Employee Handbook

EMPLOYEE HANDBOOK I PVCMT-HRM-01 Country Annexure I (Deputation Allowance) EUROPE (International Business Tour Allowance) (Euros) Aden Austria (Euros) 42 Belgium 54 Bulgaria 56 64 Czech Republic 72 50 Denmark 85 57 Finland 67 68 France 76 70 Germany 90 57 Greece 93 65 Greenland 76 54 England 80 53 Hungary 72 73 Ireland 70 54 97 80 Italy 72 78 Latvia/ Estonia 106 50 104 58 Lithuania 67 64 Luxemburg 77 59 Netherlands (Holland) 85 71 78 33 Norway 95 58 Poland 44 44 Portugal 77 109 Romania 59 68 Sweden 145 52 Switzerland 91 Commonwealth of 69 59 Independent States 63 Ukraine 78 47 Spain 84 Yugoslavia 63 51

INTERNET 11 REIMBURSEMENT POLICY

EMPLOYEE HANDBOOK I PVCMT-HRM-01 Mobile Bill Reimbursement Policy The objective of this Policy is to provide guidelines for reimbursement of mobile bill expenses on account of voice calls made for official purpose. Entitlement & Cost Level wise maximum entitlement limits for reimbursement of mobile expenses are given below: Level/Category (INR/Month) Band 1 & 2 on Actual Band 3 on Actual Band 4 Rental Plan Rs. 499 or as per approved tariff plan Band 5 & 6 Rental Plan Rs. 399 or as per approved tariff plan *The plan can be revised as per tariff revisions by telecom operator. *Key management bill will be paid on actual. Reimbursement ■ Employees should directly submit bills/receipt for their own mobile phones to the accounts department for reimbursement, clearly distinguishing between official and personal calls. ■ Expenses for International calls* made for official work will be completely borne by the Company for which the employee should make a clear declaration in the bill. This should be duly authorized by concerned Department/Function Head before submitting to the Administration Department for reimbursement or payment to the Mobile service provider. ■ Reimbursement limits and the classification of Roles as External Interfacing and non- External Interfacing will be redefined from time to time based on requirements. ■ Reimbursement will include call expenses as well as fixed rentals reimbursement over and above the defined limits will only be entertained upon submission of official call records subject to approval from operations CFO or CEO. ■ International call will be activated with approval of HOD, CFO or CEO after filling the request form (Form can be collected from HR Dept). 53

INTERNET USAGE & 12 ELECTRONIC MAIL POLICY

EMPLOYEE HANDBOOK I PVCMT-HRM-01 The purpose of this policy is to define the appropriate uses of the Internet by employees and affiliates. Allowed Usage Internet usage is granted for the sole purpose of supporting business activities necessary to carry out job functions. All users must follow the corporate principles regarding resource usage and exercise good judgment in using the Internet. Questions can be addressed to the IT department. Acceptable use of the Internet for performing job functions might include: 1. Communication between employees and non-employees for business purposes. 2. IT technical support downloading software upgrades and patches. 3. Review of possible vendor/customer web sites for product information. 4. Reference regulatory or technical information. 5. Research Personal Usage Using company computer resources to access the Internet for personal purposes, without approval from the user’s manager and the IT department, may be considered cause for disciplinary action up to and including termination. All users of the Internet should be aware that the company network creates an audit log reflecting request for service, both in-bound and out-bound addresses, and is periodically reviewed. Users who choose to store or transmit personal information such as private keys, credit Prohibited Usage ■ Acquisition, storage, and dissemination of data which is illegal, pornographic, or which negatively depicts race, sex or creed is specifically prohibited. ■ The company also prohibits the conduct of a business enterprise, political activity, engaging in any form of intelligence collection from our facilities, engaging in fraudulent activities, or knowingly disseminating false or otherwise libellous materials. ■ Unauthorized downloading of any shareware programs or files for use without authorization in advance from the IT Department and the user’s manager. ■ Any ordering (shopping) of items or services on the Internet. ■ Playing of any games. ■ Forwarding of chain letters. 55

EMPLOYEE HANDBOOK I PVCMT-HRM-01 ■ Participation in any on-line contest or promotion. ■ Acceptance of promotional gifts. Software License The company strongly supports strict adherence to software vendors’ license agreements. When at work, or when company computing, or networking resources are employed, copying of software in a manner not consistent with the vendor’s license is strictly forbidden. Questions regarding lawful versus unlawful copying should be referred to the IT Department for review or to request a ruling from the Legal Department before any copying is done. Other Guidelines ■ All computers should be strictly used for official purposes. Only authorized persons may access the computers. GAMES ARE STRICTLY PROHIBITED. Personal CD’s/Pen drives are not allowed to be used on company computers except with granted permission and upon scanning for viruses. Permission must be sought f rom the IT/Admin Manager/Management for using personal devices or accessories. ■ The use of email system must be related to business needs ONLY. ■ Website access is monitored, and disciplinary action will be taken against person who is found to be doing any illegal activity. ■ Company reserves the right to intercept and filter out incoming mails/attachments especially the executables/documents whenever a virus threat is anticipated. ■ While sending mails to external agencies, a disclaimer is to be appended after signatures. Privacy Policy The Company reserves the right, to inspect or monitor any information system, at any time, without user consent or notice and irrespective of any password protection. Users should not have any expectation of privacy with respect to any use of or information contained on any Desktop/Laptop, whether personal or Office related. Laptop and Data Card PVCMT will provide the Laptops / Data card for team members to enable them to work more efficiently. HOD shall be entitled to nominate the team members who shall be provided with the Company Laptops / Data Card. While nominating the team members, the HOD should ensure that: 1. The nature of work of the person is not “office based” (where a desktop can meet the requirement) 56

EMPLOYEE HANDBOOK I PVCMT-HRM-01 2. There is a genuine need for the team member to stay connected on a 24-hour basis, and therefore, it is imperative for him/her to have a laptop and data card. 3. The nature of work demands it (for example for the sales guys who are on the field, making client representations etc.). Loss and Damage of Laptop ■ Any loss or damage to the devices must be reported to IT / Admin / HR department, within 24 hours. ■ After considering the facts of the matter, IT will assess as to whether the loss / damage is attributed to the negligence / carelessness of the user in question. ■ The principle of natural justice shall be applied and an equal opportunity of being heard shall be given to the user. If the user is found to be guilty of negligence / carelessness, resulting in the loss / damage, the penalty for damages shall be decided by a committee consisting of CEO, HR and Finance department. ■ The extent of penalty shall be decided after considering the circumstance of the incident and age of the device. ■ It is the responsibility of the user to get documentation done along with the IT team, in case, they file an insurance claim with respect to loss / damage (like the copy of FIR) within the stipulated time limit. 57

PREVENTION OF 13 SEXUAL HARASSMENT

EMPLOYEE HANDBOOK I PVCMT-HRM-01 The objective here is to lay down the detailed processes and rules to ensure protection of all employees against sexual harassment at the workplace. Prevention and redressal of complaints of sexual harassment as per The Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013 are binding at the workplace. Policy Details “Sexual Harassment” includes any one or more of the following unwelcome acts or behavior (whether directly or by implication) namely: 1. Physical contact and advances; or 2. A demand or request for sexual favours; or 3. Making sexually coloured remarks; or 4. Showing pornography; or 5. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature. In addition, prohibited forms of harassment include but are not limited to the following: 1. Objectionable physical proximity or contact 2. Discussion of a person's physical characteristics or dress 3. Unwelcome suggestions regarding, or invitations to, social events or activities 4. Telling offensive jokes or sexually explicit stories 5. Circulation or posting of offensive cartoons or pictures 6. Use of offensive language or demeaning terms 7. Any unwelcome advances Other Guidelines Internal Committee (IC) Internal Complaints Committees (ICC) are constituted by PVCMT to address issues related to sexual harassment raised by aggrieved employees and ensure time bound treatment of the complaints as per The Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013 and rules made there under the said Act. Redressal Process 1. Any employee who feels and is being sexually harassed directly or indirectly may submit a complaint of the alleged incident to any member of the Committee in writing with her/his signature within 10 days of occurrence of incident. 2. The Committee will maintain a register to endorse the complaint received by it and keep the contents confidential. 59

EMPLOYEE HANDBOOK I PVCMT-HRM-01 3. The Committee will hold a meeting with the Complainant within five days of the receipt of the complaint, but no later than a week in any case. 4. At the first meeting, the Committee members shall hear the Complainant and record her/his allegations. The Complainant can also submit any corroborative material with a Documentary proof, oral or written material, etc., to substantiate her/his complaint. 5. Thereafter, the person against whom complaint is made may be called for a deposition before the Committee and an opportunity will be given to her/him to give an explanation, where after, an “Enquiry” shall be conducted and concluded. 6. In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management. 60

GRIEVANCE 14REDRESSAL POLICY

EMPLOYEE HANDBOOK I PVCMT-HRM-01 This grievance redressal policy provides employees with an easily accessible process for settlement of grievances. The objective is to provide employees a forum to confidently voice their concerns or ask questions without fear of retribution. All this contributes to a healthy work environment and improves the organization's productivity efficiency. Grievance Handling 'Grievance' for the purpose of this scheme would mean a grievance relating to any employee arising out of the implementation of the policies/rules or decisions of the organization. The grievance can include any matter relating to wage/salary payment, leave, increment, working conditions, seniority, work assignment, acting arrangements, non-extension of benefits under rules, interpretation of Service Rules, settlements etc., of an individual nature. We are all expected to communicate honestly and openly with supervisors and others in leadership positions and in good faith, raise concerns—including those about safety, possible misconduct, and violations of laws, regulations or internal requirements. When concerns are raised, employees in supervisory and other leadership positions are expected to: ■ Particularly important is our policy that prohibits retaining records of an employee's appeal or documenting a conflict in his or her personnel folders. ■ Employees in supervisory and other leadership positions may not retaliate, tolerate retaliation by others, or threaten retaliation. How to Raise Concerns If an employee has a concern or question, they are encouraged to address it directly with their supervisor/manager. Additionally, if employees encounter an undesirable workplace situation at our factory, they must immediately bring them to PVCMT's attention by contacting the concerned supervisor. Here are some of the key steps they should follow: 1. The employee is encouraged to resolve issues and complaints through informal discussions with his or her supervisor or their section manager. 2. If informal dialogue doesn't provide satisfactory results or the employee is not comfortable raising the issue with the supervisor, they can pursue formal steps by reaching out to senior management / Human Resources or write an email to [email protected] 3. Records of an employee's appeal are not retained in any of his or her personnel folders and no penalty results from using this process. 4. The employee will receive, through his or her supervisor, a written reply relating to the issue from senior management. 62

EMPLOYEE HANDBOOK I PVCMT-HRM-01 Investigations PVCMT takes allegations of misconduct seriously and will take appropriate action. All reported violations of the Code of Conduct are investigated by a GRIEVANCE REDRESSAL COMMITTEE. Grievance Redressal Committee The Grievance Committee will be led by the Head (Human Resources) and two other senior members across departments. HOD (Human Resources) will be In-charge of the Grievance Cell and will maintain a Grievance Register and all the correspondence records etc. related to such grievances and will liaison with concern authorities in this regard. All grievances referred to the Grievance Redressal Committee/ Chief Executive Officer shall be registered, maintaining employee confidentiality. The number of grievances settled or pending will be reported to the C.E.O. every 6 months. 63

EMPLOYMENT 15SUGGESTION SCHEME

EMPLOYEE HANDBOOK I PVCMT-HRM-01 PVCMT believes in fostering an environment of creativity and innovation. The Employee Suggestion Scheme (ESS) is a step towards encouraging employees to use their creative potential and ideas that contribute to efficiencies, productivity, and general well-being of the organization. Good suggestions will be suitably rewarded. Employee Suggestion Scheme The scheme generally invites all types of Suggestions, which will benefit the organization and the employees and therefore spells out certain criteria to determine what is or is not a valid suggestion. Here are the steps you can follow if you want to make suggestions: 1. A 'suggestion box' is placed at all the levels of the office premises. 2. If you have a suggestion, you can write it down and put it into the box and put your name against it. 3. We regularly check the contents of the suggestion boxes, and your suggestions will always greatly be appreciated! But what makes for good suggestions? Suggestions will be rewarded should they bring about: 1. Improved operating efficiency. 2. Improvement in working condition including health and welfare. 3. Improved safety standards, communication, facilities & image. 4. Improvement in productivity and/or quality. 5. Improvement in maintenance of machines/building/infrastructure 6. Result in saving in material including fuel and power etc. 7. Provide better and more effective welfare measures. 8. Simplification of Practices / Procedures / Processes. 9. Elimination of ineffective movements / Delays / Rework. 10. Economy in stationery, office facilities, administration. 11. Reduction of wastages pertaining to cost, time, energy, maintenance, environment etc. 12. Any other area which may improve Company's performance. 65

EMPLOYEE HANDBOOK I PVCMT-HRM-01 What about suggestions that are invalid? Here are some examples of suggestions that will not be accepted: 1. Suggestions pertaining to the Company/Govt. Policies. 2. Matters which are already under consideration of Management. 3. Complaints or Grievances. 4. Suggestions already adopted or implemented. Repeat Suggestions. Impracticable/ Non-Implementable suggestions on cost & technical considerations & nonstandard practices. Administration of Suggestion Scheme In order to motivate and appreciate our employees we have created the “Suggestion Evaluation Committee” to review the suggestions shared and process them as per the requirements. We would evaluate the suggestions shared and “Award” the Best suggestions on quarterly basis. The nature and value of the reward shall be determined based on the Merit Points accorded to each 'Acceptable Suggestion' based on the following “Evaluation Plan”: S. No. Parameters Score (Maximum) 1 Originality of the Idea/Innovation and extent of applicability. 12000 2 Reduction of wastage, improved productivity/uptime 6000 ratios and monetary saving. 4500 3 Innovation in the field of safety practices and Improvement 4 Fostering team building Nil Constitution of Suggestion Evaluation Committee (SEC) will include 3 HODs from across functions and will rotate on an annual basis. 66

WHISTLE 16 BLOWER POLICY

EMPLOYEE HANDBOOK I PVCMT-HRM-01 PVCMT is committed to following the highest standards of ethical, moral and legal conduct in all its operations. We encourage employees who have genuine concerns about suspected misconduct to come forward, without fear of punishment or unfair treatment. The policy aims to provide employees a legitimate platform to raise concerns of violations of legal or regulatory requirements, incorrect or misrepresentation of financial statements and reports, etc. Guidelines The Whistle Blower (WB) Policy provides a secure framework, within which, employees can play an important role in upholding PVCMT's Principles and Code of Conduct. The Policy encourages employees of PVCMT to report unethical or improper practices or acts, or violations of the Code of Conduct. Under the Policy, every employee of the Group is expected to promptly report to the Whistle Blower Committees (Delegation/Company) any actual or possible violation of: 1. Principles of Conduct & Action 2. The Code of Conduct for Employees 3. Any unlawful, unethical or improper activity concerning any Business in India Who is the Whistle-blower? Any Employee, Director or Third party who discloses or demonstrates evidence of unethical activity or any conduct that may constitute a breach of the Company's Code of Conduct or Values. Typically, a whistle-blower comes to the decision to make a disclosure or express a genuine concern/grievance/allegation, after a lot of thought. Whistle-blower Complaint Every Whistle Blower who believes they have a legitimate case is expected to read and understand this policy and abide some basics, before going ahead with the complaint. 1. It is advisable that any individual only reports the violation after gathering adequate facts/data to substantiate the complaint and not act merely based on hearsay or rumour. 2. No action will be taken against the whistleblower, if the complaint was made in good faith, but no misconduct was found upon subsequent investigation. However, if a complaint, after investigation proves to be frivolous, malicious or made with ulterior intent, the Investigating Committee can take appropriate disciplinary or legal 68

EMPLOYEE HANDBOOK I PVCMT-HRM-01 action against the concerned whistleblower. Protection to A Whistle-blower We condemn any kind of discrimination, harassment, victimization or any other unfair employment practices against whistleblowers. Complete protection is provided for whistleblowers against any unfair practices; retaliation, threat, intimidation, termination/suspension of service, disciplinary action, transfer, demotion, refusal of promotion, or such like. This includes any direct or indirect use of authority to obstruct the whistleblower's right to continue to perform his/her duties/functions in a free and fair manner. Whistle-blower Process A Whistle Blower can raise a concern with the CORPORATE OMBUDSMAN by: 1. Place your text here ◦ a) Sending an e-mail to [email protected] or HR head or CEO. ◦ b) In person - complaints can be reported verbally on Telephone to the HR. Verbal reports will normally be transcribed and documented by the CORPORATE OMBUDSMAN. 2. Whistle blower complaints received shall be reviewed by the CORPORATE OMBUDSMAN or by the Redressal Committee constituted by him/her (detailed procedures below). ◦ a) The CORPORATE OMBUDSMAN or the Committee will assess whether/not the issue raised constitutes a whistleblower complaint. In case of a review by the Redressal ◦ b) Committee, it shall submit a report to CORPORATE OMBUDSMAN detailing whether the issue(s) raised constitute(s) a whistle blower complaint or not. ◦ The CORPORATE OMBUDSMAN or the Redressal Committee, to whom the complaint may be directed by the CORPORATE OMBUDSMAN, will respond to the concern within 48 working hours of receiving it 3. Once the assessment is made by the CORPORATE OMBUDSMAN, the Redressal Committee will conduct an effective investigation and discuss the steps to be taken to investigate the issue. 4. The CORPORATE OMBUDSMAN and the designated officer will provide feedback to the Whistle Blower on the progress of the investigation. 5. The CORPORATE OMBUDSMAN shall submit a report of all the complaints received during every quarter to senior management. 69

EMPLOYEE HANDBOOK I PVCMT-HRM-01 Dealing with Anonymity A whistleblower may choose to keep his/her identity anonymous. In such cases, the complaint should be accompanied by strong evidence and data. Confidentiality All the complaints are treated in a confidential and sensitive manner. In specific cases where it becomes critical and necessary to disclose the identity of the whistleblower, it may be disclosed, only on a 'need-to-know-basis, with the prior approval of the whistleblower, in the process of investigation. Investigation Procedure ■ Stakeholders write to CORPORATE OMBUDSMAN and raise a concern with required evidence and documents. ■ A Redressal Committee with a minimum of 7 members consisting of experts is formed. Committee members come with the right knowledge and objectivity from within the company and are assigned to determine the legitimacy of the matter and respond within 48 working hours. ■ The Redressal Committee conducts an inquiry and comes up with a report within 15 to 45 working days from the date of the initial complaint. ■ The Redressal Committee report recommends corrective actions to appropriate managers for implementation. In the event the accused is found guilty, penalties are prescribed through the CORPORATE OMBUDSMAN, and implemented by HR. The whistle blower also receives an update on the outcome. Retention of Documents All Complaints received in writing or documented along with results of the investigation shall be retained by the Company. 70

MEDIA 17 POLICY

EMPLOYEE HANDBOOK I PVCMT-HRM-01 The objective of this policy is to ensure PVCMT public image is always safeguarded. The policy lays down guidelines on how staff should effectively handle communications with the media. Policy Guidelines ■ Only approved and authorized spokespersons can speak to the media. ■ No employee can speak on behalf of PVCMT to the press unless they have been officially deputed by Corporate Communication with approval of CEO. ■ Employee’s authorized to represent PVCMT to the media should not offer personal views, opinions or speculation — or provide information on matters falling outside his/her direct knowledge, involvement and responsibility. ■ Employees must avoid discussing matters of policy, legislation, personnel actions or official investigations on any matter. ■ Should employees be asked to write for a publication, this needs official authorization, and all content must be approved by HR/Corporate Communications. ■ Applies to publication of articles/ press notes in newspapers/ journals/ books/ electronic media. ■ Should the media reach out directly to any employee, the employee must politely direct the caller to Corporate Communications or the Company spokesperson by: 1. Providing contact details and designated time slots to the media 2. Giving the Corporate Communications department a heads up 3. Avoid giving the media any informal information should they meet at a social gathering Company Spokespersons For easy coordination between the Organization and the media, the contact person would be MARKETING HEAD/CEO, for any communications please direct the query to the concern person. What Are The Media Guidelines To Follow? ■ Keep overall messaging and external communication consistent and aligned with guidelines set by PVCMT. ■ In case an employee comes across a report or a news item that misrepresents facts about the organization or distorts a story out of context they must immediately notify the Corporate Communications Department ■ Similarly, if there is any of our product / person pictures or Organization logos or diagrams used without due credit, the copy of the same must be sent to Corporate 72

EMPLOYEE HANDBOOK I PVCMT-HRM-01 Communications/Marketing/HR. ■ Employees are duty bound to read all the above policies and adhere to them; the HR department is always on stand-by for clarity. 73

PATENT 18 POLICY

EMPLOYEE HANDBOOK I PVCMT-HRM-01 PVCMT believes it’s Intellectual Property is an important asset in the conduct of its business and prohibits the unauthorized use or disclosure of this information. Policy Guidelines ■ Employee of the organization may submit their innovation/invention by accessing the Company Intranet and receive Invention Disclosure Number (ID). ■ This ID will get registered in internal data base (IPMS). ■ Patent committee sends acknowledgement of receipt including internal reference (ID) to inventor. ■ Patent Committee forward the ID to the responsible Patent Professional (PP) to decide about the ID (filing of an application, i.e. take it forward and file for a Patent or Release, i.e., release the disclosure to the employee). ■ Based on the decision, the Patent Committee will do the following: ■ Filing of an application: forward the decision to Patent Administration for implementation in IPMS. ■ Release: Patent Committee sends release letter to inventor i.e. no longer interested in the invention. ■ If a decision is taken to file invention, then they instruct the Legal Team to draft and file an application with the Indian Patent Office or request filing licence to file outside of India. ■ Once in a quarter, Patent Committee will communicate Invention Disclosure Number (ID) status to HR India very clearly mentioning employee whose inventions are decided to be filed for Patent. Rewards This policy provides that employees receive cash reward when the ID is approved by the Patent Committee and is filed as a Patent with the Authority. The reward will be given as per following norms: Number of Inventors Reward Amount in INR One Inventor INR 20,000 Two Inventor Three Inventor INR 10,000 each INR 7,000 each Four Inventor or more INR 20,000 divided equally 75

CODE OF 19 CONDUCT

EMPLOYEE HANDBOOK I PVCMT-HRM-01 The code of conduct expresses PVCMT's commitment to conducting business ethically. PVCMT's code of conduct policy is based on our core values, responsibilities, commitments, and promises. This document gives you the general information and guidance about the Company’s expectations, situations that needs the attention of the stakeholders and channels of communication available. This set of documents is also the first step for the clearing any queries/ questions relating to the ethics we follow. We are committed to create a disciplined and healthy working environment, free from harassment and discrimination. Please review the entire Code of Conduct and refer to it whenever you have a question on the same. PVCMT can also request you to confirm in writing that you have reviewed the Code and agree to all the company’s Core vale and Reputation. . What Are My Responsibilties I LEAD BY EXAMPLE Each one of the employees must lead by example by acting responsibly and with integrity by following the company values. I AM THE EXAMPLE FOR MY TEAM Frequently, a Manager is the primary individual to be reached about a worry in our workplace. Managers have some duties: ■ Encourage your group to raise issues and shout out. ■ Promote our qualities, the Code of Conduct and consistence with arrangements and the law. ■ Actively support morals and consistence mindfulness and preparing programs. ■ Have open roads for correspondence. ■ Communicate a positive message about your obligation to morals and consistence. ■ Listen and react decently to worker concerns. ■ Find acceptable and complete goals to moral issues. ■ Escalate concerns when extra help is required. ■ Be a good example of moral conduct. PROTECTION FROM RETALIATION PVCMT’s non-retaliation policy is an embodiment of our values and a cornerstone of our 77

EMPLOYEE HANDBOOK I PVCMT-HRM-01 Code. If you observe violations of PVCMT’s values and principles, you are encouraged to report such incidents to HR or email [email protected]. PVCMT will protect you and ensure that you are not retaliated against because of any report that you raise in good faith. PVCMT does not tolerate any form of retaliation (whether by a manager, co- worker or otherwise) against an individual because he or she made a good faith report of an integrity concern. This protection also extends to anyone who assists with or cooperates in an investigation or report of an integrity concern or question. We support those who support our values. RAISE YOUR VOICE!! If you believe that you have been discriminated against, harassed or have not been given equal opportunities at work, you are encouraged to submit a complaint to: ■ Your manager ■ Your Skip-level manager ■ Human Resources ■ Email - [email protected] Respecting Each Other AN EQUAL OPPORTUNITY WORKPLACE FREE OF DISCRIMINATION OR HARASSMENT We are committed to following fair employment practices that provide equal opportunities to all employees. We do not discriminate or allow harassment on the basis of race, color, religion, disability, gender, national origin, sexual orientation, gender identity, gender expression, age, genetic information, or any other legally protected status. At PV Clean, we value diversity and believe that a diverse workplace builds a competitive advantage. To put these values in practice, all of us must ensure that decisions affecting employees are based on business factors only. For instance, decisions regarding hiring, promotion, termination, transfer, leave of absence or compensation should only be based on relevant business factors. We must also ensure that we never verbally or physically mistreat others or engage in offensive behavior, and we should not tolerate those who do. This includes harassing, bullying, abusive or intimidating treatment, inappropriate language or gestures, disorderly conduct, violence and any other conduct that interferes with a co-worker’s ability to do his or her job. The Company’s Anti-Discrimination and Anti-Harassment Policy applies to all persons involved in the operations of the Company and prohibits harassment by any employee of the Company towards other employees as well as outside vendors and customers. 78

EMPLOYEE HANDBOOK I PVCMT-HRM-01 A SAFE PLACE TO WORK To work effectively, all of us need a healthy and safe work environment. All forms of substance abuse as well as the use or distribution of drugs and alcohol while at work is prohibited. Unless required as part of your role (for instance for security personnel where deemed necessary), possession and / or use of weapons / firearms or ammunition while on business of the Company is prohibited. All of us should be safe at our place of work. Should you observe any unsafe situations at work, please reach out to the HR department. POLICY ON PERSONAL CONDUCT PV Clean employees are expected to always ensure that their conduct, in official as well as personal capacity is such that PV Clean’s reputation is upheld. They must remember that one is judged by how he or she acts and the company he or she keeps. Our reputation will be upheld if we act with integrity in all our dealings, even at a personal level, and we always do what we think is right at all times. In official as well as personal capacity, employees at no times should indulge in any action / behavior that : Violates any law; or Is indicative of personal indiscretion; or Is socially unacceptable. IMPROPER CONDUCT ■ Exercise of sound judgement and common sense will equip every employee to judge as to whether his / her actions can be construed as improper conduct. The key question that employees need to ask themselves at all times is whether this conduct befits a cultured, mature, and socially responsible adult? ■ It also must be kept in mind that while major lapses of law and social behavior are usually prevented very often seemingly minor mistakes can and do result in improper conduct. Even such actions need to be avoided. Indicative examples are: ■ Getting drunk in a party or a social function or misbehaving in public. ■ To be under the influence of liquor, narcotics or any other form of intoxication while representing PV Clean or reporting to work at the PV Clean’s premises or at a customer’s / supplier’s premises. ■ Using abusive - expletive infested language e Inflicting verbal abuse on anyone (including employees) Loud and irresponsible behavior in public which causes discomfort and embarrassment to surrounding people. ■ Manhandling or physical assault on anyone. ■ Unreasonable criticism ■ Undue show of authority ■ Reporting to work in an inappropriate dress or presenting oneself in a shabby manner 79

EMPLOYEE HANDBOOK I PVCMT-HRM-01 The range of possibilities covered by this policy is too wide for any pre-defined guidelines. Respect for the self as well as for others must be the guiding principle for personal conduct. However, it is imperative that employees remember to exercise sound judgement and demonstrate a serious sense of responsibility and maturity all times and in official as well as personal capacities. Ethics In Our Business Activities PVCMT enjoys a hard-won reputation for honesty, integrity, and fair dealings. Without question, this reputation for integrity is an invaluable part of our success. There are certain regulations that PVCMT is subject to and we should ensure that we comply both in letter and in spirit with these as is applicable. PREVENTING CORRUPTION Corruption diverts public resources from priorities such as health, education, and inf rastructure and impedes economic growth. Corruption undermines public accountability and the rule of law. Corruption is anti-competitive, increases costs of doing business and introduces significant uncertainty into business. Bribery thus raises the risks of doing business, putting a company’s bottom line and reputation in jeopardy. Companies that pay bribes to win business ultimately undermine their own long-term interests and the best interests of their investors. We should never offer, directly or indirectly, any form of gift, entertainment, or anything of value to any government official or commercial partners including customers or their representatives to: ■ Obtain or retain business. ■ Influence business decisions; or ■ Secure an unfair advantage This includes bribes, kickbacks, and facilitation payments. WHAT IS A BRIBE? A bribe is anything of value that may be seen as an attempt to influence an action or a decision to obtain or retain business or acquire an improper advantage. This could include money, gifts, favors, use of company resources, entertainment, or other items of value. WHAT IS A KICKBACK? A kickback is a form of corruption that involves two parties agreeing that a portion of their sales or profits will be kicked back (given back) to the purchasing party in exchange for making the deal. 80

EMPLOYEE HANDBOOK I PVCMT-HRM-01 WHAT IS A FACILITATION PAYMENT? Certain countries may have a practice of ‘facilitation payments’, which are payments to government officials to expedite or ensure routine actions, such as issuing visas, work permits, licenses etc. PV Clean does not do any of these, nor do we allow third parties acting on our behalf, such as vendors, agents, customers, consultants, alliance partners, suppliers and contractors to make any such payments. Also remember that while managing these relationships, we must be on the watch for any actions relating to bribery, kickbacks, improper payments, or other corrupting influences. We can and will be held responsible for the conduct of our third parties if they violate the law while working on our behalf. GIFTS AND ENTERTAINMENT In connection with certain holidays and other occasions, it is customary in many parts of the world to give gifts of nominal value to customers, government officials and other parties who have a business relationship with the Company. However, we should be careful that while doing so, we do not violate any regulations or do anything that is contrary to our values. When we offer a gift to a customer, a government official or any third party, we should keep the following in mind: ■ It is not done to obtain or retain business or gain an improper advantage in business. ■ It is lawful permitted under the policies of the client. ■ It constitutes a bona fide promotion or goodwill expenditure. ■ It is not in the form of cash. ■ The gift is of nominal value (on an individual and aggregate basis. CHARITABLE CONTRIBUTIONS PVCMT believes that charitable contributions and donations are an integral part of its corporate social responsibility. Typical areas for granting support are education and research, social welfare, disaster relief and other similar social causes. Before making a charitable contribution on behalf of PVCMT, we should keep in mind the following: ■ The recipient is a registered, tax-paying, recognized organization. ■ The contributions are permissible under applicable local laws. ■ Contributions are made without demand or expectation of business return. ■ Beneficiaries of such contributions should not be related to the directors or executive officers of PVCMT. 81

EMPLOYEE HANDBOOK I PVCMT-HRM-01 ■ Contributions shall not be made in cash or to the private account of an individual. ■ Any amounts contributed or donations made towards charitable causes shall be fairly and accurately reflected in PV Clean’s books of accounts. ANTI- BOYCOTT LAWS In the course of our work, we may receive requests for PV Clean to boycott certain countries, companies, or other entities. Boycott activity can take the form of refusals to do business with certain groups or requests for information about boycotted entities. We should not cooperate with any boycott that is not initiated by Indian governments. This may be considered as an illegal foreign boycott. Be alert to these situations, as these requests may be contained as part of larger documents such as master service agreements, invoices or statements of work. TRANSACTING WITH THIRD PARTIES We try, to the extent reasonably practicable, to directly interact with government officials. However, if third party agents are required to interface with government authorities on behalf of PV Clean, we should verify the credentials and reputation of such a third-party agent prior to any agreement with them and ensure that a formal contract is executed, including appropriate provisions requiring the third-party agent to comply with applicable anti-corruption and local laws. Keep in mind that the Company and individual directors, officers or employees may be liable for a payment made by a third-party agent, if the Company makes a payment or transfers other value to that third party agent knowing that it will be given to a government official. We ensure that the fee, commission, or other remuneration paid to intermediaries or third-party agents is reasonable, bona fide and commensurate with the functions and services performed. We should keep track of such expenses so that they are fairly and accurately reflected in PV Clean’s books of accounts. Red Flags While Transacting with Third Parties ■ Background check (case to case basis) reveals a flawed background or reputation. ■ Agent suggested by a government official. ■ Agent objects to anti-corruption compliance requirements. ■ Agent has a personal or business relationship with a government official. ■ Unusual contract terms or payment arrangements such as payment in cash, payment in another country’s currency or payment to a financial institution outside the country where the contract is performed. 82

EMPLOYEE HANDBOOK I PVCMT-HRM-01 ■ Requests that identity of the agent be kept confidential. ■ Commission exceeds the ‘going rate’ or must be paid in cash. ■ Indication that ‘facilitation payments are required’ to ‘get the business moving’. ■ Request false invoices or any other type of false documentation; or CONFLICT OF INTEREST WHAT DOES CONFLICT OF INTEREST MEAN? When the interests or benefits of one person conflict with the interests or benefits of the Company, a conflict of interest is said to occur. We must avoid situations involving actual or potential conflict of interest so that even the slightest doubt about our integrity is not raised. Conflicts of interest also occur when we or our family members receive improper personal benefits, or preferential treatment because of our position, or the position of a family member, in the Company. Remember that such situations might impact our judgment or responsibilities towards our Company and our shareholders and customers. WHEN COULD I BE FACED WITH A ‘CONFLICT OF INTEREST’ ISSUE? Some examples include: OUTSIDE EMPLOYMENT If you take part in any activity that enhances or supports a competitor’s position or accept simultaneous employment with any other company or business entity, it is considered outside employment and a conflict of interest. This includes performing services as an employee, agent or contractor for a customer, supplier or any other entity that has a business relationship with the Company while working at PV Clean. WORKING WITH FAMILY AND FRIENDS To avoid conflicts of interest and any appearance of favouritism, ensure that you do not work directly for, supervise or make employment decisions about a family member. This includes positions or assignments within the same department and the employment of such individuals in positions that have a financial or other dependence or influence (e.g., an auditing or control relationship, or a supervisor / subordinate relationship). Please reach out to your manager and HR manager if you have any questions about this. The Human Resources Department is responsible for determining whether an acknowledged relationship is covered by the policy. RELATED PARTY TRANSACTIONS You should also avoid conducting Company business with a relative, or with a business in which a relative is associated in any significant role. Relatives include spouse, siblings, children, parents, grandparents, grandchildren, aunts, uncles, nieces, nephews, cousins, step relationships, and in-laws. 83

EMPLOYEE HANDBOOK I PVCMT-HRM-01 RELATIONSHIPS AT WORK Personal or romantic involvement with a competitor, supplier, or another employee of the Company might affect your ability to exercise good judgment on behalf of the Company. This could lead to conflict of interest. Personal relationships and romantic liaisons between employees who are in a manager-employee reporting structure may lead to team management challenges and reduced morale. Such relationships must be disclosed to the manager immediately, who may take appropriate corrective action. OUTSIDE INVESTMENTS You should not have a financial interest, including through a relative, in any organization if that interest would give or appear to give you a conflict of interest with the Company. You should be particularly sensitive to financial interests in competitors, suppliers, customers, distributors, and strategic partners. POLITICAL ACTIVITIES PVCMT reserves the right to communicate its position on important issues to the elected representatives and other government officials. PV Clean’ funds or assets must not be used as contribution for political campaigns or political practices under any circumstances without the prior written approval of the MD and CEO. We do not seek reimbursement for political contributions or use PV Clean resources for personal political activities. We also do not indicate in any manner that we represent our Company’s opinion about a candidate for office or any political cause or decision of any government. LOBBYING If our work includes meetings with government, elected officials, all of which might be construed as ‘lobbying’, we must be aware that such activities are regulated. We should not claim to represent our Company at such meetings unless we are specifically designated by the Company to do so. As in all other spheres of our activity, any meetings of this sort should be carried out with high integrity. Protecting Company Assets COMPANY CONFIDENTIAL INFORMATION For the Company, its confidential information is a valuable asset, and every director, employee, supplier, customer and agent of the Company must protect it. Confidential information includes all non-public information. It also includes personal information (regardless of its source) that we obtain during business. We must take care that all confidential information is used for Company business purposes only and in case of personal information, in addition, it must be processed on instructions from the Company in accordance with laid out policies, procedures and guidelines and as per applicable privacy laws and regulations. 84

EMPLOYEE HANDBOOK I PVCMT-HRM-01 Upon joining PV Clean, all employees sign a Confidentiality and Non-disclosure Agreement which details their confidentiality obligations to the Company. As employees, we have access to significant amount of company information that may not be available to the public, and we should preserve the confidentiality of information obtained in the Company’s service. Information of a confidential, private and sensitive nature must be used responsibly and controlled and protected to prevent its prohibited, arbitrary or careless disclosure. Unless the Company has provided its specific consent, which should preferably be in writing, or there is a legal or professional right or duty to disclose, we are prohibited from disclosing confidential Company information. Confidential or proprietary information about clients, our organization, or other parties, which has been gained through employment or affiliation with PV Clean, may not be used for personal advantage or for the benefit of third parties. IMPROPER OPPORTUNITIES When we receive information as part of our job, we should not trade with it for our personal benefit. Neither should we pass on the information to our friends and family members or indirectly compete with the Company. Information obtained as part of our job should not be taken advantage of even after we leave the organization. COMPANY INTELLECTUAL PROPERTY The intellectual property (IP) of the Company must be protected as a vital business asset. Our IP portfolio includes copyrights, patents, trademarks, service marks, trade secrets, design rights, logos, brands and know-how. We must use our IP focusing on protecting these assets. It is important to ensure that to the extent permitted by law, the rights to all IP created using the Company’s time and expense that which are within the scope of our duties are assigned to and are the property of the Company. We should promptly disclose any works, inventions or developments we create to obtain legal protection over them. PROVIDING INFORMATION TO THE MEDIA To protect our confidential information from misuse and to ensure that only accurate information about the Company is disclosed, we have designated our Corporate Communications team to handle exchanges with the media. Additionally, our Chief Executive Officer, Managing Director are the official Company spokespeople for any matters. All inquiries or calls from the press and financial analysts should be referred to the Corporate Communications team. We must not post or discuss information concerning the Company’s product and solutions or business on the Internet unless we are authorized to do so. Neither must we create a perception that we are speaking or posting on behalf of the Company. Remember that your online posts will be available for a long time, so think carefully prior to posting any information that could affect our Company. 85

EMPLOYEE HANDBOOK I PVCMT-HRM-01 PHYSICAL ACCESS CONTROL PV Clean has developed procedures covering physical/technical access control wherever possible to ensure privacy of communications, maintenance of the security of the Company communication equipment, and safeguard Company assets from theft, misuse and destruction. We are responsible for complying with the security policies in your location. You must not defeat or cause to defeat the purpose for which the access control was implemented. USE OF COMPANY ASSETS The use of PV Clean’s assets for individual profit or any unlawful, unauthorized personal or unethical purpose is prohibited. Our information technology, intellectual property (e.g., copyrights, patents, and trademarks), facilities, equipment, machines, software, and cash may be used for business purposes only, including responsible and accurate expense reimbursement, and in accordance with applicable policies. Other assets (e.g., computers, printers, and copiers) may be used for minor and incidental personal purposes provided such use is kept to a minimum, and does not create any significant incremental costs, interfere with work duties, or violate any laws or PV Clean’s policies. The use of any PV Clean’s resources for personal or political activities is prohibited. Computer hardware, software, data, and facilities are valuable resources that need protection from potential destruction, theft, or misuse. These resources may also include confidential client or PV Clean’s information that requires safeguarding. It is your responsibility to prevent unauthorized access through the use of ID badges, passwords, or other security codes, and physical security measures (such as using computer cable locks, not leaving computers unattended in cars, and other normal precautions). Copyrighted materials (e.g., books, music, software, and magazines) should not be reproduced, distributed, or altered without permission of the copyright owner or an authorized agent. Software used in connection with the business of PV Clean should be properly licensed and used only in accordance with that license. Using unlicensed software could constitute copyright infringement and may be grounds for disciplinary action. EXPENSE CLAIMS Each supervisor, manager, and individual employee has an obligation to each other and to the Company to comply with PV Clean’s business expenses and reimbursement policies and practices. All business-related expense claims must be authorized by your manager before being incurred. Personal expenses will not be reimbursed by the Company. Committed To Our Customers And Our Suppliers To many people, you are the only “PV Clean” that they will ever meet—as such you are a brand ambassador and a representative of the Company. For instance, if our job involves working with current or potential Company customers / suppliers, we must act in a 86

EMPLOYEE HANDBOOK I PVCMT-HRM-01 manner that is representative of our values. The goodwill our Company enjoys is one of our most important assets, and we must preserve and enhance our reputation through our actions. FAIR DEALINGS We must deal fairly with the Company’s customers, suppliers, partners, service providers, competitors and anyone else with whom we interact while at work. We should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of facts or any other unfair dealing practice. CONFIDENTIAL INFORMATION OF CLIENTS AND THIRD PARTIES The Confidentiality and Nondisclosure Agreement we sign when we join the Company details our confidentiality obligations to the Company and its clients. We have access to significant amounts of client information that may not be available to the public, and we are required to preserve the confidentiality of information obtained in client service. Information of a confidential, private and sensitive nature must be used responsibly and controlled and protected to prevent its prohibited, arbitrary or careless disclosure. Unless the client has provided its specific consent, which should preferably be in writing, or there is a legal or professional right or duty to process or disclose, we are prohibited from processing or disclosing confidential client information. Confidential or proprietary information including personal information about clients, our organization, or other parties, which has been gained through employment or affiliation with PV Clean, may not be used for personal advantage or for the benefit of third parties. We are committed to protect the confidentiality of processing such personal information by implementing adequate technical and organizational measures, and all employees, agents, consultants, suppliers, contractors, are made aware of their responsibility to use, or process personal information, unless authorized by law and/or contractually agreed. FREE AND FAIR COMPETITION At PV Clean, we believe that a free and fair market benefits all of us and ensures that our clients receive the best quality products and services at the best prices. In our country we have laws to encourage and protect free and fair market competition by regulating anti- competitive conduct, including unfair acts by market leaders. These laws regulate our relationships with our customers, competitors, distributors, and resellers. What do we need to know? What is regulated? How do we comply? ■ Anti-trust laws generally address the following areas: Unfair pricing practices (including price discrimination), secret rebates, exclusive dealerships or distributorships which are questionable, restrictions on carrying competing products and other practices. If you come across any such questionable practices in the course of your work, for instance, while working , please contact the HR. ■ You should not knowingly make false or misleading statements regarding our 87

EMPLOYEE HANDBOOK I PVCMT-HRM-01 competitors or the products and services of our competitors, customers, or suppliers. ■ Collusion among competitors is illegal. Our communications with competitors should always avoid subjects such as prices or other terms and conditions of sale, customers, and suppliers. You should not enter into an agreement or understanding, written or oral, express, or implied, with any competitor on these subjects. INDUSTRIAL ESPIONAGE Our commitment to fairness includes respecting the rights of our competitors and abiding by all applicable laws. As a lawful competitor and to help ensure the integrity of the competitive marketplace, we must respect our competitors. Take care that we do not appropriate or unlawfully use the information, material, products, intellectual property, or proprietary or confidential information of anyone including suppliers, customers, business partners or competitors. SELECTING SUPPLIERS The Company’s suppliers make significant contributions to our success. We strive to create an environment where our suppliers are confident that they will be treated with respect. We select our significant suppliers or enter into significant supplier agreements though a competitive bid process where possible. Records, Disclosures And Audits MAINTAINING ACCURATE RECORDS The integrity of our financial transactions and records is critical to the operation of our business. Our shareholders’ trust is based on their confidence in the accurate recording of our financial transactions. If you have responsibility for or any involvement in financial reporting or accounting, you should have an appropriate understanding of, and you should seek in good faith to adhere to, relevant accounting and financial reporting principles, standards, laws, rules and regulations and the company’s financial and accounting policies, controls and procedures. If you are a senior officer, you should seek to ensure that the internal controls and procedures in your business area are in place, understood and followed. ENSURING ACCURATE PUBLIC DISCLOSURES PV Clean is committed to provide full, fair, accurate, timely and clear disclosures in reports and documents that we file with, or submit to our regulators and in our other public communications. To enable this, we must ensure that we comply with our disclosure controls and procedures, and our internal control over financial reporting. AUDITORS Our outside auditors have a duty to review our records in a fair and accurate manner. We must cooperate with them in good faith and in accordance with law. We must never 88

EMPLOYEE HANDBOOK I PVCMT-HRM-01 mislead them in any manner regarding financial records, processes, controls or procedures or other matters which they may enquire about. INTERACTING WITH REGULATORS We must fully and truthfully cooperate with any examination or request for information from a regulator or law enforcement agency. Any contact with law enforcement agencies or regulators must be coordinated through the HR & Admin Department. Administering Our Code The HR & Admin is responsible for administering the Code and reports to the CEO and Boards of the Company. INVESTIGATIONS We have put in place a process to review and investigate all potential legal or Code violations. Investigations will be conducted in confidence and will be respectful and fair. If an allegation is substantiated by an investigation, the appropriate management team will review the findings and determine the outcome. Should you report a potential violation in good faith, you are assured of all support by the Company. This support is extended to any person who is assisting in any investigation or process with respect to such a violation as well. You can report any potential violation in good faith without ever worrying, for instance if it will affect you professionally. Any such retaliation may be immediately reported to the HR. If you are the subject of an external investigation, you should immediately report this to your manager unless it is prohibited by law. ACKNOWLEDGEMENT Employees and our Board of Directors are required to acknowledge that they have read and understood the Code. Our Independent directors may be required to acknowledge acceptance of the Code for Independent Directors as well. You must remember that under no circumstances does your failure to read our Code, sign an acknowledgement or certify online exempt you from your obligation to comply with our Code. Disciplinary Actions If you violate our Code, the Company will take appropriate disciplinary action. The matters covered in this Code are of the utmost importance to the Company, its shareholders and its business partners, and are essential to the Company’s ability to conduct its business in accordance with its stated values. We expect all of our directors, officers, employees and third party agents to adhere to these rules in carrying out their duties for the Company. We take violations of this Code, Company policies and applicable laws seriously. Where appropriate, the Company takes prompt corrective action, up to and including termination of employment. We strive for consistency and fairness in discipline for Code 89

EMPLOYEE HANDBOOK I PVCMT-HRM-01 violations. Discipline may include a verbal or written warning; suspension with or without pay; loss or reduction of variable pay/Bonus, demotion; or, for the most serious offenses or repeated misconduct, termination of employment. Any disciplinary action depends on the nature, severity, and frequency of the violation. It may vary depending upon local law. Please understand that those who violate the laws or regulations mentioned in the Code could expose themselves and the Company to substantial civil damages and criminal penalties. Corrective action may be taken if you: ■ Violate the Code, Company policies and procedures, or applicable laws. ■ Direct others to violate the Code, Company policies and procedures, or applicable laws. ■ Are aware of a violation or potential violation and fail to report it. ■ Fail to effectively monitor the actions of people you manage. ■ Do not cooperate in a Company audit or investigation. ■ Fail to participate in required training. ■ Retaliate against someone for reporting a concern in good faith or for participating in an investigation of such a report. ■ Disclose information learned during an internal investigation. 90

PV CLEAN MOBILITY TECHNOLOGIES PVT. LTD. 9.1 GURGAON - FAROOKHNAGAR ROAD, VILLAGE DHANKOT, GURUGRAM, HARYANA, INDIA - 122001 e. [email protected]