Limited.

1
Zero Tolerance Policy (ZTP)

This policy document will apply to; without restriction and/or limitation to any previous agreements to
allemployees of irrespective of grade and/or role. The
document will be used as a guideline to classify the severity of non-compliance and to recommend
actions for each instance of non-compliance. However implementation of the recommended actions will
be at the discretion of the respective Centre Manager and/or the Chairperson of the Disciplinary
Action Committee who may choose to reduce, waive off or increase the severity of actions
recommended.
1. Actions, gestures, language or other communication written, verbal and non-verbal, that is, or can be
perceived to be profane, vulgar, abusive or discriminatory with regard to race, religion, culture, sex,
sexual orientation or lifestyle of a customer, employee, vendor or partner or
.
2. Consistent interruptions in a rude and sarcastic manner.

3. Vilifying products, affiliates and competitors.

4. Exchange of personal e-mail addresses, flirting, making dates or inappropriate conversation with
customers or other departments.

5. Coming to work intoxicated.

6. Breaking any promise made to the customer including but not limited to:
Promising but not making a call back,
Not keeping customer informed when it was promised or mandated as per procedure.
Abandoning Member "on hold" (greater than five minutes).
Refusing to escalate to a supervisor at customer's request.

7. Call Avoidance (Call means any method of communication with customer, including chat, voice,
e-mail etc.) in any form including but not limited to
Intentionally disconnecting/avoiding the customer.
Intentionally not answering
Telling customers that systems are down when they are not,
Putting the customer on hold as soon as the call begins
Transferring the customer back into the Queue

8. Breach of Regulatory Compliance

Actions that breach or can lead to breach of the Data Protection Act including but not limited
ion to an
unauthorized third party etc.
Non-compliance to EOI regulations/commitments.
Breach of applicable fair trading and privacy laws

the race, religion, sexual orientation or medical/personal history or condition of the customer
Releasing confidential information without authorization.
Disclosing their role as an outsource service provider to a Member.

2
9. Usage of Mobile Phone
Using Mobile phone in the restricted area such as Production Floor
Using Camera Phone in the restricted area
Zero Tolerance Policy (Guidelines)

Any instances of non adherence to any of the ZTP policy will lead to immediate referral for Disciplinary
action. All recommendations for disciplinary action must specify the source of information, the date of
violation, the clause and the action recommended.

Disciplinary action can include:

Warning letter.
Termination.

Severity of action will depend on:

The nature of the breach and any breach which has a direct customer impact and/or
regulatory impact will be treated as unpardonable.
Previous instances of the same or similar non-compliance.

I, __________________________________, S/o/D/o/W/o ______________________________, hereby

declare that I have read the above policy and understood the contents therein and assure that I will abide
by the policies mentioned herein. I also authorize the Management to take any action against me for any
non-compliance.

Signature*: __________________________

Date: __________________________

* This is a common Policy and you may need to sign process specific policy, if any process demands. In
that case, that policy will also become a part of this policy.

3
 CONSENT FORM

Manager HR Dated: ____________________

Dear Sir / Madam,

Subject: Consent for working in night shifts in terms of notification no.

No.:-2398/ 36-3-2000-1 [Dook. Van.]/99 dated 22nd October, 2005 of Govt. of UP.

1 _______________________________________ employee code no. ________________________

working as _______________________________ in . At
its
establishment at ____________________________________, do hereby willingly and without any

undue influence, give my free consent to be deployed and work in night shifts on any day of the week.

__________________

4
 TERMS & CONDITIONS OF EMPLOYMENT

Name of the Joinee: ____________________________________________________________

Location: _____________________________________________________________________

Date: _________________________________________________________________________

Appointment Ref. No.: ___________________________________________________________

Please read through this document carefully, sign at the end and hand this over along with your other
joining papers. This is necessary and forms part of your joining papers.

1. ost honesty and

professional ethics. If you are found guilty at any point of moral turpitude or of dishonesty in dealing

the value involved your services would be terminated with immediate effect notwithstanding other
terms and conditions mentioned in this letter.
2. If during the period of your services, the management comes to the conclusion that you have
committed any misconduct, you may be dismissed from services as per the rules of the company with
immediate effect, notwithstanding anything else mentioned in this letter.
3. You are required not to engage yourself in any other gainful or commercial employment business or
activity part time or full time, directly; indirectly or simultaneously as long as you are employed with
Services Or engage yourself directly or indirectly in
any other profitable business connected with the dealings or activities of the company in any way.
Any action to the contrary would render your services liable for termination notwithstanding an other
conditions in this letter.
4. You are required to maintain the secrecy of, and not divulge or communicates in any manner, any
information regarding your remuneration to any other employee of the company except to your
immediate superior.
5. You appointment and its continuance is subject to your being certifies physically and mentally fit by
a quality register medical practitioner (RMP) nominated by the company. The opinion of the RMP
nominated by the company shall be final $ binding on the parties.

ACCEPTED BY

Employee Name: ____________________________________________________________

Signature: ________________________________________________________
Date: ______________________________________________________________________

5
 TO WHOM SO EVER IN MAY CONCERN
E-Mail Policy:

I have read and understood -Mail policy. I fully understand the terms of this policy and
agree to abide by the
management use all mails I send or receive. I know that any violation of this policy could lead to dismissal

Internet Policy:

I have read and underst

use the Internet address of any site that I visit and keep a record of any network activity in which I transmit
or receive any kind of file. I acknowledge that any message I send or receive will be recorded and stored
in an archive file for management use. I know that any violation of this policy could lead to dismissal or
even criminal prosecution.

Employee Signature*: _________________________________

Employee Name: _________________________________

Employee Code: __________________________________

6
 NETWORK USAGE POLICY

All the members of are responsible for maintaining a

work environment that promotes respect for all the people. Standards are created not to restrict the
freedom or productivity of any individual, but to protect the many privileges enjoyed by the members.
. is responsible for securing its network and computing
system in a reasonable and economically feasible degree against unauthorized access and/or abuse,
while making them accessible for authorized and legitimate users. This responsibility includes informing
users of expected standards of conduct and the punitive measures for not adhering to them. Any attempt
to violate the provisions of this policy will result in disciplinary action in the form of temporary
revocation of users account, regardless of the success or failure of the attempt. Permanent revocation can
result from disciplinary actions taken by a panel judiciary board called upon to investigate network
abuses. The users of the network are responsible for respecting and adhering to national and
international laws. Any attempt to break those laws through the use of the network may result in
litigation against the offender by the proper authorities. If such an event occurs,
Services will fully comply with the authorities to provide any information
necessary for the litigation process.
Section1 General Computing Policy
Once a user receives a user ID to be used to access the network and computer systems on that network,
they are solely responsible for all actions taken while using that user ID. Therefore:
1.1 Sharing your user ID with any other person is prohibited. In a result that you do share ID with
other person, you will be solely responsible for the actions that the other person appropriated.
1.2 Deletion, examination, copying, or modification of files and/or date belonging to other users without
their prior consent is prohibited.
1.3 Attempts to evade or change resources quota are prohibited.
1.4 Continued impedance of other users through mass consumption of system resources, after receipt of
a request to cease such activity, is prohibited
1.5 Use of facilities and/or services for personal communication purposes is prohibited.
1.6 Any unauthorized, deliberate action, which damages or disrupts a computing system, alters its
normal performance, or causes it to malfunction, is a violation regardless of system location or time
duration
1.7 Making copies of any software without authorization, is prohibited
Section 2 Network Security Policy
As a user of the network, you may be allowed to access other networks. Therefore:
3.1 Use of system and/or networks in attempt to gain unauthorized access to remote system is
prohibited.
3.2 Use of system and/or networks to connect to other system in evasion of the physical limitations of
the remote system/local is prohibited.
3.3 Decryption of system or users passwords is prohibited.
3.4 The copying of system files is prohibited.
3.5 The copying of copyrighted materials, such as third-party software, without the express written
permission of the owner or the proper license, is prohibited.
3.6
3.7 Any attempt to secure a higher level of privilege on Network systems are punishable disciplinary
offenses.
3.8
organization network or into external networks is prohibitive.
Employee Signature*: _________________________________

7
3.9 To bring in external software and loading it onto organization network, without proper approval is
prohibited.
3.10 Deliberate misuse of any communication equipments is a punishable offense. This includes and is
not limited to the use of voicemail, email, photocopiers, fax machines and headsets.

Section 3 Internet Usage Policy

Whenever you access Internet, your user ID is logged in the proxy server of
You are responsible for all transmission and access requests originating from your
user ID. Therefore:
4.1 Using internet access provided through . for
personal commercial gain and recreation (such as game playing and sports) is prohibited.
4.2 Transmission of confidential information outside or inside of
to Unauthorized personnel is prohibited.
4.3 Inappropriate and unprofessional behavior on-line such as use of threats, intimid
is offense.
4.4 Sending jokes, cartoons, images that may be offending / sensitive to a particular religion/sect/faith is
Strictly prohibited and may even result in termination.
4.5 Viewing, downloading or transmission of pornographic material is a punishable disciplinary offense.
4.6 Consumption of internet resources for non-business related activities (such as video, audio or down
Loading large files) is not approved

Please read the policy carefully and confirm that you have read and understood the policy and will abide
by the policy

Employee Signature* ____________________________

Employee Name: ____________________________

Employee Code: _____________________________

Date: _____________________________

8
 CONFIDENTIALITY UNDERTAKING

This has reference to my appointment letter dated __________________________ whereby I have been
appointed as __________________________________ on the terms and conditions stipulated there under
and which I have duly signed in my acceptance of the same.

I recognize that as per terms of my appointment, I have been employed in a position of trust and confidence

I therefore agree to the following:

1) TREATMENT OF CONFIDENTIAL INFORMATION

a) I shall never, directly or indirectly disclose, transfer or use any confidential information as such
term is defined in Section (b) below, except with the prior written consent of the Company or

business.

b) If I am required to disclose confidential information pursuant to a valid and existing order of a

court or other Governmental body, I must give prompt notice to the Company of any such potential
disclosure and allow the Company a reasonable opportunity to limit such disclosure.

2) DEFINITION OF CONFIDENTIAL INFORMATION

a) Production processes, marketing techniques and arrangements, mailing lists, purchasing

information, pricing policies, quoting procedure, financial information, customer and prospect
names and requirements, employee, customer, supplier and distributor data, price lists and other

the Company does business:

b) Computer software whether now or hereafter existing, developed for use of any operating system
or machine, all modifications, enhancements, and versions and all options available with respect
thereto, and all future products developed or derived there from.
c) Source and object code, flowcharts, algorithms, coding sheets, routines, sub-routines, compilers,
assemblers, design concepts and related documentation and manuals.
d) Discoveries, concepts and ideas including, without limitation, the nature and results of research
and development activities, processes, formulas, inventions, computer-related equipment or
-
e) All other materials or information related to the business or activities of the Company, which are
not generally known to others engaged in similar businesses or activities.
f) All ideas which are derived from or related to my access to or knowledge of any of the enumerated
materials and information, and
g) All information about or belonging to suppliers and clients of, and all parties to any agreement
with, the Company which would be confidential information pursuant to the above definition if
such other parties were in the position of the Company.

The absence of any marking or statement that particular information is Confidential Information shall
not affect its status as Confidential Information.

Employee Signature*: _________________________________

9
3) OWNERSHIP OF CONFIDENTIAL INFORMATION

a) All rights, title and interest in all Confidential Information shall be and remain the exclusive
property of the Company all Confidential Information developed in whole or in part by me during
my assignment, with the Company, to assign to the Company all right, title and interest I may have
in such Confidential Information and to execute any instruments and to do all other things
reasonably requested by the Company both during and after my tenure with Company in order to
vest more fully in the Company all ownership rights in Confidential Information transferred by me
to the Company. Notwithstanding the foregoing obligations, I need not assign any right to any
invention for which no equipment supplies, facility or Confidential Information of the supplies,
facilities, or Confidential Information of the Company was used, and which invention was
s business
or actual or demonstrably anticipated research and development, or result from, any work
performed by me for the Company.
b) If any or more of the item described above are protect able by copyright and are deemed in any
way to fall with the definit
solely, completely and exclusively by the Company. If any one or more of the aforementioned

contained in 17 U.S.C.S. 101, such items shall be deemed to be assigned and transferred
completely & exclusively to the Company by virtue of the execution of this Undertaking.

4) MATERIALS

All notes, data, tapes, reference items, sketches, drawings, memoranda, records and other materials in

exclusively to the Company, and I shall return to the Company all copies of such materials in my
possession or under my control at the request of the Company or, in the absence of such a request,
upon the termination of my services with the Company. This section will be enforceable against my
heirs successors and assigns.

5) NO CONFLICTING AGREEMENT

I represent that my performance of all the terms of this Undertaking and any services to be rendered
as an employee of the Company do not and shall not breach any fiduciary or other duty or any covenant
agreement or understanding including, without limitation any agreement relating to any proprietary
information, knowledge of data acquired by me in confidence, trust, or otherwise, prior to my contract
by the Company to which I am a party or by the terms of which I may be bound. I covenant and agree
that I shall not disclose to the Company, or induce the Company to use, any such proprietary
information, knowledge or data belonging to any previous employer or others and that I will disclose
to the Company the terms and subject to any prior confidentiality or invention, agreement or
agreements I have entered into. I further covenant and agree not to enter into any agreement or
understanding either written or oral, in conflict with the provisions or this Undertaking.

Employee Signature*: _________________________________

10
6) HUMAN RESOURCE

I understand that the Company values its employees and requires fair protection from the loss of its
employees. From the date of termination of my services for any reason whatsoever, and ending two
years thereafter, I shall not directly or indirectly induce any individual who shall have been an
employee of the Company, and at any time during the one year period prior to the termination of this

7) REASONABLENESS OF RESTRICTIONS

I have carefully read and considered the contents of the Undertaking and having done so, acknowledge
that the restrictions set forth are fair and reasonable and are reasonably required for the protection of
the interest of the Company and its business, officers, directors and the employees?. I further
acknowledge that the restrictions set for during this Undertaking shall not impair my ability to secure
employment upon completion of this contractual assignment within the fields of my choice including
without limitation, those areas I am to be or have been engaged by the Company.

Employee Signature*: _________________________________

11
 UNDERTAKING

As a condition and consideration of my employment or association with

responsible position and my receipt of the compensation now and hereafter paid to me by the Company,
I hereby agree to the following:

1. Confidential Information:

a. Company Information. I confirm that protection of the Company's Confidential Information and
goodwill is of utmost necessity and that I agree that I shall not, directly or indirectly, except where
authorized by the competent authority of the Company for the benefit of the Company at any time
divulge, communicate or disclose to any persons, firms, corporations, companies, governmental
entities or agencies or any other entities, other than the Company ("Third Parties"), or use or cause
or authorize any Third Parties to use except for the benefit of the Company, any such Confidential
Information, or any other information which I know or should know by virtue of being the
employee of the Company, whether or not any of the foregoing information is actually novel or
unique, except as otherwise required by law,

b. Former employer Information. I agree that I will not, during my employment or association with
the Company, improperly use or disclose any proprietary information or trade secrets of any former
employer or Third Parties and that I will not bring into the premises of the Company any
unpublished document or proprietary information belonging to any such employer or Third Parties
unless consented to in writing by such employer or Third Parties.

c. Third Party Information. I recognize that the Company has received and in the future will receive
from Third Parties, which may or may not be the customers or prospective customers of the
Company, their confidential or proprietary information subject to a duty on
maintain the confidentiality of such information and use it only for certain limited purposes. I agree
to hold all such confidential or proprietary information in the strictest confidence and not to
disclose it to any person, firm or corporation or to use it except as necessary in carrying out my

d. Employee Has and Shall Receive Confidential Information. I acknowledge that I have been
provided with information about the Company during the term of my employment or association
with the Company (including any renewals or extensions) and my employment or association will
continue to bring me into close contact with confidential affairs of the Company. Thus, I
acknowledge that by reason of my employment or association with the Company, I will acquire
Confidential Information.

e. Employee Acknowledges Importance of Confidential Information. I acknowledge that all

Confidential Information is of great value to Company, and essential to preservation of the
business and the goodwill of the Company.

f. Employee's Services Special and Unique. I recognize the duties and services to be performed by
myself, as an employee or associate of the Company, are special, extraordinary and unique, and
intellectual in nature.

Employee Signature*: _________________________________

12
 a. shall include all:

1. Production processes, marketing techniques and arrangements, mailing lists, purchasing

information, pricing policies, quoting procedure, financial information, funding information,
customer and prospect names and requirements, employee, customer, agents, supplier and
distributor data, business strategies, plans, assets, liabilities, revenues, profits price lists and

Company carries out its business:

2. Computer software whether now or hereafter existing, developed for use of any operating
system or machine, all modifications, enhancements, and versions and all options available
with respect thereto, and all future products developed or derived there from.

3. Source and object code, flowcharts, algorithms, coding sheets, routines, sub-routines,
compilers, assemblers, design concepts and related documentation and manuals.

4. Discoveries, concepts and ideas including, without limitation, the nature and results of research
and development activities, processes, formulas, products, patents, inventions, computer-
related equipment or technology, techniques, "know-
specifications, procedures, methods, designs, strategies and any other information required for
carrying out the business of the Company. These shall also include any information about the
customers and clients of the Company.

5. All other materials or information related to the business or activities of the Company, which
are not generally known to others engaged in similar businesses or activities.

6. All ideas which are derived from or related to my access to or knowledge of any of the
enumerated materials and information, and

7. All information about or belonging to suppliers and clients of, and all parties to any agreement
with, the Company which would be confidential information pursuant to the above definition
if such other parties were in the position of the Company.

8. The markets, customers, prospective customers (whom Company has contacted, made sales
presentations, provided bids, or otherwise specifically solicited during the Term hereof),
suppliers, vendors and employees of the Company, records of transactions, and other
information concerning the business of Company. Such customers or prospects shall include,
but not limited to customers of the Company on whom I called or with whom I became
acquainted while being associated with the Company.

9. The absence of any marking or statement that particular information is Confidential

Information shall not affect its status as Confidential Information.

is purpose shall mean and include all

information, regardless of the form and whether oral, written, stored in a computer database or
otherwise, which has been disclosed by the Company or any of its employees or promoters to
myself. I understand that Confidential Information does not include any of the foregoing items,
which has become publicly known and made generally available through no wrongful act of

Employee Signature*: _________________________________

13
 mine or of others who were under confidentiality obligations as to the item or items involved. I
hereby accept the responsibility for maintaining the secrecy and confidentiality of such
Information and all portions thereof during the term of my employment or association with the
Company and for a period of eighteen (18) months thereafter following the termination of my
employment or cessation of my association with the Company and recognize without any
objection or protest the unequivocal right of the Company to ascertain from my employers of any
breach or threatened breach by me of this undertaking.

h) Ownership Of Confidential Information

1. All rights, title and interest in all Confidential Information shall be and remain the exclusive
property of the Company including all Confidential Information developed in whole or in part
by me during my assignment with the Company, I agree and shall assign to the Company all
right, title and interest I may have in such Confidential Information and to execute any
instruments and to do all other things reasonably requested by the Company both during both
during and after my tenure with Company in order to vest more fully in the Company all
ownership rights in Confidential Information transferred by me to the Company.

2. If any one or more of the items described above are protected under the copyright laws and

the Company. If any one or more of the aforementioned items are protected by categories of

nation or jurisdiction, such items shall be deemed to be assigned and transferred completely
and exclusively to the Company by virtue of the execution of this Agreement.
i) Materials. All notes, data, tapes, reference items, sketches, drawings, memoranda, records and
other materials in any way relating to Confidential Information or otherwise to the
business shall belong exclusively to the Company, and I shall return to the Company all copies of
such materials in my possession or under my control at the request of the Company or, in the
absence of such a request, upon the termination of my employment or cessation of my association
with the Company. This section will be enforceable against my heirs, successors and assigns.

2. Proprietary Information.

a) Return of Proprietary Information. Upon termination of my employment or cessation of my

association with the Company, for any reason, I shall immediately turn over to the Company any
"proprietary information," as defined below. I shall have no right to retain any copies of any
material qualifying as "proprietary information" for any reason whatsoever after termination of my
employment or cessation of my association with the Company, without the express written consent
of the Company.
b) Non-Disclosure. It is understood and agreed that, in the course of my employment hereunder and
through my activities for and on behalf of the Company, I will receive, deal with and have access
to the Company's "proprietary information" and I hold the Company's "proprietary information"
in trust and confidence for the Company. I agree that I shall not, during the term of this Agreement
or thereafter, in any fashion, form or manner, directly or indirectly, retain, make copies of, divulge,
disclose or communicate to any person, in any manner whatsoever, except

Employee Signature*: _________________________________

. 14
 when necessary or required in the normal course of my employment hereunder and for the benefit
of the Company or with the express written consent of the Company, any of the Company's
"proprietary information" or any information of any kind, nature or description whatsoever
concerning any matters affecting or relating to the Company's business.

c) Proprietary Information Defined. For purposes of this Agreement, "proprietary information"

means and includes the following: the identity of clients or customers or potential clients or
customers of the Company; any written, typed or printed lists or other materials identifying the
clients or customers of the Company; any financial or other information supplied by clients or
customers of the Company; any and all data or information involving the techniques, programs,
methods or contacts employed by the Company in the conduct of its business; any lists, documents,
manuals, records, forms, or other material used by the Company in the conduct of its business; any
descriptive materials describing the methods and procedures employed by the Company in the
conduct of its business; and any other secret or confidential information concerning the Company's
business or affairs. The terms "list" and "document" (or their equivalent) as used in this Section
are not limited to a physical writing or compilation but also include any and all information
whatsoever regarding the subject matter of the "list" or "document," whether or not such
compilation has been reduced to writing

3. Inventions.

a) Inventions Retained and Licensed. I have attached hereto, as Exhibit A, a list describing all
inventions, original works of authorship, developments, improvements, and trade secrets which
were made by me prior to my employment with the Company

research and development, and which are not assigned to the Company hereunder, or, if no such
list is attached, I represent that there are no such Prior Inventions. If in the course of my
employment or association with the Company, I incorporate into a Company product, process or
machine a Prior Invention owned by me or in which I have an interest, the Company is hereby
granted and shall have a nonexclusive, royalty-free, irrevocable, perpetual, worldwide license to
make, have made, modify, use and sell such Prior Invention as part of or in connection with such
product, process or machine.

b) Assignment of Inventions Any and all inventions, products, designs, discoveries, literary works,
art works and work product of any nature (collectively, the "Inventions"), whether or not can be
patented or copyrightable, which I have conceived and/or made during my employment or
association with the Company, whether or not during working hours, and which have or may have
any applicability to any aspect of the business of the Company, shall be the sole and exclusive
property of the Company, and by the execution hereof, I hereby irrevocably assign, transfer and
convey to the Company all of my right, title and interest in and to all Inventions, which may be
developed during my employment or association with the Company (solely or jointly with others).
I shall inform the Company of any Inventions promptly after it has been conceived and/or made
in the detail necessary to permit the Company to understand the same and practice them without
the exercise of further inventive skill. When required to do so by the Company, I shall execute any
and all documents necessary to desirable to convey title in any copyright or patent applications
covering any of such Inventions in India or in foreign countries. However, the failure on my part
to so execute any such documents shall in no way be deemed to affect the assignment, transfer and
conveyance of such Inventions to the Company hereby.

Employee Signature*: _________________________________

15
 c) Maintenance of Records. I agree to keep and maintain adequate and current written records of all
Inventions made by me (solely or jointly with others) during the terms of my employment with the
Company. The records will be in the form of notes, sketches, drawings, and any other format that
may be specified by the Company. The records will be available to and remain the sole property
of the Company at all times.

d) Patent and Copyright Registrations. I agree to assist the Company, or its designee, at the

any copyrights, patents, mask work rights or other intellectual property rights relating thereto in
any and all countries, including the disclosure to the Company of all pertinent information and
data with respect thereto, the execution of all applications, specifications, oaths, assignments and
all other instruments which the Company shall deem necessary in order to apply for and obtain
such rights and in order to assign and convey to the Company and its nominees the sole and
exclusive rights, the title and interest in and to such Inventions, and any copy rights, patents, mask
work rights or other intellectual property rights relating thereto. I further agree that my obligation
to execute or cause to be executed, when it is in my power to do so, any such instrument or papers
shall continue after the termination of my employment or cessation of my association with the
Company. If the Company is unable, because of my mental or physical incapacity or for any other
reason, to secure my signature to apply for or to pursue any application for any Indian or foreign
patents or copyright registrations covering Inventions or original works of authorship assigned to
the Company as above, then I hereby irrevocably designate and appoint the Company and its duly
authorized officers and agents as my agent and attorney in fact, to act for and in my behalf and
stead to execute and file any such applications and to do all other lawfully permitted acts to further
the prosecution and issuance of letters patent or copyright registrations thereon with the same legal
force and effect as if executed by me.

4. Non-Competition. I agree that, during the term of my employment or association with the Company,
I will not engage in any other employment, occupation, consulting or other business activity with any
Third Parties, directly related to the business in which the Company is now involved or becomes
involved during the term of my employment, nor will I engage in any other activities that conflict with
my obligations to the Company. I also agree that after the termination of my employment or cessation
of my association with the Company for any reason whatsoever, I shall not undertake any employment
or enter into any kind of association with any Third Parties for a period of eighteen (18) months in
India or any place outside India where I was posted by the Company in the last eighteen (18) months
prior to the termination of my employment or cessation of my association with the Company, where
such Third Parties are in competitive business with the Company and whereby to carry out my
functions with such Third Parties I may be obliged to use any of the Confidential Information,
Proprietary Information, Inventions belonging to the Company or Third Party Information made
available to the Company. I further agree that I shall abide by the provisions of Exhibit B as and where
applicable to myself. I understand that if I violate the above undertaking then I shall be liable for
suitable damages, which will be decided at the discretion of the Company after taking into
consideration the nature and extent of the violation. I acknowledge that the Confidential Information,

Company has a legitimate interest in including a non-competition clause in this Agreement. I also
agree that if any of the provisions of this Agreement is violated or likely to be violated then the
Company shall also be entitled to move for injunction against me before a competent court.

Employee Signature*: _________________________________

16
5. Returning Company Documents. I agree that, at the time of leaving the employment or on the cessation
of my association with the Company, I will deliver to the Company (and will not keep in my
possession, recreate or deliver to anyone else) any and all Confidential Information, Proprietary
Information or Inventions or reproductions of any aforementioned items developed by me pursuant to
my employment or association with the Company or otherwise belonging to the Company.

6. Notification to New Employer. In the event that I leave the employment or if my association with the
Company ceases, I hereby grant consent to notification by the Company to my new employer about
my rights and obligations under this undertaking.

7. Solicitation of Employees For a period of eighteen (18) months after termination of my employment
or cessation of my association with the Company for any reason whatsoever, I shall not, solicit or
cause or authorize directly or indirectly to be solicited for employment, or cause or authorize directly
or indirectly to be employed on my own behalf or on behalf of any Third Parties, any person who is
an employee of the Company. I also agree not to use or disclose to any Third Parties any information
obtained by myself while being an employee of the Company concerning the names and addresses of
the Company's past and present employees.

8. Solicitation of Customers. I agree that during the term of my employment or association with the
Company and for a period of eighteen (18) months thereafter, I shall not solicit or cause or authorize
directly or indirectly to be solicited, or accept or cause or authorize directly or indirectly to be accepted,
for or on behalf of myself or Third Parties, any business from any Third Parties who are, at any time
within eighteen (18) months prior to termination of my employment or cessation of my association,
customers or prospects of the Company.

9. Solicitation of Business Partners. I agree that during the term of my employment or association with
the Company and for a period of eighteen (18) months thereafter, I shall not solicit or authorize directly
or indirectly to be solicited for or on behalf of myself or any Third Parties any of the Principals,
Distributors, Agents, Re-sellers, Joint Venture Partners, Dealers, any major Suppliers or any business
partners of the Company, who have at any time within eighteen (18) months prior to the termination
of my employment or cessation of my association have a relationship with the Company, to
disassociate or modify their relationship with the Company to my benefit or to the benefit of any
Third Parties. This shall include any of the parties with whom the Company made substantial progress
in negotiating any relationship in the nature described above.

10. Representations. I agree to execute any proper oath or verify any proper document required to carry
out the terms of this Agreement. I represent that my performance of all the terms of this Agreement
will not breach any agreement to keep in confidence proprietary information acquired by me in
confidence or in trust prior to my employment or association with the Company. I have not entered
into, and I agree I will not enter into, any oral or written agreement in conflict herewith.

11. General Provisions.

a. Governing Law: Consent to Personal Jurisdiction. The laws of the Republic of India shall govern
this Agreement. I hereby expressly consent to the jurisdiction of such competent courts in India
for any lawsuit filed there against me by the Company arising from or relating to this Agreement.

Employee Signature*: _________________________________

17
 b. Entire Agreement This Agreement and my employment agreement with the Company set forth the
entire agreement and understanding between the Company and me relating to the subject matter
herein and merge all prior agreements and discussions between us. No modification of or
amendment to this Agreement, nor any waiver of any rights under this agreement, will be effective
unless in writing signed by the party to be charged. Any subsequent change or changes in my
duties, salary or compensation will not affect the validity or scope of this Agreement.

c. Severe ability. If one or more of the provisions in this Agreement are deemed void by law, then
the remaining provisions will continue in full force and effect.

Dated: _________________
__________________________

__________________________

Witness Name*: _______________________

Witness Signature*: _______________________

18
 EXHIBIT A

LIST OF PRIOR INVENTIONS AND ORIGINAL WORKS OF AUTHORSHIP

Title Date Identifying Number or Brief

Description

_________________________ No. of inventions or improvements

_________________________ Additional Sheets attached

Employee *: ___________________________________

Name of Employee: ___________________________________

Date: ___________________________________

19
 EXHIBIT B

The following are the activities, as applicable, the Employee has agreed not to do after the termination of
his employment or cessation of his association with the Company. These are not exhaustive in nature and
are in addition to the obligations he has already undertaken in the Agreement:

1. Shall not during the term of his employment or association with the Company and for a period of
eighteen (18) months thereafter, solicit or cause or authorize directly or indirectly to be solicited,
or accept or cause or authorize directly or indirectly to be accepted, for or on behalf of himself or
any Third Parties any project on which he had worked for any customer(s) of the Company in a
period of eighteen (18) months prior to the termination of his employment or cessation of his
association with the Company. He shall also not work on any project(s) similar to any project(s),
he is or was working for any customer(s) of the Company for a period of eighteen (18) months
prior to the termination of his employment or cessation of his association with the Company, for
any competitor(s) of the said customer(s) of the Company during the term of his employment or
association with the Company and for a period of eighteen (18) months thereafter.

2. Cannot make use of any exclusive project related technology applied by the Company and about,
which he came to know during his employment or association with the Company.

3. Cannot work on similar project(s), for and on behalf of any Third Parties, which he is or was
working on for a period of eighteen (18) months prior to the termination of his employment or
cessation of his association with the Company, using non-generic (specific methodology,
techniques etc.) skills acquired during his employment or association with the Company.

4. Cannot use or divulge any proprietary or confidential tool, technology, methods, processes, project
methodology of the Company as well as that of any of the clients or customers of the Company
for which he worked or came into contact during his employment or association with the Company.

5. Cannot prospect with customers visited as the Company sales employee for a period up to 18
months from cessation of service. Cannot also make sales calls to any prospect in the concerned
region of the geography of the Company for a period of 18 months from cessation of service.

6. Cannot join the sales department of such Third Parties who are or were customers of the Company
for eighteen (18) months prior from the date of the termination of his employment or cessation of
his association with the Company and with which he was dealing with directly as the contact
person for the Company.

7. Cannot divulge to any Third Parties about the sales revenues of the Company from its customers
in India or any place outside India where he was posted by the Company in the last eighteen (18)
months prior to the termination of his employment or cessation of his association with the
Company or the sales revenue of any other territory if he came to know about the same because of
his employment or association with the Company.

Employee Signature*: _________________________________

20
 8. Cannot divulge or use or share with any Third Parties the sales and marketing strategy and
competition, sales plans, account plans, strategies, documents and presentations and any related
information about the Company, which are in the nature of proprietary information of the
Company and, which he came to know about because of his employment or association with the
Company, for his own benefit or for the benefit of any Third Parties for eighteen (18) months prior
to the termination of his employment or cessation of his association with the Company.

Cannot divulge or use, utilize, divulge or share with any Third Parties any information, facts, information,
documents and any related information about the Company, which are in the nature of proprietary
information of the Company or otherwise and, which he came to know about because of his employment
or association with the Company, for his own benefit or for the benefit of any Third Parties for eighteen
(18) months prior to the termination of his employment or cessation of his association with the Company.

Employee Signature*: _____________________

Date: _____________________

21
 Information Security Policy

Policy Statement Employee Name: ____________________

confidentiality, integrity and continuous availability of information systems under its

governance.
Purpose

infrastructure. This includes information assets critical to the operation of the business, external
information i.e. Information assets belonging to customers, suppliers and business partners in
the operation of

The implementation of this policy is a testimony of

continual commitment to maintain and improve the organisatio
confidence to business partners in the conduct of business with
It is the policy of

- To preserve Confidentiality
That is to protect Information Assets against unauthorized disclosure.
- To maintain Integrity
That is to protect Information Assets from unauthorised or accidental modification ensuring the

- To ensure Availability
That is, ensure that Information Assets are available as and when required adhering to the
from destruction that is,
ensuring to the maximum extent possible that Information Assets are available upon extreme
disasters.

Scope
The policy extends to all functions and activities of the company. All Information assets belonging to the
atives,
suppliers, service providers and their personnel are part of the Scope.

Goals
To identify through appropriate risk assessment, the degree of protection of information assets, the
preparedness against threats, to understand their vulnerabilities and the threats that may expose them to
risk.

To manage and minimise the risks to an acceptable level through the design, implementation and
maintenance of a formal Information Security Management System (ISMS)

Employee Signature*: _________________________________

22
To comply with Legislation including:

1. IT Act, India 2000

2. To comply with Contractual conditions that lay down the requirements for information security
3. Commitment to be in compliance with ISMS
practices such as BS7799-2: 2002 or ISO 27001
4. Commitment to achieve and maintain certification of
5. Commitment to achieve continual improvement in Controls implemented with adhering to the best
practices as per ISMS identified standards and/or
vendor standards/practices wherever applicable.
Methodology
A systematic - Do - Check -
Information Security Management Systems.
Specific policies / practices exist to support the methodology, they include mandatory requirements to
ISMS practices, and a combination of policies both at the corporate level and centre level policies, some
of which are referred (not exhaustive):

1. HR Manual
2. Quality Manual
3. Administration Manual
4. Non Disclosure Agreement with all employees & business partners
5. IT Manual (Computer Usage Policy, Access Control Policy, Configuration Policy)
6. Incident Management and Reporting System (All these should be in place and uploaded on the
intranet).

Responsibilities

The Steering Committee creates and reviews this policy.

The Information Security Manager facilitates the implementation of this policy through the appropriate
policies and practices. The Information Security Manager is assisted by the Implementation Team to carry
out activities related to ISMS and the Audit Team to ensure compliance.

The BCP Manager formulates and facilitates the implementation of the BCP through appropriate tests and
drills, supported by representatives from Operations, Information Technology (System Administration),
and Administration departments.

The constitution of the Steering Committee, Implementation team and Audit team is represented by all
the organisational processes / functions / divisions and is enlisted in an Addendum

IT team responds to security incidents related to IT and maintains system and network operations and
communication. Team controls access to networks, systems and applications and strictly adhere to
security policy as they are provided with high privileges.

Every individual has responsibility to comply with the security policy and procedures that are defined as
part of Information Security Management System.

Employee Signature*: _________________________________

23
 Disciplinary Action

Any deliberate attempt to jeopardise the information assets or the supporting infrastructure will be subject
to disciplinary action.

Summary

All the members of are responsible for maintaining a

work environment that promotes respect for all the people. Standards are created not to restrict the
freedom or productivity of any individual, but to protect the many privileges enjoyed by the members.
Services is responsible for securing its network and
computing system in a reasonable and economically feasible degree against unauthorized access and/or
abuse, while making them accessible for authorized and legitimate users. This responsibility includes
informing users of expected standards of conduct and the punitive measures for not adhering to them.
Any attempt to violate the provisions will result in disciplinary action in the form of temporary
revocation of users account, regardless of the success or failure of the attempt.
Permanent revocation can result from disciplinary actions taken by panel judiciary board called upon to
investigate network abuses. The users of the network are responsible for respecting and adhering to
national and international laws. Any attempt to break those laws through the use of the network may
result in litigation against the offender by the proper authorities. If such an event occurs,
Services will fully comply with the authorities to provide any
information necessary for the litigation process.

Some of the Information security policies are as follows:-

General Computing Policy

Once a user receives a user ID to be used to access the network and computer systems on that
network, they are solely responsible for all actions taken while using that user ID. Therefore:
i. Sharing your user ID with any other person is prohibited. In a result that you do share ID with
other person, you will be solely responsible for the actions that the other person appropriates.
ii. Deletion, examination, copying, or modification of files and/or date belonging to other users
without their prior consent is prohibited.
iii. Attempts to evade or change resources quota are prohibited.
iv. Continued impedance of other users through mass consumption of system resources, after receipt
of a request to cease such activity, is prohibited.
v. Use of facilities and/or services for personal communication purposes is prohibited.
vi. Any unauthorized, deliberate action, which damages or disrupts a computing system, alters its
normal performance, or causes it to malfunction, is a violation regardless of system location or
time duration.
vii. Making copies of any software without authorization is prohibited.

Employee Signature*: _________________________________

24
 Network Security Policy

As a user of the network, you may be allowed to access other networks (and/or the company systems
attached to those networks). Therefore:
i. Use of system and/or networks in attempt to gain unauthorized access to remote system is
prohibited.
ii. Use of system and/or networks to connect to other system, in evasion of the physical limitations
of the remote system/local, is prohibited.
iii. Decryption of system or users passwords is prohibited.
iv. The copying of system files is prohibited.
v. The copying of copyrighted materials, such as third-party software, without the express written
permission of the owner or the proper license is prohibited.
vi.
vii. Any attempt to acquire a higher level of privilege on Network systems is punishable disciplinary
offenses.
viii.
organization network or into external networks is prohibited.
ix. To bring in external software and loading it onto organization network, without proper approval is
prohibited.
x. Deliberate misuse of any communication equipments is a punishable offense. This includes and is
not limited to the use of voicemail, email, and photocopiers, fax machines and headsets.

Internet Usage Policy

Whenever you access Internet, your user ID is logged in the proxy server of
You are responsible for all transmission and access requests
originating from your user ID. Therefore:

i. Using internet access provided through for

personal commercial gain and recreation (such as game playing and sports) is prohibited.
ii. Transmission of confidential information outside or inside of
Services to unauthorized personnel is prohibited.
iii. Inappropriate and unprofessional behavior on-line such as use of threats, intimidations or

iv. Sending jokes, cartoons, images that may be offending/ sensitive to a particular religion/sect/faith
is strictly prohibited and may even result in termination.
v. Viewing, downloading or transmission of pornographic material is a punishable disciplinary
offense.
vi. Consumption of internet resources for non-business related activities (such as video, audio or down
loading large files) is not approved.
vii.
an employee visits and keep a record of any network activity in which an employee transmits or
receives any kind of file.

Employee Signature*: _________________________________

25
Electronic Mail Policy

All messages generated on or handled by electronic communication systems, including back-up copies,
are considered to be the property of Services, which
should be used for official purposes. Following aspects are covered in the email policy:
i. Only employees and other persons duly authorized by the appropriate
Services authority will be permitted to use
Services electronic mail systems and resources.
ii. The use of electronic mail system must be
related to business needs.
iii. All authorized users will be provided with a unique user-identification (user-id.). The system
admin at all centers and offices will administer the e-mail system with appropriate settings of the
mailbox size, maximum size of out-going attachment etc.
iv. All Emails between the Services center passes
through the private network or VPN, the mails between
v. servers are secured.
For management purposes, company security software may scan and record all mails that an
employee can send or receive.

Read the policy carefully and confirm that you have read and understood the policy and will abide by
the policy.

Employee Signature*: _________________________________

26
 Declaration

I, _______________________________, S/o, W/o, D/o _________________________________

resident of ____________________________________________________________________, do
hereby solemnly affirm and declare as under:

1. I have read and understood the Policy Statement of the Information Security Management;

2. I have read and understood the Information Security Policies of

Services such as email policy, Internet usage policy and network usage
policy and general computing policy.
3. I agree to abide with all the requirements of the Policy Statement;

4. I agree to keep the Information assets confidential and to protect them against unauthorized
disclosure;

5. I agree to protect Information Assets from unauthorised or accidental modification ensuring the
;

6. I will comply with all the applicable legislations including the IT Act India 2000, Contractual
conditions that lay down the requirements for information security,
ISMS practices and other followed practices;

7. I agree not to make any deliberate attempt to destroy or damage any Iinformation Assets or the
supporting infrastructure.

*..................................

Date...................................

Note: To refer more on security policy and learn about

Security, log on to
https://bserv.myhcl.com

and click on Corporate Information Security link

User Name : Employee Code

Password: Access your given Personal Email Account to get the Password from BAG
Support Team

28
 INDUCTION PACKET SAM CLAUSE

I agree to abide by all terms and conditions listed in the Software Asset Management (SAM) Policy at all
times. I will ensure that software will be installed on my machine only after I have received the requisite
approvals for the same. I also agree to keep track of the software inventory on my machine(s), and to take
necessary corrective actions if any installation is not in accordance with the SAM Policy. I further agree
that the company will not accept any liability in respect of any unauthorized use of software and I shall be
personally liable for any damages or other liability arising on account of violation of SAM policy.

Signature: Employee Name: _____________

Date: ___________ Employee Code:______________

27
 HCL TECHNOLOGIES LTD BUSINESS SERVICES

MEDICAL SELF DECLARATION

Name
Date Of Birth Your
Photograph
Contact No
Blood Group (Self Attested)
Height in cm/inch
Weight in Kg

Part 2: General Medical history-

Are you in good health and free from physical and mental disease or infirmity or medical
complaints? If no, give full details.

Can you do your regular work without any limitation? If no, give full details.

Have you ever taken narcotics or other habit forming drugs or been treated or advised in connection
with your alcohol consumption or taking of drugs? If yes, give details including month / year of
quitting if applicable.

Are you advised any special treatment? If so, please give information

Have you ever availed long leave on medical grounds in the last two years? If yes, specify the
purpose and details of medical problem

Any Plans for going on leave in coming 1 year for any medical treatment, surgery, Maternity etc. If
yes, pls give details

HCL Technologies Limited. 29

 HCL TECHNOLOGIES LTD BUSINESS SERVICES

MEDICAL SELF DECLARATION

Part 3: Specific Details

Have you ever been treated or currently under treatment for any of the following conditions? Give details

Yes/No Details incase of

Any diseases and disorders of eye, ear, nose, and throat?

Any diseases and disorders of the nervous system or

neurological system such as epilepsy, brain diseases,
migraine etc.?
Any diseases and disorders of the respiratory system such
as tuberculosis, asthma, frequent nose bleeding etc.?
Any diseases and disorders of the Cardiovascular system
such as chest pain, heart disease, high blood pressure etc.?
Any diseases and disorders of the digestive system such as
ulcers , hernia, piles, stone in gall bladder etc.
Any diseases and disorders related to genital organs,
kidney or urinary system?
Any diseases and disorders of the metabolic and endocrine
system such as diabetes, thyroid etc.?
Any cancer, tumor, cyst or any other unusual growth

Have you ever been tested for or advised to test for HIV
infection or suspected to be HIV positive?

I do hereby declare that the foregoing statements and answers have been given by me after fully
understanding the questions and the same are true and complete in every respect and that I have not
withheld or misrepresented any information or facts.
I do hereby agree and declare that these statements and this declaration shall be the basis of my
employment with .

Employee Signature:
Place:

Date:

30
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 Strengthening
Our Foundation Dedicated
to Risk
Excellence

Committed
to Ethical
Conduct

Standard of Conduct
2017
Our Business
is Built
on Trust
Ourbusinessis built on trust.As a partner tothe world’s
leading institutions, we constantly must earn that trust by
holdingourselvestothehighestpossiblestandardsand
challengingourselvesand one anothertomakesound
decisions. Our stakeholders expect us to serve them fairly
andactappropriatelyinallthatwe do,anddoingsoisan
essentialelementofourcommitmenttothehighest
standards of integrity and risk excellence.

Each one of us — irrespective of our roles or responsibili-

ties—playsanimportantpartinprotectingStateStreet’s
reputation. Our Standard of Conduct provides a strong
foundation to help us make ethical decisions and avoid con-
flicts ofinterest. I encourageyou tocarefullyreviewthis
document and understand how State Street’s standards and
expectationsapplytoyourwork.Ialsoaskthatyouspeak
upifyouhavequestions,concerns,orifyouseebehaviors
that are in conflict with these principles and rules.

Thank you.

JAY HOOLEY
Chairman and Chief Executive Officer
Thisdocumentismorethanapolicydocument;itisalso
astatementofoursharedvaluesandresponsibilitiesto
each other, to our clients and to State Street. These values
supportourmissionasan organization,whichisdriven
by the needs of ourclients more than by the laws and
regulations that set the guidelines for many of our rules.

Whether our clients are asset owners or asset managers,

theyultimatelyrepresenttheneedsandinterestsof
investors, many of whom are people saving for the future,
oftenfortheirownretirement.Itisthroughthislensthat
weviewtheprinciplesbehindourrules.Theseprinciples
includelong-termprotectionofthemarketsinwhichwe
participate, the promotion of transparency so people can
makethebestchoices,andthebeliefthatthebestthing
forourclientsis also thebest thingforStateStreet.
This is why our Standard of Conduct devotes considerable
attention to discussing principles, not just rules. The more
we understand the principles behind our rules, the better
ableweallwillbeinapplyingthemtoanygivensituation.

ANTHONY O’REILLY
Chief Ethics Officer
 This policy — the Standard of Conduct — applies to you

Who is if you are a full-time employee or part-time employee

at State Street (meaning, State Street Corporation and

Subject to its subsidiaries).

If you have oversight of a contingent worker, or of an

This Policy? employee of a joint venture which we do not control as a

subsidiary, State Street expects you to escalate and report
conduct and activities which are not consistent with the
spirit of this Standard of Conduct.

Some sections of this policy briefly summarize and put

youonnoticeregardingother corporatepoliciesand
procedures. These are not discussed in their full detail in
this document and the policies themselves may feature
additionalguidance. Compliance with these policies is a
requirement of this Standard of Conduct.

In addition, other business-unit-specific policies apply to

employees based upon their department, role and location.
You are responsible for being aware of, understanding, and
following all policies that apply to you.

Should you require clarification about the interrelationships

betweenourpolicies,contactyourLegalorCompliance
representative, or the Ethics Office.
Contents
8 THE CORE CONCEPTS OF ETHICS
8 No Trust, No Business
9 How Ethical Thinking Can Make Some Decisions a Lot Easier
10 The Power of Consultation
10 Client, Company, You
10 Our Role in the Larger Community
11 In Letter and in Spirit
13 Speaking Up
14 Ethics and its Rules

16 RULES FOR ETHICAL CONDUCT

18 Use of State Street Property and Systems
19 Handling Information
Maintaining Confidentiality
Maintaining Information Security
24 State Street Colleagues
Personal Interactions
24 Criminal Activity
Money Laundering
Bribery and Corruption
Fraud
27 Business Gifts and Entertainment
28 Other Outside Parties
Competitors
Regulators and Law Enforcement Officials
The Media
29 Personal Life
ConflictsofInterest
OutsideActivities
Using Social Media and Public Forums
Personal Trading in Securities
Political Activities and Contributions
Lobbying
34 Transitions
Joining State Street
Changing Jobs Within State Street
Leaving State Street
35 Recordkeeping
Accuracy and Completeness
Record Retention and Document Destruction Policies
36 Speaking Up
Guidance on Speaking Up
37 Administration
 The Core Concepts
of Ethics
No Trust, No Business
At State Street, our business is
dependent upon our being a trusted
partner. That is not a small point. Trust
is a keypart of our business model.
Trustisanimportantreason ourclients
are here. If a client wereever to feel
that we were not doing everything we
should to honorthattrust, that may be
reason enough for them to take their
business elsewhere.
In short, trust not only matters, it
is essential.
Trust has many dimensions. Trust
means that a client has confidence that
we willdo good quality work and do
businessfairly.Whether weareacting
as agent, managing client assets, or
serving as a trustee or custodian, our
reputation for being trustworthy is a
key reason we have been chosen for
the role.
Our actions either build or destroy
trust. When current and prospective
clients look at us — regulators,
8 • STATE STREET STANDARD OF CONDUCT 2017
counterparties, and the media too,
for that matter — this is one of the
main things they are looking at.
In particular, they pay close attention
to how we behave when faced with
difficult decisions.
Individual actions, shared impact.
Weare proud of ourreputationas a
trusted business partner. But the
reputation of any group comes from the
actions of many individual employees.
So our reputation as a whole is built up
through the individual contributions of
eachemployee.Thisisonereasonwhy
taking input from others helps to build
and maintaintrust.
This is also why we make such a point
of personal responsibility and personal
ethics. It takes every one of us to
create and maintain our reputation.
When everyone pulls together, we all
win. But when even afew do not do
theirpart,wealllose.Thecompany
loses, and so does every individual that
works here — even those who worked
hard to maintain our standards.
 How Ethical Thinking Can Make
Some Decisions a Lot Easier
All of us face tough decisions in the
course of doing our jobs. But with
ethical decision-making, many
situations can be much easier —
because it makes the right choice
clearer. As the diagram below shows,
ethical decision-making involves asking
yourself five key questions, and taking
action accordingly:

If challenged publicly, would I be

comfortable sharing details?

Is it fair and honest?

FIRST AND ALWAYS
ACKNOWLEDGE... What would happen if CONSIDER...
When faced everybody did it? Have I encouraged
with a decision, professional
ask yourself: Does this put long-term relationships challenge?
at risk for short-term gain?

Is it lawful and within the letter

and spirit of our policies?

NOT COMFORTABLE? NOT SURE? COMFORTABLE?

STOP. Escalate Consult with a business, Proceed with confidence
and involve others functional, and/or technical and document your
as appropriate. specialist, as appropriate. decision for transparency.

9 • STATE STREET STANDARD OF CONDUCT 2017

 This framework can be used to test
a decision or concern.Ithelpsus
consider a problem from different
angles and not reach a result that is
merely legally permissible or only with
short-term benefits. If a potential
course of action appears tofail one
or more of the questions above, this
should be an indication to escalate or
to invite others into a consultation.
Ethical thinking is consistent with the
State Street Values that form such an
important part of our culture.
• Always Finding Better Ways
• Stronger Together
• Global Force, Local Citizen
Consulting The Power of Consultation
With our different business lines and
makesus servicelevels,itcanoftenbedifficultto
“Stronger know what is the most appropriate way
Together” to deliver the services that clients have
chosen, while also managing conflicts
of interest. When we identify a potential
conflictwithaclientordifferencesin
approach among different business
units servicing a client, discussing
these issues with senior management
or functional specialists in your
businesscanhelpprovideabroader
perspectiveand may allow us to avoid
(or appropriately address) any conflicts.
Consulting makes us “Stronger
Together” and helps us stay aligned
with our ethical principles and rules.
Youwill find many other situations in
your day-to-day business interactions
where remembering State Street’s
values will lead to the right result for
us and our clients.
10 • STATE STREET STANDARD OF CONDUCT 2017
Client, Company, You
As a company, we expect you to treat
clients fairly in the context of the
services that we provide. In some roles,
wemaybeobligatedtoputaclient’s
interests ahead of the company’s or our
personal interests. As an employee, it
is your responsibility to keep personal
financial interests from interfering with
client interests. In practice, this means
that at State Street, as at any ethical
organization, employees must in
certain situations pass up opportunities
that provide personal gain.
What we give up and what we gain.
Why do we place a much higher bar
for acceptable conduct than in most
other companies? It is because of
theimportanceoftrust.Whiletrust
matters to any business, our
relationship with our clients and their
trust inus is criticaltoour success.
You should not have any expectation
of privacy for any communications —
business-related or personal — that
are stored or transmitted using
our systems.
What we gain is the trust of our
clients,ourbusinesspartnersandour
colleagues to build the relationships
we have.
OurRoleintheLargerCommunity
At State Street, the concept of
“community” has both corporate and
personal dimensions. Forinstance,
in the workplace, we ask that every
employeetreat othersfairlyand
respectfully, promote a positive and
diverse workplace, be a team player,
Is ethics fosterasafeworkenvironment,and
conduct themselves professionally in
about com- all ways at all times.
plying with However, these values are not
the rules, something to leave behind when you
leavethe office. Youwillbe seen as a
or is it about representative of State Street and its
understand- cultureand values. As a result, your
conduct outside of State Street could
ing and have an impact on your employment.
honoring In addition, people outside of the
the spirit company routinely expect that our
upon which employees will manage their personal
finances in a responsible manner,
the rules andmayregardanyfailuretodoso
arebased? as reason to question our claims of
financial expertise and trustworthiness.
That’swhyStateStreetencourages
all employees to follow sound
principles in managing their personal
and familyfinances.
What we believe, and invite you
to as well. At the corporate level,
StateStreet is deeply investedin
giving back to the community. This
isreflected inouractions (orfailures
to act), not just our words.
We have programs aimed at
sustainability, volunteerism, socially
responsible investing, and global
inclusion. We are also proud to make
available many opportunities for
employees to contribute personally.
This is an example of what we mean by
the value, “Global Force, Local Citizen.”
11 • STATE STREET STANDARD OF CONDUCT 2017
In Letter and in Spirit
The question is oftenasked: Is ethics
aboutcomplyingwiththe rules,oris it
about understanding and honoring the
spirit upon which therules are based?
The answer is that both are essential
and are equally important. If you are
not honoring both, you are really not
honoring eitherone.
Let’s say you find yourself in a situation
where a compliance rule applies.
You believe you understand the purpose
of the rule, and you believe cutting a
small administrativecornerwould not
violate that purpose. Would your action
constitute a violation? In this case,
it would. Please note that all rule
violations must be reported, whether
ornotweperceivetheviolationto
be material.
Whenwefailtocomplywiththeletter
of our rules, it calls into question how
serious we are about their spirit and
purpose. Additionally, you may not
correctly understand the purpose of
a rule, or its broader context.
By the same token, it is possible to
meet the basic standards of a rule
andstillnotbemeetingitspurpose.
For instance, if you know that a vendor
or government official may be willing
tobeimproperlyinfluencedbygiftsor
entertainment that are within policy
limits, it is absolutely unacceptable
to offer the gifts or entertainment.
 How can you know when you are on
solid ground and when you are not?
The answer involves these principles:
• Learn to recognize conflicts
ofinterestandsituations
where they arise.
• Always check the policy first.
If something is still unclear, it is
always better to ask than to assume.
There are no stupid questions.
• Always ask yourself the five
questions in the diagram on page 9.
No set of rules can cover every
situation. Thatiswhyethical
decision-making almost always
involves good judgment.
Developing and using good judgment
is something every employee should
striveto do. The cleareryour senseof
judgment, the more readily you will
understand the policy, the better you
will be at asking yourself and others
the right questions, and the less likely
you will be to inadvertently do
something wrong.
12 • STATE STREET STANDARD OF CONDUCT 2017
Acting lawfully and with integrity.
Many of the rules in this policy reflect
lawsorregulations.Thus,insome
cases, violating a policy could lead
not onlytopenalties, including in
somecases immediatetermination
of employment,butalsotocivilor
criminal prosecution.
For these reasons, it is important that
you comply with all applicable laws and
regulations, conduct yourself with
integrity, never make false statements
orfalsify records, and avoid actions or
activities that represent a violation of
our conflict of interest policies.
However,inmanycasesourethical
rules require application of more
rigorous standards than applicable
laws and regulations. In all cases, it is
important that you follow the standards
describedinthis policy,whetherornot
applicablelaws orregulationspermita
lower standard.
Failing Speaking Up necessarily protect you from penalties,
it is a mitigating factor, and usually
tosay Every one of us has felt the urge to
speak up when we know something is
results in lesser penalties for all but
something wrong. We also know the hesitation that
the most serious violations. In contrast,
if it later emerges that an employee
is nearly can accompany that urge. It is natural
to feel that way. And yet, particularly
knew about a violation but did not
always in the world of corporate ethics, failing
report it, that can be an aggravating
factor when considering any discipline.
a poor tosaysomethingisnearlyalwaysa
poor decision. Unlawful retaliation in any of its forms
decision. is never acceptable. State Street does
Why it is always right to speak up.
not tolerate retaliation against anyone
Reportinganissueoraskingaquestion
who reports a potentialviolation in
sooner rather than later protects
good faith. Unlawful retaliation includes
State Street and often allows an issue
negative job consequences against any
toberesolved more quickly and with
employee or contingent worker for
fewer repercussions.Italsogives
acting upon areasonable belief to:
our legal, compliance, and ethics
professionals the opportunity to fully
• Reportapotentialviolation of
review your question, concern, or
company policy or applicable law
report, and to determine what action, if
any, is appropriate. In addition, prompt • Participate or cooperate in any
reporting of any actual, attempted or internal or external investigation
suspected violation of State Street
Be aware that negative job
policy is an expectation. If an employee
consequences are not limited to
knows of a violation and fails to
formalmatters such as missed promo-
report it, that in itself is a violation.
tionopportunitiesorinappropriate
For managers, this means that when
end-of-year ratings. Job consequences
youbecomeawareofanissuerelating
may also involve exclusion from
toanemployeeorcontingentworker,
meetings and events or creating
you must address, escalate and report
a hostile work environment.
as necessary.
Anyone who retaliates against an
As for self-reporting — we are all
individual who has reported a good faith
human and we all can make
concern will themselves be subject to
mistakes. What matters is that we take
disciplinary action.
responsibility for our actions. While
itistruethat self-reporting willnot

13 • STATE STREET STANDARD OF CONDUCT 2017

ALSO
SEE
Equal Employment Opportunity
Manager Responsibilities
• Remain vigilant for any signs of
discrimination involving employees in
your group. Reportany actual or suspected
instances to Human Resources.
• Maintain an “open door policy” toward any
employee who asks to discuss workplace or
employment issues.
• Becertainyouareadequatelyfamiliarwith
the Equal Employment Opportunity Policy and
all other applicable employment laws and
policies — local, regional, and global. Take all
reasonable stepstoensure that yourhiring
and management practices do notviolate any
of these laws or policies.
State Street Responsibilities
Human Resources or its designee(s) must
promptly investigate all reports of actual
or possible violations of inclusion- and
discrimination-related rules and must take
appropriate enforcement action.
Non-CompliancewithStandardsandProcedures
Wetake compliance with our standards and
procedures seriously and have prescribed
processesforenforcing these, includingthe
Global Compliance Enforcement Procedure,
which describes enforcement actions that
may be taken for violations of the Standard of
Conduct and related policies, and mitigating
and aggravating factors that may be taken into
account in imposing any disciplinary action.
14 • STATE STREET STANDARD OF CONDUCT 2017
Truth or consequences. Someactions
carry such a highlevel ofriskto our
reputation that they can be, by
themselves, grounds for dismissal.
These include:
• Interfering with or intentionally
misleading an internal or
external investigation or audit
• Knowingly making false statements
to a client or regulator
• Knowingly making false statements
to another person at State Street
with knowledge that they are
likely to use the information in
makingabusinessdecision
• Retaliation against anyone who
has made a good-faith report of
known or possible misconduct
Ethics and its Rules
The rules in the second section of this
document (and other State Street
Compliance and Ethics policies) are
based on the ethical principles
described in this first section. It is
importanttounderstandboththe
principles and the rules, and how
they interact.
These rules are intended to ensure that
ethical behavior occurs, and they allow
us to demonstrate this fact in dealings
with clients, regulators, and others.
As a State Street employee, you are
responsible for being familiar with, and
adheringto, this Standard of Conduct
(including the ethical principles
articulated inthis firstsection),andall
 other State Street policies to which you
are subject. Complying with the rules is
a key element of Risk Excellence and is
important — even in seemingly minor
obligations, like submitting required
reports and certifications on time.
Your employee responsibilities also
include following all applicable laws
and regulations.
Employees are expected to be alert to
situationsthat,whilenot aviolationof
State Street policy, may cause a
violation of a business partner’s
policies. Finally, your responsibilities
include cooperating fully with any
examination,investigation,orinquiry—
internal orexternal.
Ask Before
YouAct.
15 • STATE STREET STANDARD OF CONDUCT 2017
Four guiding principles to bear in mind.
Ethics and compliance can be
complicated. The following brief
principlescangoalongwaytoward
providing clear guidance:
• Ifyouareindoubtastowhether
a practice is appropriate,
ask before you act.
• Follow any specific guidance
or instructions from Ethics or
Compliance. If specific guidance or
instructionssupplementarule,
or if the action (or failure to act)
runs counterto the spirit of the rule,
guidance, or instructions, you must
follow themost recent guidance
or instructionavailable.
• Never do indirectly what you are
prohibitedfromdoingdirectly.
From a policy standpoint, an indirect
violation is the sameas a direct one.
• Whilepenaltiesforviolations can be
severe,itis usuallypossibletoavoid
them by following the rules and using
good judgment. Whenyou realize you
have made a mistake, come forward.
Self-reporting is an important
mitigating factor indetermining
the outcome of most violations.
 Rules for Ethical Conduct
Thisdocumentis thefoundationfor
allbusinessconductatStateStreet,at
allofourlocationsaroundtheworld.
We take all applicable laws, rules, and
regulationsseriouslyineverycountry
where we do business. We alsoexpect
our employees to conduct themselves
in a manner consistent with the highest
level of professional integrity.
That especially applies when diverging
from these standards might result in
a temporary benefit to State Street.
Weareinbusinessforthelongterm.
State Street expects that all employees
will comply with all applicablelaws and
16 • STATE STREET STANDARD OF CONDUCT 2017
regulations as well as our own
policies. Adhering to our standards is
not only consistent with sound ethical
business practices, butsupports the
long-term growth and prospects for
all of our businesses.
Some policies at State Street areso
important that we require you to
positively confirm that you have read
them, that you understand them,
and that you agree to abide by them.
This is one of those policies, and we ask
that you re-certify your understanding
and acceptance of this policy at
least annually.
 A Word to all State Street Managers
We are all custodians of State Street’s reputation,
butmanagers have a special responsibility when
it comes to setting the tone and reinforcing core
concepts for their team members — including
by reporting and escalating issues concerning
any contingentworkers under their oversight.
As amanager,anevaluation of yourperformance
includes the actions you take to create the right
culture at State Street.
We are all custodians of
StateStreet’sreputation.
State Street also relies on you to be the first line
of defense on all ethical matters. This includes
leading byexample, reinforcing theimportance
of ethical decision-making, encouraging open
dialogue and professional challenge, and providing
an environment where your team members ask
questions and raise potential issues. The way we
respond toquestions, concerns, andissues will
either reinforce or undermine these concepts,
and signal how we value input and feedback.
17 • STATE STREET STANDARD OF CONDUCT 2017
Managers should make sure they understand
the requirements of our policies, and make sure
their advice and actions reinforce those policies.
Responsibility for protecting our reputation and
culture lies with all managers. You are not excused
from that responsibility when the employee or
conduct in question falls outside your area of
direct responsibility.
You also have responsibilities arising from specific
itemsin this policy. Those items are called outin
boxessimilar tothisonewith the label“Manager
Responsibilities.” In some cases, you will also
see material labeled “Administration.” These are
responsibilities that Ethics, Legal, or Compliance
must handle. While they may not be your
responsibilities, it is helpful to be aware of them.
State Street Policies and Your Family
In some cases, State Street policies may require
you to report or to pre-clear certain political
activities, investment decisions, or work-related
gifts and entertainment relating to family members
such as a spouse or dependent. These policies
exist tohelp uscomplywith legal andregulatory
expectations. We ask that you take the time to
make sure you explain these requirements to
and enlist the support of related persons whose
activities are covered by these policies.
ALSO Use of State Street Property
SEE
and Systems
Corporate Information
Security Controls Manual Be thoughtful and careful with your use
of State Street resources. State Street
property and systems have varying
degrees of security and access
protection, depending on the type of
informationtheyhandle.Useofthe
internet and other open-information
assets is inherently risky, and
improperusecouldopenthedoorto
an information security breach and
reputationalharm. For example, the
information you disclose in public
spaces —suchasLinkedIn—could
be used for socialengineering and
targeted attacks against State Street’s
systems, and improper use could make
oursystemssusceptibletoviruses.
You should conduct yourself in a way
thatismindfuloftheserisksatalltimes.
Use State Street property and systems
in a manner consistent with our
business purposes and professional
standards. We encourage employees to
adopt high standards of professional
conductandcourtesy.Whenusing
State Street property and systems,
do not engage in activities that would
be inappropriate in a professional
workplace. For example, employees
should never send, forward, or indicate
their approval of emails with sexual,
derogatory,orinflammatorycontent
or implication,noruse State Street
equipment or systems to access sites
with such content, or sites about
gambling, video gaming, violence, or
hate speech activities. While limited
and incidental personal use of company
systems is not prohibited, any use
that interferes with the duties or
18 • STATE STREET STANDARD OF CONDUCT 2017
productivity of anyone at State Street
(includingyou),orthatresultsincosts
to State Street, is not permitted. Any
personal communications sent using
State Street equipment or networks
automatically become State Street
property and are subject to monitoring,
archiving,regulatory investigation, and
legal discovery.
Never use State Street property for
personal advantage. While incidental
use in a reasonable context is
allowed, certain uses are never permit-
ted. This includes using equipment,
research,supplies,facilities,orfunds,
for any of the following:
• Commercial purposes
unrelated to State Street
• Personal projects
• Political volunteering
• Personal charitable fundraising
• Excessive use
Never access State Street property
and systems without authorization.
Never permit or engage in any unau-
thorized access to, or interference with,
State Street property. This includes
sharing your system IDs and/or
passwords for any reason or interfering
withStateStreetcommunications.
Do not use personal technology for
State Street business. Do not use
personal computers, smartphones,
or other electronic equipment for
business purposes except as
specifically authorized. Do not upload,
copy, or write State Street information
to non-State Street equipment,
including storage and removable
storage devices andInternetsites or
 domains outsideoftheStateStreet
security perimeter, without permission.
Donotconnectyourpersonaldevices,
such as mobile phones and tablets, to
StateStreetdevices forusesuchas
charging or streaming. Hardware
and software assets must be procured
and installed through authorized
IT channels. Do not establish or
administer any Internet websites or
domains for State Street business
purposes without prior authorization
from Global Marketing and the
Chief Legal Officer, General Counsel,
or Chief Compliance Officer.
Ourclients, Be aware of and honor intellectual
property rights. All patents,
vendors and trademarks, trade secrets, business
employees processes, and copyrights owned by
StateStreetarevaluableassets.
entrust us It is your responsibility to take all
with their reasonable steps to protect these
valuable assets. You must not
confidential discloseStateStreet’stradesecrets,
information. confidential business processes or
other confidential information to
outsideparties,useitforyour own
purposes, or take it with you when you
leave State Street, and you may not
assertanyownershiprightsinany
of StateStreet’sintellectualproperty
or information.Thisextendstoany
intellectual property or information you
create while employed at State Street.
Separately, you must respect the
intellectual property andinformation
rights of any software firm, data
provider, client, or other entity from
whom we acquire intellectual property
or informationrights.Thisincludes
observing all limits to usage,
modificationandduplicationsetby
agreement orlaw.
19 • STATE STREET STANDARD OF CONDUCT 2017
Handling Information
At State Street our internal operations,
processes,technology, andservices
all generate or use confidential
information. We perform research,
discuss client needs, take orders, settle
transactions and record and report
positions and all of these activities
are based on confidential information.
You are therefore very likely to
encounter confidential information
while performing your role at
StateStreetandyoumaycomeacross
it accidentally as well as in performing
yourrole.Ourclients,vendors,and
employees entrust us with their
confidential information and we ask that
you always assume that information is
confidential and treat it as such unless
it is clearly indicated otherwise.
It is our responsibility to protect
confidential information against unin-
tentional, malicious, orunauthorized
disclosure, misuse, alteration, loss, or
damage. To do so, we must ensure that
all information is handled appropriately
at every stage of our access, use and
transmission ofit.
Proper handling involves proper
labeling, storage, anddisposal, as well
as vigilant use of information security
techniques and technology. Takecare
not to misuse or inadvertently compro-
mise any information. For example,
limit access to information to only those
State Street employees who reasonably
need the information in connection
with their State Street responsibilities.
Information technologies and security
threats tend to change frequently.
Part ofyourroleinprotectinginforma-
tion is also keeping up with policy and

ALSO
SEE
Confidentiality Policy, and
thePrivacyandPersonal
Data Security Policy
20 • STATE STREET STANDARD OF CONDUCT 2017
procedural changes relating to
information technology.
Maintaining Confidentiality
Keep confidential information
confidential. Do not disclose
confidential information, or discuss
confidential matters, with anyone who
doesnothavealegitimateneedto
knowtheinformation—including
State Street employees.
Be aware of what constitutes
confidential information.
Most confidential information at
StateStreet falls into one of the
following categories:
• Clientinformation—includesclient
holdings, trading activity, strategies,
and asset levels; and personal
information about clients, their
employees, or familymembers.
In many cases, the fact that an
entity or individual is a client of
State Street is itself confidential.
• Third-party information
— includes information on third-
party technology, employees, or
relationships, and information
acquiredfromthesesources.
Information about vendors is an
example of third-party information.
• Sensitive or proprietary information
— includes State Street business
strategies and processes,
technologies, ideas, clients, and
transactions or financial results
thathavenot beenmadepublic.
• Personal information — includes
information on State Street
employees, contingent workers,
and joint-venture employees.
For example, their financial,
background, medical, or job
performance information.
Treat all audit, investigation, and
examination information as confidential
information, in particular Confidential
Supervisory Information. Information
associated with any audit, examination,
or investigation — including the
existence of the activity itself — is
highly sensitive. In the case of confiden-
tial supervisory information, any
disclosure is not only a violation of
policy but of law.
Confidential supervisory information,
whether from banking regulators in
the United States or other regulators
worldwide,is defined broadly.It includes
anyinformation,exchanges,orrequests
— whether written or verbal — that are
associated with regulatory supervision,
communications, or interactions
specific toStateStreet, or provided
to State Street by its regulators.
This extends to any non-public
enforcement actions or other outcomes
or events related to regulatory activity.
Do not disclose or discuss these
confidential matters with employees
who do not have a need to know.
In addition, do not disclose or discuss
these confidential matters with anyone
externaltoStateStreet,including
contingent workers, clients and
consultants, without prior approval
oftheChiefLegalOfficer, General
Counsel, or Chief Compliance Officer.
 Do not circulate emails, memoranda, or
presentations that contain confidential
information to any person who does not
have a need to know the information.
Treat all personal information as
confidential information. This includes
information about any individual,
whether associated with a client,
vendor, or State Street. Use such
informationsolelyforthepurpose
for which it was gathered and limit
access to it accordingly, distribute only
to those who need to see it for that
purpose,andkeepitonlyaslongas
youneedit(oraslongasnecessary
to satisfy investigatory and litigation
requirements, regulation or contract).
Respect individual rightstopersonal
information. Individuals in some
jurisdictions have a right to know
whentheirpersonalinformationis
being processed. They may be allowed
tocorrect or removeinaccuracies,
and request a stop to information
processing. If individuals exercise these
rights to privacy and data protection,
you must seek guidance from the
Privacy Office.
Never use any type of confidential
information for personal gain or benefit,
suchaspersonaltrading. Thisincludes
notusinginformationforthegainor
benefit of a friend, family member, or
any other third party.
Never disclose any State Street
informationto anyone who doesnot
have a legitimate need to know.
This includes family members, friends,
acquaintances,clients,vendors,and
21 • STATE STREET STANDARD OF CONDUCT 2017
industry colleagues. It also includes
any State Street employee or
contingent worker who does not need
the information to do their job. Disclose
confidential information to persons
outside State Street only with specific
authorization and in compliance with all
applicable requirements andmeasures
to preserve confidentiality. State Street
recognizes that certain disclosures of
confidential information to appropriate
government and self-regulatory
authorities are protected by “whistle-
blower” and other laws. Nothing in
this Standard of Conduct or any
employment-related arrangements are
intendedtoorshouldbeunderstoodto
prohibit or otherwise discourage such
disclosures.StateStreetwillnottoler-
ate any discipline or other retaliation
against employees who properly make
such legallyprotecteddisclosures.
Learn to spot material non-public
information. Material non-public infor-
mation(MNPI)isatype ofconfidential
information about State Street, another
company, or an investment fund, that
a reasonable investor would consider
important when deciding to buy or sell
a security. This includes information
that would be reasonably likely to affect
the market price of a security, but
whichhasnotbeenwidelydissemi-
nated to the public. Examples of MNPI
include, among other things, actual
or projected financial results, mergers
and acquisitions, significant new
product announcements, resolution of
significantlitigation, stocksplits,and
management changes.
 Treat material non-public information
appropriately. Befamiliar withany
MNPIpoliciesorprocedureswithin
your business unit. Generally, you
should not seek to obtain MNPI from
a third party or inappropriately
disclose MNPI to anyone, including a
State Street executive, who does not
have a legitimate need to know that
information.Youshouldnevertrade
for yourself, State Street or for a
client based on any MNPI you
encounter during your employment at
State Street. If you suspect you have
received MNPI, and you are not aware
of an MNPI policy or procedure in your
business unit, you should contact the
Ethics Office as soon as possible and
await further instructions.
Manager Responsibilities
You must be aware of information security
controls, and ensure they are implemented within
your area of responsibility, to the extent required
by our policies. In addition, you should:
• Review information access privileges for each
direct report at least once a year
• Understand and follow Human Resource
policies whenever a person enters or
leaves your supervision, goes on leave,
or changes jobs
22 • STATE STREET STANDARD OF CONDUCT 2017
Honor all internal information barriers.
At all times, be aware of the existence
and purpose of internal information
barriers. State Street uses both
physical and logical (systems access)
separation to reduce the risk of
improper flow of information from one
internal business area to another.
Where physical or logical separation is
not in place, State Street may choose to
create information barriers by policy.
For example, we may require all
employees in a given business area or
physical location to follow restrictions
on personal trading or confidentiality
that might otherwise apply only
to a limited number of employees.
Always adhere to any requirements
thatareinplaceforinformationbarrier
purposes, even if they may seem overly
stringent. Never do anything that would
compromise the integrity of a physical,
electronic, or policy-based information
barrier — for example, do not allow
unauthorized entry into secure
workspaces, share your passwords,
or speak about confidential matters
in publicspaces.
ALSO
SEE
Corporate Information
Security Controls Manual
and Social Media Policy
23 • STATE STREET STANDARD OF CONDUCT 2017
MaintainingInformationSecurity
Use appropriate measures for both
electronic and physical information
security. Use file and email
encryption as directed in the
Corporate Information Security
Controls Manual. Never save
confidentialinformation onto
non-State Street devices or systems.
Keeppaper copiesandelectronic
media in a lockeddrawerorcabinet.
Never forward State Street information
to a personal email account or device.
When accessing any State Street
networkremotely,alwaysuseASG
(Application SecureGateway).When
traveling, never put electronic media in
luggage that is being checked or stored.
Keepallelectronicmediasecurelyin
hand or within sight when traveling or
at any other time when they cannot be
physicallysecured.Donotuploador
downloadunauthorizedsoftwaretoor
from your State Street-owned desktop,
laptop, or mobile device.
Be careful when talking or working in
places where others are present. Keep
papers and screens out of the sight of
people around you. Keep conversations
(including phone calls) quiet or cryptic.
Theserulesapplyinsidetheofficeas
well:visitorsoremployeeswhoarenot
authorized to have access to information
could be in a position to overhear.
Restrictionsonuseofmobiledevices.
You cannot use or display any personal
or corporatemobile device on any
trading floor globally. Leave the
tradingarea ifyouneed touseyour
mobile device.
Never leave documents withconfidential
informationwhereotherpeoplecould
see them. This includes shared
facilities, such as printer trays, as well
asyour owndeskduringtimeswhen
you are not present. After meetings,
remove all papers and erase the
whiteboard. Do not make unauthorized
copies of confidential information, even
if you intend to destroy them later.
Never share passwords. Never let
anyone else log in using your password
or put the password for a device on
a note that is attached to the device
or is otherwise easily accessible.
Make sure no one else can use your
remoteaccessset-uptogetinto
the company’s information systems.
In addition, individuals must not use
State Street email addresses as an
identifier on non-business related web-
sites. Furthermore, itis impermissible
to use State Street email addresses,
employee ID numbers, or passwords
as identifiers on, or for access to non-
business related Internet activities.
Never share your identification card.
Neverlend youridentification card.
Neveropen the doorto a securearea
or allow anyone to follow you through
a locked door unless you are certain
that they are authorized to enter that
particular area.
Bypassing information security
controlstoaccessblockedwebsites,to
copy data to removable media, or for
any other reason without approval from
Corporate Information Security is
prohibited.DonotuploadStateStreet
data,systemscode,orcustomer or
vendor data to any unauthorized
State Street website. This includes websites or engage in bullying, intimidation,
designed to assist IT developers or or violence. These activities have no
runs on perform language translation for placeat State Street and willnot be
respect, business documents. excused ortolerated.

professional- Do not participatein raffles, pools,

ism and
inclusiveness.
ALSO
SEE
Non-Discrimination
Policy, Non-Retaliation
Policy, Open Door Policy,
Solicitation and Distribution
of Literature Policy, Anti-
Bullying and Harassment
Policy, and Gambling Policy
State StreetColleagues
Ourcompanylookstoyou toupholdits
ethical and professional principles, and
tomaketheseprinciplesanintegral
part of your conduct inside and outside
of theworkplace.StateStreet runs
on respect, professionalism, and
inclusiveness. These principles reflect
our culture, contribute to our business
success, and are firmly endorsed by
senior management. Yet truly putting
these principles into practice requires
theeffortsanddedicationofevery
employee and every manager.
Except where legally prohibited,
you are required to promptly inform
Human Resources if you are convicted
of a crime.
Personal Interactions
Treat all colleagues with respect.
Honor State Street’s commitment to
ensuring that all employees feel valued,
included, and respected. This applies to
everyone, regardless of an employee’s
heritage or belief, their ethnic, physical,
veteran,orgenderstatus,theirsexual
orientation or any characteristic
protected bylaw.
Avoid any speech or action that
could reasonably be seen as insulting
or derogatory, or as an instance
of discrimination or harassment.
Never use threatening language
orother formsof gamblingwhile on
State Street premises. While sporting
or lottery pools may seem like
harmless fun, they are also gambling.
As such,theseactivities, aswellas
any others that involve the wagering of
moneyinanyamount,areprohibited
on State Street premises. They are also
prohibited outside the office when
you are acting in your capacity as a
StateStreetemployee(forexample,
at a client event).
Do not pressure colleagues to support a
cause. Decisions about which charities,
organizations,politicalcandidates,or
other causes an individual supports are
the individual’s decision. Any attempt at
coercion in this regard is a violation of
policy, as is any attempt to commandeer
an employee for cause-related work
during normal working hours.
Criminal Activity
Criminal misconduct involving
financial institutions is a global issue
and is consequently an important
focus for law enforcement and
regulatory authorities everywhere that
State Street operates. It is imperative
that all employees remain vigilant to
suspicious behavior and “red flags,”
whether external or internal, that might
pose a threat to State Street or the
community, including thosethat may
reasonably indicate the following:

24 • STATE STREET STANDARD OF CONDUCT 2017


ALSO
SEE
Anti-Money Laundering
Policy, Sanctions Policy
ALSO
SEE
Anti-Bribery andCorruption
Policy and Gifts and
Entertainment Policy
25 • STATE STREET STANDARD OF CONDUCT 2017
• Money Laundering — whether
through illicit fundsdisguised
as legitimate, or by use of
transactions designed to
facilitateunlawfulactivity
• Bribery and Corruption —
including pay-to-play or
unlawful gratuities
• Fraud — whether through
misrepresentations,
omissions, or otherwise
Money Laundering
Strictly follow all “know your customer”
standards. This includes being
familiar with the customer’s stated
and customary usage of our products
and services. Never open an
account fora new customerwithout
obtaining all required documentation
and information as required by
State Street’s policies and procedures.
Promptly report to your supervisor any
unusual or suspicious activity in an
account. This includes unusual client
requests or behavior, unusual or
suspicious transaction patterns,
or otherpossibleevidence offraud,
money laundering, or other illegal acts.
Comply with applicable international
sanctions. Thisincludesallapplicable
international economic sanctions,
export controls and anti-boycott
regulations applicable to State Street
in the jurisdictions in which we
conduct business, whether directed
atcountries, entities, or individuals.
Training. All State Street employees
whohavecontactwithclientsorare
involved in handling client transactions
must participate in all required initial
and periodic training and must faithfully
follow our procedures for combating
money laundering.
Bribery andCorruption
State Street prohibits all forms of
briberyandcorruption—including
facilitation payments, pay-to-play,
abuse of authority, or misappropriation
of companyassets.
Never give or receive anything of value
that could be considered a bribe or a
kickback,orisotherwiseimproperly
linked to a particular outcome or
benefit. You must never promise,
offer, give, solicit, or receive anything
of value to any person or entity in
exchange for an unfair competitive
advantage, the awarding or retention
of business, other specific business
advantage, or any other improper
purpose. This includes small payments
(facilitating or grease payments)
made to low-level public employees
toperforma routineduty orfunction.
Nor can you direct or knowingly allow
anyone else to do these things for you.
Useofvendors. StateStreet maybe
held responsible for acts of bribery
committed by its vendors and
intermediaries when they act on our
behalf. If you are responsible for
onboarding a vendor, it is important
that,youfollowallapplicablethird-
party risk procedures to ensure that
we are dealing with vendors that will
uphold our standards. You must also
make sure that we receive proper
business services at commercial rates.
You may not approve a payment to a
vendor knowing, or having reason to
know,thatthepaymentwillbeused
 for improper purposes. Vendor
engagements must be assessed
for briberyandcorruptionriskin
accordance with third-party risk
management procedures, and
sufficient due diligence may be
required prior to hiring vendors and
intermediaries. You are responsible
forperformingduediligenceonthe
vendors you engage, and ensuring that
thetermsunderwhichyouengage
them are appropriate for State Street.
All vendor relationships — including
intermediaries — must be periodically
reviewed after hire, based on the
risk associated with that entity.
The relationship must also undergo
review if circumstances are known
to have changed. No vendors or
intermediaries may be engaged or
used in violation of laws, regulations,
or applicable business unit policies.
Never make any charitable donation for
the purpose of improperly gaining a
benefit for State Street. Youmust never
make or recommend a charitable
contribution in order to secure business
forStateStreetorotherwisegainfavor
withanypersonor entity(including
anyagent or consultantworkingforor
on behalf of such a person or entity).
This prohibition applies to charitable
donations made with State Street
funds as well as to personal charitable
contributions (meaning those for which
no reimbursement from State Street
is sought).
Neveraskotherstomakecharitable
or political contributions in any
instance where such solicitation is
prohibited or inappropriate. Examples
of such instances include making
paymentsthroughconsultantsto
obtain a favor in violation of our
Anti-Bribery and Corruption Policy
or “pay-to-play” regulations.

Manager Responsibilities
When considering whether to approve corporate
charitable donation requests, managers should
consider the following:

• Whether adonation to this charity could

undermineStateStreet’sreputation

• Whether the donation was requested by an

official or client who is in a position to make
decisions in our favor

• Whether the client or official or their

friends and family could directly benefit
from thedonation

• Whether the payment is conditioned on

receiving business benefits, or whether there
is a current request for information, request
for proposal, or a pending business decision

26 • STATE STREET STANDARD OF CONDUCT 2017

There are When makingor receiving employment
referrals, never request or extend
multiple preferential treatment. State Street
channels accepts referrals of talent from
employees, clients, business contacts,
available for and other sources, but in no case
you to raise will StateStreet hire, or createor
tailor a role for a less-qualified or
any concerns. under-qualified individual based on
areferralorin violation of applicable
law. State Street will subject all
candidates to our normal hiring
procedures and referred candidates
should expecttobeevaluatedinthe
same manner as other candidates.
This applies at every employment
level, from internships to senior
management positions. Be aware that
aggressive promotion of a particular
candidate may be interpreted as an
attempt at improper influence.
Use particular care with referrals from
clients or regulators. When a referral
ALSO ismadefromaclientorregulator,or
SEE
whenever we identify that a candidate
Gifts and Entertainment
Policy and Anti-Bribery is related to a client or regulator, that
and Corruption Policy relationship must be disclosed to Talent
Acquisition. Prior to making any offer
to such a candidate, Talent Acquisition
objectively reviews the recruitment
process to ensure that this has been
appropriate and free of improper
influence. This includes performing
an independent assessment of the
suitability of the candidate and the
roleandoftheprocessbywhichthe
candidate has been selected.
27 • STATE STREET STANDARD OF CONDUCT 2017
Fraud
Fraud is strictly prohibited by
State Street in all forms. Fraud can be
more than deliberate deceit. Fraud
sometimes involves an intentional act,
likerecklesslyor evennegligently
making a false or incomplete
representation.Itmayalsoinvolvea
failure to disclose relevant facts.
Voice any concerns you have regarding
fraud,corruption, dishonesty, or other
inappropriate activities. There are
multiple channels available for you
to raise any concerns, including your
manager, Human Resources, Global
Security, Compliance, or Legal, as well
as through Speaking Up procedures on
page 36. This rule applies to incidents
that you experience as well as those
you witness or otherwise become
aware of.
Business Gifts and Entertainment
In a business context, gifts and
entertainment can help personalize
relationshipswithclients and business
partners and promote mutual respect
and understanding. However, we should
never allow gifts or entertainment to
inappropriately sway their business
decisions, or our own. To those ends,
it is imperative that gifts and entertain-
ment (offered and received) remain
reasonable in value, infrequent, and
carry a legitimate business purpose.
No gift or entertainment is permitted
if itinvolves any actual or perceived
impropriety or conflict of interest.
Do not solicit gifts or entertainment
from business partners.
 Pre-clear all gifts and eligible
entertainment. Gifts. Do not provide any
giftthatexceedstheterritory-specific
limit (e.g., 250 USD). If your gift falls
under the territory-specific limit, you
must have pre-approval from your
manager and the Ethics Office.
Entertainment. Pre-clear any
entertainment that has a per-person
cost higher than the territory-specific
limit, takes place in a Corporate
Hospitality Suite, or involves an entity
with an open RFP.
Pre-clear gifts and entertainment
involving public or US Union officials.
Gifts and entertainment involving
employees or representatives of
governments, public entities, and US
unions, are heavily constrained by laws
andregulationsatthelocal,state,and
national levels. State Street requires
pre-approval for gifts or entertainment
involving such individuals, with limited
specific exceptions.
Plan business-appropriate events.
State Street regularly sponsors
events like conferences and training
to strengthen our market presence.
If you host or sponsor an event,
ensurethatthereisavalid business
purpose. This business purpose must
not be overshadowed by non-business
elements like associated gifts
or entertainment.
28 • STATE STREET STANDARD OF CONDUCT 2017
Other Outside Parties
While business-related contact with
competitors, regulators, professional/
industry groups, or the media is
infrequent for many State Street
employees, it is vital for all employees
to know the rules. How State Street
presents itself tothesepartiesisof
very high importance.
Competitors
Never engage in unfair competitive
actions. Fair competition is upheld
by State Street policy and by law.
Nevermisuseaclient’sconfidential
information, misrepresent any material
facts, or engage in any other unfair
dealing with competitors. Be sure
you understand the permissible scope
of cross-selling and bundling to
ensurethatproductsandservices
arenotlinkedina mannerthatwould
violate law.
Get approval before discussing our
pricing strategies with any competitors
or entering into agreements concerning
market opportunities or otherwise
engaging in joint action. These activities
requiretheadvanceapprovalofthe
Chief Legal Officer or General Counsel.
Acquire competitive information and
market data only from public sources
and through lawful means.
 Regulators and Law
Enforcement Officials
If contacted by a regulator or law
enforcement official, get instructions
from the Chief Legal Officer, General
Counsel, or Head of Litigation before
engaging in any communications in
connectionwith aninquiry. Thisapplies
to any subpoena, search warrant, or
similarlegaldocument,aswellasin
thecaseof an email, letter,phonecall,
in-personvisit,oranyotherformof
contact (otherthan ordinary course,
day-to-day communications with
banking regulators). State Street
cooperatesfullywithallregulatory
and law enforcement officials.
ALSO The Media
SEE
Get approval from Global Marketing
Corporate Media Policy,
Investor Relations before making any statement or
Disclosure Guidelines
releasing any information tothe media.
This extends to any interviews,
comments on background, and public
appearances, and to any social media
postings that include information
about StateStreet.
Various Get approval from Global Marketing
before commenting on, or agreeing to
laws and participate in, any media-facing content
regulations like press releases–including third-
partypress releases.
can some-
Consultwith InvestorRelationsand
times extend Legal before releasing any information
to life outside that may be of interest to the investor
community (including investors in
the office. State Street’s own securities).
Examples of such information
include financial results, non-public
information, projections of future
activitiesor performance, or other
29 • STATE STREET STANDARD OF CONDUCT 2017
information that may be of interest
to analysts who follow State Street
securities or to others in the
investor community.
NotethatStateStreetcommunicates
with theinvestment community only
throughspecificchannels.Weneither
use nor permit the use of social media
to communicate information of interest
to the investment community.
Refer any media inquiries to Public
Relations,and any inquiries from the
investment community to Investor
Relations. Do not respond to questions,
even if asked repeatedly. This includes
requests to comment on market
rumors or speculation. Outside the US,
you may also refer inquiries to the
Global Marketing representative for
your office or region.
Personal Life
In a financial services firm, the
demands of ethical behavior and the
requirements of various laws and
regulations can sometimes extend to
lifeoutsideoftheoffice.Insomecases,
as in the case of personal trading,
these requirements can encompass
actionsoraccountsoffamilymembers
or members of your household aswell.
Incertainareas,includingpersonal
trading and political contributions,
someemployeesmaybesubjectto
additional rules and requirements, such
as pre-clearance of personal trades or
contributions. For more information,
see the Political Contributions and
Activities Policy and your local
Personal InvestmentPolicy.
ALSO Conflicts ofInterest
SEE
State Street seeks to identify and
Conflicts of Interest Policy
appropriately manage conflicts of
interest when it renders services
or executes transactions with its
clients.Ifwefailtomanageconflicts
appropriately, we may suffer
reputational harm, or become a
targetforlegalorregulatoryaction.
Escalate potential organizational
conflicts. If youbecomeawareofa
potential business conflict of interest,
you should escalate the issue to
your Business Unit Conflict Manager.
For example, if you have reason
tosuspectthatoneclientisbeing
favored over another, or if similar
client groups are receiving different
treatment or services.
If you plan to engage in an outside
activity, you must first determine
whether the activity:
• Requires pre-clearance approval
(e.g., any outside employment)
• Requires post-activity approval
(e.g., trade associations)
• Requires neither preclearance
nor post-activity approval
(e.g., community activities)
• Is prohibited (e.g., working
for a competitor)
To assist in this assessment, we
maintain a register of outside activities.
If you have any questions, please
consult the Outside Activities Policy,
speakwithyourmanager,orcallthe
Ethics Office.

ALSO Report personal conflicts. Using Social Media and

SEE
Social Media Policy and
External Social Media
Marketing Policy
ALSO
SEE
Outside Activity Policy
Our personal interests can sometimes
affectourabilitytoobjectivelyand
zealouslyrepresentStateStreet’s
interests and goals while performing
our role. If you believe you have any
personal conflict, immediately report
the issue to your manager.
Avoid impermissible conflicts.
Avoid any personal conflict that cannot
be managed or mitigated. For example,
do not lend or borrow money from
clients orcolleagues.
For more information on the
appropriate reporting procedures,
consult our Conflicts of Interest Policy.
Outside Activities
Certain outside activities carry
unmanageable reputational or
regulatory risks to State Street.
Public Forums
Use judgment and discretionin your
personal use of social media. If you
identifyorconnectStateStreetona
socialnetworksite,beawarethatyour
posts and otheractivities on that site,
includingthosethatarerepostedto
othersites,willreflectonStateStreet.
Be aware that identifying your affiliation
with State Street on certain sites (such
as political sites) could be seen by some
peopleas an indication thatthereis an
official connection or endorsement
wherenoneexists.Beawareas well
that posts linking or connecting
State Street can be monitored and may
be treated as policy violations.
State Street does not discourage
theuseofsocialmediain privatelife.
These rules on social media are
intended only to prevent unintended

30 • STATE STREET STANDARD OF CONDUCT 2017

 consequences to State Street from
employee use of social media, and do
not limit any rights you have under
law andregulation.
Unless you have specific permission
fromGlobalMarketing,donotstate
or imply that you are speaking for
State Street or that State Street
endorsesany message. Thisincludes
guarding against thepossibility of a
personal message being mistaken for a
message that is sponsored or approved
by State Street. Expressing views or
recommendations about specific
financial products or strategies is,
at a minimum, strongly discouraged.
Making remarks of this type can
suggest that the information is based
on State Street proprietary research or
informationoris being madeonbehalf
of StateStreet. If you haveidentified
yourself as being connected to
State Street, then it is prohibited.
Depending on the forum and on your
job function, other policy restrictions
may apply as well. In any case, any
social media message on behalf of
State Street must be approved
and published through company-
approved channels.
Report any unauthorized posting of non-
public information. If you become aware
of any posting of State Street non-
public information on a public forum or
a third-party media or other site, alert
the Public Relations Office immediately.
Personal Trading in Securities
ALSO
SEE
Never trade securities based on
Conflicts of Interest Policy
improper use of information, or enable
anyone else to do so. Trading that
involves the improper use of
31 • STATE STREET STANDARD OF CONDUCT 2017
information canbe a serious crime,
and may carry severe consequences
for you and State Street. Do not relay
information,or“tip”afamilymember,
friend, or other third-party. Never trade
based on the following:
• Information you receive about the
trades or holdings of State Street or
its clients. This prohibition extends
to front-running (trading just before
a similar State Street or client trade)
and tailgating (trading just after a
similar State Street or client trade)
• Information intended for the
useofStateStreetclients
• Information on an investment
opportunity available to State Street
• Non-public information (e.g.,
regarding State Street or any
client or other issuer), at the
time you intend to trade
Donotbuy or sell securitiesbased
on any research recommendation
made by State Street to clients until
after the recommendationhas been
publicly distributed.
Do not trade securities of clients or
business partners with whom you work.
This includes anyclients for whose
relationshipswithStateStreetyou
have responsibility or to whose
confidential information you have
access, as well as any business
partners you overseetowhomyou
can direct business. For instance,
you should not invest in any fund
serviced by an account team where
you are a member.
The prohibition on trading includes long
andshort positions, options,other
Your main derivatives, and funds or other pooled Do not make any personal contribution,
or engage in any activity, that would
vehicles sponsored by any client or
focus should business partner. cause State Street to be ineligible to do

be on client Never engage in options, hedging,

interests. or short sales involving securities
issued by State Street. Anything
beyond simple purchases or sales
is strictly prohibited.
Never allow personal trading to
interferewithyourjobperformance.
As a State Street employee, your main
focusshouldbeonclientinterestsand
your other State Street duties; personal
tradingis aprivilegeandnotaright.
If you trade excessively, the Ethics
Office may take disciplinary action.
Discuss any possible exceptions to
these rules with the Ethics Office prior
to taking any action. In limited cases,
a legitimateexception to theserules
may be recognized, such as for
certain transactions occurring in
connection with the exercise of options
orinabenefitplanorcompensation
arrangement. Do not takeany action
unlessanduntilyouarenotifiedbythe
Ethics Office that your request for an
exception has been granted.
PoliticalActivities and Contributions
ALSO
SEE
Every employee has the right to partici-
Political Contributions
and Activities Policy pateas an individual inthe political
process,andStateStreetapplauds
civic and political involvement on the
part of its employees in any instance
when it does not violate a policy or law.
Theserulesonpoliticalactivitiesare
intended only to prevent unintended
consequences to State Street arising
from employee personal political
activities and contributions.
business with any government entity.
Many jurisdictions (including many US
federal,state, andlocaljurisdictions)
have strict “pay-to-play” laws designed
toprohibittheimproperinfluencingof
government decision-making through
campaign contributions.
In complying with these laws,
appearanceis asimportantasreality.
It is essential that personal campaign
contributions, whether made directly
or indirectly, do not cause even the
appearance of funneling corporate
money toacandidateorincumbent in
exchange for being awarded a contract
to, for instance, manage a government
pension plan.
When making personal political
contributions, including those to
political parties and PACs (Political
Action Committees), your contributions
must be documented asbeing paid
from your personal funds. Never seek
reimbursement for personal political
contributions from State Street, as such
reimbursement would make them
StateStreetcontributions.Ifyouare
one of the State Street employees who
is required to pre-clear personal
politicalcontributions,youmustalso
abide by that requirement.
Some personal political activities
may be considered indirect financial
contributions. For example, volunteer-
ing for a campaign, renting a hall for
a fundraising event, paying for printing
or postageofcampaignmaterials,
or hosting an event at your home.

32 • STATE STREET STANDARD OF CONDUCT 2017

 These indirect political contributions
and activities are subject to the
same restrictions under this Standard
of Conduct as are direct political
contributions and activities.
If you have any questions about whether
any personal political contribution or
activity is limited or prohibited, contact
the Ethics Office in advance.
Never make any political contribution for
the purpose of improperly gaining a
benefit for State Street. Youmust never
make a political contribution with the
intent of obtaining or retaining business
or any other advantage.
Do not use the name of any State Street
entityin connection with your own or
another person’s personal political
contributions oractivities. Thisincludes
keepingthe StateStreet nameoff any
political solicitation message or
fundraising collateral.
Do not use State Street resources
for personal political activities.
For example, do not:
• Engage in political activities
while at work
• Use State Street computers, email,
printers, copiers, phones, or other
equipment for political purposes
• Pressure co-workers, business
partners, or clients to participate
in politicalactivities
• Solicit contributions or coordinate
the solicitation of contributions
from any person while at work or
by using State Street resources
33 • STATE STREET STANDARD OF CONDUCT 2017
Never engage in any personal political
activity that could appear to be official
State Street activity. An example
would be identifying your affiliation
with State Street in a personal
political endorsement or fundraiser.
Any activity that could be viewed as
being conducted on behalf of, or with
the backing of, State Streetrequires
the approval of the Chief Legal Officer.
Never make any political contribution on
behalf of State Street without approval.
All political contributions made by or on
behalf of State Street must be approved
by the CEO. Political activities require
the approval of the Chief Legal Officer
and the Chief Ethics Officer.
Lobbying
Never lobby on behalf of State Street
without approval. Lobbying is a regu-
lated activity. Any lobbying on behalf of
StateStreet must beconducted by, or
undertheauspicesof,RIGA.Notethat
most contacts with elected officials,
either individually or as part of a group,
couldbeconstruedas lobbyingand
may require documentation and/or
reporting. If you thinkthere isany
chance that an activity would constitute
lobbying, contact RIGA.
Procurement lobbying. In addition to
the activities described above, certain
jurisdictions may require employees
and/or entities that solicit government
business to register as lobbyists.
Where required to do so, you must
registeras a lobbyist. Contactthe
Ethics Office if you have questions.
 Transitions
Any change in your employment status
or job function typicallyinvolves a
changeinthepolicyrequirements
to which you are subject. It may also
involvechangesinyourphysicalor
systems access permissions. It is your
duty to stay abreast of these changes.
Joining StateStreet
Study and absorb the ethics and
compliance requirements of your new
job. Statistically, there is an above-
average risk of policy violations during
thefirst daysofemployment(mainly
becauseoflackofawarenessofthe
rules). Youcan help lower that risk by
familiarizing yourself with our ethics
and compliance policies as early
as possible.
Manager Responsibilities
Managers must ensure that adequate time is set
asidefor newemployees to read and understand
ourpoliciesandrequirements,andmusthelp
familiarize new employees with these policies
and requirements.
34 • STATE STREET STANDARD OF CONDUCT 2017
Complete all required training and
paperwork on time. Completing
your initial ethics and compliance
requirements is a fundamental
condition of employment, and missing
a deadline is a serious matter.
Never disclose to anyone at State Street
any confidential information from
a third party or former employer.
This information could be considered
inside information. Disclosing
confidentialinformation ofanother
without the right to do so could also
cause damage to State Street.
Changing Jobs Within State Street
Review with your manager any changes
inapplicable requirements or access.
Youshould be notified of any changes,
but it is your duty to check with the
manager for your new position about
all policies, rules, laws, records
management practices, and access
permissions to physical spaces as well
as State Street electronic networks and
data. Employees transferring to certain
business units may be required to
disclose their political contributions
prior to any transfer being approved.
Such contributions may impact your
ability to move into certain roles.
Records are Be aware that in some cases,
knowledge or records from a previous
critical forthe State Street position could be
operation of considered inside information in your
new position. Toavoid any breaches
our business. of information barriers, consult your
manager or the Ethics Office.
Leaving StateStreet
Return all company property. This
includes electronic devices and other
equipment, physical records, and
information and materials created
while working on behalf of State Street.
Be aware of those responsibilities that
you remain bound to. These include:
• Continuingtomaintainconfidentiality
• Continuing to protect
intellectual property
• Continuingtorefrainfrom
trading on inside information
• Honoring any post-employment
obligations created by contract or law
In some cases you may also be
obligated to support an ongoing or
future investigation or legalaction.
In cases where you are not obligated,
we may ask that you do so.
Recordkeeping
Records are criticalfor theoperation of
our business, for legal purposes, and
for documenting our financial results
and our compliance with law and policy.
As aStateStreetemployee,youare
personally responsible for the integrity
of the records, reports, and information
that you prepare or control.
35 • STATE STREET STANDARD OF CONDUCT 2017
Accuracy and Completeness
Carefully review all statements and
representations. Any representation
that you make in the course of your
duties must be true, complete, and
accurate. This responsibility extends
to records that were drafted by
othersunderyoursupervisionor
oversight, or records that you use
in the performance of your role.
Carefully evaluate statements that
purport to be factual, and include
appropriate disclaimers when
necessary. If the statement or
representation requires personal
judgment,ensurethejudgmentis
made in good faith, and consistent with
applicable industry standards, laws,
and regulations. For example, all
accounting judgments should be
consistent with Generally Accepted
Accounting Principles.
Performappropriatediligencebefore
making personal or corporate
certifications. Takegreatcare when
you are asked to certify matters such
as your personal compliance with our
policies, accuracy of your account
holdings, orthe particulars of an event
or transaction. If you have a question
about the matter you are being asked to
certify,contactwhoeverisrequesting
the certification and discuss the matter
with them.Thesecertificationsare
part ofourcontrolenvironmentand
should not be made without due care.
The same level of due diligence should
occur for any certifications you are
asked to make on behalf of State Street
toclients, regulators, or other parties.
Such matters may include State Street’s
compliance with client policies,
Rules to Live By contractual requirements or the
accuracy of regulatory, financial, or
If you see othersubmissions. If you are unclear
something, whetheryouauthorizedtomakesuch
a certification on behalf of State Street,
saysome- you should discussthematter with
thing. your manager.
Never alter or falsify a business record.
This applies universally, but in
particular tothefollowing situations:
• Falsification of books, records,
oraccounts for purposes of fraud
or deceit (for example, backdating
documents or submitting
falsified expense reportsor
inaccurate time records)
• Altering a record after the fact,
in particular in anticipation of an
audit orinvestigation (whether
internal or external); address any
issuesbyprovidinganexplanation
at the time the issues are identified.
Alteration includes selective removal
ordestruction of material orcontent
Record Retention and Document
Destruction Policies
Understand and follow the record
retention and document destruction
policies that apply to your records.
Thesepolicies may differ by business
area. Do not keep any information,
especially confidential information,
pastitsretention dateestablishedby
contractorlaw,withtheimportant
exceptionofanyinformationyouare
still using or on which a legal hold has
been placed. Legal hold instructions
supersede all other instructions.
When disposing of confidential
information, be sure to do it securely.
36 • STATE STREET STANDARD OF CONDUCT 2017
Never destroy records that could
be relevant to an investigation.
This applies with respect to any lawsuit
or regulatory examination and to any
type of investigation, inquiry, audit,
or other proceeding, whether internal
or external.
Speaking Up
“If you see something, say something”
and “If you’re not sure, ask.”
These are rules to live by.
Every State Street employee has
aduty tolet usknow of anyactual
or possible violations of policy or law.
In addition, if you have a question
or concern, youshould bring it to
your manager, your compliance
representative or the Ethics Office to
makesure it ishandledproperly.
Guidance on Speaking Up
Promptly report all known, suspected,
or potential violations. If you have
reason to believe that there may
have been a violation of law or policy,
whetherbyyouor someoneelse,
you must escalate the matter.
Additionally, if you have knowledge
ofa threat or safetyissuethat has the
potential to impact the workplace,
you must notify Global Security
promptly (e.g., a restraining order
with workplace safety implications,
or specific threats against a
State Street facility).
You have You have many other options for
reporting concerns (see pages 39-40),
many options including ourwhistleblower hotline.
for reporting Thehotlineisavailableforconcerns
regarding known or suspected
concerns. violations of law or regulations,
questionable business conduct, and
matters pertaining to accounting
practices, internal accounting controls,
or auditing. The hotline is active
24 hours per day, 7 days per week,
365 days per year and is operated by an
independent third party. You can report
anonymously(exceptwherelocallaw
does not permit), although identifying
yourself allows us to act as quickly and
appropriately as possible. All reports
are provided to theBoard of Directors’
Lead Director, the Chief legal Officer
and the General Auditor, and are held
in the strictest confidence to the extent
permitted bylaw.
Administration
Administered by the Ethics Office.
All employees are required to read
this policy and successfully complete
a trainingcertification when joining
the company and annually thereafter.
In order to ensure compliance with
theStandard ofConduct, youare
required to comply with any Ethics
Office request for information.
Interpretation/exceptions. The Chief
Legal Officer and General Counsel
are authorized to interpret this policy
and provide guidance. They have also
extended these same powers to the
Corporate Compliance Officer and
the Chief Ethics Officer.
37 • STATE STREET STANDARD OF CONDUCT 2017
TheChiefLegalOfficerandGeneral
Counsel are also authorized to grant
exceptions to rules in this policy, based
on a review of relevant facts and
circumstances, such as local customs
or laws, contractual obligations, and
financialhardships.Anyemployee
may submit a request in writing to the
Chief Legal Officer or General Counsel.
Exceptions will be granted only if
there is a compelling reason, and
any exception granted must remain
consistent with the general intent
and principles of this policy.
If the employee requesting an exception
is an executive officer for purposes of
Section 16of the Securities Exchange
Act of 1934, the Chief Legal Officer
mustalsosubmittheproposaltothe
Examining and Audit Committee of the
Board of Directors for consideration.
Any waivers granted to Section 16
officers must be disclosed to the
Examining and Audit Committee and
publicly disclosed.
Alldecisionsoninterpretationand
exceptions are made at the discretion
of the Chief Legal Officer or General
Counsel (and the Examining and Audit
Committee, where applicable) and
are conclusive.
Thispolicyisnotanemployment
contractanddoesnotcreatearight
tocontinued employment for any
length of time or any other right in
favor of employees.
 AmendmentPolicy. TheEthicsOffice
willperiodicallyreviewandupdatethis
documentasitconsidersnecessary
andfollowingconsultation withthe
Chief Legal Officer or the General
Counsel. The electronic version of the
Standard of Conduct will contain any
changes made to the document after its
date of printed publication. In the event
of any such change, the electronic
versionwillbethemostup-to-date.

Manager Responsibilities Administration

Managersshouldbeawarethattheyhavean
impactonouremployees’willingnesstoraise
issues and concerns. Managers must act
promptly on any reports they receive, which may
include further reporting up the management
chainortothewhistleblowinghotline,Global
Human Resources, Legal, Compliance, the
Ethics Office, Global Security Control Center,
or elsewhere as appropriate. Managers must
never engage in or tolerate any retaliatory
behavior and must promote a work environment
that does not permit retaliatory behavior.
A senior attorney (senior vice president or
above), the Senior Compliance Officer, the
Chief Legal Officer, or the General Auditor
must be advised of information concerning
any apparentor possibleviolation of law or
fraudulent activity, identifying it in that manner.
IfthesituationinvolvestheChiefExecutive
OfficerorChiefFinancialOfficer, thematter
must be reported to the General Auditor or the
ChiefLegalOfficer, whowillkeepeachother
informed of the situation and will immediately
advise the Chairman of the Examining and
Audit Committee of the Board of Directors.
Communications from the whistleblower hotline
areforwarded withinStateStreetforfurther
action asappropriate.

38 • STATE STREET STANDARD OF CONDUCT 2017

Who Should I Contact?

For questions or concerns about Actual or possible violations of policy or law

policies orsituations
• your manager
• your manager
• the Ethics Office
• your business-aligned Senior Compliance Officer
• Legal
• the Ethics Office
• Global Security
• Global HumanResources
• Lead Director of the Board
• Legal (via confidential whistleblower hotline)

ethics@statestreet.com
ghrservicectr@statestreet.com

Complaints/concerns about company policies Workplace safety including suspicious

or conduct including complaints about accounting or
accounting controls, auditing or potential corruption
• Lead Director of the Board
(via confidential whistleblower hotline)
activities, criminal or irregular behavior
• if injury or damage is imminent,
contact police, fire, or other appropriate
outside emergency personnel

• in all other cases,

contact Global Security:
North America: +1 617 985 8475
EMEA: +44 203 395 4444
APAC: +612 9323 6242

39 • STATE STREET STANDARD OF CONDUCT 2017

Who Should I Contact? (cont.)

The Network
Confidential
Reporting
333 Research Court
Norcross, GA 30092 USA
www.tnwinc.com/webreport

US and Canada 1 888 736 9833 Japan KDD: 00531 11 4442

Cable & Wireless IDC: 0066 33 801143
Austria 0 80 200 288 then 1 888 736 9833 Softbank Telecom: 0066 33 112661
NTT: 0034 800 900131
Australia 1 800 08 7428
South Korea 00798 11 002 1599
Belgium 0800 7 5651
Luxembourg 800 2 7148
Cayman Islands 1 888 736 9833
Netherlands 0800 022 7427
China Telecom South: 10 800 110 0731
China Netcom: 10 800 711 0788 Poland 0 0 800 111 1730

France 0800 91 2790 Singapore 800 110 1607

Germany 0800 180 8934 South Africa 0800 981 281

Hong Kong 800 90 3272 Switzerland 0800 89 6872

India 000 800 100 1389 Taiwan 00801 10 4147

Ireland 1 800 550 000 then 1 888 736 9833 UAE 0 800 121 then 1 888 736 9833

Italy 800 788952 UK 0808 234 4889

40 • STATE STREET STANDARD OF CONDUCT 2017

State Street Corporation
State Street Financial Center
One Lincoln Street
Boston, Massachusetts 02111–2900
+1 617 786 3000
www.statestreet.com
NYSEtickersymbol:STT ©2017 State Street Corporation - All Rights Reserved
 Emp.Code No.

NOMINATION FORM
To,

M/s. HCL Technologies Limited

A-11, Sector-16
Noida - 201 301

1. I, Mr/Ms. _________________ ( Name in Full here) , hereby nominate the person(s) mentioned below to receive the benefits
under the Term Life and Group personal accident Policy , payable after my death in proportion indicated against the name(s) of the
nominee(s).

2. This document supercedes any previous nominations.

NOMINEE (S)

Proportion Name of
Nominee's by which Guardian
relationship Age of the (In case
Name of nominee/nominees Address of Nominee
ID No. with the Nominee Insurance nominee is
Employee amount will a minor)
be shared

Note : * ID No. could be either Passport No. / Driving License No. / Voter’s ID No. / PAN Card No.

Name of the employee in Full _____________________________________

Father’s / Husband’s Name _____________________________________

Residential Address _____________________________________

Gender _____________________________________

Marital Status _____________________________________

Date of Birth _____________________________________

Designation _____________________________________

Emp. Code No. _____________________________________

Date of Appointment _____________________________________

Place: Noida

Date:

Signature or thumb impression of the Employee

 DECLARATION BY WITNESSES

Nomination signed/thumb - impressed before me

Name in full and full addresses of witnesses

1 ……………………………………………………………………………………………………………………………………………………………..

2 ……………………………………………………………………………………………………………………………………………………………..

Signature of Witnesses :

1 ………………………………………………………………………. Date:…………………………. Place:…………………………………….

2 ………………………………………………………………………. Date:…………………………. Place:…………………………………….