Policy- 0011 – Misconduct Policy

PURPOSE OF THIS POLICY

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The purpose of this policy is to support and reinforce the Code of Business Ethics which sets conduct
expectations for all Company personnel. This policy provides examples of the types of behavior which could
constitute misconduct and explains what the Company may do to address misconduct by employees of the
Indian offices and other Polestar employees working in India. This policy addresses misconduct that occurs
worldwide during employment, on business travel for the Company, at customer or partner sites and while at
Company events or on Company property. It also addresses behavior that occurs outside the workplace and
working hours but which has a negative impact on the Company.

POLICY

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General Definition of Misconduct

Misconduct is any behavior which is below the standards required by the Company. It includes any actions which
are unprofessional and are damaging or potentially damaging to the Company and Third Parties (“Third Parties”
include Company employees, contractors, consultants, clients and partners.) In order to help employees
understand the kinds of actions which are misconduct, the following examples are provided. This list is not
exhaustive and the Company reserves the discretion to take appropriate action with respect to any action that in
the opinion of management is below the standards set by the Company or which could result in harm to the
Company’s employees, assets, interests or reputation.

Types and Examples of Misconduct

I. Types of Misconduct include, but are not limited to:

a. Conducting business in a way that is dishonest.

b. Engaging in any activity which is in conflict with the interest of the Company or Third Parties.

c. Engaging in behavior which disrupts the workplace or Third Parties.

d. Bullying, Harassing or Discriminatory behavior.

e. Failure to comply with managerial or Company direction or retaliation.

f. Engaging in actions which could or do compromise health and safety of Third Parties or others.

g. Misuse of Company property or systems.

h. Inappropriate use of restricted personal assets/devices

i. Violation of any Company policy, Code of Business Ethics and/or any employee requirements of the
Terms of Employment.

j. Engaging in any kind of factionalism with an intention to create rift or apply duress on the company.
Anybody initiating a meeting or an email to that effect would be considered as disruptive.

II. Examples are:

Conducting business in a way that is dishonest

i. Theft, fraud or dishonesty in connection with the Company and Third Parties’ business or property.

ii. Taking or giving of bribes or benefits (in any form whatsoever) in connection with the Company’s and Third
Parties’ business for the employee’s own interest.
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iii. Failure to comply with procedures, policies and guidelines on Time & Expense reporting –filing fake or
intentionally inaccurate time reports, directly or indirectly tampering or making unauthorized correction in time
reports, time cards, attendance sheets or similar documentation. This is applicable to any Company or client time
& expense reporting process, which employees are directed to use.

iv. Providing false testimonials, information and personal details, including information relating to one’s name,
age, parents’ names, qualification, details about previous employment such as period of service, compensation
submitted to the Company before or during the time of the employment.

v. Submission of fake and/or altered documentation to support leaves or claims for other benefits.

vi. Conducting or engaging in illegal activities, individually or which could subject the Company to liability,
including but not limited to corruption, anti-trust violations or bribery.

vii. Being involved in any legal proceedings which may result in the employee’s inability to perform his/her work in
accordance with the employment contract.

viii. Unauthorized occupation, use or sub-letting of Company’s land, quarters or any tangible property.

ix. Changing the privileges of any system/application/user account/access without appropriate

authority/authorization.

x. Altering an email address, or altering an email to suggest a different sender or message.

xi. Any act that constitutes abuse of authority or position. This includes misuse of the authority given by the
Company to sign documents for and on behalf of the Company. This also includes misuse of the decision making
authority provided to make decisions for and on behalf of the Company.

xii. Making public statements in person, in the press or in social media which are unauthorized or damaging to
the reputation of the Company or Third Parties.

xiii. Manipulation of any data on the Company or its client’s tools/applications/databases.

Engaging in any activity which is in conflict with the interest of the Company or third parties

Examples include:

i. Unauthorized dual employment ( refer policy 0016 - Dual Employment);

ii. Unauthorized solicitation

iii. Conflicts of Interest

Engaging in behavior which disrupts the workplace or Third Parties

Examples include:

i. Fighting or riotous, disorderly or indecent behavior while on-site at the Company’s or its contractors’, agents’ or
clients’ facilities, or at a Company related event, including any behavior threatening, abusing or assaulting any
other person or inciting such conduct.

ii. Acting in a disorderly, discourteous, rude, boisterous, rowdy or unruly manner that causes disturbance to other
individuals.

iii. Being impaired by or inappropriately consuming alcohol or drugs.

iv. Trading, selling or barter of alcohol or illegal drugs.

v. Money lending or forcing other employees to lend or donate money. Soliciting employees or clients for any kind
of donation whether at the Company or an outside location, for causes not expressly authorized by the Company.
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vi. Smoking on-site at the Company’s or its contractors’, agents’ or clients’ facilities, except in specifically
designated smoking zones.

vii. Causing damage to work in progress or to property of the Company or its contractors, agents or clients.

viii. Inappropriately using or permitting the use of Company property, including its facilities, vehicles and
equipment by non-authorized persons.

ix. Any reckless, negligent or intentional act or omission that leads to or is capable of causing damage,
destruction or loss of property belonging to the Company or Third Parties. Such acts include, but are not limited
to, provoking quarrels, physical fighting and discourteous or rude behaviour towards Company employees, client
or partner employees, guests or service providers.

x. Taking part in any form of gambling within Company or client premises or during any Company or client
sponsored activity or using Company or a Third Parties’ property to take part in gambling.

xi. Violation of the Company’s Business Attire Policy.

Bullying, harassing or discriminatory behavior

Examples include:

i. Violation of the Company’s policies on meritocracy, including making decisions regarding an individual or
providing or withholding benefits of employment because of that individual’s protected characteristics.

ii. Violation of the Company’s policies against harassment, including engaging in any improper conduct, such as:

1. Physical and/or verbal sexual references

2. a demand or request for sexual favor
3. sexually colored remarks; and/or
4. Accessing, downloading, sharing or circulating offensive, inappropriate, obscene or pornographic
material.

iii. Engaging in bullying behavior, including any behavior which causes embarrassment to or intimidation of others
(legitimate and constructive performance behavior and disciplinary action does not constitute bullying behavior).

iv. Engaging in behavior that is unbecoming of an employee of the Company or acting in a manner that is
prejudicial to the interests of the Company, such as any conduct that violates common decency.

v. Retaliating against any employee who brings, or is a witness to a claim of bullying, harassment or
discrimination.

Failure to comply with managerial or Company direction or retaliation

Examples include:

i. Willful insubordination or disobedience (including Company as well as client specific instructions).

ii. Gross or habitual negligence in the performance of assigned tasks or duties.

iii. Refusal to accept work opportunity assigned by the Company.

iv. Willful neglect of responsibility, including sleeping while on duty, unauthorized intervals or breaks from work,
slowing down work or hampering productivity and/or the quality of work and inciting others to do any of the
foregoing.

v. Unpunctuality and/or unauthorized absence in violation of the Company’s leave policies.

vi. Absenteeism which is without authorization.

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vii. Failure to co-operate with or interference with any internal investigation conducted by the Company, including
an alleged violation of Company Policy and/or the Company Code of Business Ethics.

viii. Failure to take training programmes required or directed by the Company.

ix. Retaliation against any employee or other person who has participated in a Company investigation or for
reporting any violations of law, Company policy or Code of Business Ethics.

Engaging in actions which could or do compromise the health or safety of the Company’s employees,
partners, agents, clients or others.

Examples include:

i. Failure or refusal to wear or use any protective equipment when asked to by the Company, or failure to adhere
to safety guidelines communicated by the Company or its clients or other locations visited in the course of
employment.

ii. Disregard of location regulations on safety, security, sanitation and orderly conditions of the workplace such as
but not limited to:

1. Playing or tampering with any security and safety devices, including fire extinguishers, fire alarms or
smoke detectors;
2. Unauthorized use of fire exit stairwells;
3. Disobeying any written or verbal security instructions from authorized security personnel/ guards;

iii. Violence/ threats to Company or Third Parties’ employees or premises.

iv. Any act that would endanger the life, health or safety of other employees such as but not limited to:

1. Possession, use or sale of firearms, explosives or other dangerous or illegal items;

2. Intentionally reporting false information to the Company or Third Parties such as but not limited to calling
with bomb threats, or reporting fictional hazards.

v. Refusal to comply with the health and wellness regulations of the Company such as but not limited to the
following:

1. Failure or refusal to undertake medical examinations as prescribed by accredited Company physicians;

2. Non-disclosure of having been diagnosed with an infectious disease or reporting for work while
knowingly suffering from an infectious illness.

vi. Employees leaving their visitor/s unescorted inside Company premises and/or employees taking unapproved
non-Company person(s) to production floors.

vii. Tailgating/trespassing inside Company and/or its client’s premises.

viii. Gaining or attempt to gain unauthorized access or entering or attempt to enter ‘Restricted Project Bays’. Note
– the doors to all ‘Restricted Project Bays’ are marked appropriately.

Misuse of Company property or systems

Examples include:

i. Unauthorized use of computer hardware including the unauthorized use or sharing of passwords. Please refer
to policy 0047 – Acceptable Use of Information, Devices and Technology

ii. Excessive unauthorized personal use of office equipment, telephone, services, or other office facilities provided
by the Company or its client. Please refer to policy 0047 – Acceptable Use of Information, Devices and
Technology to understand acceptable use of Company systems.

iii. Non-compliance with any Company and/or its clients’ or partners’ applicable information security procedures
and policies.
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iv. Inappropriately accessing, disclosing, transferring or misusing any confidential or personal information of the
Company as well as the Company’s clients.

v. Violation of ‘Clear Screen’ guidelines as communicated by the Company through email/ any other mode of
communication. Any Company and/or Third Parties’ confidential and/or critical and/or secret information on one’s
computer should not be visible and/or accessible to any unauthorized person. Users are supposed to lock their
computer before leaving it unattended.

vi. Sending spam emails within or outside Company network. SPAM emails are unsolicited emails resulting from
variety of reasons, including business-related Internet searches or personal internet searches or even browsing
habits.

vii. Violation of ‘Clean Desk’ guidelines as communicated by the Company through email/ any other mode of
communication. Clean Desk guidelines include, but not limited to leaving papers containing Company and/or
client confidential and/or critical and/or secret information unattended at one’s desk and/or at the printer, leaving
the cabinet unlocked and/or unattended.

viii. Unauthorized use of third party software on the desktop/laptop provided by the Company and/or its client.
This includes download and/or installation of pirated or unlicensed software, or other use of third party software
which is inconsistent with the applicable license terms.

ix. Downloading and/or installation of material that is a copyright or property of a third party without requisite
authorization/license.

x. Failure to protect Company and/or client “confidential” and/or “critical” and/or “restricted” information in mobile
devices and/or PDA.

xi. Failure to protect password of any Company and/or client provided user accounts/ accesses. This includes
sharing and/or compromise of password to any Company and/or client provided user accounts/ accesses.

xii. Compromising or misusing any Company or client information including any intellectual property, by sharing it
with an unauthorized person/party or by sending it to an external email account or copying it to a personal
storage device.

xiii. Unauthorized access of the Company or Third Parties’ system/software or confidential data on a personal or
any third party desktop/laptop.

xiv. Publishing or uploading Company and/or Third Parties’ information or intellectual property on internet, public
portals, internal or external discussion boards, social networking sites, personal email accounts, any other
storage space available in public domain without express authorization to do so.

xv. Theft of any data or information or intellectual property that is related to the Company, or Third Parties.

xvi. Using company equipment to access, download, share or circulate offensive, inappropriate, obscene,
pornographic, violent or illegal material.

xvii. Hacking or attempt to hack into Company or Third Parties’ systems.

Inappropriate use of restricted personal assets/devices

Examples include:

i. Use of personal or official photography devices including cameras, hand phones to record pictures/ videos etc.
inside Company restricted marked premises without express approvals.

ii. Carrying and/or usage of hand/mobile phones and/or any personal belongings including but not restricted to
bag, lunch box, purse, in prohibited areas.

iii. Carrying and/or usage of unapproved personal electronic media or storage devices such as, but not limited to
USB, HDD, cameras, CDs, DVDs, laptops, and SD cards.

Violation of any Company policy, Code of Business Ethics and/or any employee requirements of the
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Terms of Employment.

Disciplinary and Remedial Action

The Company believes that any allegations of misconduct should be dealt with as expeditiously and equitably as
the circumstances allow. Investigations will be fair and as complete, impartial and confidential as the
circumstances allow. After the Company has reasonably concluded that misconduct has occurred discipline will
be determined taking into account such factors as: whether the employee has received prior notice, training or
discipline; the impact of the misconduct on the Company, its employees or third parties; the legal and business
risks to the Company resulting from the misconduct or from failure to take firm action; and whether there is a
pattern of, or repeat of misconduct that needs to be addressed. Nothing in this policy is intended to limit the
Company’s discretion to determine the appropriate discipline up to and including immediate termination of
employment.

Disciplinary action for misconduct may be taken against an employee and includes but is not limited to any one or
more of the following (and not necessarily in the order set out below)

1. Counseling including verbal warning;

2. Email warning;
3. A letter setting out the warning (s);
4. Immediate suspension or termination of employment;
5. Withholding of release/relieving letter.

The warnings or counseling may also reflect actions that the Company will take to ensure that the misconduct will
not reoccur, including but not limited to, requiring employees to take certain actions such as making apologies or
amends; requiring an employee to take training; impact on the employee’s rating, bonus or salary, career
progression; reassigning the employee; moving the employee out of a managerial or team lead role; moving an
employee off a project; reassigning client responsibility; or other disciplinary or rehabilitation plan.

Documentation

A copy or record of all warnings and termination notifications may be placed in the employee personnel file. While
written warnings become a permanent part of the employee record, managers are encouraged to note the
employee’s improvement and successful completion of the terms specified in the warning in a memo for inclusion
in the employee personnel file as an attachment to the warning.