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Volume 1- Issue 1Employee Manualfor

Managers & Associates

(KEC International Ltd.)

Release Date: April 2012

*Not applicable to KEC International Ltd.- Officers- Refer Volume 2

Volume 1- Issue 1


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Table of Contents

1. Welcome to RPG ------------------------------------------------------------------------- 4

1.1About RPG Group & Business Sectors ----------------------------------------------------------- 5

1.2

Vision -------------------------------------------------------------------------------------------------- 61.3Values ------------------------------------------------------------------------------------------------- 6

1.4Human Resources Mandate ----------------------------------------------------------------------- 7

1.5Employer Brand Proposition ---------------------------------------------------------------------- 7

1.6Reward and Recognition Programs-------------------------------------------------------------- 8

1.6.1 RPG Outstanding Achievers Award ( VP & Above) --------------------------------- 8

1.6.2 RPG Top Gear Award ( AM to GM) ----------------------------------------------------- 8

1.7Communication Channels------------------------------------------------------------------------- 9

1.8Grow @RPG ----------------------------------------------------------------------------------------- 9

1.9Group CSR Initiatives------------------------------------------------------------------------------ 10

2. Welcome to KEC International ------------------------------------------------------ 11

2.1About KEC International -------------------------------------------------------------------------- 12

2.2Historical Milestones ------------------------------------------------------------------------------- 12

2.3Vision -------------------------------------------------------------------------------------------------- 12

2.4Mission ------------------------------------------------------------------------------------------------ 13

2.5Organogram ------------------------------------------------------------------------------------------ 13

2.6Management ------------------------------------------------------------------------------------------13

2.7Grade and Designations --------------------------------------------------------------------------- 14

2.8Business Spectrum ----------------------------------------------------------------------------------15

2.9

Culture Pillars --------------------------------------------------------------------------------------- 17

2.10 HR Vision ---------------------------------------------------------------------------------------- 17

2.11KEC Felicitations ----------------------------------------------------------------------------------- 17

2.12KEC CSR Initiatives -------------------------------------------------------------------------------- 20

3. Workplace Guidelines ----------------------------------------------------------------- 22

3.1Ethics and Code of Conduct ---------------------------------------------------------------------- 23

3.2Open Door Policy ----------------------------------------------------------------------------------- 30

3.3Equal Opportunity Employer -------------------------------------------------------------------- 30

3.4Payroll Guidelines ---------------------------------------------------------------------------------- 31

3.5

Social Media Policy --------------------------------------------------------------------------------- 31

3.6Dress Code Policy ------------------------------------------------------------------------------------34

3.7Office Timings and Attendance ------------------------------------------------------------------- 35

3.8Environment, Health & Safety (EHS) Policy ----------------------------------------------------38

3.9Quality Policy -----------------------------------------------------------------------------------------38

3.10 Office Security Guidelines--------------------------------------------------------------------- 39

4. Information Technology Policy ---------------------------------------------------- 40

4.1Electronic Communication Policy--------------------------------------------------------------41


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4.2Hardware Procurement & Disposal ----------------------------------------------------------44

4.3Information Security Policy --------------------------------------------------------------------45

4.4Virus Combat Policy -----------------------------------------------------------------------------46

5. HR Policies/Procedures and Entitlements/Benefits--------------------------- 485.1Parichay - The KEC - Employee Referral Policy --------------------------------------------49

5.2Travel Policy ---------------------------------------------------------------------------------------51

5.3Transfer Policy / Assistance for shifting of residence-------------------------------------52

5.4Exit Policy ------------------------------------------------------------------------------------------53

5.5Entitlements & Benefits -------------------------------------------------------------------------54

5.5.1 Policy on Mobiles / Landlines/ WLL------------------------------------------------54

5.5.2 CAP Customised Allowance Pool Rules-------------------------------------------55

5.5.3 Leave Rules ------------------------------------------------------------------------------56

5.5.4 Conveyance Expenses and Meal Allowance----------------------------------------59

5.5.5

Annual Health Check Up---------------------------------------------------------------605.5.6 Kit Allowance----------------------------------------------------------------------------61

5.5.7 Health and Medical Policy -------------------------------------------------------------61

5.5.7.1 Group Medical Policy (Hospitalization)---------------------------------------61

5.5.7.2 Personal Accident Policy---------------------------------------------------------63

5.5.7.3 Group Term Life Insurance-------------------------------------------------------64

5.5.8 Retirement Benefits --------------------------------------------------------------------64

5.5.8.1 Provident Fund --------------------------------------------------------------------64

5.5.8.2 Gratuity -------------------------------------------------------------------------------65

5.6Procedure ------------------------------------------------------------------------------------------65

5.6.1

Reimbursement of official expenses ------------------------------------------------65

6. Policies applicable to Domestic Sites---------------------------------------------- 67

6.1Field Travel Allowance (FTA) -----------------------------------------------------------------68

6.2Site Accommodation Allowance--------------------------------------------------------------68

6.3Transfer Reimbursement Policy --------------------------------------------------------------69

6.4Disturbance Allowance--------------------------------------------------------------------------69

6.5Procedure to Apply for Leave------------------------------------------------------------------70

7. HR Processes & Practices at KEC--------------------------------------------------- 71

7.1

On Boarding ----------------------------------------------------------------------------------------727.2Performance Management System ------------------------------------------------------------73

7.2.1 Goal Setting-PRIDE----------------------------------------------------------------------73

7.2.2 Mid Term Review------------------------------------------------------------------------73

7.2.3 Annual Performance Appraisal------------------------------------------------------ 74

7.2.4 Career Dialogue------------------------------------------------------------------------- 74

7.3Capability Building------------------------------------------------------------------------------- 74

7.3.1 Development Action plan (DAP)-----------------------------------------------------75

7.3.2 Blended Learning Curriculum--------------------------------------------------------75

7.3.2.1 Classroom training---------------------------------------------------------------- 76


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7.3.2.2 E-Learning-------------------------------------------------------------------------- 76

7.3.3 Training Institute @ Butibori-------------------------------------------------------- 76

7.3.4 Organization Management Review------------------------------------------------- 77

7.4Culture Building---------------------------------------------------------------------------------- 77

7.4.1

KEC Role Model Behaviour Workshop--------------------------------------------- 777.4.2 Transform-360 Degree feedback tool---------------------------------------------- 78

7.5Employee Engagement-------------------------------------------------------------------------- 78

7.6Reward and Recognition Programs---------------------------------------------------------- 79

7.6.1 Challenger Award-----------------------------------------------------------------------79

7.6.2 U R the Brand Program---------------------------------------------------------------- 81

7.6.3 KEC Role Model Award---------------------------------------------------------------- 81

7.6.4 Well Done Award----------------------------------------------------------------------- 81

7.7 Fun @ Work Initiatives------------------------------------------------------------------------- 82

7.8 Communication Channels---------------------------------------------------------------------- 83

7.8.1

KEC Connect----------------------------------------------------------------------------- 837.8.2 HR Online-------------------------------------------------------------------------------- 83

7.8.3 Forum-------------------------------------------------------------------------------------84

7.8.4 InfraTimes------------------------------------------------------------------------------- 84

8. Annexure ----------------------------------------------------------------------- 86

8.1Forms and Templates ---------------------------------------------------------------------------87

8.2Process Documents ------------------------------------------------------------------------------88

8.3Important Links ---------------------------------------------------------------------------------- 88

*Wherever grades are mentioned it is with respect to designations only, please do not confuse it withcategories


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Section 1-Welcome to

RPG


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1.1 About RPG Group & Business Sectors

RPG Enterprises, established in 1979, is one of Indias fastest growing business groupswith a turnover of around US $3 Billion. The Group comprises of multiple companies withdiverse business interests in the areas of Tyre, Infrastructure, IT and Speciality.Below are the companies under the leadership of our Chairman, Mr. Harsh Goenka.

Business Sectors


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Respond.... Perform.... Grow....

These are the pillars on which RPG has built its foundations to become one of the largest

business houses of India with assets of over US $2.5 billion. Today the Group companies

have worldwide presence and partnerships with many transnational corporations.Wide-ranging businesses, growing returns and a reputation to reckon, makes workingwith RPG an enriching experience. At RPG entrepreneurial skills are valued, excellence isthe by-word, and performance is a pre-requisite.

RPG touches us in every sphere of our lives with infrastructure providing the foundationfor modern lifestyle, with tyres that transport us, with technology that helps us performbetter, with tea that refreshes us, with medicines that save lives, and in many other ways.It is truly a culmination of efforts highlighted by the qualities of Response, Performanceand Growth.

1.2 Vision

We shall be a leading Indian Group with a focus on market capitalization through:

Leadership in profitability and revenue growth in our chosen businesses. Being a customer-centric organization, and Being the most exciting workplace.

1.3 Values

A value system acts as a compass for a persons actions. Similarly, the RPG values are

guidelines that determine the ways in which RPGians interact with internal and external

stakeholders. The values are -

Customer Sovereignty

People Orientation

Innovation & Entrepreneurship

Transparency & Integrity

Passion for Superior Performance

Anticipation, Speed & Flexibility


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1.4 Human Resources Mandate

We at RPG believe that one of the most important competitive advantages of an

organization is its employees. Thus, it is critical that we use the right practices to acquire,

develop, engage and retain our people. Moreover, our human resource strategy needs to

be aligned with our business requirement. The HR mandate for RPG is as below-

1.5 Employer Brand Proposition

RPG has a value proposition for its present and prospective employees who outline what

the Group promises to offer and what makes RPG an exciting place to work. The Employer

Brand Position is as below-

Build a High Performance Organization

Align HR Interventions with Business Objectives

Drive People Development & Growth Opportunities

Champion RPG Values

Creating an Exciting Workplace


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1.6 Reward and Recognition Programs

1.6.1 RPG Outstanding Achievers Award (VP & Above)

This award was conceived and communicated as a part of the RPG Rewards and

Recognition policy aimed at driving high performance orientation across the RPG Group

and honour and build visibility for outstanding achievements.

Selection Criteria

Evidenced accomplishments that meet one or more of the following five parameters:

Impact on Bottom Line Impact on Quality and Customer

Impact on Process Flow / Work Method / Operational Efficiency Impact by Exemplary Leadership Contribution Outside Scope of Principal Accountabilities Adherence to/Demonstration of Group Values in action

Eligibility, Nomination and Selection

Full-time employees of the RPG Group (VP and Above). Accomplishment in the 12-month period prior to the nomination for awards Nominations from Managing Director of respective Companies & Sector Heads.

Group Chairman/ Vice Chairman to select winners.Awards

There would be up-to 5 Awards across the Group.

Winners will receive a Holiday package for two to London or equivalent

destination.

1.6.2 RPG Top Gear Performance Award (AM to GM)

The purpose of this award is to encourage high performance orientation among

employees of all Group companies. People selected, who display the defined performance

parameters, from across the RPG Group will be recognized and awarded for their

outstanding achievements.

Selection Criteria: Evidenced accomplishments that meet one or more of the following

five parameters:

Impact on Bottom Line

Impact on Quality and Customer Impact on Process Flow / Work Method / Operational Efficiency


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Contribution Outside Scope of Principal Accountabilities Adherence to/Demonstration of Group Values in action

Eligibility, Nomination and Selection

Full-time employees in the managerial cadre of the RPG Group i.e. AssistantManager to General Manager.

Accomplishment in the 12-month period prior to the nomination for awards

Nominations from Functional Heads / Customers (internal or external) Sector Business Heads to select the winners for each sector. MD/CEOs, Company

Management Committees and Sector HR Heads to facilitate selection process

Awards

In addition to the annual increments and performance incentives

Up-to FIVE Awards per Sector All individual awards; no quota based on grades / function applicable Winners to receive a Holiday package for two to a South East Asian destination

within the sanctioned budget of Rs. 120,000.

1.7 Communication Channels

RPG believes in establishing a strong connect with its numerous employees in variousGroup companies. Common platforms used to engage employees are as below

RPG Lounge An intranet spanning the entire Group. A place for all RPGians toconnect, share ideas and discuss issues. A virtual forum for the Group leadership toaddress all employees. Visit it at www.rpglounge.in

Forum Forum is a monthly information sharing session between the seniormanagement and the other employees of the company which is partly face to faceand partly through electronic media. This is an occasion where the employeesacross locations can connect with Group leaders and voice queries.

RPGCom RPGCom is the official quarterly group magazine. This magazine helps

keep employees updated with events across Group companies and variouslocations.

1.8 GROW@RPG

Grow@RPG is a way to inform employees of openings and to identify qualified and

interested applicants who might not otherwise be known to the hiring manager.


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In general, notices of all regular, full-time job openings are posted, although the Company

reserves its discretionary right not to post a particular opening. For information

regarding the latest job openings visitwww.rpglounge.com/recruit

1.9 Group CSR Initiatives

RPG is a socially responsible organization; it believes in giving back to the community

what it has gained from it. The Group has a centralized CSR team that co-ordinates teams

and volunteers at company level. CSR is encouraged as a company policy. Individual

employees are also encouraged to do their part to give back to society.

Education, employability and environment, are the three broad focus areas for the RPG

Groups CSR initiatives.

Education & Employability:

Saksham Program- Understanding the vitality of soft skills in our lives, the Groupinitiated a flagship training programme for adolescents called Saksham. It is an overallgrooming and confidence building programme focused at the age group of 16-20 years ofage.

AKSHAR Program- It has been initiated since April 2010. This intervention is focussed

on spoken English proficiency and reading English text among students.

Environment

We often tend to take for granted what Nature has gifted us. However, at RPG we realize

the importance of the global environmental crisis, and we intend to optimize resources,

reduce wastage of paper, power and food. Our aim is to become environmentally

responsible. Towards this end, RPG celebrates the World Environment Day to create

awareness about recycling wastes, reduce usage of plastic and initiate action to reduce

global warming by planting saplings with the support of the forestry department.

Our Group companies have taken several initiatives in creating awareness about global

warming, conservation of trees and recycling of paper and reduce plastic. Effective waste

management apart, one of our companies has also initiated a kitchen garden and a bio-

sanitisation project.
http://www.rpglounge.com/recruithttp://www.rpglounge.com/recruithttp://www.rpglounge.com/recruithttp://www.rpglounge.com/recruit


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Section 2-

Welcome to KEC


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2.1 About KEC International

KEC International, the flagship company of the RPG Group,is a diversified global major

in the Infrastructure Engineering, Procurement & Construction (EPC) space. Earlier

known as Kamani Engineering Company, KEC was taken over by RPG in 1982. Today,

with revenues exceeding a Billion Dollars, KEC has project footprints in more than 45

countries. 6 decades of comprehensive experience has made KEC a force to reckon in

diverse areas such as design, testing, manufacturing of towers and cables, project

management, construction of turnkey projects in areas of power transmission, power

distribution, telecom, railways and water infrastructure projects.

2.2 Historical Milestones

2.3 Vision

To be a global leader in Power Transmission and Distribution EPC business and a

significant player in other infrastructure businesses, providing superior value to all

stakeholders.


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2.4 Mission

To be a global player in the power transmission and distribution industry.

To meet customer requirements in terms of quality and time.

To be the most cost effective contracting and manufacturing company, byinstitutionalizing processes and utilizing state-of-the-art technology.

To provide a challenging and fulfilling work culture to our employees.

2.5 Organogram

2.6 Management

KEC Apex Management Body- Management Review Members (MRM) are:


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Leadership Team

2.7 Grades and Designations:

KEC International has a strong organization structure that forms the back bone of all its

businesses. The organization structure has defined grades and designations as per their

expertise, experience and capabilities. They are:

Grades Category Designation

M11 ManagingDirector

Managing Director

M10 President President

M9 ExecutiveDirector

Executive Director

M8 Vice President Chief Executive/Sr. Vice President

M7 General

Manager

Vice President

M6 Chief Manager General Manager

M5 Dy. General Manager

M4 DivisionalManager

Chief Manager

M3 Sr. Manager Sr. Manager

M2 Manager Manager M2

M1 Manager M1

M0 Asst. Manager Asst. Manager


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2.8 Business Spectrum

Transmission

KEC International Ltd is involved in Design, Supply and construction of high voltage

Overhead Transmission lines. They consist of bare overhead line conductors supported

on galvanized steel structures. The tower manufacturing factories are at Jabalpur,

Butibori, Jaipur, Mexico & Brazil. Items like conductors, insulators hardware are

outsourced from various suppliers. They are designed to resist the various loading

conditions at the design department of the company using various softwares.

Construction of the Transmission Line at site is done either by KEC departmental gang or

by using Sub-Contractors.

Distribution

KEC is involved in design, supply and construction of distribution lines. Typically a

distribution line comprises of concrete, wood or steel poles supporting bare overhead

line conductor. The concrete poles are manufactured at site in a pole plant this was done

by the company for projects in Ethiopia and Afghanistan. Steel poles are either

manufactured in the manufacturing units or outsourced. Wooden poles, conductors,

insulators and accessories are outsourced. Construction of distribution line is done at siteusing Sub contractors or departmentally.

Power Systems

Designing and construction of substations ranging from 11KV to 220KV is done at

KEC. Items like Transformers, Isolators, Fuses, switches, Lighting, Arrestors,

conductors, insulators, cables and panels are outsourced. Steel structures used for

mounting various structures are manufactured at KEC factories. Construction is

done by Sub-Contractors.

Telecom

KEC is positioned in the field of telecom, among leading vendors in providing

turnkey infrastructure solutions, to operators and tower management companies

as the company has:

o Successfully implemented about 400 sites for USOF in Chhattisgarh,Meghalaya & Mizoram on BOO basis.

o Commissioned 210kms repeater less Optical Link in Afghanistan.


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Cables

Since 1990, Cables division has supplied more than 400 kms of EHV XLPE cables

from 66 V to 132 KV in India. They are the highest suppliers of 132 KV grade 123

kms to utilities in India. Their products have been type tested & approved by CPRI

Bangalore since 1993. RPG Cables merged with KEC in March 2010 with a view to

consolidate KECs presence in the post-generation power value chain.

Cables SBU has its manufacturing plant at Mysore, Silvassa, Thane & Vadodara.

They have a dedicated Design team capable of designing cables to customer

specific requirements & various international standards.

Railways

KECs Railways division has transformed into a complete turnkey solution providerin the EPC space. The services include:

Civil Infrastructure including earthwork, bridges, tunnels, station building andfacilities.New Track laying and rehabilitation of existing tracks.Railway Electrification and power systems.Signalling & Telecommunication network.

KEC executed the first Railway Electrification Project when the Indian Railways launched

the electrification of tracks and has been continuing to do so for major projects across the

country. The main client in this sector is CORE (Central organization for Railway

Electrification). The division has developed a strong vendor base and logistics provider

network in India.

Water

It is the latest addition to KECs diverse business domain. It made its foray in this area in

2011. The waters business is an up-coming sector with tremendous growth opportunity

in the near future and KEC is poised to tap it. KEC possesses the capabilities for executionexpertise at every phase of water and waste water management. It has a tie-up with a

German company BIOWORKS AG for advanced technologies such as Activated Sludge

Process, Sequential Batch Reactor, Rotating Bed Bio Reactor, Moving Bed Bio Reactor as

well. The expertise covers activities like -

Irrigation and Hydroelectric construction

Embankment and Flood Control

Sewage and industrial effluent treatment

Potable water treatment and distribution


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2.9 Culture Pillars

Culture is the common thread that connects KECians across SBUs and geographies.

Moreover, it is this culture that has contributed to KEC evolving from an Indian

engineering company to a global infrastructure major.

The combination of cultural attributes that define a KECian are-

2.10 HR Vision

Creating an exciting workplace which inspires superior people performance.

2.11 KEC Felicitations

In its journey towards excellence, KEC has been recognized in many spheres for its

numerous accomplishments. Some notable awards are mentioned below:

KEC International wins Top Exporter Award for the Year 2010-11

KEC won Top Exporter Award for the Year 2010-11, at the prestigious 43rd edition ofEngineering Export Promotion Council (EEPC) INDIAs National Awards for ExportExcellence.

KEC has received the Gold Trophy in the Merchant Exporter category which is the highestrecognition given to Indias largest exporter of engineering goods.

To deliver any job within agreed time without comprising on quality.Delivery Focus

To internalize ownership of task & accountability of its results.Cost & Profitability Focus

To have a cost conscious approach for increasing Profitability for all jobs.Ownership & Accountability

To collaborate across functions by improving transparency and communication.Cross Functional Teamwork

To ensure high performance by empowering people.Empowering Performance

To nurture an environment of mutual care and respect with focus on personal

and professional growth.Valuing People

To leverage the diverse opportunities across SBUs and functions for

employees to experience and learn.Providing Diverse Opportunities

To be a more energetic, diverse, inclusive and dynamic workforce.Forward Looking


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Mr. Vimal Kejriwal, President - Transmission Business receiving the Award from Mr. Milan

Hovorka, Deputy Minister, Ministry of Industry and Trade, Czech Republic

KEC International wins CII Design Excellence Awards 2011

KEC wins CII Design Excellence Awards 2011 under Industrial DesignCapital GoodsCategory.

In the very first year of this New Award Category, KEC won the "Best Design Award"for Excellent Power Transmission Tower Design work.

Award being received by E V RaoKEC International wins NHRD Awards

KEC won one of the most prestigious awards in the HR domain - The JURY AWARDfor the Best HR Practice conducted by NHRDN at their 15th Annual Conference.

Apart from the Jury Award KEC also bagged the 'Most Popular Practice ExhibitAward' with the highest number of votes.

KEC wins Certificate of Merit from Indian Society of Training & Development (ISTD)for making it to the Top 20 in the category of Innovative Training Practices.

MD & CEO , Sr.VP-HR and Team Award being received by HR Team


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KEC wins an award for "Top 10 green IT Enterprise Awards 2011"

KEC received trophy from IDG media.

This award is given in recognition of contribution made to save energy, space and toimprove data security.

The publisher (IDG Media), of international magazines like CIO, PC World andComputer world in association with Schneider Electric have instituted this award.

KEC Wins Export Excellence Awards at All India level Consecutive for last 3 years

Wins Gold trophy from EEPC India. Highest Exporter in Merchant Enterprise category for years 2006-07, 2007-08 &

2008-09.

(2006-07) (2007-08) (2008-09)

Corporate Leadership Awards

Mr. Ramesh Chandak, MD & CEO, wins CA Corporate Leadership Award 2008 by theInstitute of Chartered Accountants of India.

Mr. Vardhan Dharkar, CFO, wins the Best CFO 2009Infrastructure & Construction

Category by the Institute of Chartered Accountants of India.

(Mr. Ramesh Chandak Year 2008) (Mr. Vardhan Dharkar Year 2009)


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Others Awards & Recognitions

Received Maharashtra State Top Exporter Award in Merchant Exporter Category bygovernment of Maharashtra for 2006-07 & 2007-08.

Winner of Logistics 2.0 Supply Chain Award 2009 for RPG Cables.

Amity Corporate Excellence award for having achieved the enviable position of oneof the best and most admired business organization.

Second best exporter Award to our Nagpur plant for 2009.

Best employer award to our Jaipur factory from Employers' Association ofRajasthan for 2008 & 2009.

Award of merit for Quality Circle Competition by Quality Circle Forum of India(QCFI) in 2003 and 2009.

2.12 KEC CSR Initiatives

Akshar: 1557 students being touched by Akshar program in FY 2011-12 and are

continued to be positively impacted.

In Jabalpur 530 students are benefitting in 3 Government schools

In Butibori this program is being executed and 344 kids are benefitting. The

response from the children is encouraging. In Jaipur, 8 Schools have also been identified and this program has been launched in

Jan12. 497 students are being touched through thisinitiative

Cables SBU launched Akshar program in 3 primary schools near Vadodara covering186 students

ITI Ashti:

ITI Ashti near Butibori, was adopted in Feb 2011 with Mr. Kaushal Kudesia (VP-Manufacturing) as the chairman of the Institute Management Committee (IMC)


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constituted to look into the functioning of Ashti. The Institute was shifted from its oldpremise to a new and bigger premise. Functioning from the new premise has alreadybeen started. In 2011 84 students were enrolled, who are currently being trained on fourtrades- Fitter, Wireman, Plumber, Cutting & Sewing.

Old Premise:

New Premise:


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Section 3-Workplace

Guidelines


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3.1 Ethics and Code of Conduct

Although KEC recognizes and respects the right of employees to participate in activitiesoutside their jobs, those activities must be lawful and free of conflict with their

responsibilities as KEC employees. KECians should ensure that they do not misuse

company resources or influence or discredit KECs reputation and goodwill. They must

ensure fair and transparent dealings with their customers, suppliers and colleagues.

Following are the broad parameters of the policy and the framework for proper employee

conduct.

Examples of conflicts of interest which are to be avoided

a. Holding financial interest directly or indirectly, including through close relatives in

i. A company to which business is given.

ii. In a company in which the employee is involved in making a buy-outdecision.

b. Directing business to a supplier managed by a relative or close friend.

c. Soliciting subcontractors and vendors for donation/ advertisements to a charity, inwhich the employee is involved.

d. Using company facilities for personal purposes or for spouses / relative business.

e. Treating personal expenses / trips as business expenses/ trips.

f. Taking a part-time job requiring the employee to spend time, during normalworking hours or using office equipment in meeting personal responsibilities.

g. Making a promotion decision about a spouse or relative.

Consultancy

This should be avoided by all full time employees of the company.

Membership Of Social Service Organisations

Potential conflicts arise when an employee takes up memberships of Organisations and

Associations that undertake Social Service of various kinds. Conflicts arise in the form of

fund-raising from RPG Companies for such Associations / Organizations, using company

infrastructure and facilities to discharge responsibilities towards that organisation and

providing use of such facilities directly to the Association / Organisations and its

members. Prior approval from President / CEOs should be obtained, for undertaking such

activities.


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Gifts

a. The Employee shall not seek or solicit any kind of favours, cash or kind, either directlyor through, and/or for, spouse or any other relative, from suppliers, contractors and /or vendors.

b.

Buying equipment from suppliers for personal use at high discounts is absolutelyprohibited.

c. Accepting free trips / holidays within India and / or abroad and / or members ofemployees family, from suppliers is also absolutely prohibited.

d. Business associates such as JV partners, technology suppliers and other closely relatedcompanies may also make similar offers. These should be reported to Sector Heads,who shall provide guidance.

e. Small value gifts and flowers on festive occasions from anyone are normallyacceptable but, high value gifts those in excess of Rs.500, should be reported to the

CEO / Sector Heads, before acceptance.

Directorship Of Firms and companies outside the company

All Directorships should be cleared by the Chairmans office.

Relatives As Competitors

Close relatives in the employ of competitors should be disclosed with details of

relationship and responsibilities held.

If employment is unavoidable or an ongoing one for a long time, employee shouldexercise great discretion in maintaining confidentiality of Group / company information.

Confidentiality And Discretion

Employees should, at all times, realise that they are in possession of sensitive, classified

and confidential information that should not be parted with, in any circumstances to

Competitors, Investment analysts, Stock brokers, Newspaper reporters and Media

persons. Some illustrations of such information are given here.

A)

Financial Information.B) Tax Planning measures.C) Potential Joint Venture deals being negotiated.D) New product introductions.E) Manufacturing process and recipe for products.

Employees should maintain total confidentiality with any such classified information. In

the event of any query, clarification or explanation sought by any statutory authority,

government official and/ or police or judicial authority, the employee may, after taking


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prior approval of the CEO/ MD/ President, part with such sensitive, classified and

confidential information.

Common contractors for residential homes of decision-makers and of the plant

Employees should not have the same contractors / architects, who are doing work for thecompany, for their personal jobs.

Accepting honoraria for lectures outside

This is permissible provided:

a) Advance clearance is obtained from CEO / Sector Heads.

b) Proprietary KEC information is not revealed in the talk.

Financial interest

Among the most common types of financial interest are:

a) Ownership of equity.

b) Partnership interest.

c) Direct or indirect interest through a trust or other relationship.

Financial interest is a problem as soon as it presents a potential for conflict of interest

with responsibilities as a KEC employee.

For example, the employees job might involve selecting suppliers, selling to customers, or

extending credit to other companies. A potential problem might exist if the employee or

a relative also had a personal financial interest in one of those companies.

The interest could be direct or indirect what matters is the fact that actions as a KEC

employee might affect the value of the interest in the other company.Discretion and great

care are recommended for all such opportunities, The Sector Head must be kept

informed.

Setting up part time business or taking part time Jobs

This is not permissible. Every KEC employee is expected to give the best in terms of time,

creativity and energy. Moonlighting will impede employee performance and will result in

a conflict of interest situation.

Insider trading and stock tipping

SEBI prosecutes insider trading and imposes severe penalties on persons andorganizations involved therein. Avoiding this kind of activity within the Company is ofutmost importance. An insider trader is one who


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a) either on his own behalf or any other person, deals in securities of a body corporatelisted on the stock exchange, on the basis of any unpublished price sensitiveinformation; or

b) communicates any unpublished price sensitive information to any person with or

without his request, for such information, except as required in the ordinary course ofbusiness or under any law ; or

c) Counsels, or procures for any other person, to deal in any securities or anybodycorporate, on the basis of unpublished price sensitive information.

We are committed to the principles of fair and open markets for publicly traded securities

where everyone has an equal chance to succeed. At the same time, all Employees must

exercise great care that none of the above is ever violated.

Personal integrity

In day to day work most employees are called upon to support broad company

objectives like providing equal employment opportunity and environmental protection.

Some responsibilities are on a more personal level. For example, every employee also

has a direct role in helping to keep the companys records accurate and in protecting

company assets. Other issues can challenge individual integrity. Sometimes the chance

for illegal or unethical personal gain will arise. That is when employees must remember

that integrity depends on individual integrity. Every employee should develop the ability

to distinguish the right from the wrong and relentlessly follow the right - even when it

may be very tempting to do otherwise.

Financial controls & records

Every employee should follow financial accounting, reporting and control procedures, as

well as rules for the release of financial information outside the company.

Whether a time card is being filled-out, purchase orders are being prepared or financial

status of the company is being reported, strictly follow the accounting, reporting and

control procedures. Keep records accurate, timely and complete, and protect the security

of assets.

From time to time auditors may want to look at files and discuss matters with employees.

Every employee should welcome these reviews because they are designed to prevent

problems from occurring. Under company policy, every employee is obligated to give

auditors full access to records and any other co-operation required. Also, all financial

information should be kept confidential and should be released to others, only after

considering the interests of the company as a whole and after appropriate authorization.


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Sexual harassment at workplace

The Supreme Court has laid down stringent rules in this regard. Equality in employment

can be seriously impaired when women are subjected to gender specific harassment such

as sexual harassment at workplace. Such conduct is discriminatory when the woman has

reasonable grounds to believe that her objection would disadvantage her in connectionwith her employment, including recruiting or promotion, or when it creates a hostile

working environment.

KEC strongly believes in Equality in employment. KEC understands that Equality in

employment can be seriously impaired when women are subjected to gender specific

harassment such as sexual harassment at workplace. Such conduct is discriminatory

when the woman has reasonable grounds to believe that her objection would

disadvantage her in connection with her employment, including recruiting or promotion,

or when it creates a hostile working environment. It is expected of all the KEC employeesto always maintain equality of employment and to prevent the commission of acts of

sexual harassment.

Sexual harassment is defined as unwelcome sexually determined behaviour as -

1. Physical contact and advances;

2. A demand or request for sexual favours;

3. Sexually coloured remarks;

4. Showing pornography;

5. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

In this regard, the Employee can refer to the procedure for resolution, settlement or

prosecution for acts of sexual harassment. For this purpose, a full set of guidelines is

available with each company. Any such incident must be reported to the Head of the

Company and or the Person (s) in-charge of work place so that appropriate steps are

taken to prevent sexual harassment.

Corrective action

a)

Corrective action may be required even if an employee reports a Potential conflict ofinterest. There need only be a realistic possibility of injury to KEC for a manager toconsider taking corrective action. If situation could impair an employees judgment orperformance of company duties, damage KEC reputation, or result in a direct financialloss to KEC, steps should then be taken to correct the situation.

b) While the code has attempted to cover a number of areas, it cannot be comprehensive.Whenever any conflicts are perceived, it is best to consult the President / CEO /superior before taking any decision, in such cases.


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c) A RPG Group Level Ethics Committee comprising of the President Human Resourcesand two Sector Heads nominated by Group Chairman, has been formed. Any queriesrelated to the ethical policies may be referred to this committee, for resolution.Query in this regard can be sent to President Human Resources of the Group.

d) Similarly, any breach of ethics or any anonymous letters should be referred to thiscommittee, for further action. This committee has been empowered to initiate anyinquiry proceedings / investigations and decide upon penal actions. The decisiontaken by the committee will be final and binding.

Code of Conduct

a) Employee shall devote his / her whole time and attention to and use his / her bestskills and care in the business and affairs of the Company and at all times faithfullyand diligently perform such duties assigned to him / her by the Company.

b)

Employee shall not at any time during the continuance of the employmenthereunder solicit, seek, engage or be interested or concerned either directly orindirectly or alone or jointly in any other office, trade, business or occupation savethe previous permission in writing of the Company.

c) Notwithstanding anything to the contrary in this document if, in the opinion of theCompany, an employee commit any breach in the observance of performance ofhis / her obligations hereunder or if the employee is, in the opinion of theCompany, guilty of any misconduct, including disobedience, breach of duty orgross carelessness or if the employee is absent himself / herself without leave

then and in any and every such case it shall be lawful for the Company,(notwithstanding any waiver by the Company of antecedent breach orcircumstances justifying the termination of the services of the said employeeunder this clause) to terminate this employment forthwith without noticewhatsoever and/or to dismiss the employee from the services of the Companywithout prejudice to the Companys remedial rights in respect of such breach orcircumstances. In the event of such termination or dismissal the employee will beentitled to his / her salary, if any, only upto the date of termination.

d) As a corollary to his / her obligation, the employee shall devote his / her whole-time attention to the Company and will use his / her best skills and care for thebenefit of the Company. Any discovery or invention or secret process orimprovement in procedure made or discovered by the employee or any workcapable of copy right whilst in the service of the Company in connection with or inany manner affecting or relating to the business of the Company or capable ofbeing adopted for use therein or in connection therewith shall forthwith bedisclosed to the Company and if and whenever required to do so by the Company,the employee shall, at the cost the Company, apply or join the Company inapplying for letters patents or other equivalent protection in India and in anyother part of the world for any such discovery, invention, process or improvementas aforesaid and shall at the cost of the Company execute and do all instruments


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and things necessary for vesting the said letters patents or other equivalentprotection when obtained and all right, title and interest to and in the same shallvest in the Company absolutely and as sole beneficial owner or in such otherperson as the Company may specify.

e) During employees association with the Company, he / she will have access to andbe furnished with such information, trade secrets, processes, inventions,customer/supplier lists, etc. which would be sensitive for the Company andtherefore would be treated as absolutely confidential (Confidential Information)and he / she may himself / herself develop or be a contributory to suchConfidential Information. Hence, as a corollary to employees bounden duty to actalways in the interest of the Company, he / she shall be obliged not to divulge orcommunicate to any person other than necessary to those who need to know suchinformation for Companys business and use such Confidential Information solelyfor the benefit and in the best interests of the Company.

f) (i) As such Confidential Information belongs to the Company and is always to beused for the Companys benefit, needless to mention, such obligation on the part of

employee will have to be honoured, even after he/ she ceases to be associated withthe Company. Considering the sensitivity of the confidential information whichwill come to the knowledge of the employee, he / she shall not engage in anyactivity even after ceasing to be in employment with the Company, which willadversely affect the interest of the Company including advising and utilizing theinformation for the benefit of any party to the disadvantage of the Company.

(ii) Hence the employee shall not, either directly or indirectly, at any time withintwelve months after cessation of your employment with the Company, take up anyemployment or assignment or partnership or proprietorship or become a director,shareholder, agent or associate or be associated in any manner, whatsoever, with/in any business or organisation, which is in competition with the Company.

(iii) Employee can also during the tenure with the Company and during the noticeperiod prior to your separation with the Company, be restrained from coming towork, associating or communicating with the Company officials for such time as isconsidered necessary.

g) Employee shall not at any time within twenty-four months after the cessation ofhis/ her employment with the Company, either directly or indirectly, or throughany proprietary firm or a partnership firm in which he/ she is a partner or throughany Company in which he / she is a shareholder or director, or associated in anymanner whatsoever, solicit or employ or appoint as agent, or associate with, anyemployee or officer of the Company unless a period of twelve months has elapsedsince the date of separation of the concerned employee, agent or associate, unlessspecifically approved by the Chief Executive of the Company.


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h) It is hereby agreed by the Employee that in the event of a breach of clause ( f) and(g) above, the Company shall be entitled to initiate appropriate legal proceedingsfor the redressal of the damage including proceedings to restrain him/ her fromcontinuing the said breach.

i) Employee shall also not request, encourage or cause any of the past, present orprospective customer, supplier, employee, independent contractor to withdraw,curtain or cancel a business relationship with the Company or otherwise interferein any manner with the relationship between the Company and such past, presentor prospective customer, supplier, employee, independent contractor.

j) Employee shall fully comply with all rules and regulations as applicable in theCompany as well as KEC Enterprises Corporate Governance Policies.

3.2 Open Door PolicyOur company has adopted an Open Door Policy for all employees. The purpose of our

open door policy is to encourage open communication, feedback, and discussion about

any matter of importance to an employee. Our open door policy means that employees

are free to talk with any manager at any time.

Ones immediate supervisor is ones First Point of Contact for all employment related

issues. One is encouraged to first discuss ones personal / official problem with him for

resolution.

An open door policy means that you may also discuss your issues and concerns with the

next level of management and/or Human Resources staff members if these are not

satisfactory resolved by your immediate supervisor. No matter how you approach your

problem, complaint, or suggestion, you will find managers at all levels, even the MD,

Functional heads of the organization willing to listen and to help bring about a solution or

a clarification.

3.3 Equal Opportunity EmployerKEC International Ltd is an equal opportunities employer. We do not discriminate on

grounds of age, gender, colour, race, ethnicity, language, caste, creed, economic or social

status or disability. We recognize that having a workforce that broadly reflects the

composition of the local communities in which we operate, places us in a unique position

to understand and respond to the needs of our customers. We thus use diversity as a

competitive differentiator, both in employment and in customer markets.


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3.4 Payroll Guidelines

Salary to all Employees is paid monthly, usually, on the last day of the month. The

Company pays the employees by way of a direct credit into the employees bank accounts

with Bank.

Employees shall be notified, in the event of a change the Companys banker s. The salary

is credited into respective employees accounts at the bank after deduction of Tax,

instalments towards loans and advances and other statutory deductions.

Payroll for an individual is confidential information, and secrecy of the same is to be

maintained.

3.5 Social Media Policy

This policy invites all the RPG employees to use the Social Media as a constructive tool for

business or otherwise, while, at the same time, restricting them from inappropriate usage

of this new and powerful internet communication medium.

Scope:

This Social Media Policy applies to all RPGians and interns globally, who may be using orplanning to use any of the following for Personal or Business needs:

Multimedia and social networking websites such as Facebook, Twitter, LinkedIn,

Google Plus and YouTube etc.

Blogs (Both external and in Group intranet sites)

Wikis such as Wikipedia, Knoll and any other site where text can be posted

Review and Question-Answer based portals like Glassdoor, Yahoo Answers etc.

Forums like Google Groups, Yahoo Groups, etc.

Image and Power point sharing websitesChat engines

Guidelines

While all RPGians are welcome to participate on the social web, we expect everyone who

participates in an online commentary, to understand and to follow these simple but

important guidelines. The goal here is simple: to participate in online activities in a

respectful, relevant way that protects our business interests.


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1. Dont leak out any RPG or Client Secrets:

NEVER to disclose non-public information of the company (including confidential

information**). Any information about clients or customers including their logos,

sensitive data, presentations, videos or any mention of privileged information should be

completely and inexcusably avoided to be put up on Social Media.

2. Respect your audience, clients and your co-workers:

RPG Enterprises has a global presence whose associates and clients reflect a diverse set of

customs, values and points of view. While using the social media space as an RPG

employee, don't be afraid to be yourself, but do so respectfully. This includes not only the

obvious (no ethnic slurs, personal insults, obscenity, etc.) but also proper consideration of

privacy and of topics that may be considered objectionable or inflammatorysuch as

politics, religion and work culture.

3. Maintain RPGs Legal obligations towards its clients:

Never use any of the clients or customers names in any social media posting unless you

have written permission to do so. Any sharing of cl ients intellectual property and other

assets including pictures, videos, Power Point slides etc. on social media is strictly

prohibited.

4. Be conscious when mixing your business and personal lives:

Online, your personal and business personas are likely to intersect. RPG totally respects

the free speech rights of all of its employees, but one must remember that customers,colleagues and supervisors often have access to the online content you post. Keep this in

mind when publishing information online as it can be seen by more than just friends and

family, and also know that information originally intended just for friends and family can

be forwarded on.

5. Be yourself and own up to your comments:

Identify yourself on the web with your true name and, when relevant, role at RPG and the

respective company, while you discuss any company related matter externally and write

in the first person. You must also make it clear that you are speaking for yourself and noton behalf of your company. You can use a disclaimer such as: the postings on this site are

my own and dont necessarily represent RPGs/ Name of your Companys position,

strategies or opinions.

6. Speaking on Organizations behalf:

Only the authorized spokespeople have the authority to speak on behalf of the

Organization and all the other employees will need to get prior permission from the


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Corporate Brand Communications Team or any of the Management Board members in

case they need to write anything on RPG/Group Companys behalf.

7. Negative Branding:

All employees are barred from writing defamatory comments about RPG, itsclients/customers or their fellow employees. RPG also has the right to ask the employees

to remove any of such posts that they may have published online intentionally or

unintentionally where it is directly or indirectly being mentioned.

8. Be a Scout for critical issues but do not return fire with fire:

Even if you are not an official spokesperson, you are one of the organizations most vital

assets for monitoring the social media landscape. If a defamatory or a critical post or

comment is encountered online about RPG, do not counter it with another post. The best

way to deal with this is to report the matter to the Corporate Brand Communications [email protected].

9. Remarks on Competition:

Always try and avoid publishing any remarks (positive or negative) on competitors

online.

10. Respect the law and do not indulge in spreading rumours:

Always respect the copyright law and all the other internet laws as laid down by the

Cyberlaws wing of your respective country. Apart from that, always double check on thedata you are publishing to avoid spreading wrong information on the internet

unknowingly.

11. Dont forget your day job:

With Social Media having a quality of being addictive, it should be always kept in mind,

that your day job or regular work of the day important assignments, projects , timely

deliverables and meetings should NEVER be compromised due to your overuse or extra

indulgence in social media.

**Confidential Information: Important or valuable business information that is not

available to the public. It includes trade secrets and other intellectual property that has

been developed, licensed or acquired by RPG. It can also include information of

customers, business partners or others that has been disclosed to RPG companies under

obligations of confidentiality. Examples include unannounced Financial or HR

information, strategic business plans, unannounced products or services and solutions

offerings, planned or contemplated mergers or acquisitions, lawsuits and other legal
mailto:%[email protected]:%[email protected]:%[email protected].


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proceedings, product design and technical knowledge, customer and team member

personal information.

Note

* With Social Media itself being an ever changing and evolving phenomenon, this policy issubject to iterations and changes as and when required.

3.6 Dress Code Policy

* This is not applicable to places where there is uniform given by the company.

At KEC, we encourage work place atmosphere that meets business requirement. The

dress code policy aims to define appropriate business attire to ensure uniformity andemployee comfort in the workplace. At the same time, our company should establish a

professional image to its customers, employees and partners.

Policy:

Dress Code: Monday Thursday

Employees are expected to dress in appropriate business formals/ business casuals

Dress Code: Friday

Employees may opt to wear Smart Casuals on Friday. In case of a customer interface

please stick to Formal wear.Dress Code Men Women

Business Formal Western Suit

Formal Shirt (Full/ Half Sleeves)

Formal Trousers

Formal Matching Shoes and Belt

If long hair keep it neat, tidy and

tied

Accessories or ornaments should

be minimal and not be a reason for

distraction from work

Western Suits

Formal Shirts(Full/ Half

Sleeves)

Formal Trousers

Formal skirts

Saree

Salwar/Churidar Kameez

Formal Shoes (closed) or

Sandals

Accessories or jewellery should

be subtle and not be a reason

for distraction from work.

Business Casual Full/ Half Sleeves Shirt

Formal Trousers

Formal Leather Shoes and Belt

Shirts

Trousers

Saree

Churidar/ Salwar Kameez


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Smart Casual Full / Half Sleeves Shirt

Trousers / Denims

Belt

T-shirts with collar

Sport shoes

Saree

Churidar/ Salwar Kameez,

Trousers/ Denims

T-Shirts with collar

Sport Shoes

What is not appropriate:

For Male Employees:

Traditional attire, kurta-pyjamas, round neck T-shirt, casual dressing such as

shirts or sweaters with logos or message (other than company logo), shorts, track

pants, embroidered or torn trousers / cargos / denims.

Unpolished shoes, sandals, floaters, open shoes, bathroom slippers, or leisure

footwear

Multiple piercing, piercing other than ears, untidy hair, offensive tattoos, funky

wrist jewellery or visible funky pendants.

For Female Employees:

Casual dressing, round neck T-shirt, tight and short tops, shirt or sweaters with

logos or message (other than company logo), shorts, short skirts, track pants,

embroidered or torn trousers/ cargos, Denims, capris.

Floaters, bathroom slippers.

3.7 Office Timings and Attendance

Mumbai Offices:

Working Hours:

Monday to Friday 9:00 AM to 6:00 PM

Lunch break1:00 PM to 1:30 PM

Weekly Offs - Saturday & Sunday

Contact Person:

DD Chavan (Officer HR)

Contact No: 022-66406437

Email id: [email protected]

Gurgaon Offices:

Working Hours:

Monday to Friday 9:30 AM to 6:30 PM

Lunch break: 1:00 PM to 1:30 PM

Weekly Offs: Saturday & Sunday

Contact Person:

Purabi Sarkar, (Sr. Officer - HR)

Contact No: 0124-6757952

Email id: [email protected]


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Supply Chain SBU:

Jabalpur Plant

General Shift8:00 AM to 4:30 PM

1st Shift6:30 AM to 2:30 PM

2nd Shift2:30 PM to 10:30 PM3rd Shift10:30 PM to 6:30 AM

Weekly OffStaggered due to 24X7 working

General W/off- Saturday

Contact Person:

Mr. K. Bohra, (Sr. Executive HR)

Contact No: 0761-2350024

Email Id:[email protected]

Jaipur Plant


1st Shift 7:00 AM to 3:00 PM

2nd Shift3:00 PM to 11:00 PM

3rd Shift11:00 PM to 7:00 AM

Weekly OffStagerred due to 24X7 working

General W/offSunday

Contact Person:

Mr. Ranbir Singh

Butibori Plant


1st Shift6:30 AM to 3:00 PM

2nd Shift3:00 PM to 11:30 PM

3rd Shift11:30 PM to 6:30 AM

Weekly OffStagerred due to 24X7 working

General W/off- Wednesday

Contact Person:

Mr. Tushar Kharalkar, (Officer II)

Contact No: 07104-662203


Cables SBU

Vadodara Plant:

Monday to Saturday: 9:00 AM to 5:30 PM

Lunch Break:1:00 PM 1:30 PM /

1:30 PM 2:00 PM

Weekly Off: Sunday

Contact Person:

Mr. Abhijeet Kale(CM- HR Cables)

Contact No: 022-66670307


Thane Plant:

Monday to Saturday: 9:00 AM to 5:00 PM

Lunch Break:1:00 PM 1:30 PM /

1:30 PM 2:00 PM

Weekly Off: Sunday

Contact Person:

Mr. PKN Nair, (Sr. Officer HR)

Contact No: 9833951822



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Silvassa Plant:

General Shift: 9:30 AM to 6:00 PM

Rest Interval: 1:30 PM to 2:00 PM

Shift A: 7:00 AM to 3:00 PM Rest Interval: 11:00 AM to 11:30 AM

Shift B: 3:00 PM to 11:00 PM Rest Interval: 7:00 PM to 7:30 PM

Shift C: 11:00 PM to 7:00 AM Rest Interval: 3:00 AM to 3:30 AM

Weekly Offs- For different shifts there are different weekly offs

Contact Person:

Mr. Dheeraj Kumar, (Manager HR)

Contact No: 02606618506


Mysore Plant:

Monday to Saturday9:00 AM to 5:30 PM

Lunch Break:1:00 PM - 1:30 PM

Weekly Off: Sunday

Contact Person:

Mr. Alwyn Kumar, (Manager HR)

Contact No: 0821-6553375


Office timings for other offices and project sites will be applicable as per their respective

location rules.

Attendance

All employees are required to swipe their attendance cards on reporting for duty and

while leaving after completion of working hours.Late Attendance

Late coming is not encouraged. However in very exceptional cases the same needs to be

approved by HOD. However for every late coming beyond 10 minutes for 3 occasions in a

month will result in deduction of half day leave or absence as the case may be. Frequent

late arrival will render an employee liable for disciplinary action.

*However some locations may have additional guidelines under this section, which can be

checked with SBU HR.

Maintenance of Attendance Register/Leave records

The attendance and leave records of all employees will be maintained by HR &

Administration Department of respective location.

General Attendance Rules

Working hours, paid holidays, weekly offs will be location specific.

When a Manager is transferred, deputed or posted to a new location, the workinghours, paid holidays, weekly offs applicable to new location will stand.


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Each respective location will spell out the policy / practice with regard to theabove in writing and communicate to concern Managers in that location.

3.8 EHS PolicyEnvironment, Health and Safety Policy

We are committed to ensuring a safe and healthy workplace for our employees and

contractors while protecting the environment.

To achieve this, we shall:

Comply with Environment, Health and Safety regulations and other requirements

Continually upgrade our processes to monitor and control adverse impacts on theenvironment, occupational health and safety

Institutionalize pollution prevention and conserve resources

Have an accident free workplace

Enhance awareness, skill and competence of our employees and contractors to

meet our EHS objectives.

The management and supervisory personnel will have the ownership to uphold

the principles of this policy and integrate them throughout the company and its

contractors.

3.9 Quality policy

We are committed to providing superior value to our stakeholders through continual

improvement of our Quality Management Systems.

We will achieve this by:

Excellence in project management and innovative designs

Being cost competitive through continual up gradation of our processes

Providing an exciting and challenging work culture to our employees by fostering

teamwork and enhancing their skills and competence

Complying with all applicable regulatory requirements

Every employee is committed to this personally


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3.10 Office Security Guidelines foremployees

Your belongings should be kept in safe custody (drawer) while you move out of

your work place during office hours.

Please remember to collect back your belongings kept while leaving wash room.

No direct contact with Office facilities servicemen for any services required

without Admin permission.

Visitors shall not be allowed to enter beyond reception area unless escorted by

concerned employee/security Guard.

Employees getting any un-known / new material should disclose the reason and

the description before it is taken to their work place or Department.

No equipment/materials would be allowed out of the premises without proper

gate pass issued from the Security. Employees need to co-operate and adhere to

the norms.

Security Guard will maintain list of employees who are staying beyond office hours

and employees need to co-operate with required formalities requested by the

Security.

Daily compulsory frisking of all the outside service providers including,

housekeeping and security agencies by the Security Guards.

Staff staying back late and especially coming on Sundays will need to obtain priorapproval from Admin or their SBU Head, which shall be intimated to the security.

Guards will maintain strict vigil on the premises at all times.

Security staff shall ensure every visitor shall display / swipe card entry pass while

in the Office premise.

It is important to keep record of all visitors entering into Office premises and

security staff shall ensure to collect details of visitors in designated register

maintained at their desk.

Security staff shall ensure entry pass is collected back from the visitor while

leaving premises.


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Section 4-Information

Technology Policy


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Information Technology Policy

KEC International is extensively dependent on information technology (IT) for

performing its business operations. Owing to rapid use of advanced communication

network connecting multiple locations, implementation of applications with largedatabases and implementation of Enterprise Resource Planning Solution, management of

IT function has become significantly critical. Also, due to the growing dependence on

technology for managing business, the organization is exposed to substantial IT security

risks.

We observe and follow security policies and procedures in regards to information

technology, the policies mentioned below are the guidelines for the same.

Scope of Policy

This Policy applies to all staff within the Organization who use or who have access to ITresources. This Policy therefore applies not only to member of the Organization, but also

to temporary workers, contractors and agency workers. This Policy equally applies to

mobile user whose work patterns fall outside traditional working hours or who may use

IT resources from outside the office.

This Policy is not intended to have contractual effect and it may be amended from time to

time by the Organization.

The company reserves the right to amend this policy at its discretion. In case of

amendments, users will be informed appropriately.

4.1 Electronic Communication Policy

The electronic communication systems of KEC International Ltd. including, withoutlimitation, electronic mail (e-mail), voice mail, Internet, personal computers andsoftware (collectively Electronic Communication), are valuable Company resourceswhich allow us to communicate effectively and to perform our jobs in an efficient manner.

In using Electronic Communication, the following shall be adhered to:

E-mail

E-mail is used primarily for conducting the Company business, and is not used in

any illegal, offensive, or unethical manner. Employees are prohibited from the

unauthorized access to other employee's e-mail messages.

E-mails are Company property subject to inspection by an authorized Company

representative at any time. All messages composed, sent or received by way of

Electronic Communication are and remain the property of the Company. The


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Company reserves the right to review, audit, intercept, access and disclose all such

messages, including Internet usage.

In terms of its content, email should be treated like any other form of written

communication and, as such, what is normally regarded as unacceptable in a letter

or memorandum is equally unacceptable in an email communication. Email must

not be used to make defamatory or offensive comments, including jokes and

inappropriate remarks made at someone elses expense.

E-mail should not be used to conduct personal business, non-Company commercial

ventures, religious or political causes, outside organizations, or other non-job-

related purposes.

The forwarding of chain letters, junk mail, jokes and executables is strictly

forbidden.

Email is a business communication tool and users are obliged to use this tool in a

responsible, effective and lawful manner. Although by its nature email seems to beless formal than other written communication, the same laws apply. Therefore, it is

important that users are aware of the legal risks of e-mail.

By following the guidelines in this policy, the email user can minimize the legal risks

involved in the use of e-mail. If any user disregards the rules set out in this Email

Policy, the user will be fully liable and company will disassociate itself from the user

as far as legally possible.

Emails may be monitored for numerous purposes including, but not limited to,

technical maintenance or problem resolution.

You must have no expectation of privacy in anything you create, store, send orreceive on the companys computer system. Your emails can be monitored without

prior notification if company deems this necessary. If there is evidence that you are

not adhering to the guidelines set out in this policy, company reserves the right to

take disciplinary action, including termination and/or legal action.

The Organisation reserves the right to monitor (by retrieval or interception) the

destination and source of email. In addition, the Organisation utilises automated

mail filtering software to detect inappropriate use of language. In exceptional

circumstances, where the Organisation suspects serious misuse of email, it reserves

the right to monitor and access the content of email sent or received.

Composing Messages

Caution should be exercised in composing any messages. One's style should be that

of a business communicative nature, not conversational.

Electronic Communication must not contain vulgar, obscene or dismissive remarks nor any other

words which may reasonably be considered offensive, harassing, disruptive or embarrassing to

anyone, regardless of how they may be intended. Messages should not be disparaging of any

Company employee or any other party.


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Retention

In order to lower IT storage costs and to minimize system capacity constraints, e-

mail, should be retained for the shortest period of time on server.

Owners of e-mail files should review them regularly (at least once per quarter) anddelete files which no longer serve a business purpose. Review should include not

only the inbox, but also other folders, particularly folders such as sent (that

automatically retain copies of e-mails), as well as personally created folders.

Although it may in limited instances be necessary to preserve e-mail by copying,

such copying should be restricted to information which serves a compelling

business purpose

and the copy should be retained for not less than the period prescribed by

applicable statute or regulations or Company requirements.

Electronic Communication subject to a locations record retention policy or whichmay be subject to retention periods required by law, should be copied and such

hard copies should be retained for the applicable retention period as set forth in

such policy or law.

Disclaimer

The following disclaimer will be added to each outgoing email:

KEC International accepts no liability for the content of this email, or for the

consequences of any actions taken on the basis of the information provided, unless

that information is subsequently confirmed in writing. If you are not the intended

recipient you are notified that disclosing, copying, distributing or taking any action

in reliance on the contents of this information is strictly prohibited.

Note: Please don't print this e-mail unless you really need to.

Internet

While the Company generally supports the use of Internet to obtain information

strictly for business purposes, precautions must be taken to ensure the security of

the Company's computer network. In order to reduce the risk of viruses, all

Company equipment utilized for Internet access must have virus scanning software.

Internet access provided by KEC must be used exclusively for business purposes.Please note that sending messages over the Internet is never fully secure.

Information received via the Internet, unless received from reliable sources, must

be validated before being used for business purposes.

All files downloaded from the Internet must be scanned and cleaned of viruses.

Appropriate disciplinary action will be taken against those who fail to take

precautions against the spread of viruses in the KEC network.

Any text, pictures, sound, video or other graphic objects that can be considered

offensive (e.g. pornographic material) or in any way discriminatory must not be


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displayed, stored or transmitted. As KEC staff, we are all expected to conduct

ourselves in a decent and professional manner

Harassment of any individual, corporation or organization on the Internet through

access of company facilities is strictly prohibited. Access of any third party

computer systems without the express authorization from the owner is also not

permitted. Committing such acts could subject you personally to various legal

claims.

Internet users must report all Internet security problems to the IT department

Line managers have the responsibility of affecting the appropriate sanctions on

those who violate any of these provisions. I request everyone to strictly adhere to

the above policy to ensure secure and productive use of the Internet in KEC

International Ltd.

4.2 Hardware Procurement & Disposal

Desktop or Laptop

The standardized minimum configuration for general procurement of PC and Laptop is as

follows

Processor RAM HDD O/S Monitor CD/DVD

Desktops Core 2Duo

2.0GHz

1 GB 160GB

XP - Pro TFT 17 NO

Laptops Core 2

Duo

2.0GHz

2 GB 160

GB

XP - Pro TFT 15 Combo-

Drive

Make & supplier of desktop & Laptop are to be kept common & are to be monitored

centrally by corporate IT.LAPTOPs are given to General Managers and above and to certain depts. as a

common resource enabling the dept. personnel to carry the virtual office with them

wherever they travel on office work.

For procurement of laptop or desktop, IT access request form to be prepared by the

concerned dept. with proper justification and to be approved by the SBU head.

Send approved copy of IT access request form to IT dept for obtaining quotation and

preparation of CPDC proposal. The CPDC proposal for LAPTOP to be approved by

the MD.


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Replacement/upgrade of Laptop/Desktop would be after four/five year

respectively. However in exceptional cases (due to new technology deployment) it

can be reviewed with MDs approval.

Computer PeripheralsThe Make and model of all peripheral at all location has been fixed and is monitored

centrally by Corporate IT.

For procurement of peripherals also need to follow the same process as laptop.

Computer Accessories

New requirements of accessories such as Flash drive, webcam, speakers, TFT,

mouse, data card for internet access, external hard disk etc to be provided on

request from user dully approved by SBU head.

Disposal of HardwarePreparation of list for the hardware to be disposed after hardware gets older as per

IT policy & dispose off the same after getting approval from MD.

Note: All IT resources provided to users for performing job related responsibilities must

be returned to company in good working condition whenever requested by the company

or at the time of retirement or in case of resignation.

4.3 Information Security PolicyKEC defines the Information Security Forum (ISF) as the top-level authority responsible

for coordinating information security strategy across the corporation.

The ISF shall determine what level of information security risk is acceptable to KEC.

The ISF as well IT staffs at each branch are responsible for implementing and executing

the procedures mentioned in this document. The execution of the procedures will be

monitored by the Branch IT staffs at branches.

Disposal of Hardware

Reviewing and approving Company information security policy and overall

responsibilities.

Monitoring exposure to major threats to company information assets.

Review and monitoring security incidents within company.

Approving major company initiative to enhance information security.


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Desktop Security

As per domain policy your desktop is having password protected screen server.

User should lock the desktop whenever he or she leaves the desk by applying the OS

based auto lock feature.User password should remain confidential and not be shared or otherwise disclosed

to another person in any manner.

Passwords should consist of at least eight alpha and numeric characters. The users

should not use their name or user-ID as a password. As far as possible, the

passwords should not be proper words.

Passwords will expire after a maximum of 45 calendar days from last date of update.

A given password should not be used more than once in 180 calendar days.

Additionally, if the password alteration cycle is less than 45 days, the same

password should not be repeated within a cycle of 3 password changes.If a user is provided with an initial password by the system administrator, this

password should be changed immediately by the user after the first time he/she

logs into the system. (One-time password).

NT user ID and password is used to access for Webmail and KEC Connect web

portal.

4.4 Virus Combat Policy

There have been a number of virus infections spreading around the globe. The loss of

valuable information and time spent from a virus infection result in substantial costs to

our company. Thus, for protection of IT resources from all possible computer viruses, all

desktops has been installed with latest antivirus software and Auto update of latest Virus

definition and scan engine, respective I.T. staff to provide the required technical support

for timely distribution of anti-virus software, its updates and upgrades as well as ensure

prompt reporting of virus incident reporting and management.

It is the responsibility of the IT Security Controller to protect the company'sinformation systems from possible computer virus attacks. The Branch IT staff

should have this responsibility at the branch level. Individual users should take

necessary precautions like downloading files only from trusted internet sites to

prevent exposure from possible computer virus attacks.

It should be ensured that the Anti-virus (AV) software is installed and active on

every machine and couldnt disable by user.

The Anti-virus software should be scan all local disk at least once in a day and it

should be properly scheduled, preferably during the lunch hours of the office.


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Every diskette, DAT, tape, pen drive, CD, DVD should be scanned for virus before

use.

Upon encountering the virus attack, the users should immediately stop using the

involved computer and report it to the Local IT staff. As the viruses have become

very complex, users should not attempt to eradicate them without expert advice.


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Section 5-

Policies/Procedures

And

Entitlements/Benefits


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Policies & Procedures:

5.1 Parichay - Employee Referral Policy:

Objective

To leverage our employees social and professional network to identify & attract

competent talent

This program would ensure that:

Quality CVs are received by HR department

The prospective employee gets an insiders view of the organization before makingthe career decision

Organization leverages on employees professional networkEmployee gets rewarded for the referral and also gets a friend on-board

Eligibility

All employees of Infrastructure Sector can refer a candidate for AM and abovepositions

Exceptions (Not eligible for reward)

Immediate Superior of potential employee

Person responsible for hiring decisionVPs and above

HR Departments across group

The Scheme

An employee may refer individuals who fit and can be hired f