PREVENTION OF SEXUAL HARASSMENT ACT AND POLICY

1. Background

Table Space Technologies (hereinafter referred to as the “Company”) is committed to provide equal opportunity and a harassment free workplace notwithstanding race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin or disability, as the case may be. Thus in order to create such a safe and conducive work environment, this Policy has been framed, in line with the provisions of the “Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act,
2013” of India (hereinafter referred to as the “Act”1) and existing rules framed thereunder namely the “Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 (hereinafter referred to as the “Rules”2).

2. Objective& Scope

Purpose of this policy is to provide protection against sexual harassment of women at workplace and the prevention and redressal of complaints of sexual harassment and matters related to it.

This policy extends to all employees including individuals coming to the workplace for employment or for any other purpose whatsoever including but not limited to visitors, vendors, contractual resources, secondees and applies to any alleged act of sexual harassment against persons at workplace, whether the incident has occurred during or beyond office hours.

This policy does not prevent any aggrieved person from taking recourse to the law of the land.

3. Important Definitions

(a) “Aggrieved Individual” means in relation to a workplace, a person, of any age, whether employed or not, who alleges to have been subject to any act of sexual harassment by the respondent and includes contractual, temporary employees and visitors.

(b) “Complainant” is any aggrieved individual (including a representative as more fully described under Rule 6 of the said Rules, if the aggrieved individual is unable to make a complaint on account of his/her physical or mental incapacity or death or otherwise) who makes a complaint alleging Sexual Harassment under this Policy.

(c) “Employee” as defined under the Act and means a person employed with the Company for any work on permanent, temporary, part-time, ad-hoc or daily wage basis, either directly or through an agent, including a contractor, who with or without the knowledge of the Principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are expressed or implied and includes a co-worker, a contract worker, probationer, trainee, apprentice or called by any other such name.

(d) “Employer” means person who are responsible for management, supervision and control of the workplace including appointment/removal/termination of employees and will include ‘Director and General Manager’, ‘Chief Executive Officer (CEO)’ and ‘Chief Operating Officer (COO) and Human Resources Head’.

(e) “Internal Committee” means and include an Internal Complaints Committee (hereinafter referred to as the “ICC”).

(f) “Member” means a member of the ICC.

(g) “Presiding officer” means the presiding officer of the ICC and shall be a woman employed at a senior level at the workplace amongst the employees.

(h) ‘Respondent” means a person against whom a complaint of alleging sexual harassment has been made under this policy.

(i) “Parties” means collectively the complainant and the respondent.

(j) “Sexual Harassment” includes any one or more of the following unwelcome acts of behaviour (whether directly or by implication):

A. Any unwelcome sexually determined behaviour or pattern of conduct that would cause discomfort and/or humiliate a person at whom the behaviour or conduct was directed namely –

(i) Physical contact and advances;

(ii) Demand or request for sexual favours;

iii) making sexually coloured remarks or remarks of sexual nature about a person’s clothing or body;

(iv) showing pornography;

(v) Any other unwelcome physical, visual, verbal or non-verbal conduct of sexual nature including but not limited to cat-call, wolf/finger whistle, vulgar/indecent jokes, letters, phone calls, text messages, e-mails, gestures etc.

Sexual harassment can involve a series of incidents or it can be a one-off occurrence.

B. The following circumstances, among other circumstances, if it occurs or is present in relation to connected with any act or behaviour of sexual harassment may amount to sexual harassment:-

– Implied or explicit promise of preferential treatment in employment; or

– Implied or explicit threat of detrimental treatment in employment; or

– Implied or explicit threat about the present or future employment status; or

– Interference with work or creating an intimidating or offensive or hostile work environment for the person; or

– Humiliating treatment affecting any person’s health or safety.

(k) “Workplace” means establishments, enterprises, institutions, offices, branches, premises, locations or units established, owned, controlled by the Company or places visited by the employees out of or during the course of employment including accommodation, transportation provided by the employer for undertaking such journey

4.Procedures & Guidelines

4.1 Composition of Internal Complaints Committee
Pursuant to the relevant provisions of the Act, an Internal Complaints Committee (ICC) has been constituted to prevent sexual harassment and to receive and effectively deal with complaints pertaining to the same. Below is the list of members of the ICC constituted by the Company for its offices at Bangalore, Hyderabad , Mumbai, Pune and Delhi.

Name Designation Email id
Ms. Anamika Gupta Presiding Officer Anamika.gupta@mytablespace.com
Mr. Manibabu Krishnan Member Manibabu.krishanan@tablespace.work
Mr. Amit Kumar Member Amit.kumar@tablespace.work
Ms. Aparna GV External Member aparna@kelphr.com

4.2 Complaint of Sexual Harassment3

4.2.1 Raising of complaint

(1) Any aggrieved individual may make in writing, a complaint of sexual harassment to the Human Resources within a period of three (3) months from the date of incident and in case of more than one incident, within a period of three (3) months from the date of last incident. Complaints arising of incidents more than three (3) months old shall not be accepted.

(2) However, the ICC may, for reasons to be recorded in writing, extend such time limit of filing complaint up to further 3 months, if it is satisfied that bonafide circumstances prevented the aggrieved individual from filing complaint within the time limit mentioned in point (1) hereinabove. The complaint should clearly mention name and available details of both the aggrieved person and the respondent. Anonymous or pseudonymous complaints will not be investigated.

(3) Where the aggrieved individual is unable to make the complaint on account of her/his physical or mental incapacity or death or otherwise, his/her representative, as more fully described under Rule 6 of the said Rules, may make a complaint.

(4) The HR Team will officially forward the complaint to the Presiding Officer of ICC within seven (7) days from the date of making of the complaint.

(5) The complainant shall submit six copies of the complaint accompanied by available supporting documents and relevant details concerning the alleged act of sexual harassment(s) including names and address of witnesses, if any which the complainant believes to be true and accurate.

4.3 Redressal Process

4.3.1 Conciliation

Before the ICC initiates an inquiry, the complainant may request the ICC to take steps to resolve the matter through conciliation provided no monetary settlement shall be made as basis of conciliation. If a settlement has been so arrived, the ICC shall record the same and forward the same to the Employer and provide copies of the settlement to the aggrieved individual and the respondent. In such cases, no further inquiry shall be conducted by the ICC.

4.3.2 Inquiry

(1) In case where a settlement is not feasible or could not be arrived at through conciliation (ref clause 4.3.1 above), the ICC will conduct an inquiry into the complaint. Additionally an inquiry may also be initiated if the aggrieved person informs the ICC that any terms of settlement (ref clause 4.3.1 above) has not been complied with by the respondent.

(2) The ICC within 7 (seven) working days of receiving the complaint shall forward one copy thereof to the respondent for obtaining a response.

(3) The respondent within 10 (ten) working days of receiving the complaint shall file his/her reply to the complaint along with list of supporting documents, names and addresses of witnesses.

(4) The ICC shall consider the reply from the respondent and initiate an inquiry. The complainant or the respondent to the complaint shall not be allowed to bring any legal practitioner to represent them at any stage of the proceedings before the ICC. ICC shall hear both the complainant and the respondent on date(s) intimated to them in advance and the principles of natural justice will be followed accordingly.

(5) In the event of failure to attend personal hearing before ICC by the complainant or the respondent on three consecutive dates (intimated in advance), the ICC shall terminate the inquiry proceedings or give an ex-parte decision. However, the ICC shall serve a notice in writing to the party (ies), 15 (fifteen) days in advance, before such termination or the ex-parte order.

(6) The inquiry process shall be completed maximum within the period of 90 (ninety) days from the date of receipt of the complaint.

(7) The ICC within 10 (ten) days from the date of completion of inquiry shall provide a report of its findings to HR Head and Director & General Manager and such report shall also be forthwith made available to the complainant and respondent.

(8) Where the conduct of Sexual Harassment amounts to a specific offence under the Indian Penal Code4 (45 of 1860) or under any other law; it shall be the duty of ICC to immediately inform the complainant of his/her right to initiate action in accordance with law with the appropriate authority, and to give advice and guidance regarding the same. Any such action or proceedings initiated shall be in addition to proceedings initiated and /or any action taken under this Policy

4.3.3 Interim relief

During pendency of the inquiry, on a written request made by the complainant, the committee may recommend to the employer to:
– Transfer the aggrieved individual or the respondent to any other workplace; or
– Grant leave to the aggrieved individual of maximum 3 months, in addition to the leave he/she would be otherwise entitled; or
– Grant such other relief to the aggrieved individual as may found to be appropriate; or
– Restraint the respondent from reporting on the work performance of the complainant.

Once the recommendation of interim relief are implemented, HR HEAD shall inform the committee regarding the same.

4.3.4 Prohibition on disclosure of information

This policy and the law prohibits any person including ICC Members from publishing, communicating or making known to the public, press and media in any manner, contents of the complaint, the identity and addresses of the aggrieved person, respondent and witnesses, any information relating to conciliation and inquiry proceedings, or recommendations of the ICC during the proceedings under the provisions of the Act. Any violation thereto shall also be subject to applicable disciplinary action as outlined in Employee Handbook. Further HR HEAD shall impose monetary sanctions as per provisions of the Act and Rules.

4.3.5 Protection to Complainant

The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action. The Company will ensure that the victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.

However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue and/or produces any forged or misleading document) will be subject to applicable disciplinary action.

4.3.6 Appeal

Any person aggrieved by the recommendation of ICC may prefer an appeal under the relevant provisions of the Act and Rules.

4.3.7 Disciplinary Proceedings

Pursuant to written recommendation of HR Head on the basis of report and findings of ICC and subject to the final outcome of the appeal proceedings, if any, (ref. clause 4.3.6 above) necessary disciplinary proceedings may be initiated against the respondent in terms of the guidelines of the Company.

Annexure-2

Sections of the Indian Penal Code (IPC) – Sexual Harassment and Punishment for
Sexual Harassment

Under the Indian Penal Code, the newly introduced Section (Section 354A) which deals with Sexual Harassment has made this a ‘cognizable offense’ i.e. a person charged with Sexual Harassment may be arrested without a warrant.

(1) A man committing any of the following acts:

(i) physical contact and advances involving unwelcome and explicit sexual overtures; or
(ii) a demand or request for sexual favours; or
(iii) showing pornography against the will of a woman; or
(iv) making sexually coloured remarks,

shall be guilty of the offence of sexual harassment.

(2) Any man who commits the offence specified in clause (i) or clause (ii) or clause (iii) above, shall be punished with rigorous imprisonment for a term which may extend to three years, or with fine, or with both.

(3) Any man who commits the offence specified in clause (iv) above shall be punished with imprisonment of either description (i.e. either simple or rigorous) for a term which may extend to one year, or with fine, or with both.

In addition to Section 354A set out above, acts of Sexual Harassment may also constitute other offenses under IPC including Section 354 (assault or criminal force to woman with intent to outrage her modesty), Section 354C (Voyeurism), Section 354D (Stalking), Section 375 and 376 (Rape) and Section 509 (word, gesture or act intended to insult the modesty of a woman) of the IPC.

ANTI BRIBERY POLICY

1. Objective

The objective of this policy is to:
i. conduct business in an honest and ethical manner.
ii. set out our responsibilities to comply with laws against bribery and corruption; and
iii. provide guidance on how to recognise and deal with bribery and corruption issues

2. Scope

The Anti bribery Policy is applicable to all employees of Table Space Technologies.

3. What is Bribery?

Bribery is:

a) The offer, promise or receipt of any gift, hospitality, loan, fee, reward or other advantage to induce or reward behaviour which is dishonest, illegal or a breach of trust, duty, good faith or impartiality in the performance of a person’s functions or activities (including but not limited to, a person’s public functions, activities in their employment or otherwise in connection with a business); or

b) The offer or promise of any gift, hospitality, loan, fee, reward or other advantage to a public official with the intention of influencing the public official in the performance of their public function, to obtain a business advantage.

Bribery includes not only direct payments, but also authorising or permitting an associate or third party to commit any of the acts or take any part in the actions identified in (a) and (b) above.

4. Not Acceptable

It is not acceptable to:

a) give, promise to give, or offer, a payment, gift or hospitality to secure or award an improper business advantage;
b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate, expedite, or reward any action or procedure;
c) accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
d) induce another individual or associate to indulge in any of the acts prohibited in this policy;
e) threaten or retaliate against another associate who has refused to commit a bribery offence or who has raised concerns under this policy;
f) give or accept any gift where such gift is or could reasonably be perceived to be a contravention of this policy and / or applicable law; or
g) engage in any activity that might lead to a breach of this policy.

5. Raising a Concern Or Complaint

Associates are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, you should raise the matter with your reporting manager or consult an appropriate member of the Human Resource (HR) team.

6. What to do when you are a victim of bribery or corruption?

If you are offered a bribe by a third party, or if you are asked to make a bribe, or if you suspect that you may be asked to commit such a violation, or if you believe that you or anyone else is a victim of any form of unlawful activity, you must comply with this policy.

7. Protection

Associates who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. The Company encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

The Company is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in corruption, or because of reporting concerns under this policy in good faith. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any detrimental treatment as a result of refusing to take part in corruption, or because of reporting concerns under this policy in good faith, you should inform your reporting manager or a member of the Human Resources team of the Company immediately. If the matter is not remedied, and if you are an associate, you should raise the matter to HR or Reporting Manager.

8. Potential Risk Scenarios

This section contains a list of possible red flags that may arise during the course of business. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any red flags you must report them promptly:

(a) Being aware that a third party engages in, or has been accused of engaging in, improper business practices;

(b) Learning that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;

(c) A third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

(d) A third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

(e) A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

(f) A third party requests an unexpected additional fee or commission to “facilitate” a service;

(g) A third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

(h) A third party requests that a payment is made to “overlook” potential legal violations;

(i) A third party requests that you provide employment or some other advantage to a friend or relative;

(j) You receive an invoice from a third party that appears to be non-standard or customised

(k) A third party insists on the use of side letters or refuses to put terms agreed in writing;

(l) You observe that the Company has been invoiced for a commission or fee payment that appears large compared to the service stated to have been provided

(m) A third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to the Company; and/or

(n) You are offered an unusually generous gift or lavish hospitality by a third party.

9. Examples

This section contains a list of examples of prohibited bribery. It is not intended to be exhaustive and is for illustrative purposes only.

Offering a bribe

You offer a potential customer tickets to a major sporting event, but only if they agree to do business with us. This would be an offence (by you) as you are making the offer to gain an improper commercial and contractual advantage. The Company may also be found to have committed an offence because the offer has been made improperly to obtain business for us. It may also be an offence for the potential customer to accept your offer.

Receiving a bribe

A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in our organisation to ensure we continue to do business with them. It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain an improper personal advantage.

CODE OF CONDUCT

1. Objective

The objective of this policy is to:

i. Lay down fundamental standards of business conduct that will guide Table Space employees, in their everyday actions carried out on behalf of the Company.
However, the code (policy) goes beyond what is described and does not serve as a substitute for an individual’s accountability for exercising good judgement and common sense.
The policy aims at promoting honest, legal and ethical actions from all concerned.

2. Scope

The Code of Conduct is applicable to all employees of Table Space Technologies.

3. Code of Conduct (Policy)

3.1 Integrity in Personal Conduct
Being an integral part of the company, Table Space expects its employees to follow the following basic guidelines for their personal conduct:
• Transactions with others including Clients/Tenants, Landlords, Brokers, Vendors, and fellow employees in a fair and dignified manner.

• Being responsible to the best of his/ her knowledge, for fair representation and accuracy of information in the documents prepared or signed off by him / her.

• Ensuring that his/ her personal information provided to the organization is factual and accurate including prior work experience, educational qualification, compensation details, etc.

• Being responsible for ensuring that official expenses and personal claims are factual, correct and within the organization rules.

3.2 Employee Conduct at Work

The employees shall always treat each other professionally and shall govern themselves by the goals, objectives and the interests of the company.

Key tenets that will preside over all our business dealings and interactions as Table Space employees include:

• Acting with highest standard of personal and professional integrity, honesty and ethical conduct.

• Complying with business policies, processes, systems and regulations of the company.

• Complying with all applicable legal and regulatory requirements.

• Keeping the interest of the company over and above any personal / third party interests.

• Promoting cooperative and professional relationship within the company to promote its larger intent.

• Sharing available knowledge, information and resources within the defined/applicable area of influence only.

• Supporting Table Space in maintaining a safe and secure work environment by observing discipline on internal guidelines.

• Securing physical, financial and intellectual property/ assets and interests of the Company in every possible situation by following company policies and procedures to prevent their loss, theft or unauthorized use.

• Obtaining proper authorization and approval before entering into financial or contractual commitments on behalf of the company.

3.3 Conflict of Interest

A conflict of interest arises when employee’s personal activities and relationships interfere, or appear to interfere, with their ability to act in the best interest of the Company. The Company expects that its employees will be free from actual, apparent or potential conflicts of interest when dealing on behalf of the Company and carry out their duties and responsibilities in a fair and objective manner including:

• Making internal business decisions free from personal or external influences and ensuring that these do not lead to personal benefits over and above the benefits to the company.

• Exercising utmost care while dealing with or selecting a Tenant/Landlord/Broker/supplier on behalf of the Company where judgment might get influenced due to familiarity because of personal/ professional interaction with any Tenant/Landlord/Broker/supplier/ vendor, self/ family member stake, or any personal interest that may get fulfilled due to any related decision.

• Ensuring objectivity in people related decisions including hiring, allocation of job responsibilities, performance rating, promotion, etc. Such decisions to be based on qualifications, performance, skills and experience and free from bias and personal interest.

Including in personal business or accepting a particular assignment in any other organization for remuneration or structure

In Table Space employees are expected to proactively/immediately disclose any business interests that they or their immediate family members have, to their manager or the management of the company.

It is important both to disclose relevant facts before getting involved or acquiring interest in an outside party which may have a bearing on the company and to refrain from being part of the decision-making process where the interests are/ conflicting.

3.4 Confidentiality of Information & Reporting

Confidentiality of Information governs each employee, who comes across or handles confidential or non-public data and information about the Company. Employees are required to maintain confidentiality of information and share the same only with authorized personnel for relevant, prescribed purposes. Such information could include:

• Proprietary information, intellectual property rights and goodwill of the company including details on projects and proposals, business plans, Company processes, Business development strategies, Customer lists, Customer preferences, Identified business locations, Computer codes, Financial information, compensation data, Employee relation strategies, Technological data, Marketing strategies etc.
• No material from the company entity or any web site owned, operated, licensed, or controlled by Table Space, may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way, without the prior written permission of the management. Except employees can download one copy of the materials on any single computer for employees’ personal, non-commercial use only, provided he/she keeps intact all copyright and other proprietary notices.

• Any personal information on employees/customers/clients/ Tenants/Landlords/Brokers/suppliers/vendors or related records required for business, legal or contractual purposes.
• Confidential information and/or intellectual property of any of the a fore mentioned that is provided to employees under agreement for specific use.
• Also, Internet access and e-mail that are provided to company employees will be used for legitimate business use and employees must comply with all company policies and requirements governing their usage.
• All this information will be only with authorized company employees having a legitimate need to know or with third parties subject to prior approval and appropriate safeguards. Also, all employees are obligated to protect the Company’s confidential information at all times, including outside of the workplace and working hours, and even after employment ends.

3.5 Use of Company Assets

The Company expects employees to protect the Company’s assets and use those assets in the manner intended.

• Company assets are to be used for Company purposes only, refrain from usage for personal or third-party benefit

• Company may provide certain benefits / assets to employees for personal usage, but these may be used only as prescribed in the relevant policies.

• Theft of Company assets—whether physical theft such as unauthorized removal of Company product, equipment or information, or theft through embezzlement or intentional misreporting of time or expenses—may result in termination and criminal prosecution. The Company treats workplace theft of assets belonging to other employees the same way it treats theft of Company assets.

• Employees are refrained from undertaking personal activities during work hours that interfere with or prevent them from fulfilling their job responsibilities.

• Employees are prohibited from using Company computers and equipment for outside businesses, or for illegal or unethical activities such as gambling, pornography or other offensive subject matter.

• Ensure any use of Company materials or equipment for company purposes but outside company premises is authorized by the management in writing.

3.6 Dealing with Customers/Tenants

Table Space values its partnerships with its Customers/Tenants. To ensure this, employees are required to:

• Deal fairly with Customers/Tenants, treating them honestly and with utmost respect.
• Refrain from engaging in unfair, deceptive or misleading practices.
• Always present Company products/services in an honest and forthright manner.
• Avoid any dealings beyond the call of the duty.
• Refrain from accepting any gratification including tips from the Customers/Tenants while on duty or after duty hours in any form whatsoever.

3.7 Gifts and Entertainment

The propriety of giving or receiving gifts from another employee or Customer/Tenant/Broker/supplier/ vendor or probable Customer/Tenant/Broker/supplier/ vendor or any person belonging to any company with whom the company may have any business dealing depends on the value and intent of the gift. Any tangible item and cash or cash equivalents as well as favors, special considerations, gratuities and discounts can be considered as gifts. And the only acceptable purpose of gifts and entertainment is to create goodwill or strengthen business relationships. Hence, all employees of the company: Can offer/ accept any employment related gift if it comfortably falls within the range of common business courtesies.
• Will refrain from offering or accepting gifts, hospitality or entertainment that may be inappropriate or may affect or otherwise appear to influence business judgment of either party.

• Under no circumstances accept cash or cash equivalents, such as gift certificates or gift cards, regardless of the amount, from anyone who has business dealings with the company.

4. Dealing with Landlords, Brokers, Clients, Suppliers and Partners
• You shall treat Landlords, Brokers, Clients, Suppliers and Partners with respect and conduct yourself in a professional and workmanlike manner and in compliance with all applicable laws, obligations, rules, and regulations. Employee demeanor and language shall be respectful in line with Table Space values based on mutual respect and trust.
• You shall not exploit your position at the company for personal gain by giving, offering, or promising anything of value to, or soliciting or accepting anything of value from Landlords, Brokers, Clients, Suppliers and Partners. Partners or family members may not receive personal benefits as a result of an employee’s position at Table Space. No employee shall have any personal interest incompatible with Table Space’s interests. All employees are expected to act in Table Space’s best interest.
• You shall not make any representation, guarantee or warranty concerning the company, its products or services, or any of the terms or conditions of any agreement, except as authorized by the company
• Employees may have access to confidential information that may affect a contract bid or the business award process, such as selection plans, ranking of bids, proposals, competitors involved and competitive range determinations. Confidential information may also include any information on products, ongoing developments, financial data, business strategy, business manuals and literature, work procedures, supplier databases, etc. Employees shall refrain from disclosing such information without prior approval. Confidential information related to quotes and bids from Landlords, Brokers, Clients, Partners and Suppliers is not to be shared with any other Landlords, Brokers, Clients, Partners and Suppliers or third party at any time. Employees will keep confidential information from Landlords, Brokers, Partners and Suppliers confidential.
• Employees must show intellectual and moral rigor in decision making. Employees shall ensure that contracts are awarded and administered free from improper influence. Employees shall select Landlords, Brokers and Suppliers and award business on the basis of fair competition and on the basis of meeting appropriate selection criteria. Arrangements with or among Landlords, Brokers, Partners and Suppliers that could limit or distort competition shall be avoided. Employees shall not request any payment from Landlords, Brokers, Partners and Suppliers as a condition of being placed on a preferred Landlords, Brokers, Partners and Suppliers list. Employees shall select and award business to Landlords, Brokers, Partners and Suppliers that are committed to acting fairly and with integrity towards their stakeholders.
• Long-term agreements with Landlords, Brokers, Partners and Suppliers should periodically be subject to fair and open competition, to obtain the best current market offering and to provide alternative Landlords, Brokers, Partners and Suppliers with an opportunity to win the business.
• Employees shall report to their managers any concerns about compliance with the Code of Conduct and/or any applicable laws or regulations.
• Employees should never offer anything of value to a government official in an effort to get any favorable treatment.

5. Internal Reporting of Unethical and Illegal Conduct

If a decision about a particular action is not covered specifically by this Code or associated Standards of Conduct, Employee is required to seek guidance from their supervisor or appropriate internal resources, such as his seniors and the management.

The Company seeks to detect unethical and illegal conduct and to ensure that any concerns are thoroughly investigated with appropriate actions taken based on the outcome.

Employee is required to promptly report unethical and illegal conduct through the appropriate internal channels.

The company will protect Employee who report, or consider reporting unethical and illegal conduct from retaliation, retribution and any form of harassment directed against them.

6. Violation of Code

The Company strives to impose discipline that fits the nature and circumstances of each Code violation. The Company uses a system of progressive discipline, issuing letters of reprimand for less significant, first-time offenses. Violations of a more serious nature may result in suspension without pay; loss of performance bonus or even termination of employment.
When an employee is found to have violated the Code, notation of the final decision, and a copy of any letter of reprimand, will be placed in the employee’s personnel file as part of the employee’s permanent record.

7. Responsibilities

7.1 Employee Responsibility

• All Employees must comply with this Policy, and associated standards of conduct in the pursuit of Company business.
• If a decision about a particular action is not covered specifically by this Policy or associated Standards of Conduct, Employee is required to seek guidance from his or her superior or management.
• Failure by any Employee, including Band III and above who ignore prohibited conduct, or have knowledge of the conduct and fail to correct it, to comply with this or any Table Space policy will be subjected to disciplinary action up to and including separation from the Company.

7.2 Management Responsibility

Senior management of the company is ultimately responsible for ensuring compliance with this Policy. Management at all levels must be role-models for compliance with this Policy and associated standards by visibly demonstrating support and by regularly encouraging adherence by Table Space Employee.
Managers must ensure their employee receives guidance, training and communication on ethical behavior and legal compliance relevant to their duties for the Company.
• Ensure that the people they supervise understand their responsibilities under the Code of Conduct and other Company policies.
• Take opportunities to discuss the Code and reinforce the importance of ethics and compliance with employees.
• Create an environment where employees feel comfortable raising concerns.
• Consider conduct in relation to the Code and other Company policies when evaluating employees.
• Never encourage or direct employees to achieve business results at the expense of ethical conduct or compliance with the Code or the law.
• Always act to stop violations of the Code or the law by those you supervise.
• Respond to Questions and Concerns, if possible, give immediate response. However, in case of doubt make sure to clarify with the management of the company.

8. Signature and Acknowledgement

All new employees must sign an acknowledgement form confirming that they have read the Table Space Code of Conduct (Policy) and agree to abide by its provisions. All employees will be required to make similar acknowledgements on a periodic basis.

Failure to read the Code or sign the acknowledgement form does not excuse an employee from compliance with the Code.

9. Termination of Services

The Company may terminate with or without cause under the following conditions-

With Cause: The Company may, immediately and without notice, terminate your services with “Cause”. The term “Cause” shall, as used in this document mean
(1) the commission of a crime involving moral turpitude, theft, fraud or deceit;
(2) conduct that has an adverse effect on the Company’s reputation;
(3) substantial or continued unwillingness or inability to perform duties assigned to the Employee;
(4) gross negligence or deliberate misconduct;
(5) any material breach of terms and conditions specified in this letter;
(6) Unauthorized absence from work for a period of three or more consecutive days without due consent or notifying your manager;
(7) providing any false information to the company.

Without Cause: In the event that the employment is terminated without Cause, the employee will be provided with a 15 days’ written notice period prior to such termination or basic salary in lieu thereof.

10. Exceptions / Deviations
Any exceptions/deviations from Table Space Code of Conduct require approval from the Senior Management of the Company.

11. Interpretation and amendment
The Company’s Management:
• Is the sole authority to interpret the contents of this policy.
• Reserves the right to amend, abrogate, modify, and revise any or all clauses of this policy as per its discretion.

NON-DISCRIMINATION POLICY

PURPOSE: To define the company policy and practices towards non- discrimination of an employee or group of employees.

SCOPE: For all employees of Table Space Technologies Private Limited (“Company”)

• It is the belief of the company that the personnel are solely employed, trained, promoted and compensated on the basis of performance and competence irrespective of race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, HIV status, Marital status, Pregnancy status etc.
• The company shall not interfere with the rights of the employees to observe tenets or practices, or to meet needs relating to race, caste, national origin, religion, disability, gender, sexual orientation, union membership or political affiliation.
• Managerial and supervisory personnel are trained on the policies of the Company, aimed at prohibiting discrimination to ensure that personnel are not discriminated against on any basis.
• All employees are treated in a decent manner and are free from verbal, physical and sexual harassment and other discriminatory practices. This shall include behaviour, gestures, language, physical contact that is sexually coercive, threatening, abusive or exploitative. Equal opportunities & equal treatment is the basic principle adopted by the company for employees possessing similar at work. (Equal work, equal pay)
• The HR has the responsibility to communicate, deploy and monitor the practices of the company aimed at prohibiting discrimination right from the Induction stage of an employee in the organisation and sub-contractors before the signing of contract with the organisation.
• The HR has to report the management on the audit findings, employee interview reports to the top management.