Supplier Code of Conduct

Greaves Electric Mobility Private Limited (GEMPL) expects the companies with whom we do business to embrace this commitment - to - integrity by complying  with; and training their employees/sub-contractors on GEMPL’s Supplier Code of Conduct (SCoC).

COMPLIANCE WITH THE SUPPLIER CODE OF CONDUCT

Suppliers and their employees, personnel, agents, and subcontractors (collectively referred to as “Suppliers”) must adhere to this Supplier Code of Conduct while conducting business with or on  behalf of GEMPL. Suppliers must require their subcontractors acknowledge and implement the SCoC in their operations and across their supply chains. Suppliers must promptly inform  their GEMPL contact, a member of GEMPL management, or the contacts provided at the  end of this document when any situation develops that causes the Supplier to operate in  violation of this Code of Conduct.

All GEMPL Suppliers must conduct their employment practices in full compliance with all  applicable laws and regulations and in compliance with GEMPL requirements, which may exceed local legal requirements. In all cases in which GEMPL requirements are more stringent than local legal requirements, Suppliers are required to meet the GEMPL  requirements.

While GEMPL Suppliers are expected to self-monitor and demonstrate their compliance with the SCoC, GEMPL may audit Suppliers or inspect Suppliers’ facilities to confirm compliance. Where the Suppliers are unlawful or inconsistent in their practice with the SCoC, or any GEMPL policy, shall be at risk of termination of their business relationship with GEMPL. Complying with  the SCoC provided by GEMPL are required in addition to meeting any other obligations contained in any contract a Supplier may have with GEMPL. GEMPL is committed to maintaining a high standard on human rights and fair labor practices  in its supply chain. When requested by GEMPL, Supplier will provide necessary information and supporting documentation to enable GEMPL to perform and complete supply chain due  diligence, including disclosure of certain information from subcontractors as may be required by  GEMPL.

LEGAL AND REGULATORY COMPLIANCE PRACTICES

All GEMPL Suppliers shall be in full compliance with all applicable laws and regulations while conducting business with and/or on behalf of GEMPL, and shall, without limitation, meet the following requirements:

1. Trade: Comply with all laws and regulations applicable to the import or export of the Items,  including but not limited to trade laws and sanctions regulations. Suppliers will not provide controlled technologies, products, or technical data to GEMPL, without providing notice of  such controls as necessary for GEMPL to maintain compliance with applicable laws.
2. Competition: Conduct business in full compliance with applicable antitrust and competition laws that govern the jurisdictions in which they conduct business.
3. Anti-Corruption: Conduct business in full compliance with the anti-corruption and anti-money laundering laws that govern the  jurisdictions in which Suppliers conduct business.
4. Suppliers must comply with all applicable anti-corruption and anti-money laundering laws,  as well as laws governing lobbying, gifts, donations, hiring, and payments to public officials, political campaign contribution laws, and other related regulations. Suppliers must prohibit any and all forms of bribery, corruption, extortion,  and embezzlement. All business dealings shall be transparently performed and accurately reflected in Supplier’s business books and records. Compliance monitoring,  record keeping, and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.
5. No Supplier shall, directly or indirectly, promise, authorize, offer, or pay anything of value:
   1. (including but not limited to gifts, travel, hospitality, charitable donations, or  employment) to any government official or other party to improperly influence any act or decision of such official for the purpose of promoting the business interests of GEMPL in any respect, or to otherwise improperly promote the business interests of  GEMPL in any respect.
6. "Government official" refers to all of the following: (i) any employee of a government  GEMPL or subdivision, including elected officials; (ii) any private person acting on behalf of:  a government GEMPL, even if just temporarily; (iii) officers and employees of companies  that are owned or controlled by the government; (iv) candidates for political office; (v)  political party officials; and (vi) officers, employees and representatives of public  international organizations, such as the World Bank and United Nations.
7. Suppliers must report signs of any personnel, representative, or partner performing   unethically or engaged in bribery or kickbacks.

BUSINESS PRACTICES AND ETHICS

All GEMPL Suppliers must conduct business interactions and activities with integrity and trust,  without limitation:

1. Business Information Reporting: All business information and reporting activities are to be  conducted honestly and accurately and in compliance with all applicable laws regarding their completion and accuracy.
2. Communication: Be honest, direct, and truthful in discussions, including those with  regulatory agency representatives and government officials.
3. Press: Only speak to the press on behalf of GEMPL if expressly authorized in writing to do so by a GEMPL communications representative.
4. Publicity: Suppliers will not issue press releases or other publicity related to their  relationship or agreements with GEMPL without the prior written consent of GEMPL  contract signee.
5. Gifts and Entertainment: Use good judgment when exchanging business courtesies. Gifts, meals, entertainment, hospitality, and trips that are lavish or lack transparency or a legitimate  purpose may be viewed as bribes, may create the appearance of a conflict of interest, or may be  perceived as an attempt to improperly influence decision making. Giving business courtesies to GEMPL employees, if permitted at all, should be modest and infrequent. Never give anything to gain an improper business advantage. When deciding whether to give a gift, entertainment or other courtesy, apply the following requirements:
6. Suppliers are prohibited from paying expenses for travel, lodging, gifts, hospitality,  entertainment, or charitable contributions for government officials on GEMPL’s behalf.
   1. Suppliers are prohibited from paying expenses for travel, lodging, gifts, hospitality, entertainment, or charitable contributions for government officials on GEMPL’s behalf.
   2. Travel expenses must be reasonable, have legitimate business purposes, and not be excessive or lavish. (See Travel section below.)
   3. Do not offer anything of value to obtain or retain a benefit or advantage for the giver, and do not offer anything that might appear to influence, compromise judgment, or obligate GEMPL employee(s).
   4. Entertainment and meals should be modest, infrequent, and occur in the normal course of business.
   5. Suppliers may not offer any business courtesy unless it is permissible under both this Code and the Supplier’s gift policy.
   6. Be aware of limits. The value of any courtesy offered by a Supplier to a GEMPL employee may not exceed the limits applicable to the employee’s business unit and country. GEMPL business unit and country limits may prohibit courtesies entirely or set  maximum limits at varying amounts. It is the Supplier’s responsibility to ask the recipient what the applicable limits are and to not exceed those limits.
   7. Suppliers are not allowed to give gifts of any value to any member of GEMPL Procurement or its representatives.
   8. Any morale events for employees of the Supplier should be organized by the Supplier, and not by GEMPL. If employees of the Supplier need to participate in a morale event  with GEMPL FTEs, GEMPL should work out a plan for shared funding with the  Supplier.
7. Conflicts of Interest: The Suppliers shall ensure that, if found that its conduct with GEMPL or its employees in conflict or appears to be in conflict with the best interest of GEMPL or if Suppliers become aware of a conflict of interest or are concerned that a conflict might develop, shall notify GEMPL. Suppliers shall be honest, direct, and truthful when answering questions from GEMPL about relationships with GEMPL employees. Suppliers shall avoid improprieties and conflicts of  interests or the appearance of either. Suppliers must not deal directly with any GEMPL  employee whose spouse, domestic partner, other family member or relative holds a financial  interest in the Supplier.
8. Conflicts of Interest: The Suppliers shall ensure that, if found that its conduct with GEMPL or its employees in conflict or appears to be in conflict with the best interest of GEMPL or if Suppliers become aware of a conflict of interest or are concerned that a conflict might develop, shall notify GEMPL. Suppliers shall be honest, direct, and truthful when answering questions from GEMPL about relationships with GEMPL employees. Suppliers shall avoid improprieties and conflicts of  interests or the appearance of either. Suppliers must not deal directly with any GEMPL  employee whose spouse, domestic partner, other family member or relative holds a financial  interest in the Supplier.
9. Conducting business with legal documents: Supply materials or services only upon receiving legal documents (Agreements, Purchase orders, etc.) authorized by GEMPL’s designated personnel, and not rely on word of mouth or informal communication. No claims will be entertained from Suppliers, if not supported by documents officially authorized by GEMPL and its authorized personnel.
10. Engaging Subcontractors: Obtain written consent from GEMPL prior to engaging a  subcontractor to fulfill Supplier’s obligations to GEMPL in addition to meeting any other  obligations contained in any agreement a Supplier may have with GEMPL.

HUMAN RIGHTS AND FAIR LABOR PRACTICES

GEMPL expects its Suppliers to (1) comply fully with all employment laws, (2) share its  commitment to respect all human rights and to provide equal opportunity in the workplace as  set forth in the Indian Laws and Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights and (3) take effective measures to remedy any adverse human rights and  fair labor impacts, including the disclosure of any and all potential violations and cooperating  fully in subsequent investigations into such violations.

All GEMPL Suppliers must, without limitation:

1. Not discriminate and not harass. GEMPL is committed to maintaining a workplace with no discrimination in which all individuals and applicants are treated equally with respect and dignity. Suppliers must commit to a workforce and workplace free of harassment, unlawful discrimination, and retaliation. Suppliers should ensure their business practices respect the rights of different demographic groups, including women,  and migrant workers. While we recognize and respect cultural differences, Suppliers must provide equal opportunity in the workplace and reasonable accommodation, and not  engage in harassment or discrimination in employment on the basis of age, ancestry,  citizenship, color, family or medical care leave, gender identity or expression, genetic  information, immigration status, marital or family status medical condition, national origin, physical or mental disability, political affiliation, union membership, protected  veteran status, race, religion, sex (including pregnancy), sexual orientation, or any other  characteristic protected by applicable local laws, regulations, and ordinances. Supplier shall not require workers or potential workers to undergo medical tests  including pregnancy tests, except where required by applicable laws or regulations or  prudent for workplace safety and shall not improperly discriminate based on test results.  Suppliers must accommodate all disabilities to the extent required by law.
2. Prohibit the use of child labor. The supplier shall comply with the legal requirements on the minimum age of the employees. The Supplier shall ensure that the Child labor must not be followed under any circumstance. Supplier must work towards ‘no child labor’ policy. Suppliers must not employ anyone under the age of 15, under the age for completing compulsory education, or under the legal minimum working age for employment,  whichever requirement is most restrictive. Suppliers are required to have a remediation  plan in place to ensure that, in the event of any child labor found, Suppliers must follow international standards, local legal requirements, or GEMPL’s child labor remediation  requirements. GEMPL supports all forms of legal youth employment, including the  development of legitimate workplace apprenticeship programs for the educational  benefit of young people. GEMPL will not do business with any Supplier that uses such  programs in a fraudulent or deceptive manner. Suppliers must prohibit workers who are  under the age of 18 from performing work that is likely to jeopardize their health or safety such as night work, overtime, heavy lifting and working with toxic or hazardous  materials.
3. Prohibit the use of Forced Labour, Prison Labour and Trafficking in Persons. GEMPL does not tolerate slavery, forced labor, or human trafficking in any form. All Suppliers of GEMPL, including part suppliers, service providers, recruiters, employment agencies, sub-agencies, and recruitment firms must ensure that all the national, state and regional laws and policies relating abolition of bonded labor, prison labor and forced labor were duly complied and the Suppliers are prohibited from using forced labor and prison labor, trafficking in persons, and  the procurement of commercial sex acts. All forms of forced labor are prohibited,  including indentured labour, bonded labour (including debt bondage, trafficked or slave) or  any other form of forced labour. All forms of prison labour are prohibited. Support for or engagement in any form of human trafficking or involuntary labour through threat, force, fraudulent claims, or other coercion is prohibited. Suppliers must have a voluntary labour compliance plan in place that (1) relies on the ILO’s “Indicators of Forced Labour” to identify instances of forced labor in the supply chain; (2) provides provisions for training Supplier personnel and raising their awareness of issues related to forced labor, and (3)  details what remediation the Supplier will provide in case of any violations. All Suppliers  must inform employees, agents, sub-agencies, recruiters, contractors, and subcontractors  about Supplier’s policies that prohibit human trafficking, prison labor, forced labor, and  other forms of slavery and provide training and programs to promote awareness, risk  identification, employee reporting, corrective action, and potential penalties for violations.
4. Ensure workers have access to identity-related and personal documents. Suppliers, agents, and sub-agents must ensure that they will respect the identity of all their employees and the identity related documents must not be  shared with anyone without an authorization from the concerned employee. The Suppliers, agents and sub-agents are prohibited from requiring workers to lodge “deposits,”  withholding employee identity or immigration papers (including but not limited to Aadhaar, PAN Card, Election ID Card, Ration Card, passports, drivers’ licenses, or work permits (regardless of the issuing authority), or  destroying, concealing, confiscating, or otherwise restricting or denying workers’ access  to such documents. Workers must be free to resign their employment in accordance with  local and national laws or regulations without unlawful penalty.
5. Provide safe housing when the Supplier intends to provide accommodations. If the Supplier is to provide housing or hotel accommodations for employees working in the  country where work will be performed, the Supplier must ensure that all accommodations provided must be in compliance with the country’s housing and safety standards.
6. Provide return transportation for foreign migrant workers. When the Supplier is hiring foreign  workers who are not nationals of the country in which the work is taking place and who are recruited and who migrate from their home country to another country for the  specific purpose of working for the Supplier, Suppliers must provide either return  transportation for such workers or should reimburse the workers for the cost of such trip upon  the end of their employment. This requirement does not apply to workers with permanent residency or professional employees who are on short-term or long-term assignments.
7. Use appropriately trained recruiters to support compliance. Suppliers must use  recruiters, employment agencies, and recruiting companies that are trained and which comply with international standards, local labour laws of the countries in which the  recruitment takes place, or GEMPL requirements, whichever are stricter. Recruitment fees or other similar fees charged to workers and payable to the employer, recruiting  agent, or sub-agent are strictly prohibited. If such fees are found to have been paid by workers, Suppliers will be required to repay such fees to the workers.
8. Make conditions of employment clear when hiring. Suppliers must prohibit the use of misleading or fraudulent practices during the recruitment or employment process.  Suppliers must disclose, in a format and language accessible to the worker, basic  information regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, living conditions, housing and associated costs  (if any), any other costs to be charged to the worker, and any hazards involved in the  work. Such disclosures must be made before the worker enters employment and as  needed throughout their term of employment. All contracts and employee handbooks  (where applicable) must (1) clearly convey the conditions of employment in a language  understood by the worker, and (2) reflect applicable laws and regulations.
9. Provide written employment contracts or agreements when necessary. If required  by law or contract, Suppliers must provide an employment contract, recruitment  agreement or other work document in writing, in a language that the employee  understands, that includes details about work descriptions, wages, prohibitions on  charging recruitment fees, work locations, living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance processes, and the content of  applicable laws and regulations that prohibit trafficking in persons. If the employee must relocate to perform the work, the work document shall be provided to the employee at  least five days prior to that relocation. Foreign migrant workers must receive the  employment contract prior to the worker departing from his or her country of origin and  there shall be no substitutions or changes to the employment contract upon arrival in  the receiving country unless changes are made to meet applicable law and/or provide  equal or better employment terms.
10. Provide fair compensation. Suppliers must provide fair compensation for all employees and workers, including employees who are permanent, temporary, or dispatched, migrant workers, apprentices, and contract workers. Such compensation must meet the  legal minimum standards as required by local law. All employees and workers shall be provided with a clear, timely, and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. Suppliers may not use deductions from wages as a disciplinary measure. Any deductions  from wages not provided for by national law or local law are permitted only with proof of express, written, and freely given permission of the worker concerned. All disciplinary measures must be recorded. Wages and benefits paid for a standard work week must  meet local and national legal standards. Suppliers must provide benefits to employees  that meet legal standards and at the levels expected in the industry and in accordance  with GEMPL requirements.
11. Treat employees with dignity and respect. Suppliers must not engage in any harsh or  inhumane treatment, including violence, gender-based violence, sexual or other  harassment including psychological harassments or threats, sexual abuse, corporal  punishment, mental or physical coercion, bullying, or public shaming. Verbal abuse or other forms of intimidation are prohibited. Suppliers shall have a humane treatment  policy and monitor supervisors to ensure appropriate conduct. Disciplinary policies and  procedures in support of these requirements shall be clearly defined and communicated  to workers.
12. Meet working hours and rest day requirements. Suppliers are prohibited from requiring workers to work more than the maximum hours as set by Indian labour law and acceptable international standards, state and municipal laws, GEMPL requirements, or in the freely negotiated and legitimate collective agreement, whichever are most restrictive.  Suppliers must ensure overtime is voluntary and paid in accordance with local and national laws or regulations. A work week must not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers must be allowed at least one day off per seven-day work week. Suppliers must keep employee working  hours and pay records in accordance with local and national laws or regulations and  provide such records to GEMPL upon request.
13. Ensure freedom of association and right to collective bargaining. Suppliers must  respect workers’ rights to freedom of association, collective bargaining, and peaceful  assembly (including the right to refrain from such activities) in accordance with local  legal requirements and responsibilities, or GEMPL requirements, whichever are stricter. Workers should not be intimidated, harassed or face reprisal for exercising this right.  When local laws or circumstances restrict this right, Suppliers should pursue other ways  of engaging in meaningful dialogue with their workers on employment issues and workplace concerns.
14. Provide effective grievance procedures and work in partnership with GEMPL to remedy any identified human rights violations. Suppliers must provide employees with effective grievance procedures for raising workplace concerns, including concerns  involving harassment and discrimination, to the attention of management for  appropriate resolution. Workers must be given a safe environment to provide their grievances and feedback. Suppliers must review these reporting procedures periodically. The grievance procedures provided must be accessible, culturally appropriate, and include the option to report anonymously where appropriate. Workers and/or their  representatives must be able to openly communicate and share ideas and concerns with  management regarding working conditions and management practices without fear of  discrimination, reprisal, intimidation, or harassment. Suppliers must periodically provide  workers with information and training on all grievance procedures. All forms of  retaliation against workers for raising a workplace concern are strictly prohibited.  Suppliers shall not retaliate through use of personal attacks, intimidation, or other threats against workers who act to raise workplace concerns, including infringement of  worker rights under local legal requirements or international standards. Suppliers agree  to work in partnership with GEMPL to remedy any identified human rights violations  and associated adverse impacts.

HEALTH AND SAFETY 

GEMPL Suppliers are required to develop and implement health and safety management  practices in all aspects of their business. Without limitation, Suppliers must:

1. Ensure compliance with all applicable occupational health and safety laws and  regulations, including but not limited to requirements that address occupational safety, emergency preparedness, occupational injury and illness prevention, industrial hygiene, physically demanding work, ergonomics, machine safeguarding, sanitation, food, and housing and provide compliance evidence upon GEMPL request.
2. Provide a safe and healthy work environment for all employees, take action to manage  and minimize the causes of hazards inherent in the working environment, and implement controls to protect sensitive populations.
3. Establish an occupational health and safety management system that, at a minimum, demonstrates that health and safety management is integral to the business, allows for  leadership and encourages employee participation to set policy, roles, responsibilities, and accountabilities, provides for risk and hazard identification and assessment, and  provides appropriate communication channels for employee access to health and safety  information. This management system must include procedures and processes to address incident recordkeeping, investigation, correction action, and continual  improvement.
4. Prohibit the use, possession, distribution, or sale of illegal drugs.

ENVIRONMENTAL PROTECTION AND COMPLIANCE

GEMPL recognizes its social responsibility to protect the environment and promote  environmental sustainability. We expect Suppliers to share our corporate commitments to  proactively reduce carbon emissions, reduce water consumption, and minimize waste generation. GEMPL reserves the right to request information from its Suppliers regarding their own environmental practices.  All GEMPL Suppliers must, without limitation:

1. Comply with all applicable environmental laws, regulations, and international treaties (where applicable), including those that regulate hazardous materials, air, and water emissions, and wastes.
2. Comply with all applicable laws and regulations regarding the prohibition or restriction of specific substances in manufacturing, in products, or in packaging.
3. Supplier agrees to conform to all GEMPL requirements regarding product and packaging marking and labeling, material content, recycling, and disposal as directed by  GEMPL in their business contracts.
4. Obtain and maintain all required environmental permits, regulatory approvals, and  registrations.
5. Prevent or eliminate waste of all types, including water discharges and energy losses, by  implementing appropriate conservation measures in Supplier facilities through (1) the use of conservation-minded maintenance and production processes, (2) by  implementing strategies to reduce, reuse, and recycle materials (in that order), whenever  possible, prior to disposal, and seek and use renewable energy whenever possible.
6. Identify any chemicals, waste, or other materials that may be released, and which may  pose a threat to the environment, and manage such chemicals or materials appropriately to ensure their safe handling, movement, storage, use, reuse, recycling, and disposal. Ozone-depleting substances are to be effectively managed and phased out in accordance with the relevant laws and protocols.
7. Suppliers must also ensure that they are compliant to any greenhouse gas emission targets that may be made mandatory by the Indian government in keeping with international treaties. Where requested, suppliers must disclose complete, consistent, and accurate scope 1, 2 and 3 greenhouse  gas (GHG) emissions data and/or components required to calculate GHG emissions data,  via CDP or an alternative method identified by GEMPL. Suppliers may also be required  to provide independent or third-party assurance over such disclosed emissions data.

PROTECTING INFORMATION 

GEMPL Suppliers must respect intellectual property rights, protect confidential information,  comply with security standards, policies, and controls, comply with privacy rules and regulations,  and adhere to GEMPL’s Document Retention Policy and Retention Schedule as applicable. All GEMPL Suppliers must, without limitation:

1. Business Continuity

   Ensure maintenance of a measurable documented emergency response and disaster recovery plan to provide protection of data and intellectual property and the business  continuity of the services and/or goods being provided to GEMPL. The plan must include  implementation procedures and at a minimum continuity and recovery plans for: weather or  other natural disaster, labour or other resource constraints, system and/or facilities outage or  unavailability, power outage, and telecommunication outage. The Supplier will review and test their business continuity plan at least annually to ensure it is fully compliant with  industry best standards for continuity management and, without limiting the foregoing,  compliant with all of GEMPL’s requirements.

2. Physical and Intellectual Property

   1. Protect and responsibly use the physical and intellectual assets of GEMPL, including intellectual property, tangible property, supplies, consumables, and equipment, when authorized by GEMPL to use such assets.
   2. Respect and protect the intellectual property rights of all parties by only using information technology and software that has been legitimately acquired and licensed. Use software, hardware, and content only in accordance with their associated licenses or terms of use.
   3. Use GEMPL-provided information technology and systems (including email) only for  authorized GEMPL business-related purposes. GEMPL strictly prohibits Suppliers  from using GEMPL-provided technology and systems to (1) create, access, store, print,  solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually  explicit, or otherwise offensive or inappropriate, or (2) send any false, derogatory, or  malicious communications.
   4. Any solicitation of GEMPL employees using information gathered from GEMPL provided technology or systems is prohibited.
   5. Comply with the intellectual property ownership rights of GEMPL and others, including  but not limited to copyrights, patents, trademarks, and trade secrets. Manage the transfer of technology and know-how in a manner that protects intellectual property  rights.
   6. Consider all data stored or transmitted on GEMPL-owned or leased equipment as  property of GEMPL. GEMPL may monitor all use of the corporate network and all systems (including email) and may access all data stored or transmitted using the GEMPL network.

3. Security

   1. Work closely with the designated accountable GEMPL project owner to understand and comply with security standards, policies, and controls if providing goods, services, or  software.
   2. Disclose and ensure any identified vulnerabilities are addressed immediately. software that has been legitimately acquired and licensed. Use software, hardware, and content only in accordance with their associated licenses or terms of use.
   3. Do not provide access to GEMPL information, or customer information, without a legitimate business need, and permission from the responsible owner.
   4. Do not bypass security controls, restrictions, or any other security measures.
   5. Do not share account credentials with others and always authenticate with assigned account credentials.
   6. Do not repurpose or synchronize GEMPL credentials with accounts on third-party sites.
   7. Always maintain direct control of corporate and personal devices and lock or secure devices when not in use.
   8. If a GEMPL asset or personal device containing GEMPL business-related data is lost or stolen, report it to GEMPL’s Legal team as soon as possible.
   9. Clearly display an employee access card at all times when in a GEMPL facility. Ensure visitors are registered at the reception desk with a GEMPL host. Challenge anyone not  displaying an access card and escort them to the nearest GEMPL receptionist/security  point of contact.
   10. Keep computer software up to date and fully patched.
   11. Do not download or install untrusted, unlicensed, prohibited, or illegal software on any  device or system that accesses GEMPL business data or services.
   12. Ensure personal devices that are used to conduct GEMPL business are up to date and are enrolled in the Modern Access device management system.
   13. Report any potential incident that involves GEMPL customer data (whether internally or through a partner or Supplier) as soon as possible.

4. Privacy

   1. Follow all applicable privacy and data protection laws of India and other applicable laws.
   2. Provide clear and accurate privacy notices when collecting or processing personal data. collect, use, process, store, transfer, and disclose Personal Data only as permitted in the agreements with GEMPL.
   3. Retain Personal Data only as long as is reasonably necessary to satisfy the purpose for which it was disclosed or as long as legally required.
   4. Implement technical, administrative, and physical safeguards that are consistent with industry best practices to protect Personal Data from theft, fraud, improper access disclosure, and misuse. In the event of any unauthorized access or disclosure of Personal Data, Suppliers must promptly notify GEMPL.
   5. Honor privacy choices by using data only as agreed to by GEMPL representatives or GEMPL’s customers.
   6. Protect data by building secure products and services.
   7. Cooperate with GEMPL Compliance efforts.

5. Retention of Corporate Records and Internal Business Information (all formats):

   The requirements below apply to all formats of information assets, globally and enterprise wide.

   1. All business records created, managed, or used on GEMPL premises or with GEMPL equipment/tools will be retained in full compliance with GEMPL’s Document  Retention Policy, Corporate Retention Schedule, and other GEMPL-directed practices.
   2. Unless otherwise specified, GEMPL will retain all rights of ownership, and control of all information created, managed, or used outside of GEMPL’s premises and/or GEMPL equipment/tools as described in the contract with GEMPL.
   3. In specific instances Supplier may be required to retain, pull, or otherwise provide data to GEMPL for a prescribed amount of time as established in the contract or in the case of  a legal or audit matter a hold may require data be retained beyond that obligation.

ADDITIONAL STANDARDS FOR ACCESS TO GEMPL

Any External Parties, including but not limited to Suppliers, Contractors, Sub-Contractors, Consultants, Landlords, Business Guests, and Partners requiring access to GEMPL’s network  and/or facilities, the following additional standards apply.

1. PRE-PLACEMENT/ ACCESS POLICY

   Suppliers, Contractors, Sub-Contractors, Consultants, Landlords, Business Guests, and Partners  must conduct Pre-Placement/Access background screens that meet GEMPL requirements on  all their personnel that (1) require any access to GEMPL’s network, including email,  websites, or any other tool, platform, or (2) require unescorted access to GEMPL facilities  (whether owned or leased) including being issued a cardkey, or other access badges. The  purpose of such screens is to ensure that those with access to GEMPL’s facilities, equipment,  networks, or systems do not present undue safety or security risks.

   For certain personnel placements, the Supplier must conduct additional periodic background  screens. To the extent allowable by applicable law, GEMPL will identify minimum background  screening components, specific to each country, which must be conducted. Background screens  will typically include review of the following components: identity check, criminal record review,  national criminal database search, sex offender registry check, and global sanctions review. GEMPL may require additional screens, such as education verification, prior employment verification, verification of job-related licenses, consumer credit report review, drug testing,  and/or other relevant information gathering if required for a specific placement.

   After receiving each background screening report, Supplier must evaluate whether the Supplier’s personnel are suitable to access GEMPL facilities and/or network required for their work connected to GEMPL. Specifically, Supplier must adjudicate whether the background screening report contains information such as criminal convictions or other matters that may  deem the individual unsuited to perform work and/or have GEMPL provisioned access.  Examples of convictions that may be reasonably related and should be reviewed by the Supplier  include, but are not limited to, crimes of dishonesty (such as property or identity theft,  embezzlement, fraud, forgery, etc.) and violence (such as murder, rape, sexual abuse, kidnapping, assault, robbery, stalking, harassment, etc.). Suppliers may be required to certify that  they have conducted and reviewed

   Pre-placement/Access screens for their personnel, consistent  with this policy. Supplier must adjudicate any criminal convictions, serious delinquency or debt, or any other matters disclosed in the background screen that may deem the individual unsuitable for Placement/Access at GEMPL.

   GEMPL reserves the right to review and discuss information collected during the screening  process with Suppliers for any individual requiring placement or access, including any situation  that would require Supplier personnel to access credit card, financial, or sensitive personal data  of GEMPL customers, partners, employees, or other third parties. Any such discussions shall  be conducted consistent with applicable law. Based on that review, GEMPL may prohibit  placement and/or access, as it deems appropriate, to any individual.

   If a Supplier uses any sub-contractor to perform services that (1) require any access to GEMPL’s network, including email, SharePoint sites, or any other tool, site, platform, or (2)  require unescorted access to GEMPL facilities (whether owned or leased) including being  issued cardkey, or other access badges, the Supplier must ensure that its contracts with sub- contractors include the requirements set forth in this policy. In addition, if a sub-contractor’s personnel will require access to credit card, financial, or sensitive personal data of GEMPL customers, partners, employees, or third parties, the Supplier must also take reasonable steps, in compliance with applicable law, to ensure that sub-contractors conduct the required background screening, as defined in this policy.

   If a Supplier becomes aware of criminal activity by their personnel or the sub-contract(s) who currently have access to GEMPL owned or leased facilities or access to GEMPL’s networks,  the Supplier must refer the information to GEMPL Legal team within 24 hours of becoming aware of the information to determine whether it is acceptable for such individual to  continue to have access. If it is not acceptable, GEMPL Legal team will coordinate with the Supplier to remove the individual from GEMPL assignment and ensure all  access is expeditiously revoked. Suppliers must comply with all applicable laws when removing  any Supplier personnel or sub-contractor(s) from GEMPL’s owned or leased property. If this  criminal activity suggests a possible threat of physical harm directed at GEMPL property or employees, the Supplier must immediately inform its GEMPL business contact and GEMPL  Legal team, but in no event later than 24 hours after becoming aware of the information.

   In all instances, Suppliers must comply with any other applicable national, state, and municipal laws, including data privacy laws. Suppliers are responsible for providing the relevant notices and, if required, obtaining lawful consents, or establishing other lawful bases to (1) conduct the Pre-Placement/Access background screens, and (2) if required, provide GEMPL with the necessary consent required for GEMPL to receive and use that  information lawfully.

   In addition to any indemnification obligations in the relevant contract, if any, pursuant to which Supplier was engaged by GEMPL, Supplier agrees to indemnify and hold harmless GEMPL,  its affiliates and subsidiaries and their respective officers, directors, employees, agents and  insurers (“GEMPL Parties”) from any and all damages, penalties, fines, losses, liability,  judgments, settlements, award costs and expenses (including reasonable attorneys’ fees and  expenses) arising out of or in connection with any claims, assertions, demands, causes of action,  suits, proceedings, investigations, enforcement or other actions, whether at law or equity  (“Claims”) related to (1) any breach by Supplier of this Pre-Placement/Access Policy; (2) Supplier’s violation of applicable laws or ordinances related in any manner to the subject matter  discussed in this Pre-Placement/Access Policy, (3) Supplier’s negligence, misconduct, recklessness, errors or omissions, and/or (4) Supplier’s employment decisions. Supplier shall also  indemnify and hold harmless GEMPL parties from any Claims brought by an employee or  contractor of Supplier against one or more of GEMPL parties related to the background  screens described in this Pre-Placement/Access Policy. For clarity, the additional indemnity obligations in the Pre-Placement/Access Policy Section of the Supplier Code of Conduct apply solely in connection with Supplier’s personnel access to GEMPL’s facilities, equipment,  networks, or systems.

2. PRE-PLACEMENT/ ACCESS POLICY

   1. Suppliers must not use any GEMPL-provided facilities (e.g., buildings and site services) other than in performance of services provided to GEMPL without the prior written consent of GEMPL.
   2. When Supplier personnel require cardkey access to GEMPL facilities, an account on GEMPL’s email system, and/or any other access to any of GEMPL’s networks or  systems, the Supplier and its personnel assigned to GEMPL must sign all applicable  contract(s) required by GEMPL
   3. Suppliers and their employees must not use their location on GEMPL’s premises or network access to obtain information or materials or physical access other than as expressly authorized by GEMPL. GEMPL will not be responsible for loss, damage, theft, or disappearance of any personal property or vehicles located on GEMPL premises belonging to any Supplier or its employees or approved subcontractors.
   4. If a Supplier becomes aware that a “significant” injury to someone or damage to property has occurred on GEMPL premises, the Supplier must notify GEMPL promptly and provide adequate details to enable GEMPL to investigate the cause.  “Significant” in this case means injury to a person that results in hospital treatment or death, or damage to or loss of property with an estimated repair or replacement value in  excess of INR 100,000.