CodeofConduct__mahipal__2024082790040.pdf

EXOTEL CODE OF CONDUCT POLICY Ownership: Document Owner Ashutosh Garg Function HR Approver(s) / Designation Sumanpreet Pahuja / VP-HR Recipients...

EXOTEL CODE OF CONDUCT POLICY Ownership: Document Owner Ashutosh Garg Function HR Approver(s) / Designation Sumanpreet Pahuja / VP-HR Recipients All Employees Version History: Version Description Prepared By Date Reviewed By Date Approved By Date Number of Change October 06, Arjun Singh October 06, Sumanpreet October 06, 1.0 Ashutosh Garg Document created 2023 Deswal 2023 Pahuja 2023 August 21, Arjun Singh August 21, Sumanpreet August 21, Designations 1.1 Rinkle 2024 Deswal 2024 Pahuja 2024 Updated Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065  Table of Contents I. Scope....................................................................................................................................................3 II. Applicability...........................................................................................................................................3 III. Purpose.................................................................................................................................................3 IV. Expectations from Employees...............................................................................................................3 V. Expectations from Managers................................................................................................................4 VI. Conduct and Behaviour.........................................................................................................................4 VII. Harassment Free Workplace.................................................................................................................6 VIII. Conflict of Interest................................................................................................................................6 IX. Confidentiality & Non-Solicitation........................................................................................................8 X. IPR (Intellectual Property Rights)..........................................................................................................8 XI. Reporting violations of the COC and seeking help................................................................................9 XII. Waiver of the COC.................................................................................................................................9 XIII. Acknowledgement................................................................................................................................9 XIV. Exceptions Handling............................................................................................................................10 XV. Policy Changes....................................................................................................................................10 Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065 I. Scope The Exotel Code of Conduct Policy (“this Policy”) is effective from August 21, 2024 and supersedes any previous policy or practice regarding Code of Conduct/Standard Ethics. This Policy applies to all the employees of Exotel Techcom Private Limited, its subsidiaries and affiliates (collectively referred to as “the Company” OR “Exotel”). This policy outlines the Code of Conduct as well as the Standard Ethics that Exotel as an organization aims to uphold and reinforce. Violation of the policy will call for strict disciplinary action up to and including termination. II. Applicability The Code of Conduct is applicable to all company employees (subsidiaries & affiliates) be it on a regular/ temporary/ or ad-hoc or daily wage basis in the organization. This policy is also applicable to external staff like Vendors, Partners, Associates, and Operators, when they are representing Exotel or dealing with Exotel. In some instances, relatives and friends are also included for compliance with the Code to ensure that employees through such relationships do not commit any acts indirectly, which are not permitted to be done directly by the employees. III. Purpose The sole objective of the Code of Conduct is to create a harmonious workspace with a holistic work culture wherein each employee is contributing towards bringing the company close to its vision of being “The most respected technology company” while realizing their own potential. IV. Expectations from Employees All employees must always: Be aware of their actions which should be in accordance with the company’s policies and procedures, internal or otherwise, that are applicable to their duties and responsibilities It is of the utmost importance for employees to be well-versed with the Code of Conduct as ignorance is never an excuse for breaching the Code or engaging in inappropriate professional/personal behavior during the course of employment with the Company. Perform to the best of their capabilities to ensure efficiency, productivity, and cohesion Uphold integrity and discipline as well as act in a dignified and ethical manner at workplace including extended workplaces at all times Demonstrate a professional image as a representative of the company and hence exercise good judgement in choosing attire and dress appropriately for their role in the office Maintain a professional and respectful demeanor at all times, even when speaking to others about colleagues or customers. Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065  Whenever you are in doubt if your conduct is appropriate or not; ask yourself the following 3 questions: 1. Does your conduct reflect Exotel Values? 2. Is it good for Exotel as an organization? 3. Will I feel good about it if everyone knew about it? If answer to any of the above is “No” or “Not Sure” then in that case, you should pause and re-think your actions. In case of any doubt you can seek help from: Your Line manager/Skip Level Manager/BU Head Senior HR Representatives V. Expectations from Managers Managers have additional expectations being the role model for the team: Managers at all times should display appropriate conduct befitting their role Ensure all employees you supervise understand the importance of the code of conduct policy and always follow the rules in their everyday routine Always act to stop your team members from violating the code of conduct Create a workplace where your team members feel free to raise concerns regarding code of conduct violation Promptly reach out to HR in case you notice any code of conduct violation or when you receive a complaint from your team members regarding code of conduct violation VI. Conduct and Behaviour The following actions are expressly prohibited and in case of non-adherence by an employee may result in disciplinary action and depending on the severity of the misconduct may lead to termination of employment without prior warning at the sole discretion of the company: 1. Disruptive Behaviour: Assault, fighting, riotous or disorderly or indecent behaviour or any act that constitutes a violation of discipline (at the Company’s sole discretion), as well as inciting or instigating any such act. 2. Smoking, Drinking and Substance Abuse: The consumption (except at functions sponsored by or approved by the Company) possession or supplying of alcoholic beverages and illegal drugs in company facilities, vehicles or on company premises. Reporting for work under the influence of alcohol or non-prescribed drugs Getting drunk or excessive consumption of liquor when outside on company-sponsored events, outbound programs, office travel and such. Refusal to submit for medical examination as and when required by the concerned authority. 3. Breaking the law: Flouting the Indian Penal Code within the premises of the Company or outside the premises of the Company or committing any act of commission or omission within the premises of the works/establishment of the Company or outside, whether amounting to an offence or not, which would tend to have the effect of or result in spoiling the reputation, public confidence, discipline or prestige of the Company/ or its management. Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065 4. Interpersonal Behaviour: Insulting behaviour, rude words, gestures or actions, hurling expletives or derogatory comments towards colleagues, customers and business associates with the aim of dominance, intimidation and/or coercion. 5. Bribery*: Receiving or presenting bribes or any gifts, personal benefits or capital in any manner whatsoever that is or could be interpreted as intending to influence the decision of customers, suppliers, government officials or political representatives. 6. Misappropriation of funds, Company Data or Company assets for personal use. 7. Causing Information breach for any proprietary data entrusted for official work by the company. 8. Defamation & Slander: Making or publishing false, derogatory, defamatory or malicious statements against the Company/ its management/ its Employees/ its customers and/or its products and software services 9. Stealing, misusing or showing careless attitude towards company assets or property of other employees 10. Creating pressurizing tactics or causing employee panic by group emailing/group forwards without justified cause 11. Submitting False documents for employment verification or falsifying company records 12. Engaging in any political or religious propaganda within the office premises. 13. Joining or becoming a member of any banned or extremist outfit. 14. Posting objectionable content on social media 15. Disheveled Appearance, not maintaining proper personal hygiene, body odour 16. Absence from workplace: Recurrent absences or frequently overstaying the sanctioned leave without satisfactory grounds, as well as habitual absence from your appointed place of work without prior information or sufficient cause. Applying or obtaining leave on a false pretext. Not reporting to your shift on time or not completing your work hours Manipulating Biometric attendance system by not punching in and out appropriately or tailgating 17. Not Reinforcing the Code of Conduct: Remaining a by-stander when the Code is breached. (Please bear in mind that it’s your duty to report it.) Asking or encouraging others to breach the Code. Revealing the identity of a complainant who has come forward with a complaint pertaining to the breach of the Code. Punishing a complainant who has come forward with a complaint by harassing him/her directly or creating a hostile workplace for the complainant. It would be virtually impossible to cite examples of every type of activity that might give rise to a question of unethical or inappropriate conduct. Therefore, it is essential for each one of us to perform our duties and responsibilities and hold ourselves accountable for the same based on our own judgement. *Please refer to Conflict of interest section for additional details. Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065 VII. Harassment Free Workplace Harassment means and includes the following: Making derogatory remarks pertaining to gender, race, religion, sexual orientation, belief or any difference. Excluding/boycotting a person from office related social activities or teamwork without just cause. Being insensitive to the sentiments and cultural milieu at the workplace. Sexual harassment: It is governed by the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013, please refer to the “Prevention of Sexual Harassment at Workplace Policy” available on the Company’s HR portal (FlexiEle) for detailed information. The Company is strongly committed to ensuring a safe and harassment-free workplace and has a zero- tolerance for any and all such acts of harassment (real or threatened). A harmonious atmosphere is necessary for every individual to be productive at work, based on mutual respect and dignity, which is the objective each employee should strive for along with their day-to-day duties and responsibilities. Repercussions for harassment are severe and are likely to lead to immediate termination besides undertaking applicable legal action. The consequences of the same may be penal in nature, if suitable legal action is initiated. All employees of the Company have a personal responsibility to ensure that their behaviour is in accordance to this policy. All employees are expected to maintain a work environment free from any kind of harassment and reinforce the values of inclusion and respect for all. VIII. Conflict of Interest 1. What is Conflict of Interest: When the interests or benefits of an employee conflict with the interests or benefits of the Company, a conflict of interest is said to occur. Conflict of interest can arise when personal relationships or financial interests overlap with job responsibilities. Please find below a few examples of conflict of interests: Influencing Exotel business transactions, whether directly or indirectly, to improperly benefit your friends or relatives for profitable gains, especially when in a leadership role. Accepting gifts*, entertainment, and other business courtesies in lieu of offering business opportunities at Exotel Serving as a board member of another company without prior approval^. Interfering in the company hiring process which results in hiring of relatives over other qualified candidates, also referred to as “Nepotism”: * Exotel employees can accept gifts up to worth INR 2000 from Vendors etc. (to be disclosed to Reporting manager) Above INR 2000, not allowed to accept the gifts but will still need to disclose the name of vendor/person offering gift to COC by dropping an email on [email protected] Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065 a. Nepotism/Employment of Relatives**: Members of an employee's immediate family will be considered for employment on the basis of their qualifications. Employment of relatives will be permitted; however, they may not be placed: within the same department if in supervisory or management positions in a direct or indirect reporting relationship as the head of a division which has operational control, financial control, or supervisory or managerial authority of the business unit or department in which the Team Member’s spouse, relative, or domestic partner is employed in a position where a relative checks, audits or authorizes the other party’s work or in a position where a relative may have the ability to influence, or appear to influence, the employment, development, compensation or working conditions of the other. b. In case the new employee will work in a different department than the current employee and it is clear that neither person will be in the direct line of supervision of each other, the hiring may take place. Existing Employee will not participate or influence hiring process for his/her relatives in any way. All relatives of current employees who apply to the Company must disclose names of relatives employed at time of application. c. Romantic relationships between co-workers can create a conflict of interest, especially if there is power differential between two parties: Consensual Relationships at Workplace: Company does not encourage consensual relationships at the workplace that may have an adverse impact or create conflicting circumstances with the company’s business. All employees should be aware of the possibility that an apparent consensual relationship with another employee may be interpreted either now, or at a later date, as non- consensual and, therefore, lead to charges of sexual harassment. This is true regardless of the level, department, function, or gender of the employees romantically involved. In addition, employee-manager romantic relationships can create a potential conflict of interest and possibly compromise the ability of the manager to fairly evaluate the skills and performance of that employee and others. Please note Exotel has zero tolerance for Hierarchical Romantic Relationships. In situations where employees become romantically involved with one another and one of the employees becomes, or currently is, the manager of the other, the onus is on the manager to make HR aware of possible conflict of interest as soon as possible. HR on its part will try to assign either the manager or the employee (involved in the relationship) to a different role which is not directly connected to the manager. If a suitable role is not available/not acceptable to the involved parties, then HR at its discretion may ask one or both of them to leave the organization. Applicable notice will be given to the employee(s) who have been asked to leave. We have given few common situations where conflict of interests arises often; coming up with examples of all the possible situations is not logically possible. The general rule of thumb is if you are thinking of entering into a business situation or a personal relationship which may create a conflict of interest or appearance of a conflict of interest, then don’t get involved. If in doubt, please review the situation with your line manager or senior HR representative. Any information shared with Human Resource representatives will be treated with strict confidentiality. Non-disclosure of conflict may lead to disciplinary action including termination. **For more Details on hiring of Immediate family members/Relatives / Spouse please refer to Annexure C Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065 IX. Confidentiality & Non-Solicitation Apart from the conduct which has been outlined under various headings above; an employee is expected to uphold all the conditions mentioned in the Appointment letter/Service Agreement which they have signed at the time of joining the company. Employee is also asked to sign a Confidentiality & Non-Solicitation Agreement at the start of the employment. This agreement confirms that employee will not disclose any information from Company, Company's members, or organizations for which Company does work. Failure to abide by this confidentiality agreement is a serious offence and could result in disciplinary action. All information concerning the Company's business including customer data that is not available to the general public is confidential. Employee is therefore obliged, during and after their employment, to maintain the confidentiality of information or records proprietary to the Company, its member companies and customers and use such information only for the purpose of effectively discharging his/her duties. We encourage you not to record any calls or meetings without the consent of your colleagues. Prior consent be obtained from customers before any calls or meetings are recorded. This is an important step in ensuring that all parties involved are aware of the recording and have the opportunity to consent. Clean desk and clear screen policy: At the end of each working day, employees are expected to put aside all papers, files, stationery etc. so as to keep the workstations clean. Employees must always ensure, when not at the workstations, that their computer screens are locked, to avoid any untoward incidents with respect to confidential information. Make sure that all employee-related/customer-related, or other potentially sensitive documents are locked in desks or file cabinets and all confidential and proprietary information is returned upon termination of employment. For more information on Confidentiality & Non-Solicitation, please refer to the Agreement which you signed at the time of joining. Please note that your Salary/Increment details are strictly confidential information and if you are found to be discussing it with other employees or seek information about salaries of other employees, it will be treated as breach of confidentiality and may lead to appropriate disciplinary action. X. IPR (Intellectual Property Rights) The ownership of all “Software Developmental” work and documentation created by the employee during the course of employment with Exotel shall from the moment of its creation, vest in the company. The employee acknowledges and agrees that all of the company/ its customer’s confidential information, sensitive data and work product developed as a result of the employee’s engagement by the company/ its customer, including, in each case, any derivative works thereof will remain, the property of the company/ its customer as applicable. Any violation or breach of the terms of IPR rights of the company/its customers or infringement of their IPR rights otherwise shall be considered a material breach of terms of employment and the company is entitled to take strict action against employee and claim damages, costs and expenses of rectifying such breach including criminal action and termination of employment contract. Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065 XI. Reporting violations of the COC and seeking help Company believes that it has clearly outlined its expectations from employees regarding their behaviour in the code of conduct policy hence any violation or the deviation from the COC policy should be reported immediately. Employee can use following guidelines to report the violations: Complaints on Sexual Harassment: All such complaints will be governed by the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013. Please refer to the “Prevention of Sexual Harassment Policy at workplace” available on the Company’s HR portal (FlexiEle) for detailed information. You can write to [email protected] furnishing complete details of the complaint. Please note no emails regarding POSH complaint should be sent to [email protected] to keep confidentiality of the aggrieved person. For all other complaints: For all other complaints please write to [email protected] with following details: o Specific clauses of the COC which have been violated o The individuals, group of people or functions involved o Complete details of the incident and whether one time or recurring The company has formed a COC Committee to investigate all COC Violations/Deviations. The names of the members constituting COC Committee are given in Annexure A. After receipt of complaint, COC Committee will investigate the complaint and submit its report within 45 days to HR for taking appropriate action. If the case involves BU head or other senior leader then the report will be submitted to Management forum for taking action. HR shall maintain records such as Agenda, Minutes of the COC Committee Meetings, along with all documentary evidence, etc. During an ongoing investigation, it is imperative that all concerned employees give their full co-operation and ensure that they are fair and honest in their responses. If after the investigation it is found that reporting was done with malafide or malicious intent, the reporting employee could be subject to disciplinary action, leading up to, but not limited to termination except in case of genuine misunderstanding in which case the employee will have to submit relevant evidence. XII. Waiver of the COC When certain situations require waiver of the COC, employees must obtain permission from COC committee along with their respective BU Head before taking any action. In case if waiver is requested by BU Head then Management Forum will be the authority to issue the waiver. Names of the members in the Management Forum are given in Annexure B. XIII. Acknowledgement It’s compulsory for each employee of the company to read this policy and sign an acknowledgement stating that they have read and understood the COC policy and agrees to abide by it. HR will take employee acknowledgment either online via Exotel HRMS (FlexiEle) or via pen and paper. (Annexure D given at the end of this document) Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065 XIV. Exceptions Handling COC Committee reserves the rights to handle the exceptions and alter/modify any of the clauses written in this Policy based on the organizational interest/legal requirements from time to time. XV. Policy Changes Company has the absolute right, in its sole discretion, to interpret and modify, amend and or terminate this Policy with respect to any employee, group of employees or in its entirety at any time. The decision to terminate or amend may be due to changes in law or any other reason. If the Policy is terminated, an individual will not have any further rights under this Policy. This Policy does not create an obligation for continued employment or imply an employment contract. Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065  FAQs Q1. One of the company vendors always sends fruit basket or sweets during Diwali, can I accept it? Ans. Fruit basket or Sweets are limited value items which the vendor is sharing occasionally so it is ok to accept it. Our suggestion will be to open it and share it with team members. At any point if you feel a vendor is continuously sending you gifts or the value of gift is above 2000, you are expected to say a firm no to the Vendor and also highlight this behaviour by dropping an email to [email protected]. Q2. My spouse is starting an online gifts delivery company. To fulfill regulatory requirements, I need to be appointed as a director and I will also have a majority share in the company. Is it Ok for me to accept this role? Ans: As per your information, your spouse is starting a business which does not compete with Exotel directly, so it is OK to be part of their company in the role of Director but you will have to disclose this information to HR along with DIN#. Good Luck to your spouse on their new venture. Q3. I want to refer my girlfriend to a position which has recently opened up in my department. Do I need to disclose this to HR? Ans: If you both are going to work in employee-manager relationship or you are in a position which directly audits/appraises or impacts her work or vice versa, it is imperative that you disclose this relationship to HR. For more details please refer to consensual relationships at workplace. As a guideline, you both are expected to be mature enough to keep your relationship within the workplace completely professional. Q4. While having coffee with my co-worker, she asked about my salary and now I have realized that she is earning less than me even though we are on the same level and performing similar duties. She is planning to reach out to my manager to discuss the same. What should I do? Ans: Compensation information is strictly confidential and classified. You must not disclose your salary details to anyone at the workplace nor ask others to disclose their salary information. In the above situation, both you and your co-worker have breached confidentiality, and both of you shall face disciplinary action. Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065  Annexure A Code of Conduct Committee: COC Committee Members S.No. Name Designation IC Status 1. Sumanpreet Pahuja Vice President - Human Resources Chairperson 2. Gaurav Agrawal Senior Vice President - Customer Member Success 3. Sachin Bhatia Co-Founder and CBO - International Member Employee can reach out to COC Committee via [email protected]. All communications sent to COCcommittee is completely confidential. Annexure B Management Forum: MF Members S.No. Name Designation IC Status 1. Shivakumar Ganesan Chief Executive Officer Chairperson 2. Ishwar Sridharan Co-Founder and CBO - US Member 3. Sachin Bhatia Co-Founder and CBO - International Member Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065  Annexure C Hiring of Relatives/ Spouse in Exotel Applicability: Applicable to new hiring (Lateral employee movement like IJP is subject to validation) Current Employee Placements (before August 2023) will remain intact. Immediate Family is defined as: Parent(s), Stepparent(s), foster parent(s), sibling(s) / cousin(s), Child(ren) grandparent(s), spouse, domestic partners, stepchild(ren), Parent(s)-in-law, Brother- in- law, Sister-in-law Family members or Spouse of Team Members may be hired within organization as long as they satisfy following condition: In the same Business Unit (BU) - The two employees are separated in a parallel structure by at least 3 levels. In a different Business Unit (BU) - The two employees are separated in a parallel structure by at least 2 levels. Common Manager Manager A Manager B Manager C Manager D Employee Relative Figure 1 Same BU CommonManager Manager A Manager B Employee Relative Figure 2 Different BU Disclosures Needed: Post implementation of this policy all candidates at time of recruitment will have to disclose if they have any relatives working in Exotel. All current employees will also have to disclose if they have any relatives working in the company. Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065  Annexure D (Acknowledgement) (Employee Commitment to abide by the Exotel - Code of Conduct) I acknowledge that I have received, read and understood the Exotel - Code of Conduct policy (COC). I agree to comply with the standards mentioned in the COC and all related policies and procedures as part of my continued employment or association with Exotel. I will report any potential violation of which I become aware of promptly to my reporting manger, or in accordance with the mechanism set forth in this Code. I understand that any violation of the Code or any policy or procedures is ground for the disciplinary action. Name of the Employee ………………………………………………………………………………………………………. Employee Code ………………………………………………………………………………………………………. Designation ………………………………………………………………………………………………………. Business Unit ………………………………………………………………………………………………………. Department ………………………………………………………………………………………………………. Location ………………………………………………………………………………………………………. Please disclose names of ………………………………………………………………………………………………………. relatives / spouse if currently employed at Exotel If you are Director in any ………………………………………………………………………………………………………. organization, please disclose the DIN# and name of the company Signature ………………………………………………………………………………………………………. Date ………………………………………………………………………………………………………. (Note: It shall be the responsibility of the Corporate HR along with Line managers of each BU to get the above acknowledgement signed from each employee either online or in pen and paper format and should form part of the employees’ personal file.) Registered office: Exotel Techcom Pvt. Ltd., Workshaala Argus, 2nd floor, 82-1-838/1, 100 Feet Rd, Binnamangala, Stage 1, Bengaluru - 560038, Karnataka (India) | Tel: +91 80889 19888 | Email: [email protected] Web: www.exotel.com | CIN - U72900KA2011PTC059065