discriminatory behavior will be subject to immediate disciplinary action, up to and including
termination. If the company becomes aware of a contractor or vendor engaged in inappropriate
behavior, the relationship will enter a probationary period or be terminated, depending on the
severity of the incident.

When a company becomes aware of an incident involving harassment, bullying, data breach
or discriminatory behavior an [internal or external] independent third party will investigate the
matter. During the investigation, the accused employee(s) may be removed from the working
environment and, in extreme cases, may be suspended on full pay.

To ensure a safe and inclusive workplace, all employees are asked to report instances in which they
experienced or witnessed harassment, bullying, data breach or discrimination (as defined below).
To notify us of the incident, please reach out to HR on hr@antino.com. When you reach out, we
ask you to include the following information:

• Fairness:

All employees at a company are guaranteed a fair and impartial investigation process. The
integrity of the investigation is the joint responsibility of the senior leadership and Board of
Directors, whose personal biases and individual relationships will never factor into the
investigation. If a member of leadership or Board of Directors has a direct or indirect conflict - of-
interest, they will recuse themselves from the processes. To ensure fairness, investigations
will be carried out by HR and an independent third party with no actual or perceived conflict of
interest in the outcome.

• Transparency:

Company commits to a discrete but transparent investigation process. Throughout the

investigation, all involved parties (i.e., the employee(s) making the complaint(s) as well as the
employee(s) accused of misconduct) will be provided regular updates as to the status of the
case. After the investigation has been concluded, a detailed written response will be provided.

24.4. Prohibited Conduct

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The Policy applies to any individual who engages in the following behavior(s):

1. Harassment: The Occupational Health and Safety Act defines workplace harassment
as “engaging in a course of vexatious comment or conduct against a worker in a workplace that
is known or ought reasonably to be known to be unwelcome. More simply put, harassment
is any one-time or repeated unwanted physical, verbal, or non- verbal conduct that violates a
person’s dignity or creates an intimidating, hostile, degrading, uncomfortable, or toxic
environment.
Examples of harassment include, but are not limited to:
• Making threatening remarks
• Sexual assault
• Gender-based insults or jokes causing embarrassment or humiliation
• Repeated unwanted social or sexual invitations
• Inappropriate or unwelcome comments on a person’s physical attributes or
appearance

2. Bullying: Bullying is any physical, verbal, and non-verbal conduct that is malicious or
insulting. Bullying can make a person feel vulnerable, excluded, humiliated, undermined,
fearful, or threatened. Bullying can take the form of physical, verbal, and non-verbal
conduct. Examples of bullying include, but are not limited to:
• Physical threats
• Psychological threats
• Overbearing or intimidating levels of supervision
• Shouting at colleagues in public or private
• Spreading malicious rumours

3. Discriminatory Behavior: Discrimination refers to behavior that treats people differently

or adversely because of one or more of the facets of their identity, including race, color,
ethnic origin, gender expression, religion, age, sex, sexual orientation, marital status,
family status, physical or mental disability, or genetic characteristics. Any such behavior
can have lasting emotional and mental effects on the individual or individuals targeted and
can contribute to a toxic and non-inclusive workplace. Examples of discrimination include, but
are not limited to:
• Making insensitive jokes
• Factoring an individual’s identity into a hiring decision
• Purposefully excluding a colleague based on their gender
• Using a racial slur
• Repeatedly calling a racialized employee by the name of a different person of the
same race
• Commenting on a person’s physical appearance in reference to racial
characteristics such as skin tone

4. Data Breach: Any security violation, in which sensitive, protected or confidential data is
copied, transmitted, viewed, stolen, or used by an individual unauthorized to do so will
come under data breach. Examples of data breach in the workplace can include, but are
not limited to:
• Sensitive financial data of company
• Business related data (business model, client data)
• Employee confidential data (compensation, increment, performance bonus)
• Loss or theft of equipment containing Departmental information
• Using unencrypted memory sticks
Any individual or group of individuals who will disclose any confidential information will be liable
under this policy. Disciplinary actions will be taken on the individual disclosing the information
and the one to whom it is disclosed.

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 5. Damage to company property: “Property,” as the term is used in this policy, is defined as
any piece of equipment, furnishing, vehicle, building or supply leased, owned, donated or
otherwise in the custodial care of company or any person acting as its agent. If there is a
clear indication that company property damage was the result of employee misuse or
abuse, the company may try to recover costs associated with replacing the equipment from
the said employee.

24.5. Disciplinary Action:

Employees who are found to be in violation of the Zero Tolerance Policy may face a variety
of disciplinary actions, up to and including immediate termination. Disciplinary action may be
recommended by an independent investigator and will be determined by senior leadership. The
severity of the disciplinary action depends on the type of misconduct, which may include but is
not limited to temporary leave without pay, probationary period placement, and permanent
dismissal and legal recourse.

24.6. No Retaliation

Any employee who files a valid complaint will not be subject to any form of retaliation, either
direct (i.e., dismissal or demotion) or indirect (i.e., being passed over for a promotion).
Employees who do participate in retaliatory measures will be investigated and subject to
disciplinary action.

24.7. Appeals Procedure

Employees who have been found to be in violation of the Zero Tolerance Policy may appeal
this finding. To do so, they must file a written appeal with a member of the HR Function within
5 business days of receiving confirmation of their violation. The appeal will be handled by a
third-party investigator who was not involved with the original investigation. The decision of this
investigator will be final.

Business Ethics

The employees shall act in an ethical manner, while continuously observing the needs of the
public and environment. Specifically, a Zero Tolerance Policy has been developed to oversee
the conduct of the employees.

25. WHISTLE BLOWER POLICY

25.1 PURPOSE

The policy has been put in place to ensure any concerns raised regarding any misconduct or
improper state of affairs or circumstances in relation to the Company’s business are dealt with
effectively, securely, appropriately, and in accordance with the Law. The Company encourages the
reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct
involving the Company’s business and provides protections and measures to individuals who make
a disclosure in relation to such conduct without fear of victimization or reprisal.

This policy will be provided to all employees and officers of the Company upon commencement of
their employment or engagement.

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25.2 SCOPE

This policy applies to any person who is, or has been, any of the following with respect to the
Company:

• Employee
• Officer;
• Director;
• Contractor (including sub-contractors and employees of contractors); Supplier (including
employees of suppliers);
• Consultant; Auditor; Associate; and
• Relative, dependent, spouse, or dependent of a spouse of any of the above.

This policy is intended to apply to the above persons in all geographies in which the Company
operates a business.

25.3 REPORTABLE CONDUCT

You may make a report or disclosure under this policy if you have reasonable grounds to believe that
a Company director, officer, employee, contractor, supplier, consultant or other person who has
business dealings with the Company has engaged in conduct (Reportable Conduct) which is:

• Dishonest, fraudulent or corrupt;

• Illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and
criminal damage to property);
• Unethical including any breach of the Company’s policies such as the Code of Conduct;
Oppressive or grossly negligent;
• Potentially damaging to the Company, its employees or a third party; Misconduct or an
improper state of affairs;
• A danger, or represents a danger to the public or financial system; Harassment,
discrimination, victimization or bullying.
• Any disclosures that do not fall within the definition of Reportable Conduct, will not qualify for
protection under the Act. It will be at the Company’s discretion whether it considers there is a
reasonable suspicion that the Reportable Conduct is occurring and/or whether the conduct
constitutes “misconduct or improper state of affairs” under the Act.

For the avoidance of doubt, Reportable Conduct does not include personal work -related grievances.
A personal work-related grievance is a grievance about any matter in relation to a staff member’s
current or former employment, having implications (or tending to have implications) for that person
personally and that do not have broader implications for the Company. Examples of personal work-
related grievances are as follows:

• An interpersonal conflict between the staff member and another employee;

• A decision relating to the engagement, transfer or promotion of the staff member;
• A decision relating to the terms and conditions of engagement of the staff member;
• A decision to suspend or terminate the engagement of the staff member, or otherwiseto
discipline the staff member.

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Personal work-related grievances should be reported to your manager or in accordance with the
Company’s Grievance Policy as mentioned in the HR/Employee Manual.

25.4 MAKING A DISCLOSURE

The Company relies on its employees maintaining a culture of honest and ethical behavior.
Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a
disclosure under this policy.

There are several ways in which you may report or disclose any issue or behavior which you consider
to be Reportable Conduct.

25.5 Reporting

You may disclose any Reportable Conduct to the Whistleblower Protection Officers listed below:

• General/In-house Counsel/Legal Counsel

• Chief Executive Officer

You can make a disclosure outside of business hours by contacting the above Whistleblower
Protection Officers via email.

You are also encouraged to contact the above Whistleblower Protection Officers to obtain any
additional information you may require before making a disclosure or for any clarification regarding
this policy.

If you are unable to use any of the above reporting channels, a disclosure can be made to an
anonymous email to hr@antino.com & info@antino.com

The Whistleblower Protection Officer or eligible recipient will safeguard your interests andwill ensure
the integrity of the reporting mechanism.

25.6 Anonymity

When making a disclosure, you may do so anonymously. It may be difficult for the Company to
properly investigate the matters disclosed if a report is submitted anonymously and therefore the
Company encourages you to share your identity when making a disclosure, however you are not
required to do so.

You may only make a public disclosure if:

• You have previously disclosed the information to the Management or Whistleblower

Officer;
• At least 90 days has passed since the previous disclosure was made;

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25.7 INVESTIGATION

The Company will investigate all matters reported under this policy as soon as practicable after the
matter has been reported. The Whistleblower Protection Officer will investigate the matter and where
necessary, appoint an external investigator to assist in conducting the investigation. All investigations
will be conducted in a fair, independent and timely manner and all reasonable efforts will be made
to preserve confidentiality during the investigation.

If the report is not anonymous, the Whistleblower Protection Officer or external investigator will
contact you, by your preferred method of communication to discuss the investigation process and
any other matters that are relevant to the investigation.

Where you have chosen to remain anonymous, your identity will not be disclosed to the investigator
or to any other person and the Company will conduct the investigation based on the information
provided to it.

Where possible, the Whistleblower Protection Officer will provide you with feedback on the progress
and expected timeframes of the investigation. The person against whom any allegations have been
made will also be informed of the concerns and will be provided with an opportunity to respond
(unless there are any restrictions or other reasonable bases for not doing so).

25.8 PROTECTION OF WHISTLEBLOWERS

The Company is committed to ensuring that any person who makes a disclosure is treated fairly
and does not suffer detriment and that confidentiality is preserved in respect of all matters raised
under this policy.

The Company (or any person engaged by the Company) will not engage in ‘Detrimental Conduct’
against you if you have made a disclosure under this policy.

Detrimental Conduct includes actual or threatened conduct such as the following (without limitation):

• Termination of employment;

• Injury to employment including demotion, disciplinary action;

• Alternation of position or duties;

• Discrimination;

• Harassment, bullying or intimidation; Victimization;

• Damage to a person’s reputation;

• Damage to a person’s business or financial position; or

• Any other damage to a person.

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The Company also strictly prohibits all forms of Detrimental Conduct against any person who
is involved in an investigation of a matter disclosed under the policy in response to their involvement
in that investigation.

25.9 Protection of Confidentiality

All information received from you will be treated confidentially and sensitively.

You will not be required to provide your name when making a disclosure. To make a disclosure
on an anonymous basis, it is recommended that you use a pseudonym and contact the
Whistleblowing Protection Officers in the manner outlined above.

If you report on an anonymous basis, you will still qualify for the protections in this policy.

If you make a disclosure under this policy, your identity (or any information which would likely to
identify you) will only be shared if:

· You give your consent to share that information; or

· The disclosure is allowed or required by law (for example where the concern is raised
with a lawyer for the purposes of obtaining legal advice); or

Where it is necessary to disclose information for the effective investigation of the matter, and this
is likely to lead to your identification, all reasonable steps will be taken to reduce the risk that you will
be identified. For example, all personal information or reference to you witnessing an event will
be redacted from any report, you will be referred to in a gender - neutral context, where possible you
will be contacted to help identify certain aspects of your disclosure that could inadvertently identify
you. Any disclosure under this policy will also be handled and investigated by qualified staff.

26 Policy on Performance Improvement Plan (PIP)

Objective

• This policy is a guideline for Team Leaders and Managers to assist employees who are not
meeting expected job performance or behavioral standards

• This aims at resolving performance issues by developing an Improvement plan (PIP) for the
employee in a specified time and tracking the progress

• The primary focus is to resolve issues, which hinder individual performance/ desired
behaviour which include quality, TAT, productivity, work timings, lack of communication
among other aspects at work.

Applicability

This policy is applicable to employees/contract/trainees of Antino Labs.

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Circumstances for Performance/Behavioural Improvement Plan

The employee needs to be given a Performance improvement plan under the following
circumstances:
• Fail to consistently meet standards of job performance

• Displays inappropriate behaviour at work

• Wherein the reporting supervisor has exhausted all options as per the processes to correct or
improve the performance or the behaviour prior to initiating the PIP. The concerned supervisor must
furnish the details of the specific steps taken as per the improvement plan, the communications
evidenced on the same, and the results from it while raising a request for the PIP with the manager
for approval and further initiation with the HR. The Manager and HR will check and verify the
eligibility for the PIP.
Process on PIP

VERBAL WARNING

• Supervisor identifies that the employee’s performance/behaviour is unsatisfactory from the

regular daily, weekly, and monthly reviews as per the laid-out processes. The supervisor has one on
one discussion with the employee, facilitated by HR.

• The minutes of the one-on-one reviews must be documented. The minutes need to be mailed
by the reporting supervisor to the employee.

• The supervisor to set expectations with the employee, on a standard expected

performance/behaviour with clear timelines.

• PIP Period is for 7/15/30 days, and the weekly reviews and reporting are mandatory
by the supervisor on the outcome.

· HR will be a part of every PIP discussion.

• The immediate supervisor should have an interim discussion to assess progress and give
feedback to the employee

• The maximum duration for the improvement plan is 30 days.

Review on PIP

If the performance does not meet the standards as outlined in the PIP, the following action
needs to be taken: -

· The supervisor needs to prepare a detailed report on the gaps in performance or behavior.

· A signed copy or mail, signed by the manager needs to be handed over to HR for further
processing copying his/her reporting manager.

· A discussion needs to be held between the reporting supervisor, reporting manager and HR on
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how to proceed further.

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 · In case it is decided that a PIP needs to be extended, then the employee, reporting manager/
supervisor and HR will meet and communicate the PIP extension time period. The extension(s) can
be of a maximum of 3 times, after that Post PIP Action needs to be taken by the management in
consultation with HR & reporting Manager.

Post PIP Action(s)

· In case it is decided that the performance of the employee is not improving as per the set Goals
and standards, then the Management can initiate termination of the employee. The employee,
reporting manager/ supervisor and HR will meet and communicate the termination decision.
· Details on what will be the last working day, full and final settlement etc. needs to be discussed
before the meeting

· If the performance goals are met by the employee during the PIP as evidenced through the
numbers or the behaviour, then the employee will be put back to the normal work mode. However,
any repeat instances of the same performance or behaviour over the following 3 months will result
in the same actions as mentioned above.

27 OTHER MATTERS

Any breach of this policy will be taken seriously and may result in disciplinary action, up to and
including termination of employment.

In so far as this policy imposes any obligations on the Company, those obligations are not contractual
and do not give rise to any contractual rights. To the extent that this policy describes benefits and
entitlements for employees, they are discretionary in nature and are also not intended to be
contractual. The terms and conditions of employment that are intended to be contractual are set out
in an employee’s written employment contract.

The Company may unilaterally introduce, vary, remove or replace this policy at any time. Employees
are encouraged to read this policy in conjunction with other relevant Company policies,including:

· Code of Conduct
· Grievance Policy

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DECLARATION & ACKNOWLEDGEMENT

1. THE EMPLOYEE DECLARES & CONFIRMS THAT HE/SHE HAS READ THE COMPLETE
MANUAL AND THAT HE/SHE UNDERTSNADS THE VARIOUS ASPECTS LAID OUT HERE AND
AGREES TO ABIDE AND FOLLOW THE SAME IN ALL EARNESTNESS IN HIS/HER DAY-TO- DAY
WORKING.

2. THE EMPLOYEE ALSO UNDERSTANDS THE IMPLICATION OF BREACH OF ANY CLAUSE

OUTLINED HERE. THE EMPLOYE UNDERSTANDS THAT IT IS HIS/HER DUTY TO READ IN
DETAIL THE MANUAL AND ITS CLAUSES MENTIONED HERE, FAILING THUS IS HIS/HER OWN
ACTION/JUDGEMENT. NOT KNOWING THE POLICIES OR CLAUSES LAID DOWN HERE WILL
NOT BE TAKEN AS AN EXCUSE AND THE FULL FORCE OF THE ACTION WILL BE BROUGH
DOWN UPON THE EMPLOYEE WHO VIOLATES (INTENTIONALLY OR UN- INTENTIONALLY)
ANY PROVISION LAID OUT ABOVE.

DECLARATION & ACKNOWLEDGEMENT

1. THE EMPLOYEE DECLARES & CONFIRMS THAT HE/SHE HAS READ THE COMPLETE
MANUAL AND THAT HE/SHE UNDERTSNADS THE VARIOUS ASPECTS LAID OUT HERE AND
AGREES TO ABIDE AND FOLLOW THE SAME IN ALL EARNESTNESS IN HIS/HER DAY-TO- DAY
WORKING.

2. THE EMPLOYEE ALSO UNDERSTANDS THE IMPLICATION OF BREACH OF ANY CLAUSE

OUTLINED HERE. THE EMPLOYE UNDERSTANDS THAT IT IS HIS/HER DUTY TO READ IN
DETAIL THE MANUAL AND ITS CLAUSES MENTIONED HERE, FAILING THUS IS HIS/HER OWN
ACTION/JUDGEMENT. NOT KNOWING THE POLICIES OR CLAUSES LAID DOWN HERE WILL
NOT BE TAKEN AS AN EXCUSE AND THE FULL FORCE OF THE ACTION WILL BE BROUGH
DOWN UPON THE EMPLOYEE WHO VIOLATES (INTENTIONALLY OR UN- INTENTIONALLY)
ANY PROVISION LAID OUT ABOVE.

Name:

Designation:

Signature:

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