Teleperformance DIBS = A Code of ConductTzTeleperformance DIBS= enn Cue UC eae sth ken is Dear Employees, Integrity is one of Teleperformance's five core values, which - along with Respect, Innovation, Professionalism and Commitment - are the pillars of our corporate culture. At Teleperformance, each individual is responsible for acting with integrity at all times. Our commitment to act with integrity means complying with the highest professional and ethical standards, as well as the spirit and the letter of the laws that govern our industry, our company and our operations. Conducting ourselves in an ethical manner and with integrity helps us earn the trust and respect of the people we serve and those with whom we work. This Code of Conduct, which can also be found on the Group's intranet, is an essential resource for all Teleperformance employees. This Code of Conduct outlines Teleperformance’s policies on business conduct and identifies the people who can answer any questions you might have about compliance-related issues. Please use it as a guide to help you make the right decisions, and resolve any issues that may arise in connection with your professional duties. It has been designed as a resource to be used at all times throughout the year, and | encourage you to consult it regularly. Our Code of Conduct cannot exist without us, the Teleperformance team. Continuous improvement and corrective action are an integral part of our Global Compliance Framework. If you have any questions or if you witness any inappropriate behaviour, | strongly urge you to make use of the Ethics Hotline, our internal reporting system, to bring it to the attention of our Compliance team, Acting with integrity depends on each of us understanding and following the policies related to ‘our standards for behaviour. It is imperative that all of us at Teleperformance abide by the highest standards. We owe this to our clients, our partners, our shareholders and ourselves. Let me thank all of you for your unfailing commitment to upholding the principles contained within this Code of Conduct and to promoting it both inside and outside the company. Daniel Julien Chairman and Chief Executive OfficerTeleperformance Internal Use OnlyTeleperformance DIBS. Introduction Teleperformance SE (including all its subsidiaries, “Teleperformance” or the “Group”) adheres to the U.N. Global Compact, a United Nations initiative created to encourage companies to adopt a socially responsible attitude by committing to promote principles relating to human rights, international labor standards and anti-corruption, and to integrate those principles into their practices. It is a commitment that ensures that markets, business, technology and finance operate for the benefit of economies and societies worldwide. In 2011, Teleperformance made a commitment to combat all forms of corruption within its subsidiaries. In furtherance of that commitment, Teleperformance adopted this Code of Conduct, This Code of Conduct contains the fundamental principles for assisting and guiding Teleperformance employees in respecting the laws and regulations that govern their activity. It forms part of the Global Compliance Framework adopted by the Group. It is appended to the Internal Regulations of each Teleperformance subsidiary, as applicable. This Code of Conduct includes the Group’s Compliance policies regarding: = Anti-corruption = Influence peddling = Anti-money laundering = Gifts, travel and entertainment "Donations, sponsorship and philanthropy = Political activities = Facilitation payments = Conflicts of interestTeleperformance Internal Use OnlyTeleperformance DIBSs aS en uu ruke et arte i Presentation of the Organization Teleperformance’s Global Compliance Organization is a dedicated structure that stretches from senior management of the Group and the Audit and Compliance Committee of the Teleperformance SE Board of Directors to every level of the Group. This dedicated structure ensures that the policies and procedures of our Global Compliance Program are effectively and efficiently implemented Group-wide, The Global Compliance Organization includes the following leaders: "Chief Compliance Officer "Deputy Chief Compliance Officer and Chief Privacy Officer * Global Privacy Office, including the Regional Data Privacy Officers for the UK and CEMEA region, the Americas, and Asia. The Chief Compliance Officer and Deputy Chief Compliance Officer provide reports and updates to senior management of Teleperformance and to the Audit and Compliance Committee of the Teleperformance SE Board of Directors. More information about the Global Compliance Organization can be found on the Group's intranet. Global Compliance Framework The Global Compliance Framework encompasses Teleperformance’s compliance policies and procedures, including this Code of Conduct. The components of the Global Compliance Framework can be found on the Group's intranet. The Chief Compliance Officer and Deputy Chief Compliance Officer and Chief Privacy Officer are responsible for the Group-wide implementation and monitoring of the Global Compliance Framework. How to obt: formation and answers; How to forward suggestions ‘Asan employee, if you have questions, need advice or have ideas or suggestions, you can raise these with your Local Contact. Your Local Contact is one of the following people: * Your manager * Your contact in your local Human Resources Department or local Legal Department + Amember of the Compliance Department, including your Regional Data Privacy Officer + Amember of the internal Audit DepartmentTeleperformance Internal Use OnlyDIeS= Definitions of Certain Terms used in this Code of Conduct Corruption is dishonest, unethical or fraudulent conduct to obtain a benefit or for other improper purposes. It includes criminally-sanctioned conduct in which an individual (the corrupted person) solicits, approves or accepts a donation, offer, promise, gifts or benefit of any kind in order to perform, delay or refrain from performing an act that directly or indirectly falls within the scope of his/her individual duties. The benefits may be financial but need not be exclusively financial Corruption may take various forms, ranging from influence peddling to Facilitation Payments, to Bribery. The persons involved may be government officials or private individuals such as clients, suppliers or business partners, Acts of Corruption are sometimes facilitated by the use of commercial intermediaries in an attempt to hide them or conceal them from potential investigations. Generally, there are two types of Corruption: = Active Corruj n, which consists of offering someone a benefit in order to influence a decision or decision-making mechanism or in exchange for a benefit (authorization, right, supply, business, contract, financial gain, etc.); "Passive Corruption, which consists of accepting or receiving a benefit (usually money or service) in return for using one’s influence to affect a decision. Passive Corruption is not necessarily solicited, but it may be and it may include practices as serious as extortion. Facilitation Payment is a form of Corruption in which money is paid, typically to a public or government official, to ensure the performance or acceleration of certain administrative formalities or processes, Bribery is a common form of Corruption where cash or any other gift of value is offered to another person in return for a favorable decision or result, inaction or delayed action, Extortion means demanding undue recompense in return for the grant of business, a contract or authorization, by exerting pressure that may range from occasional or daily demands for money to physical threats against individuals and their familyTeleperformance Internal Use OnlyTeleperformance DIBS. Re eee et The Code of Conduct, along with our policies, values and standards, applies to all of Teleperformance’s economic operations, at the local, national, regional and/or international level Each country has its own laws, regulations, customs and expectations. You must apply the Code in conjunction with your lacal regulations, whichever sets the higher standard, If you have a question about application of cade, you should refer to the Code on the Intranet or ask your line manager for guidance. If you are unsure of what to do or concerned that the Code is being broken, you have a responsibility to speak up to the following = Your line manager = Your human resources representative, and = Use channels defined in Ethics Hotline policy When our Code refers to “You” it means all of us, whatever job we do at Teleperformance. It also includes everyone who works with us in a full time, part time or temporary job, and all the contractors we work with around the world Compliance with law Teleperformance employees must act in strict compliance with all laws applicable to them. In the event of employment or an assignment outside your country of residence, employees also must act in strict compliance with applicable domestic law in the location of their employment or assignment. In the event of confusion, lack of understanding or doubt about the applicable law and/or its content, employees must immediately inform their Local Contact or their Regional Data Privacy Officer. DeesTeleperformance Internal Use OnlyTeleperformance DIBSs Dee eee keer ad Our People Teleperformance is all of us - who we are, and what we do. So we want it to be a great place for all of us to work. A place where we all feel valued, and there’s equal opportunity for everyone to grow and develop. Human Rights We are aware that human rights are the basic rights and freedoms that belong to every person in the world. They are based on core principles like dignity, fairness, equality and respect. Hence we respect human rights in the way we do our business and do not take part in, or benefit from, any activity, which abuses them. It is fundamental part of our values and code of, conduct. We have transparent processes to ensure we respect human rights. Always: * Observe, protect and promote human rights = Comply with legal requirements regarding employment, wages and working hours + Report any cases of human-rights abuse. Never: = Hire child or forced labour, or work with suppliers or partners who do so = Ignore, personally display or engage in human-rights abuse.Teleperformance Internal Use OnlyTeleperformance DIBS= We endeavour Teleperformance to be a workplace of mutual trust and respect. So we treat Fair Treatment & Equal Opportunities everyone fairly and equally, and value difference and diversity. Employee policies and practices shall be administered in a manner that ensures that decisions are merit based and that equal opportunities are provided to all employees and all qualified applicants for employment without regard to their race, caste, religion, colour, ancestry, marital status, sex, age, nationality, disability and veteran status. We won't encourage and/or tolerate any form of discrimination, Where we are allowed to, we will promote equality by encouraging recruitment from disadvantaged groups, such as people with disabilities. We are also committed to constructive working relationships with unions and employee representatives, Always: "Understand what behaviour is appropriate, so you do not discriminate against other people = Reflect our Values in your actions = Understand and comply with Teleperformance policies, employment laws and regulations = Respect local cultures and traditions = Report any concerns you may have about discrimination or unfair treatment Never: = Tolerate, personally display or engage in unlawful discrimination or prejudice of any kind. Respectful Workplace Every Teleperformance employee has the right to work in a respectful work environment. All employees shall be treated with dignity and in accordance with our policy to maintain a work environment which is safe, free of any kind of harassment - whether sexual, physical, verbal or psychological We have zero tolerance towards harassment of any kind, threat, or any violence against an employee, whether by a colleague, third party or a member of the public. If you harass a co-worker, you will face disciplinary action. Harassment means any behaviour that offends someone, violates their dignity or intimidates or humiliates them, including sexual harassment. Harassment in the workplace can include: = Bullying = Using threatening, abusive or insulting words "Threatening behaviour, orTeleperformance Internal Use OnlyDIeS= = Unwanted physical contact, or Open hostility "Spread of malicious remarks and gossip = Sexual harassment We take violence extremely seriously. Examples of violence include: "Verbal abuse "Offensive language = Racist or sexist remarks "Physical threats or assault = Physical attacks, including spitting and throwing objects. So if you see it or experience it, speak up. We will support you if you suffer mental or physical trauma, The company has constituted an internal complaints committee to address sexual harassment complaints. Where appropriate, we will encourage police intervention, pursue criminal charges and support you in civil proceedings. Always: = Treat everyone you interact with at work with courtesy, dignity and respect. = Recognise cultural differences, find out about local practices and adapt your behaviour accordingly. Take reasonable care of yourself and other people who may be affected by your actions. = Follow rules and procedures designed for safe working. = Report all incidents of harassment, verbal abuse, threats and physical assault "Assist in any investigation into an incident, Report any dangers or concerns you may have about potentially violent or abusive situations or the environment in which you work. Never: = Behave in a way that could be offensive, intimidating, malicious or insulting. = Humiliate, denigrate or injure another person. = Retaliate against someone who has made a complaint, = Threaten anyone with physical violence or verbal abuse,Teleperformance Internal Use OnlyTeleperformance DIBS= Teleperformance is committed to providing a safe and productive work environment free from substance abuse (drug and alcohol). Substance Abuse Employees are prohibited from using, possessing, selling or distributing drugs or alcohol or other substances at workplace. Where necessary, we may enforce procedures to prevent drug and alcohol use. These can include screening for drugs or alcohol. Your line manager or human resources department can tell you more. If you have an alcohol or drug problem, you should confide with your manager and seek professional help as soon as possible. Failing or refusing to do so will lead to disciplinary action, including dismissal. If you take time off because of drugs or alcohol, we will assess your fitness before you return. You must also agree to follow-up counselling and accept regular medical check-ups and unannounced testing. If you are undergoing treatment, we will respect your privacy as far as possible. If you worked in a safety-sensitive job or location before your treatment, we cannot guarantee that you will return to the same job or location. While it is our policy to help employees with substance-abuse problems, we also have a responsibility to maintain discipline and a safe working environment, and to respond to poor performance, misconduct or excessive absence. Our support for employees can therefore take place at the same time as disciplinary procedures, Always = Be fit and ready to carry out your duties while at work = Come to work free from alcohol or drugs which could affect your performance, client obligations, or which would breach the law or regulations = Tell your manager if you are taking prescribed drugs which could affect your performance at work = Report substance abuse by others Never: = Be in possession of drugs other than those prescribed by a doctor = Distribute or sell drugs, alcohol or alcoholic substances on Teleperformance premises and Property (including transport vehicles and extended workplace) = Misuse drugs or alcohol while on dutyTeleperformance Internal Use Only 10Teleperformance DIBS= We trust our employees to work in our best interests and to protect our reputation. Our Business Personal and business integrity often comes down to common sense: if in doubt be cautious and ask your manager. To do otherwise could damage our business. Fair Competition in Markets Teleperformance as an organization shall: Compete fairly, openly and ethically. Never fix prices or try to control supplies. Support laws that promote and protect competition. Never arbitrarily boycott customers or suppliers or enter into any other anti-competitive agreements, 5. Specifically, not engage in activities, which generate or support the formation of monopolies, dominant market positions, cartels and similar unfair trade practices. 6. Collect information about the competition only in the normal course of business 7. Market its products and services on its own merits and shall not make unfair and misleading statements about competitors, products & services. Not use its influence to intimidate anyone or coerce them into anti-competitive conduct. Be accurate and truthful in anything we say to prospective customers, in bids or in contract negotiations, 10. Meet all contractual obligations through the work we do for our customers Always: "Make sure that decisions about pricing, customers, bids and markets are taken by us alone Make sure there is a legitimate reason for discussions with a competitor, supplier or contractor = Seek legal advice if you are uncertain about how to proceed = Use only publicly available sources to understand a competitor's business * Report any suspicion of anti-competitive behaviour to your respective manager / the company's legal team. Never: = Discuss or agree any of the following with competitors: Fixing prices, discounts or pricing policy, for all or part of a contract ‘+ Trading terms or conditions of contract © Dividing up markets, customers or ter ries ‘© Partnering, with the explicit goal of eliminating all competition, or ‘+ Rigging a competitive bidding process, including arrangements to submit a sham bidTeleperformance Internal Use Only 1Teleperformance DIBS= Working with Suppliers & Third Parties We deal fairly, honestly and transparently with suppliers and third parties, and expect them to be fair and honest too. We select our suppliers on merit and expect them to meet our compliance and ethical standards. We apply consistent procurement processes and keep to our delegated approval authorities. We ensure that our supplier relationships are always based on fair and honest dealing Always: = Follow procurement processes and stay within your delegated authority + Use preferred suppliers = Ensure our supplier relationships are based on fair and honest dealings = Communicate honestly and openly with suppliers = Be clear on our terms of business and keep to them + Raise a Purchase Order before committing to buying goods and services, Never: = Breach your delegated authority = Make a contractual commitment to a supplier until you have all the necessary approvals = Tolerate ethical breaches by suppliersTeleperformance Internal Use Only 2DIeS= Political Activities Teleperformance observes strict political, religious and philosophical neutrality. Accordingly, Teleperformance’s policy is not to make financial contributions to political candidates, elected representatives or officials, political parties, or religious organizations. Teleperformance respects its employees’ right to participate as individuals in the political process as long as they make sure that they do not represent Teleperformance and their activities are not viewed by others as participation by or on behalf of Teleperformance. We respect the authority of governments and maintain honest relationships with them, their agencies, officials and staff. We contribute to public debates about policies that affect our business. However, we are always impartial about party politics. Teleperformance as an organisation shall: = Be committed to and support a functioning local constitution and system, "Not support, directly or indirectly any specific political party or candidate for political office. "Not offer or give any company funds or property as donations, directly or indirectly, to any specific political party, candidate or campaign. If you need to attend a political party’s event for briefing purposes, you should take care that this does not compromise our impartiality. How to behave If you choose to do so, participate in political activities in your own name and outside of work hours and work locations. Never use Teleperformance premises, materials, supplies, equipment or other resources for political activities. Do not use Teleperformance’s corporate image, logos, stationery or other Teleperformance- branded materials to support your political views. Respect the beliefs of others. If you participate in any political decision-making process that addresses any matter related in any way to Teleperformance, its business, industry, clients or employees, you must inform your local Legal Department or Regional Data Privacy Officer and abstain from discussion and voting on such matter. Always: + Make clear you are speaking on your own behalf, if you engage in personal political activity = Ifyou choose to do so, participate in political activities in your own name and outside of work hours and work locations.Teleperformance Internal Use Only 23Teleperformance DIBS= = Respect the beliefs of others. Never: * Use Teleperformance premises, materials, supplies, equipment or other resources for political activities. + Donot use Teleperformance’s corporate image, logos, stationery or other Teleperformance-branded materials to support your political views Examples + I1do some volunteer work for a local political candidate whose policies are very much in line with Teleperformance's values. May | use the copy machine to run off a few flyers? No. Teleperformance prohibits the use of company resources of any nature as well as any participation during working hours to support personal political activities. = Lam active in the local political community where | live. Do | need to disclose these activities to Teleperformance? Disclosure is required only in certain instances. Please speak with your local Legal Department or Regional Data Privacy Officer to find out if disclosure is appropriate in your case. "Ihave been asked to contribute to a political party candidate’s campaign. Am | allowed to make such donations? Yes, as long as the donation is made on your own behalf using your own money. Donations must not be made on behalf of Teleperformance or made to benefit, Teleperformance in any way.Teleperformance Internal Use Only 14Teleperformance DIBS= When someone receives something of value without having paid the fair market value for it, he or she has received a gift. For purposes of this Code of Conduct, travel and entertainment mean giving or receiving something of value, such as meals, drinks, admission tickets, Gifts, Travel and Entertainment transportation, travel costs, accommodation or allowances, without paying for it. Teleperformance requires its employees who engage with clients, prospective clients, business partners, vendors, suppliers and other third parties to follow certain guidelines in considering offering or accepting gifts, travel and/or entertainment. Teleperformance generally permits the giving and receiving of business gifts and entertainment under the following conditions: = They are reasonable in value and frequency; = They are appropriate and customary business courtesies; = They are consistent with laws and lawful business practices applicable in that jurisdiction; "No inference can be drawn that the gift, travel or entertainment could influence either the Teleperformance employee in a business decision or the performance of his/her duties for Teleperformance, OR the business decisions of the person receiving them; "They are proper in appearance and without risk of embarrassment or harm to the reputation of Teleperformance or of the person receiving the gift, travel or entertainment. In all cases, you must keep a written record specifying the type of gift, travel and/or entertainment, its justification, and you must ensure that the gift, travel and/or entertainment cannot be considered to be given with the aim of improperly influencing a decision How to behave Teleperformance employees should not give or accept any lavish or excessive gifts or benefits, whether monetary or non-monetary, directly or indirectly, to or from any government official, tions should never client, supplier, subcontractor or any other third party. Gifts or in influence a Teleperformance employee's business decision or be seen as influencing the person receiving them. Always: = Make sure any gifts or hospitality you offer comply with local laws and regulations = Understand local customs for giving and receiving gifts and hospitality = Use common sense when deciding what is reasonable = Talk to your line manager if you have been offered a substantial gift or hospitality Never: = Solicit gifts, services, benefits or hospitality from customers or suppliers = Offer or accept: © Cash or its equivalent such as cheques, loans, gift certificates, stock or optionsTeleperformance Internal Use Only 15DIeS= © Gifts or hospitality if you think that it may create an undue influence or business obligation ‘* Adiscount that is not available to all employees * Entertainment that is indecent or sexually orientated, that does not comply with Teleperformance’s Values and code or which might adversely affect our reputation Be embarrassed to decline a gift or hospitality Examples have been offered a gift that | think is intended to influence my decision on a Teleperformance business matter. What should | do? Politely refuse the gift and report it to your Local Contact or your Regional Data Privacy Officer. = As part of my job, | organize numerous meetings and trips. Now a hotel where | often book rooms for Teleperformance employees has offered me a free weekend for my parents’ wedding anniversary. Can | accept it? No. Even if you are not personally going to benefit from the gift, accepting the offer gives the appearance of accepting a benefit to influence your business decisions and makes it difficult to remain impartial when you arrange the future hotel accommodation for Teleperformance.Teleperformance Internal Use Only 16Teleperformance DIBS= A conflict of interest may occur when a Teleperformance employee has a financial, business or Conflicts of Interest personal interest or activity that interferes or conflicts, or appears to interfere or conflict, with Teleperformance's best interests or reputation. "Conflict of Interest" generally describes situations where an employee's own interest may influence the way he or she handles company business. It usually involves a situation where an ‘employee or an employee's family members can benefit personally from transactions involving, the company. For example if you employed your spouse / partner / relative as a supplier. While a possible conflict between personal interests and company interests does not always result in damage to the company, its very existence creates an inappropriate condition. Even the appearance of a conflict of interest should be avoided. It is not possible to describe all instances where 2 conflict of interest could occur. There are many situations that are or could be perceived as a conflict of interest, such as: = A situation that interferes with your duties or responsibilities to Teleperformance, or that affects your ability to act the best interests of Teleperformance; = A situation in which you, a family member or friend receives an improper benefit, including money, services or other gain, as a result of your position with Teleperformance; ‘© Sells material, equipment or property to the company; ‘© Renders any service to the company; * Has contractual relations or business dealings with the company * Competes with or engages in a similar business as that of the company. (For this point a formal disclosure of this information must be made to the HR Department / HOD). "A situation in which you learn about a business opportunity through your position at Teleperformance and you, a family member or friend uses it for personal benefit or otherwise against Teleperformance’s best interests. = A situation in which employee uses company equipment, personnel or facilities for personal gain. Financial interests in businesses do not include ownership of stock in corporations listed on a stock exchange or is one the board of directors for corporations which are not in direct competition with our line of business, You are required to make informed business choices in the best interests of the Group. You should avoid any situation in which your personal interests, or the interests of your close friends or relatives, are ~- or appear to be in conflict with Teleperformance’s best interests,Teleperformance Internal Use Only vTeleperformance DIBS= How to Behave When you conduct professional activities, you must act only in the best interests of Teleperformance, and refrain from benefiting or taking advantage of any situation, either directly or indirectly through a third party, for your own gain or that of others. You must identify actual and potential conflicts of interest in advance, and comply strictly with the procedures provided for by Teleperformance in specific areas of operation, such as procurement, subcontracting and business development. You must also comply with the regulations that apply in your country or the country concerned. You must disclose in writing to your manager and local Legal Department all your outside interests or those of your family members that create, or could appear to create, a conflict of interest. Avoid using Teleperformance resources for personal gain or benefit of any kind. This includes Teleperformance office equipment, materials, time, resources and/or intellectual property. Company business must be conducted solely on the basis of merit and open competition. Employees must refrain from actions that might impair their independent judgment or provide an unfair advantage to a contractor. Employees should not indulge in dual employment or perform work or render services for an organisation that competes with the company or with which the company does business without appropriate approval from management. Always: = Be professional and impartial in your relationships with contractors and suppliers + Tell your line manager about any relationships which could create a conflict of interest = Excuse yourself from making decisions that may create a conflict of interest for you = Gain management approval before you start any dual employment Never: = Use your position, contacts or confidential information to benefit yourself or your family and friends = Allow your relationship with contractors and suppliers to influence decisions you make on behalf of Teleperformance = Accept gifts or hospitality that might place you under an obligation "Borrow or take benefit from the company’s customers’ or individuals or firms or vendors with which we do businessTeleperformance Internal Use Only 18Teleperformance DIBS. Examples While performing my job, | discovered a great business opportunity that may be worth a lot of money. May | take the opportunity for myself? If the opportunity is within Teleperformance’s line of work or related to a Teleperformance business partner or supplier, you must disclose the opportunity to your manager, local Legal Department or Regional Data Privacy Officer and follow their advice. You must avoid outside jobs or employment that could affect your performance at Teleperformance. If you are unsure, seek the advice of your Local Contact Teleperformance Code of Conduct ~ May 2018 17 My spouse works for one of Teleperformance’s competitors. We don't talk about work at home, and | cannot see what my spouse does in his or her professional life. Yet some of, my colleagues have suggested | am in a compromising situation. What should I do? This could create the appearance of a conflict of interest. To protect both yourself and the ‘company, you should disclose the facts to your manager, local Legal Department or Regional Data Privacy Officer. In addition, you and your spouse should take steps to ensure that confidential or proprietary information of both companies is protected and not disclosed to the other party. For example, you should not share your Teleperformance log-in or password with your spouse or anyone else. ges vrayTeleperformance Internal Use Only 19Teleperformance DIBS= Influence peddling occurs when a person offers or accepts promises, gifts or any other benefit Influence peddling from another person in order for the recipient to use his or her position or political influence to obtain benefits, employment, tenders or any other favorable decision, typically from a government official or public authority. At Teleperformance, influence peddling is strictly forbidden. How to behave Teleperformance employees should be particularly careful, when they are working on behalf of, the company in matters involving representatives of a government agency or public authority, to ensure that there is no influence peddling or other form of Corruption or Bribery. Examples = am working on an RFP for a tender abroad. | have been told that | should contact a local influential person in the country to get this tender. May | do it? No. You must consult your Local Contact, the Legal Department of the country concerned or the Group Compliance Department to obtain advice as to how to proceed. = Lam involved in obtaining the necessary permits to build a new Teleperformance contact center abroad. | have been told that | should contact a local influential person in that country to get the permits. May I contact this person? No. You should not contact the local person. You must consult your Local Contact, the Legal Department of the country concerned or the Group Compliance Department to obtain advice as to how to proceed. "1am working on the acquisition of a foreign company by Teleperformance. | have been told that the services of an intermediary located in that country are compulsory as part of the procedure for getting the necessary regulatory approvals. What should | do? You must contact your Local Contact, the Legal Department of the country concerned or the Group Compliance Department to obtain advice as to how to proceed.Teleperformance Internal Use Only 20Teleperformance DIBS= Donations, contributions, philanthropy, sponsorship Charitable donations, contributions and sponsorships are gifts given for a charitable purpose or to support a particular charitable or philanthropic cause. A charitable donation, contribution or sponsorship can be in the form of cash, services or new or used goods. It can also include emergency or humanitarian aid, development aid support, and medical care assistance. ‘As a responsible corporate citizen, Teleperformance believes in contributing to the communities where we work by supporting worthy charitable causes, organizations and activities through our Corporate Social Responsibility Committee, How to behave ‘Any charitable donation or contribution to, or sponsorship of, a charitable cause or activity on behalf of Teleperformance must be approved in advance in writing by the Chair of the Corporate Social Responsibility Committee (csr@teleperformance.com) When contributing to a charity or sponsoring a charitable cause or activity on behalf of Teleperformance, the Corporate Social Responsibility Committee must ensure that the recipient is a bona fide charity, appropriately registered or licensed in the local jurisdiction, and that the contribution is in line with our corporate values and policies. Donations or contributions to, or sponsorship of, a charity associated with a government official are not permitted, All approved charitable donations, contributions or sponsorships must be properly accounted for and accurately reported in the company’s books. Example + While at a jobsite, | was approached by a local community member about giving a donation to a local charitable organization. What should I do? You are free to give to charitable organizations on your own behalf using your own money. If Teleperformance is being asked to donate, you should refer the request to your, Local Contact or the Chair of the CSR Committee (csr @teleperformance.com) for further consideration.Teleperformance Internal Use Only 21Teleperformance DIBS= Money laundering is the concealment of the origin or source of illegally obtained money or property, or the process of making illegally-gained proceeds appear to be legal. Money Anti-money laundering laundering also includes assisting with the placement, concealment or conversion of direct or indirect proceeds of a crime or offense. Reverse money laundering is the process of disguising a legitimate source of funds that are to be used for illegal purposes, ‘At Teleperformance, money laundering and reverse money laundering are strictly forbidden. Teleperformance employees must ensure that Teleperformance does not receive or assist in any way with the proceeds of any criminal activity. This could constitute a criminal offense of i. money laundering or reverse money launder Payments must not be made to intermediaries unless the payments are legal, comply with the terms of a written contract and are made following delivery of a proper invoice. No payment may be made without appropriate documentation, including evidence of the work performed, Receipts must be provided for reimbursable expenses. Payments must never be made in cash. How to behave Teleperformance employees must be alert to any unusual or suspicious activity or signs of, money laundering and report this to the Group Finance Department in Paris. When dealing with suppliers, do not wire funds to an account outside the supplier’s country of activity or to a third-party bank account. Do not make payments in a manner that is outside the normal course of business and do not split payments between different bank accounts. When receiving money from clients, be alert to payments from multiple bank accounts, from 2 bank account located in a tax haven, from foreign bank accounts outside the client’s country of activity, an early payment outside the normal course of business, as well as payments made in cash. You must report any such activity to the Group Finance Department in Paris. = Lwas asked by a long-standing supplier to pay a portion of the supplier's invoice by wiring funds to a bank account in the name of someone other than the supplier. What should | do? You must immediately bring this unusual request to the attention of the Group Finance Department in Paris and follow their advice,Teleperformance Internal Use Only 2Teleperformance DIBS= Anti-corruption, Anti-Bribery and Facilitation Payments ‘At Teleperformance, all acts of Corruption, Bribery or Extortion in any form are strictly forbidden. As a global company, Teleperformance must comply with all applicable laws relating to Corruption, Bribery and illegal payments, including the US Foreign Corrupt Practices Act, the UK Bribery Act, the French anti-corruption law known as Sapin I, and other similar anti- corruption laws in the jurisdictions where we do business. These laws generally prohibit the bribery of government officials and private individuals in the conduct of their duties. They also require that Teleperformance keep appropriate books and records, and they establish criminal and civil penalties for violations. We must always conduct Teleperformance’s business in accordance with these laws. Teleperformance employees shall not offer or accept bribes or any other kind of improper payment, including Facilitation Payments. Paying a small sum of money to an official to speed up their actions is known as a facilitation payment. Our position is clear: we will not make facilitation payments and we do not allow others who work for or represent us to make them. However, we do recognise that on rare occasions an employee may be coerced into paying. if your safety or liberty is threatened, then you should pay. In such scenario, it is employee's responsibility to record the payment and the circumstances and report them to his line manager. We also recognise that there are legitimate fees for speeding up some services. An ‘example might be a fee to quickly process a visa application. In such cases the fees should be fixed and published, the payment must be transparent and open, and you must obtain a receipt and record the transaction. In addition, Teleperformance employees shall not provide or accept other objects of value such as gifts, loans, discounts or excessive hospitality expenses, or use the company’s funds to influence a decision under any circumstances. This concern, among others, suppliers, clients, competitors, public authority representatives, political parties, individuals with political exposure, etc. Teleperformance employees must refrain from offering, giving, promising or soliciting, either directly or through a third party, any payment or supply of services, gifts, entertainment or other benefits to obtain or retain business or a competitive advantage. In addition, Teleperformance employees shall not perform any act through a third party that they are not authorized to perform directly. These rules apply to transactions and interactions with government officials, companies and private individuals. How to behave Before entering into a relationship with a business partner, supplier or other third party, you must ensure that the appropriate financial and other due diligence has been conducted on that person or company. Before engaging with a business partner, supplier or other third party, please contact your local Legal Department or Regional Data Privacy Officer for guidance if you are unsure which due diligence and other procedures you must follow.Teleperformance Internal Use Only 23Teleperformance D | BS = oe Always: "Act with honesty and integrity and encourage others to do the same = Understand the risks of bribery and corruption = Report any concerns about bribery and corruption within Teleperformance or in our dealings with others Report a facilitation payment = Report any payments made due to extortion Be cautious when giving or receiving gifts or entertainment (see the section on Gifts and Hospitality) Never: = Offer, accept, solicit or pay a bribe or facilitation payment = Use agents to offer or accept bribes or facilitation payments + Do anything to encourage someone else to break these rules Examples = Ihave been told that hiring a local “consultant” could help us get all the necessary permits we need from a foreign government. This consultant requested a large retainer and said that he would use the money to “help move the process along”. Can | advance this retainer? Who should | contact? No. You must not pay any retainer or any other sum until you have made sure that no improper payments are being made and you know exactly what services are being provided. You must consult with Teleperformance senior management. = 1am responsible for setting up new offices and the local authorities have requested a payment before installing our phone lines. What should | do? You must not make this payment unless it corresponds to legitimate fees relating to phone line installation Payments must not be made to intermediaries unless the payments are legal, comply with the terms of a written contract, and are made following delivery of a proper invoice. No payment may be made without appropriate documentation, including evidence of the work performed, and receipts must be provided for reimbursable expenses. Payments must never be made in cash. + | am attending an international trade show where Teleperformance is one of the exhibitors. We plan to give away Teleperformance-branded promotional materials, and | may invite some of the visitors, who may be government officials, out for drinks. Will | be in violation of anti-corruption laws? Providing promotional materials to our clients is a legitimate expense when the materials are designed to demonstrate or explain our products and services as part of a trade show. Some anti-corruption laws and/or government policies may prevent you from providing any hospitality whatsoever to a government official, so you should ask the government official whether he or she is entitled to accept your hospitalityTeleperformance Internal Use Only 24DIeS= Generally, no matter who your guests are, you must always be careful to ensure that the expenses are moderate and comply the instructions in the “Gifts, travel and entertainment” section of this Code of Conduct. In all cases, you must keep a written record specifying the type of gift or hospitality and its justification, and you must ensure that the gift or hospitality cannot be considered to be given with the aim of improperly influencing a decision.Teleperformance Internal Use Only 25Teleperformance DIBS= Teleperformance as an organization shall strive to provide a safe and healthy working environment and comply, in the conduct of its business affairs, with all regulations regarding the preservation of the environment of the territory it operates in. All employees to adhere to, BCP/DR rules & regulations as laid by Teleperformance. Health, Safety and Environment We want to help build a better world for future generations. So we treat the environments we work in and the people we work among with care, respect, and thoughtfulness. We attempt to prevent environmental damage and minimise our use of energy and resources. Inside Information Inside information is information: "About Teleperformance, or other companies we are negotiating or doing business with © That is not generally known to the public, and ‘© That if generally known to the public, would: - Probably affect the price of Teleperformance’s shares or the shares of another ‘company, or Influence a person's or client's investment decision Examples of inside information include our full-year or half-year financial results, a major new contract or an acquisition or business disposal If you regularly or periodically possess inside information or have it because of a project you are working on, then you are an Employee Insider. The Company Secretary will tell you this in writing. Employee Insiders cannot deal in company shares without written approval. We are required to keep a list of Employee Insiders and may have to disclose it to the regulatory authorities. Insider information must not be used for insider trading, for our own or anyone else’s benefit. Always: = Inform your line manager if you discover information that you believe to be potentially price sensitive information = Gain approval, as an Employee Insider, before you deal in Teleperformance’s shares Never: = Act on or disclose inside information + Pass on inside information or encourage another person to deal in any company’s shares Cn the basis of it, even if they do not directly profitTeleperformance Internal Use Only 26Teleperformance DIBS= It’s the job of every one of us to protect the information and ideas that give us our competitive advantage. Our Information Confidential Information and Records We deal with confidential and sensitive information on behalf of the clients we service and our, business operations every day. We are responsible for protecting the information, which we have accessed, and to be alert to any instances of an unsolicited approach or misuse. Your use of confidential information must comply with our policy and the law. Any violations or breach, whether intentional or inadvertent, should be reported to Teleperformance. These include: "To protect our informatio ‘a consistent and appropriate manner, it is important that we classify and clearly mark the information so that we are all clear on its importance. = Any entry or exit of sensitive information to or from the premises (temporarily or permanently), either physically or electronically has to have prior approval. The same has to be recorded with the Security and Department Head. = All information handled within the company should be adequately labelled, sorted, and stored up to defined expiration date. = All documents, files, records, customer details, client data, project plans, strategies, developments, execution process, quality metrics, etc., relating to the business of Teleperformance, its clients and customers, that is proprietary to Teleperformance, or its clients shall be deemed to be “Confidential information”. + Confidential Information is to be strictly confidential and no employee shall, directly or indirectly, make known such confidential information (either physically or verbally or electronically) to any person or entity or permit such confidential information to be disclosed or made known to any person or entity, in each case either inside Teleperformance or otherwise. = Every employee should faithfully and diligently protect such confidential information from being disclosed to unauthorized persons. Such persons include, but are not necessarily limited to, persons who are not Teleperformance employees, persons who are Teleperformance employees but who do not have a need to know the confidential information in order to perform their duties, persons not under a written confidentiality agreement with Teleperformance in regard to the confidential information, and persons not directly aware of the proprietary and trade secret nature of the confidential information. = All documents, files, records, project plans, strategies, customer details and items of information or equipment relating to Teleperformance’s business are and shall remain the property of Teleperformance, including notes, documents, and files created in the performance of duties of employment. = All documents, files, records, and items of information relating to Teleperformance’s business, clients and customers shall not be altered, modified, or deleted unless authorized by the authorised person or respective Head of Department.Teleperformance Internal Use Only 27DIeS= If you leave Teleperformance to work elsewhere, you must not reveal confidential information about Teleperformance. Similarly, if you previously worked for a customer or competitor, you should keep the information you obtained there confidential. It is never acceptable to coerce someone into divulging confidential information about a previous employer. Our policies and the law require us to keep certain types of information for specified periods. You must make sure you know and follow these requirements. Always: + Follow all information security, data protection and retention rules that apply where you work + Protect information and records from unauthorised accessor interference * Use confidential information only for the purpose for which it was intended * Understand the legal restrictions on moving information, particularly outside its country of origin = Retain information in line with retention requirements Never: = Leave sensitive information lying around or unsecured = Discuss confidential information in public = Disclose confidential information to a new employer = Disclose confidential information about your former employers = Conceal, alter, destroy or tamper with company records = Share confidential information of the company and its clients / customers to any external person or company for any reason what so ever.Teleperformance Internal Use Only 28Teleperformance DIBS= We are expected to carefully manage the way we use IT equipment, passwords and logins. We must also accurately classify our information and dispose of it properly. Securing Information and Using Our Systems We must protect valuable information from unauthorised disclosure, modification or deletion. We also respect people's right to keep their personal data private, You must ensure that the following are encrypted before you use them: = Personal computers (PCs) which are not used wholly within = our secure premises = Portable PCs and devices, and = Removable media, You must not: = Connect non- Teleperformance or Private IT equipment to Teleperformance or customer networks without your IT department's permission. + Intentionally introduce viruses, Trojans or other malicious programs into systems belonging to us, our customers or our partners. * Download software from the Internet and install it upon the company computer equipment. "Use company’s computer to make unauthorised entry into any other computer or network. * Dispute or interfere with other computer or network services or equipment. * Use internet access to transmit confidential, political, obscene, threatening or harassing materials = Attempt to bypass or modify company’s fire wall security and settings. You must keep your login details safe. If you believe your password has been used without your knowledge, you must change it and report it to your line manager or IT department. You must maintain appropriate privacy for our information and ensure it is classified in line with Teleperformance, or where agreed, your customers’ standards. If you handle a customer's information, you must use the customer's classification. If the customer does not specify a classification, then use Teleperformance’s classification. You must not disclose information with a protective marking to any person who does not have the right or need to know. You should only copy it onto removable media when there is a significant or unavoidable business need and the removable media is encrypted. If you are electronically transmitting the information outside Teleperformance, then you should encrypt it. We can only hold personal information if we are legally entitled to. You should not provide information about Teleperformance employees, our customers or partners to any third parties, unless you are authorised and permitted,Teleperformance Internal Use Only 29DIeS= You must dispose of any media (for example printouts or discs), in a way which protects it, against unauthorised access to the information on the media. You must permanently remove business-sensitive and personal information from devices prior to their disposal or reuse. Always: = Keep your passwords and other login details safe = Maintain appropriate privacy levels for information = Use encrypted computers, devices and removable media = Lock your PC when you leave it unattended = Consider the security of documents, PCs and IT equipment when travelling Report the loss of any laptop, mobile phone, PDA, removable media device or any paperwork that contains confidential, customer or personal data Never: Use a password that does not meet our guidelines = Log on to an Teleperformance or customer system using someone else’s password or log ‘on someone else using yours Write down or disclose your username, password or any other access code or use someone else’s. Including such information related to customers, ‘Attempt to crack or capture passwords or decode encrypted information = Remove or disable our anti-virus software and malware controls, Use an unencrypted computer or device outside secure Teleperformance premises Leave PCs or other IT equipment in an unattended vehicle for a long period Disrupt network communications, interfere with service to others or change an information system so others cannot use it Unless as part of authorised security activities: * Access or transmit information about, or software designed for, breaching security * Create computer viruses, or * Monitor or intercept network trafficTeleperformance Internal Use Only 30Teleperformance DIBS= We want our employees to access, process and publish information in ways that meet our Business Communications and Technology professional, social, ethical, legal and security requirements, while protecting our reputation. Email - Business Communication tool: Email is a business communication tool and users are obliged to use this tool in a responsible, effective and lawful manner. Although by its nature email seems to be less formal than other written communication, the same laws apply. "If you send/forward emails with any libellous, defamatory, offensive, racist or obscene remarks, you and Company can be held liable. If you receive an e-mail of this nature, you must promptly notify your supervisor. "Ifyou unlawfully forward confidential information, you and Company can be held liable. = Ifyou send an attachment that contains a virus, you and Company can be held liable. = You must only use company email addresses and messaging systems for company business. = You must attach our standard disclaimer to the end of each email you send from our system, = You must be vigilant for suspicious emails and messages, delete them immediately and report them to your IT department. You must not: = Send anonymous emails or messages from company systems. = Forward a message without acquiring permission from the sender first. "Send unsolicited email messages including advertising material ("spam"), chain letters, Ponzi or other pyramid schemes of any type. = Use company email to harass, threaten, take undue advantage, and demean etc other employees, clients and external public. = Use company email or company media to campaign, voice opinion, start or ilicit a chain response on any political, misanthropic, terrorism, ete = Forge or attempt to forge email messages and company correspondence. = Send email messages using another person's email account, = Divulge any client data / sensitive authentication data over emails + Use external email accounts (such as Hotmail, Yahoo and Gmail) instant messaging or text messaging systems to transfer information with, sensitive information owned by or relating to customers and Teleperformance Although Company's email system is meant for business use, the Company allows the reasonable use of email for personal use as long as it does not interfere with work.Teleperformance Internal Use Only 31DIeS= We may monitor your use of the internet, email, messaging and other information systems for security and compliance purposes. This may include scanning all your email messages and attachments for unsuitable content. We may use any information we receive through monitoring to investigate breaches of this, standard or any law, and to instigate disciplinary or legal proceedings. We provide you with computer technology to make our processes and communication more efficient and effective, without replacing personel contact.Teleperformance Internal Use Only 32Teleperformance DIBS= The following are company property and you should only use them for their intended purposes: * Our computer hardware and software + The information on our systems, and ‘Any Teleperformance information on your home or other non- Teleperformance system, Internet Usage = The company provides Internet access to its staff to assist them in carrying out their duties for the company. It should not be used for personal reasons. = Personal use of the Internet is only permitted on a strictly limited basis and only with the specific approval of your supervisor or manager. You may only access the Internet after you have been authorised to do so by your Head of Department in writing and by using Teleperformance’ s content scanning software, firewall and router. = All legal protections to data and software provided by licenses and copyrights are to be respected You should not at any time access or download inappropriate materials, including non- business related materials or extreme material such as pornographic, racist, anti-social, or extreme political nature or which incites violence, hatred or any inappropriate or illegal activity = You should not browse personal web mails unless permitted only on a strictly limited basis with the specific approval of the Information Security Manager. = You must take care not to infringe the copyright of third parties when downloading materials or forwarding the same to others, You should ensure that all information which is posted on the organization’s website is accurate and up-to-date. Always: "Use computer hardware, software and the information on our systems responsibly and for business purposes = Ensure your personal internet use does not affect your work = Ensure our standard disclaimer is attached to your emails Never: = Make calls or send texts which are abusive or unprofessional = Call premium rate numbers, except for business reasons = Make private international calls, unless you are abroad on company business = Conduct any unapproved private employment or business activities + Distribute, showcase, store, view, print or access any pornographic, obscene, indecent, hateful or other offensive material (for example material that is racist) or anti-social or against the local governmentTeleperformance Internal Use Only 33DIeS= Engage in any illegal activity, including fraud, plagiarism, forgery, or any form of intimidation or harassment Download, store, copy or transmit the works of others (including software, games, MP3 music and video files) without their permission, as this may infringe copyright Participate in online gambling, or soliciting for personal gain Disable company security measuresTeleperformance Internal Use Only 34Teleperformance DIBS= Social media provides new opportunities for business, communication and collaboration, and Social Media new obligations for us to protect our people and reputation. Social media includes sites such as MySpace, Facebook, YouTube, Linkedin, Twitter, blogs, wikis, newsgroups and others where you can post text. We recognise that you may use social media for self-expression and that in some circumstances Teleperformance’s interests can be supported through these channels. Social media use shouldn't interfere with your responsibilities at TP DIBS. TP DIBS's computer, systems are to be used for business purposes only. When using TP DIBS's computer systems, use of social media for business purposes is allowed (ex: Facebook, Twitter, TP DIBS blogs and Linkedin), but personal use of social media networks or personal blogging of online content is discouraged and could result in disciplinary action You should get appropriate permission before you refer to or post images of current or former employees, members, vendors or suppliers. Additionally, you should get appropriate permission to use a third party's copyrights, copyrighted material, trademarks, service marks or other intellectual property. You should be aware that TP DIBS may observe content and information made available by you through social media. You should use your best judgment in posting material that is neither inappropriate nor harmful to TP DIBS, its employees, or Customers. Although not an exclusive list, some specific examples of prohibited social media conduct include posting commentary, content, or images that are defamatory, pornographic, proprietary, harassing, libellous, or that can create a hostile work environment. Social media networks, blogs and other types of online content sometimes generate press and media attention or legal questions. You should refer these inquiries to authorized TP DIBS spokespersons You are responsible for everything you publish on social media. if you identify yourself as a Teleperformance employee, then: * Your profile and content must be correct and consistent with the way you would present yourself and Teleperformance to colleagues and customers = You must not post indecent, offensive, discriminatory or defamatory content = Your content must respect all religious, political, economic and racial differences and opinions = Your content must respect others’ privacy, and "Anything you state as fact must be correct and fair, and where you make mistakes, you must correct them as soon as possible. If you publish anything about Teleperformance, you must make clear that the views are yours and do not represent those of Teleperformance. You must comply with our requests not toTeleperformance Internal Use Only 35Teleperformance DIBS=: discuss topics related to confidentiality, customer, job profile or legal aspects. You must also comply if we ask you to remove information which breaches legislation, regulations or our policies. Where authorized and appropriate for your work, you may publish material on social media sites which refers to Teleperformance or uses our name, providing you: "Behave professionally = Do not harm the reputation of Teleperformance and our employees "Check the privacy settings, to ensure that your posts do not compromise your identity, location or other personal details in a way that could put you, your colleagues, the ‘company or our customers at risk. If you publish Teleperformance information on the internet, you must comply with the Corporate Communications team’s guidelines. You must keep the material up-to-date and not compromise our intellectual property, misrepresent us or communicate in a way which may harm our reputation. If you find online material about Teleperformance which is wrong, unfair or defamatory, you should tell your line manager or communications team, Always: = Ensure you publish material which is correct and fair = Make it clear that you have published information in a personal capacity and that it does not represent Teleperformance’s view = Remove information you have published which breaches legislation, regulations or ‘company policy Never: "Publish information that could compromise the security of you, the company, colleagues or customers = Publish a selfie or photo with company lanyard, ID Card, uniform or logo = Publish the name of the client or process working or post comments " Co-branded "Publish, post or release any information that is considered confidential or not public. If there are questions about what is considered confidential, you should check with the Human Resources Department and/or supervisor You are strictly prohibited from publishing comments, pictures, judgement, feedback related to any Customer or Customer's client or release any information that is considered confidential or not public.Teleperformance Internal Use Only 36Teleperformance DIBS= ur reputation is affected by what people hear about us, either directly or through the media. Any written or verbal statements by the company impact all stakeholders including customers, financial analysts, brokers, policy makers & the regulator. So what any of us say really matters and we therefore don’t start rumour or talk idly. All external communications shall be done and routed by the external communication team and authorised representatives of the ‘company. External Communications We must therefore make sure that our external communications are co-ordinated and consistent, This includes: "Any financial information on the company will be limited to as permitted by the CFO. Forecasts and future projections will not be communicated in external communiqués as a standard policy. * Announcements on growth and market share will be based on declared figures by industry bodies like NASSCOM Achievements, market success, rewards and recognition announcements will be made quoting the source of such claims. = In reply to questions on Competitor's strategy, our standard stance should be that we hold them in high esteem and that it would be inappropriate on our company's part to express any opinion about the same. Press meetings and conferences shall only be addressed by the authorised business heads {CEO /MD/ Group COO / CSO / CHRO). Any exception to this needs the prior approval of the ceo. Get approval from your line manager and external communications manager before accepting, representation on behalf of Teleperformance for external presentation and speeches. Employees must refrain from making any comments on below topics/items which are classified as “Restricted”, under all circumstances: = Information about any aspect of any potential public offering in India or overseas. "Information on the operational or financial position of the company that has not been made public "Information on the prospects of the company or its subsidiaries. Statements with respect to any projections on performance, forecasts or opinions. "Any proposed acquisitions or mergers. = Client contracts, MSA, SLA, process procedures = New areas of business. "Any Company related information, which an employee becomes privy to, during the discharge of one's duties.Teleperformance Internal Use Only 37Teleperformance DIBS= = Ensure information is accurate and complete, and get approval before disclosing it. = Promptly forward requests from the media or other organisations to your divisional ‘communications manager or corporate communications. = Report any unintended disclosure of information, such as loss or theft. Always: = Keep a record of all actions, decisions and communications during a critical event. Never: = Make false or misleading claims. "Provide information to investors, analysts and associated media unless approved by Investor Relations. "Make use of any mass media for vindication of your grievances either individually or collectively. = Speak on behalf of Teleperformance, if you are nat authorised to "Participate in any discussion/ interview as a representative of Teleperformance without prior written consent of the management / external communications manager. "Share any information directly except when these have been cleared by external communications, in discussions with the CEO/MD/Group COO/ CSO / CHRO. "Share plans on manpower hiring and manpower planning, employee salaries, internal budgets, sales targets or terms, any of our strategic or financial partners, any information whatsoever on the valuation of the company or its brands, any information on the company’s plans to tap the foreign equity market, the probable size, lead managers, underwriters etc; unless approved by external communications and the relevant authorised person. + Give out stories / information to any online media (websites) especially those which are based overseas or have a strong overseas presence, = Solicit articles or contributing pieces in national and international media without the approval of external communications team. = Comment on any topic classified as “Restricted Information”.Teleperformance Internal Use Only 38Teleperformance DIBS= Enforcement of the Teleperformance Code of Conduct; Disciplinary sanctions Any Teleperformance employee who has attempted to breach or has breached this Code of Conduct, whether by negligence or wilful misconduct, will be subject to disciplinary sanctions: in accordance with applicable laws and regulations, including administrative measures and criminal penalties, as well as disciplinary sanctions provided for in the Internal Regulations of the company of which he or she is an employee or corporate officer.Teleperformance Internal Use Only 39Teleperformance DIBS. ue aes oe ay Teleperformance encourages a culture of openness where each person may raise concerns and views about our Code of Conduct and be confident that they will be heard by management. We are all responsible for ensuring the application of and compliance with this Code of Conduct. We understand that you may have concerns about certain practices and need advice and guidance in order to make sure that you comply with this Code of Conduct. If you need guidance on any topic related to this Code of Conduct, please contact your manager. If you believe that informing your manager may present difficulties or that the reported irregularity would not result in appropriate follow-up, the Ethics Hotline is another method for reporting potential breaches. There are several ways of reporting suspect behaviour: Contact one of the following people: = Your local Chief Human Resources Officer = Your local Chief Legal Officer = Your Regional Data Privacy Officer "The Chief Executive Officer for your country = The Regional Chief Executive Officer for your region 2. Use the Ethics Hotline We encourage Teleperformance employees to use the Ethics Hotline to report when they personally, acting in good faith, reasonably and selflessly, believe that wrongful business conduct has taken place, is taking place or is about to take place. Reports made through the Ethics Hotline will be investigated in accordance with the procedures set forth in the Ethics Hotline Policy. No retaliation will be made against anyone who in good faith, reasonably and selflessly reports wrongful business conduct through the Ethics Hotline, subject to the terms of the Ethics Hotline Policy and applicable laws and regulations. Any employee who reported through the Ethics Hotline and believes he or she is being subjected to retaliation should report this via the Ethics Hotline or can report by e-mailing it to below mentioned e-mail id: Teleperformance.com/EthicsHotline or call on the Regional number (toll free) at 000 800 040 1846, Reports will be treated with confidentiality within the limits of the law. The Ethics Hotline Policy and information about the Ethics Hotline are available on the intranet. Vinod Mehta Chief Human Resource Officer DeesTeleperformance Internal Use Only 40Teleperform: jance teleperformancedibs.com BB inkedin.com/company/tpdibs BB tecxdo0k coms? 0105/ V wiercom/rPoies Instagram com/tpelbs/ © outube-comfuserfndTeleperformance @ inteteperformancebiog.com