HR Policies

Focus Edumatics Private Limited

Table of Contents

Section Page No.

1. Welcome 2

2. Recruitment Policy 3

3. Workplace Commitments 10

4. Company Policies and Procedures 11

5. Attendance Policies 15

6. Leave Policies 16

7. Work Performance 20

8. Discipline Policy 21

9. Employee Health and Safety 23

10. Employee Benefits 23

11. Separation & Full and Final Settlement Policy 27

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1. Welcome

Vision, Mission & Goals Vision

o Empowering students to succeed on a global scale

Mission

o Incorporating new Technologies and Approaches to learning, and blending them with our methods

o Partnering with business leaders, and offering innovative learning solutions to improve and measure learning outcomes

Goals

o Analyzing issues and challenges faced in the field of education o Addressing the requirements in various fields of education

We are a customized e-learning solutions provider, offering Content, Media, and IT-enabled Services (ITES) for Publishers of educational materials, catering to K12, Higher Ed, Professional Development and Corporate Learning segments.

We offer our clients, the benefits of Quick Turnaround, Cost Effectiveness, Quality, and Innovation ensuring the most appropriate solutions for their needs across projects. We develop large-scale assessments for subject disciplines, high stakes tests, and digital content across grades, and assessment tagging. Developing interactive games, designs, digital animation, and videos is our forte! We provide technology-enabled solutions such as CMSs, LMSs, and assessment engines. The variety of projects we handle teamed with the innovation and solutions architecting experience we’ve gathered has helped us create a niche in the e-learning/m-learning sector.

The Focus Edumatics will execute the business as per the following flow chart

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Our Registered office is situated in Mumbai and Operational unit is in Bengaluru and branches in Coimbatore, Mohali. Our core business is E-Learning and Online Tutoring, we provide services to U S Clients. 1.1. Purpose of this Policy Handbook This Policy handbook is prepared to inform the employees about the policies and procedures of this company and to establish the company’s expectations. It is not all-inclusive or intended to provide strict interpretations of our policies; rather, it offers an overview of the work environment. This handbook is not a contract, expressed or implied, guaranteeing employment for any length of time, and is not intended to induce an employee to accept employment with the company. The company reserves the right to unilaterally revise, suspend, revoke, terminate or change any of its

policies, in whole or in part, whether described within this handbook or elsewhere, in its sole discretion. If any discrepancy between this handbook and current company policy arises, conform to current company policy. Every effort will be made to keep you informed of the company’s policies, however we cannot guarantee that notice of revisions will be provided. Feel free to ask questions

about any of the information within this handbook. This handbook supersedes and replaces any and all personnel policies and manuals previously distributed, made available or applicable to employees.

1.2. At-Will Employment

Employment at this company is at-will. An at-will employment relationship can be terminated at any time, with or without reason or notice by either the employer or the employee. The at-will employment status of each employee cannot be altered by any verbal statement or alleged verbal agreement of company personnel. It can only be changed by a legally binding, written contract covering employment status. An example of this would be a written employment agreement for a specific duration of time.

2. Recruitment and selection policy Introduction Recruitment and Selection aim is to search and hire suitable candidate to fill vacancies in Focus with the view to satisfying human resources needs. The search may be internal and/or external. Any position within Focus that becomes vacant will be filled, on completion of a Manpower Requisition Form by the immediate supervisor. Restructured on newly created positions will only be activated upon approval from the board. The success and adaptability of a Company depends upon the recruitment of employees who are flexible, adaptable and committed to the success of the Focus Group.

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2.1. Objectives This section aims to promote and maintain high standards of professional recruitment practice by encouraging recruiters to adhere to best practices. Its purposes are to: Ensure that recruitment is considered an essential part of the human resource Strategy and consequently an integral part of the overall business strategy; Ensure and explain best practice for all types of recruitment; And maintain professional standards whether recruits are easy to find; Ensure that equality of opportunity is considered an integral part of good recruitment practices and procedure; 2.2. Recruitment Authorization Procedure Authorisation All authorisation procedure detailed below must be completed prior to the commencement on any recruitment procedure. Prior to the employment of any employee the Employment Authorisation Form (Appendix 2) must be completed. The employment of all individuals for budgeted positions within Focus must be authorized by the Department Head and President. Employment of Personnel to the position of Manager of Departments will require the authorization of the President. 2.3. Procedure The Reporting Manager will raise the job proposal in HRMS. The Reporting Manager is responsible to create Job Description which matches his requirement. The Department Head will approve the proposal and shall update the comments in HRMS and instruct commencement of Recruitment. The Human Resources Department will start sourcing the candidates according to the Job Description and schedule the interview based on the availability of the interviewer.. 2.4. Employment procedure The Human Resources Officer shall receive all applications for employment and shall acknowledge receipt thereof in writing. All applicants for employment shall be addressed to the Human Resources Officer.

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The Human Resources Officer shall sort all applications that meet the minimum appointment requirements as advertised, and then forward these applications to the Department Manager concerned, together with a full list of all applications received. The Department Manager, in consultation with the Human Resources Officer, shall draw up the shortlist of candidates for interviewing. The Human Resources Officer shall invite the short listed candidates for interviews, and will ultimately make a recommendation to the President for appointment. Focus shall bear subsistence and travel and travel expenses of short listed candidates from places other than the duty station. A summary of the interviews shall be prepared by the Human Resources Officer and kept for record purposes. The Human Resources Officer shall ensure that Reference Check on shortlist candidates is done, and then the employment offer is issued in consultation with the relevant Department Manager to the selected candidate, which upon acceptance shall be followed by an appointment letter signed by the President. Once the selected candidate has accepted the employment offer, the Human Resources Officer shall send regret letters to all the unsuccessful candidates. 2.5. Employment interview panel The Employment Interview Panel shall be provided with the ground rules of and procedures for interviewing (by the Human Resources Officer) prior to the actual commencement of interviews. The Panel shall consist of the following persons: The Reporting Manager concerned The Department Manager The Human Resources Officer For Management Positions the President as well as a selected Board Member shall attend 2.6. Appointment All staff will be appointed by the Focus group of companies.

2.6.1. Letter of Offer The letter of offer will inform the candidate of his/ her selection. It will contain details of the post, grade and scale of pay being offered to the candidate. It will also contain any special terms and conditions of appointment. The letter will also contain the proposed day and date of joining, intimation of the address of joining and how to get to the address. The selected candidate will send a copy of the letter duly signed indicating that he/ she will join on the appointed date and time. If certain terms are unacceptable to him/ her, then he/ she may inform

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accordingly so that negotiations may be conducted, if required. The letter of Offer duly signed by the selected candidate (after all negotiations are over, if required) will constitute the Letter of Acceptance. Letters of Appointment: The objective of the appointment procedure is to ensure that the employee completes all formalities before he is given the formal appointment letter

2.6.2. Objectives

The objective of the appointment procedure is to ensure that the employee completes all formalities before he is given the formal appointment letter.

2.6.3. Procedure The procedure for appointment will consist of the following steps

o Joining report o Check of Certificates o Check of age of candidate o References o Secrecy Bond o Appointment Letter o Employee Personal File

Each of these steps is outlined in following sections: Joining report The prospective employee shall report to the HOD-HR on the appointed date. The HOD HR will then take the employee through the appointment procedure. Check of Certificates The appointing authority will check the certificates of the prospective employee. These will include his/her academic and other certificates as well as past experience certificates. These will be cross-checked with the information mentioned by the candidate in the application form. Check the age of candidate The appointing authority will also check the age of the candidate through his/her school leaving certificate and cross check it with the age mentioned in the application form. One of the following documents will be deemed to be satisfactory proof of the age of the employee at the time he/she enters the society’s service: - Matriculation or School Leaving Certificate or - Birth Certificate An employee, who is unable to produce documentary evidence of his / her age, will produce an affidavit regarding his/her age. Such employees will be sent to the Society’s authorized medical officer free of

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cost for examination and the medical officer’s assessment regarding the employee’s age will be binding on the employee. The age of an employee as recorded with the society at the time of his/ her employment will not thereafter be altered.

2.6.4. References The prospective employee will be asked to furnish names and address of three references who have known him/ her for more than two years. The HR department will send reference sheets to them and get their responses on the person’s qualifications, abilities and other traits.

2.6.5. Non-Disclosure Agreement

The prospective employee will also sign a Non-Disclosure Agreement such that any confidential information is not leaked out.

2.6.6. Appointment Letter

After all the above steps are completed the HOD-HR will issue a formal Appointment Letter to the selected candidate, duly signed by the HR Head. A formal identity card with the employee’s name, number, photograph and signature will be issued. The HR department will also arrange for visiting cards of employees above a certain grade. The employee will have to indicate the manner in which his/ her name should appear and verify the spelling.

2.6.7. Employee Personal File

As soon as an employee joins the society, a personal file will be opened on his/ her name. This file will be kept confidential and will be maintained and be under the care of the HR department which consists of the following 1. Joining report 2. Ratings of Test and/ or Interviews 3. Photocopies of Academic Qualification Certificates 4. Photocopies of past employment certificates 5. A record of the date of birth 6. 7. 8. Signed copy of the Non-Disclosure Agreement. 9. All correspondence before joining including copies of the letter of Offer, Letter of Acceptance, and Appointment Letter 10. Emergency contact number and address, subsequently the following will be added to the employee personal file 11. Copies of the payroll changes including promotion 12. Special work assignment, training etc. 13. Transfer records 14. Disciplinary action information 15. Long leave taken 16. Performance Appraisal Forms.

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The above records will be updated as and when any changes take place. Job Description: On appointment, an employee shall be given a job description. This shall specify the scope and terms of reference for their position. Each member of staff is expected to devote their time and attention to their work and not engage in activities that may conflict with Focus’s interests or negatively affect their performance. Job Descriptions shall be reviewed yearly. Probation: Probation offers a period of mutual testing during which decisions about a staff member’s ability to satisfy the requirements of the position can be evaluated. In turn, the Employer has an opportunity to assess the full potential, competencies and capabilities of the employee and a responsibility to assess whether or not the employee possesses satisfactory qualifications and suitability for regular employment. The length of the probation period varies from 3 to 6 months and it can be extended i.e. depends on the employees performance. At the meeting of the original selection committee for an appointment, the committee shall determine the probationary period and record the specific goals to be met to support confirmation of appointment. These are conveyed to the appointee in the letter of offer, and include the satisfactory performance of relevant duties for the level of position, as outlined in the Position Classification Standards and the position description attached to the letter of offer. During Probation Period immediate Senior or Operations manager shall evaluate the employee and judge his/her

o Work Performance o Punctuality, Sincerity towards work o Commitment o Team Player Traits o Productivity o Attitude o Attendance o Learning & Tasking Skills

Confirmation of appointment: You may be confirmed based on recommendation from Department Head after completion of Probationary Period or it may be further extended if probationary period is not meeting the expected Productivity in terms of the work assigned to you during the probationary period observed by the Department Head. Your confirmation will be in writing by the HR Based on the recommendation by the Department Head. Duration of employment: Unless otherwise stated, employment for all staff shall be on permanent basis subject to satisfactory completion of the probation period and availability of funds. 2.7. Personal Data On acceptance of an appointment, the new staff member is required to complete the Employee Personal Data Form. New employees must also furnish Focus with a declaration of dependants, that is spouse and own children; next of kin and provide photocopies of certificates and other testimonials.

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Any changes in personal status shall be reported promptly to the Human Resources Officer by completing a fresh Personal Data Form. Staff records and related correspondence shall be treated confidentially at all times. 2.8. Induction Definition Induction is the process of familiarizing a newcomer to the organization with the job Surroundings and the organization itself. Objectives The objectives of Induction are as follows:

o To help integrate the new employee into the social pattern of the organization o To minimize the amount of disruption caused in the organization by the change in command o To introduce the new employee to all key people in the organizational society o To explain the customs of the organization o To help the new employee to identify with the organization and its procedures and give them

some feeling for the significance of the work he/ she will be doing o To help overcome fears and anxieties that arises in a new job o To provide information about the organization’s rules and HR policies, introduce fellow workers

and give him/ her idea of how his/ her job fits into the overall operation of the organization.

2.8.1. Procedure

The procedure of induction will consist of the following steps:

o Orientation of New Employee o Introduction to the Society o Advice to Various departments o Introduction to the employees of the Society o Induction Training o Issue of Identity Card and Visiting Cards

Each of these steps is outlined in the following sections:

2.8.1.1. Orientation of New Employee

The Human Resources Department will plan an induction program, in consultation with the departments concerned for newly inducted employees, based on the experience and grade. The employee will be given his/ her induction program with the schedule for the next few days or weeks.

2.8.1.2. Introduction to the Society

The newly introduced employee will meet the HOD-HR. The latter will explain to him/ her Society’s mission, objectives, culture and organization structure. If possible a small booklet will be prepared incorporating the above aspects of the society.

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The HOD-HR will also ensure that the employee receives a booklet giving the important service rules/ terms and conditions of employment. The employee should also be informed about the allowances and benefits to which he/ she will be entitled and any other information relevant to the employee.

2.8.1.3. Advice to Various departments The HR department will inform the relevant department heads of the appointment of the new employee. This must include HOD-Finance as well as the HOD of the concerned department.

3. Workplace Commitments

3.1. Equal Opportunity Employment

This company is an equal opportunity employer and does not unlawfully discriminate against employees or applicants for employment on the basis of an individual’s race, color, religion, creed, sex, national origin, age, disability, marital status, veteran status or any other status protected by applicable law. This policy applies to all terms, conditions and privileges of employment, including recruitment, hiring, placement, compensation, promotion, discipline and termination. 3.2. Non-Harassment Policy / Non-Discrimination Policy

This company prohibits discrimination or harassment based on race, color, religion, creed, sex, national origin, age, disability, marital status, veteran status or any other status protected by applicable law. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and is free from discriminatory practices, including, without limitation, harassment. Consistent with its workplace policy of equal employment opportunity, the company prohibits and will not tolerate harassment on the basis of race, color, religion, creed, sex, national origin, age, disability, marital status, veteran status or any other status protected by applicable law. Violations of this policy will not be tolerated. Discrimination includes, but is not limited to: making any employment decision or employment-related action on the basis of race, color, religion, creed, age, sex, disability, national origin, marital or veteran status, or any other status protected by applicable law. Harassment is generally defined as unwelcome verbal or non-verbal conduct, based upon a person’s protected characteristic, that denigrates or shows hostility or aversion toward the person because of the characteristic, and which affects the person’s employment opportunities or benefits, has the purpose or effect of unreasonably interfering with the person’s work performance, or has the purpose or effect of creating an intimidating, hostile or offensive working environment. Harassing conduct includes, but is not limited to: epithets; slurs or negative stereotyping; threatening, intimidating or hostile acts; or denigrating jokes and display or circulation in the workplace of written or graphic material that denigrates or shows hostility or aversion toward an individual or group based on their protected characteristic.

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors and other verbal, visual or physical conduct of a sexual nature, when:

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1. submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment;

2. submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or

3. Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Examples of sexual harassment include: unwelcome or unsolicited sexual advances; displaying sexually suggestive material; unwelcome sexual flirtations, advances or propositions; suggestive comments; verbal abuse of a sexual nature; sexually-oriented jokes; crude or vulgar language or gestures; graphic or verbal commentaries about an individual’s body; display or distribution of obscene materials; physical contact such as patting, pinching or brushing against someone’s body; or physical assault of a sexual nature. 3.3. Complaint Procedure Any company employee who feels that he or she has been harassed or discriminated against, or has witnessed or become aware of discrimination or harassment in violation of these policies, should bring the matter to the immediate attention of his or her supervisor or Ms. Sarpa @ radhika.n@focusedumatics.com The company will promptly investigate all allegations of discrimination and harassment, and take action as appropriate based on the outcome of the investigation. An investigation and its results will be treated as confidential to the extent feasible and permitted by law, and the company will take appropriate action based on the outcome of the investigation. No employee will be retaliated against for making a complaint in good faith regarding a violation of these policies, or for participating in good faith in an investigation pursuant to these policies. If an employee feels he/she has been retaliated against, the employee should file a complaint using the procedures set forth above. 3.4. Drug-Free / Alcohol-Free Environment

Employees are prohibited from unlawfully consuming, distributing, possessing, selling, or using controlled substances while on duty. In addition, employees may not be under the influence of any controlled substance, such as drugs or alcohol, while at work, on company premises or engaged in company business. Prescription drugs or over-the-counter medications, taken as prescribed, are an exception to this policy. Anyone violating this policy may be subject to disciplinary action, up to and including termination. 3.5. Open-Door Policy

The company has an open-door policy and takes employee concerns and problems seriously. The company values each employee and strives to provide a positive work experience. Employees are encouraged to bring any workplace concerns or problems they might have or know about to their supervisor or some other member of management.

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4. Company Policies and Procedures 4.1. Code of Professional Conduct

This company expects its employees to adhere to a standard of professional conduct and integrity. This ensures that the work environment is safe, comfortable and productive. Employees should be respectful, courteous, and mindful of others’ feelings and needs. General cooperation between coworkers and supervisors is expected. Individuals who act in an unprofessional manner may be subject to disciplinary action.

4.2. Dress Code

Dress choice is a matter of personal discretion, taking into account requirements for any protective clothing, customer/supplier interaction and professional environment. Be aware that work attire will have an impact upon Company’s image as well as your work colleagues As a minimum standard, dress should be clean, neat and professionally appropriate. The following are examples of items that are not acceptable:

o Ripped or torn clothing o Sports sandals o Sportswear or beachwear

If you are in a work environment with inappropriate clothing you may be sent home to change, before returning to work.

o Certain days can be declared dress down days, generally Fridays. On these days, jeans and other more casual clothing, although never clothing potentially offensive to others, are allowed.

o Wearing sandals to office is unacceptable.

4.3. Payday

Salary will be disbursed within Seven Days after successful completion of Calendar month. The Salary will reflect work performed from 1st to 31st period. Payment includes, salary or wages earned less any mandatory or elected deductions. Mandatory deductions include PF, ESI, PT & TDS. Notify a HR Personnel if the paycheck appears to be inaccurate or if it has been misplaced. The company reserves the right to charge a replacement fee for any lost paychecks. Advances on paychecks are not permitted. Any change in name, address, telephone number, marital status or number of exemptions claimed by an employee must be reported to hr@focusedumatics.com/nagabhushan.l@focusedumatics.com immediately.

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4.4. Company Property

Company property, such as equipment, vehicles, telephones, computers, and software, is not for private use. These devices are to be used strictly for company business, and are not permitted off grounds unless authorized. Company property must be used in the manner for which it was intended. Upon resignation, employees are required to surrender any company property they possess. Company computers, Internet and e-mails are a privileged resource, and must be used only to complete essential job-related functions. Employees are not permitted to download any “pirated” software, files or programs and must receive permission from a supervisor before installing any new software on a company computer. Files or programs stored on company computers may not be copied for personal use. Phones are provided for business use. The company requests that employees not receive personal calls while on duty. If urgent, please keep personal calls to a minimum and conversations brief. Personal long distance calls are not permitted. Employees are reminded that they should have no expectation of privacy in their use of company computers or other electronic equipment. Violations of these policies could result in disciplinary action. 4.5. Social Media Policy

The company understands that social media can be a fun and rewarding way to communicate with family, friends and co-workers. However, use of social media also presents certain risks and carries with it certain responsibilities. To assist employees in making responsible decisions about the use of social media, the company has established these guidelines for appropriate use of social media.

This policy applies to all employees who work for the company.

Guidelines

In the rapidly expanding world of electronic communication, social media can mean many things. Social media includes all means of communicating or posting information or content of any sort on the Internet, including to your own or someone else’s web log or blog, journal or diary, personal website, social networking or affinity website, web bulletin board or a chat room, whether or not associated or affiliated with the company, as well as any other form of electronic communication. The same principles and guidelines found in the company’s policies apply to employees’ activities on-line. Ultimately, you are solely responsible for what you post on-line. Before creating on-line content, consider some of the risks and rewards that are involved. Keep in mind that any of your conduct that adversely affects your job performance, the performance of fellow employees or otherwise adversely affects customers, suppliers, people who work on behalf of the company or the company’s legitimate business interests may result in disciplinary action up to and including termination.

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Know and follow the rules Carefully read this Social Media Policy, the Equal Employment Policy, the Non-Harassment/Non-Discrimination Policy, and the Code of Professional Conduct and ensure your postings are consistent with these policies. Postings that may include maliciously defamatory remarks, unlawful harassment, and threats of violence or similar unlawful conduct will not be tolerated and may subject you to disciplinary action up to and including termination. Be responsible Use your best judgment and exercise personal responsibility. Take your responsibility as stewards of personal information to heart. Integrity, accountability, and respect are core values. We trust and expect you to exercise personal responsibility whenever you participate in social media or other on-line activities. Remember that there can be consequences to your actions in the social media world – both internally, if your comments violate company policies, and with outside individuals and/or entities. If you are about to publish, respond or engage in something that makes you even the slightest bit uncomfortable, don’t do it.

Also, we encourage you to try to resolve all differences with an individual, organization, or even the Company through direct communications with the individual, organization, or Company. Remember, the Company has an Open Door policy. It can be used to try to resolve differences with the Company, management, or even your co-workers. We encourage you to try to use the Open Door policy. It works!

Nevertheless, if you decide to post complaints or criticism, avoid using statements, photographs, video or audio that are maliciously defamatory, that are obscene, that disparage customers, that attack the Company’s product, or that might constitute unlawful harassment. Examples of such conduct might include false posts meant to intentionally or maliciously harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of race, sex, disability, religion or any other status protected by law or company policy.

Be honest and accurate The best practice is to check your facts before posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts you have altered. Remember that the Internet archives almost everything and deleted postings can be searched. Never post any information or rumors that you know to be false about the company, fellow employees, customers, suppliers, people working on behalf of the company or competitors.

Post only appropriate and respectful content

Maintain the confidentiality of the company’s trade secrets and private or confidential information. Trade secrets may include information regarding the development of systems, processes, products, know-how and technology.

Express only your personal opinions. Never represent yourself as a spokesperson for the company. If the company is a subject of the content you are creating, be clear and open about the fact that you are an employee and make it clear that your views do not represent those of the company, customers, or its suppliers. If you do publish a blog or post on-line related to the work you do or subjects associated with the company, make it clear that you are not speaking

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on behalf of the company. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of the company.”

Using social media at work Refrain from using social media while on work time, unless it is work-related as authorized by a manager. To help reduce spam and other unwanted e-mail traffic, employees should not use company e-mail addresses to register on social networks, blogs or other on-line tools utilized for personal use. Please use your own individual or private e-mail address. Retaliation is prohibited The company prohibits taking negative action against any employee for reporting a possible deviation from this policy or for cooperating in an investigation. Any employee who retaliates against another employee for reporting a possible deviation from this policy or for cooperating in an investigation will be subject to disciplinary action, up to and including termination. 4.6. Privacy Employees and employers share a relationship based on trust and mutual respect. However, the company retains the right to access all company property including computers, desks, file cabinets, storage facilities, and files and folders - electronic or otherwise - at any time. Employees should not entertain any expectations of privacy when on company grounds or while using company property. All documents, files, voice-mails and electronic information, including e-mails and other communications, created, received or maintained on or through company Property is the property of the company, not the employee. Therefore employees should have no expectation of privacy over those files or documents.

5. Attendance Policies 5.1. General Attendance The company maintains normal working hours of 8:30 hours. Hours may vary depending on work location and job responsibilities. Supervisors will provide employees with their work schedule. Should an employee have any questions regarding his/her work schedule, the employee should contact the supervisor. The company does not tolerate absenteeism without excuse. Employees who will be late to or absent from work should notify a supervisor in advance, or as soon as practicable in the event of an emergency. Chronic absenteeism may result in disciplinary action, up to and including termination. Employees who need to leave early, for illness or otherwise, should inform a supervisor before departure. Unauthorized departures may result in disciplinary action, up to and including termination.

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5.2. Tardiness Employees are expected to arrive on time and ready for work. An employee who arrives after their scheduled arrival time is considered tardy. The company recognizes that situations arise which hinder punctuality; regardless, excessive tardiness is prohibited, and may be subject to disciplinary action, up to and including termination. 5.3. Breaks When working conditions permit, and pending a supervisor’s approval, employees are entitled for breaks. But he should complete productive/Working hours for the day to get this day paid.

6. Leave Policies The company provides, as a benefit, paid vacations for its eligible employees. Forward requests for time off in advance to a supervisor, who may approve or deny the request based on company resources. The company is flexible in approving time off when doing so would not interfere with company operations. Vacation days are granted only on a full-day or half-day basis.

o This policy is subject to exigencies of work requirement and it is at the discretion of the

Management to grant, refuse, revoke, or curtail availing any Leave, as the exigencies of the work

may permit.

o For the purpose of leave calculations, “Year” shall mean calendar year commencing on the 1st

day of January and ending on the 31st day of December, and “Month” shall mean calendar

month.

o Employees desirous of proceeding on leave shall apply in the Attendance software. Any leave up

to 7 days will be sanctioned by the respective TM. Any leave exceeding 7 days but up to 15 days

will require approval from the Reporting Manager/ Production Manager. Leaves greater than 15

days but up to 30 days will require approval from the respective Reporting Manager wherever

applicable and any leave greater than 30 days will require approval from the CEO.

o Employees shall proceed on leave only after obtaining proper sanction of leaves from the

sanctioning authority.

o Absence from work without intimation and sanction, except due to illness, shall be treated as

Leave without pay/ leave with Loss of pay- (LOP) for the period of such absence. However,

employees who have remained absent without prior sanction of leave, but who have intimated

their inability to attend duty, should apply in attendance software immediately on resuming

duty and get their absence regularized.

o In the event of an employee leaving the service of the organization by the way of resignation,

he/she shall not avail any leave during the notice period required to be served. The notice period

will be counted by way of at least 30 physical working days (including intervening weekly offs &

Holidays)

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o Leaves exceeding more than 90 days will be considered as a request for resignation/relieving.

There will be exceptions, subject to approval of the management.

o The employee can either use Earned leave during the year or accumulate and carry forward such

leave accrued by him/her.

o Any new employee will be eligible to avail Earned Leave only after completing one year of

service and other type of leave after completing his probation period, but however leave would

be accrued from the date of joining on pro-rata basis.

o Any employee who avails an uninformed and or un-sanctioned leave, the leave will be counted

starting from the day of absence and till the day of resuming the duty including all intervening

holidays and /or weekly offs. This will be considered as LOP even if there is accumulated unused

leave balance in any type of leave. Employees are not eligible to take any leave when they are

serving their notice period. Any leave taken during the notice period will be considered as leave

on loss of pay.

o Attendance and Punctuality

Timely and regular attendance is an expectation of performance for all employees. To ensure adequate staffing, positive employee morale, and to meet expected productivity standards throughout the organization, employees will be held accountable for adhering to their workplace schedule. In the event an employee is unable to meet this expectation, he/she must obtain approval from their supervisor in advance of any requested schedule changes. This approval includes requests to use appropriate accrual, as well as late arrivals to or early departures from work.

6.1. Working days

The working days at the Company will be from Monday through Friday. Unless otherwise stated, work hours would be as follows:

Days Monday – Friday

Timings Flexible 8:30 production Hours

Depending on work exigencies, an employee’s working hours might vary from the timings mentioned above.

6.2. Weekly off Saturday and Sunday will be the weekly holidays based on department heads Discretion.

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6.3. Summary of Leave Rules

The following are the Leave Rules for Employees of FOCUS GROUP OF COMPANIES, India.

Type Eligibility Procedure

Casual Leave (CL)

Completion of probation period (3 months) but will accrue from the date of joining

- 1 leave for every 15 days worked, will credit in next month; will carry forward up to 6 and rest will be lapsed at the end of the year - Leave will accrue proportionately from the date of joining - Intervening Saturdays/ Sunday shall be included in the Leave Period

Earned Leave (EL)

Completion of 1 year of service, but will accrue from the date of joining

- 1 leave for every 15 days worked, will credit in next month; -Maximum Accumulation is up to 45 - EL can be encashed only at the time of separation - Monthly Basic salary will be considered for calculation - Intervening Saturday/ Sunday shall be included in the Leave Period - EL can be either suffixed or prefixed to CL - 15 days prior approval from Reporting Manager is required for availing EL exceeding 5 days

Maternity Leave (ML)

Female Employees on roll - Subject to a minimum of 80 days of working in 12 months immediately preceding the date of confinement

- Maternity benefit will be 26 weeks of which not more than 8 weeks shall precede the date of her expected delivery Maternity leave for adoptive and commissioning mothers: 12 weeks of Maternity leave may be availed by any female employee who: (i) Legally adopts a child below three months of age; or (ii)Is a commissioning mother - Any woman who is availing maternity benefit under ESIC is not eligible to take advantage of Maternity Benefit Act 1961 - Any extension of Maternity Leave should intimate employer, 10 days prior to completion of Maternity Leave Period.

Holidays (PH)

Regular Employees -Employees will be given 10 days leave for festivals and other government holidays. - The list of such holiday will defined in Holidays Table # - Holidays are observed on a paid basis for all eligible employees

Compensatory Off (CO)

Below Managerial Level

- Employees in below Managerial level are eligible for C-Off, if you work on weekly off/ national holiday - C-Off shall have to be availed within 90 days following D8the month in which it accrued, else it will lapse

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6.4. Holidays The company observes the following holidays for the year 2019:

Date Occasion Focus Edumatics

Bangalore Coimbatore OLT

01/01/2019 New Year Yes Yes Yes

14/01/2019 Sankranti Yes - -

15/01/2019 Pongal - Yes -

19/04/2019 Good Friday - Yes -

01/05/2019 May Day Yes Yes -

04/07/2019 US Independence Day - - Yes

15/08/2019 Independence Day Yes Yes Yes

16/08/2019 Independence Day Vacation - - Yes

23/08/2019 Krishna Jayanti - Yes Yes

02/09/2019 Ganesh Chathurthi Yes Yes -

02/09/2019 US Labor Day - - Yes

02/10/2019 Gandhi Jayanti Yes Yes -

07/10/2019 Dasara Yes - -

08/10/2019 Ayutha Pooja - Yes -

28/10/2019 Diwali Yes - -

01/11/2019 Kannada Rajyotsva Yes - -

28/11/2019 Thanksgiving - - Yes

25/12/2019 Christmas Yes Yes Yes

26/12/2019 Christmas Vacation - - Yes

31/12/2019 New Year Eve - - Yes

Holidays are observed on a paid basis for all eligible employees.

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Misuse of Company resources and conduct in violation of Company policy will result in disciplinary action in accordance with the Company policy, up to and including termination

6.5. Frequently asked question:

1. What happens if the duration of my punch-in time is less than 510 minutes (i.e., 8:30 hours)?

-If your office in time is less than 510 minutes and greater than or equivalent to 250 minutes,

then that day shall calculated as half a day presence for you. However, if your attendance is less

than 250 minutes, then the entire day shall be marked as “absent,” and you shall not be eligible

for payment of compensation for that day.

2. What happens if an employee works for half a day on Friday and takes leave on Monday, Will

intervening policy applies?

-If an employee takes leave on Friday for half day and do not resume to work on Monday, then

the intervening policy will not apply. In this case employee will be marked as WO on Saturday

and Sunday.

3. What happens if there is a GH on Friday and employee takes leave on Monday?

-Intervening policy will not apply only Monday will be considered as Leave.

4. What happens if an employee goes on a leave for more than a week during this week PH/GH

comes in between?

- Employee should work minimum one day or should have applied for Leave in a particular

month to get the Holiday (PH) paid or otherwise, they are fall under LOP. After date of exit,

none of the employee will applicable for Holiday.

5. Can an Employee with ESI benefit claim 6 months Basic salary once she resumes to work after

Maternity Leave?

-No, this employee is applicable for Maternity benefit only from ESIC.

6. If an employee joins and leaves the Company in the same month, will he/she be eligible to

encash EL?

-Yes, as per the accrual policy, if the employee gets one EL in the month, he/she can able to

encash the same.

7. Work Performance 7.1. Expectations The company expects every employee to act in a professional manner. Satisfactory performance of job duties and responsibilities is key to this expectation. Employees should attempt to achieve their job

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objectives, and act with diligence and consideration at all times. Poor job performance can result in disciplinary action, up to and including termination. 7.2. Reviews The company may periodically evaluate an employee’s performance. The goal of a performance review is to identify areas where an employee excels and areas that need improvement. The company uses performance reviews as a tool to determine pay increases, promotions and/or terminations. All performance reviews are based on merit, achievement and other factors that may include, but are not limited to:

- Quality of work - Attitude - Knowledge of work - Job skills - Attendance and punctuality - Teamwork and cooperation - Compliance with company policy - Past performance reviews - Improvement - Acceptance of responsibility and constructive feedback

Employees should note that a performance review does not guarantee a pay increase or promotion. Written performance evaluations may be made at any time to advise employees of unacceptable performance. Evaluations or any subsequent change in employment status, position or pay does not alter the employee’s at-will relationship with the company. Forward any questions about performance expectation or evaluation to the supervisor conducting the evaluation. 7.3. Insubordination Supervisors and employees should interact with mutual respect and common courtesy. Employees are expected to take instruction from supervisors or other persons of authority. Failure to comply with instructions or unreasonably delaying compliance is considered insubordination. Acts of insubordination are subject to disciplinary action, up to and including termination. If an employee disagrees with a supervisor, the employee should first try to mediate the situation by explaining their position. If possible, a compromise might be met and accusations of insubordination avoided.

8. Discipline Policy 8.1. Grounds for Disciplinary Action The company reserves the right to discipline and/or terminate any employee who violates company policies, practices or rules of conduct. Poor performance and misconduct are also grounds for discipline, up to and including termination.

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The following actions are unacceptable and considered grounds for disciplinary action. This list is not comprehensive; rather, it is meant merely as an example of the types of conduct that this company does not tolerate. These actions include, but are not limited to:

- Engaging in acts of discrimination or harassment in the workplace; - Possessing, distributing or being under the influence of illicit controlled substances; - Being under the influence of a controlled substance or alcohol at work, on company premises, or

while engaged in company business; - Unauthorized use of company property, equipment, devices or assets; - Damage, destruction or theft of company property, equipment, devices or assets; - Removing company property without prior authorization or disseminating company information

without authorization; - Falsification, misrepresentation or omission of information, documents or records; - Lying; - Insubordination or refusal to comply with directives; - Failing to adequately perform job responsibilities; - Excessive or unexcused absenteeism or tardiness; - Disclosing confidential or proprietary company information without permission; - Illegal or violent activity; - Falsifying injury reports or reasons for leave; - Possessing unauthorized weapons on premises; - Disregard for safety and security procedures; - Disparaging or disrespecting supervisors and/or co-workers; and - Any other action or conduct that is inconsistent with company policies, procedures, standards or

expectations. This list exhibits the types of actions or events that are subject to disciplinary action. It is not intended to indicate every act that could lead to disciplinary action. The company reserves the right to determine the severity and extent of any disciplinary action based on the circumstances of each case. 8.2. Procedures Disciplinary action is any one of a number of options used to correct unacceptable behavior or actions. Discipline may take the form of oral warnings, written warnings, probation, suspension, demotion, discharge, removal or some other disciplinary action, in no particular order. The course of action will be determined by the company at its sole discretion as it deems appropriate. 8.3. Termination Employment with the company is on an at-will basis and may be terminated voluntarily or involuntarily at any time. Upon termination, an employee is required:

- To continue to work until the last scheduled day of employment; - To turn in all reports and paperwork required to be completed by the employee when due and

no later than the last day of work;

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- To return all files, documents, equipment, keys, access cards, software or other property belonging to the company that are in the employee’s possession, custody or control, and turn in all passwords to his/her supervisor;

- To participate in an exit interview as requested by HR Personnel.

9. Employee Health and Safety 9.1. Workplace Safety The company takes every reasonable precaution to ensure that employees have a safe working environment. Safety measures and rules are in place for the protection of all employees. Ultimately, it is the responsibility of each employee to help prevent accidents. To ensure the continuation of a safe workplace, all employees should review and understand all provisions of the company’s workplace safety policy. Employees should use all safety and protective equipment provided to them, and maintain work areas in a safe and orderly manner, free from hazardous conditions. Employees who observe an unsafe practice or condition should report it to a supervisor or [enter alternate name] immediately. Employees are prohibited from making threats against anyone in connection with his/her work or engaging in violent activities while in the employ of the company. Any questions regarding safety and safe practices should be directed to HR Personnel. In the event of an accident, employees must notify a supervisor immediately. Report every injury, regardless of how minor, to a supervisor immediately. Physical discomfort caused by repetitive tasks must also be reported. For more information about on the job injuries, refer to the workers’ compensation section of this handbook. Employees should recognize any potential fire hazards and be aware of fire escape routes and fire drills. Do not block fire exits, tamper with fire extinguishers or otherwise create fire hazards. 9.2. Workplace Security Employees must be alert and aware of any potential dangers to themselves or their coworkers. Take every precaution to ensure that your surroundings are safe and secure. Guard personal belongings and company property. Visitors should be escorted at all times. Report any suspicious activity to a supervisor immediately. 9.3. Emergency Procedures If you hear a fire alarm or other emergency alert system, proceed quickly and calmly to the nearest exit. Once the building has been evacuated, only a supervisor may authorize employees to reenter.

10. Employee Benefits This handbook contains descriptions of some of our current employee benefits. Many of the company’s benefit plans are described in more formal plan documents available with HR, In the event of any inconsistencies between this handbooks or any other oral or written description of benefits and a formal plan document, the formal plan document will govern.

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10.1. Health Insurance The company makes group health benefits available to eligible employees and their family members from “Health Insurance Agency”. Eligible employees are full-time employees. Health benefits are paid fully by the employee. Employees can receive details about benefits provided, contribution rates and eligibility from HR Personnel 10.2. Workers’ Compensation As required by law, the company provides workers’ compensation benefits for the protection of employees with work-related injuries or illnesses. Workers’ compensation insurance provides coverage to employees who experience job-related injuries or illnesses. If an employee is injured or becomes ill as a result of his/her job, it is the employee’s responsibility to immediately notify a supervisor of their injury in order to receive benefits. Report every illness or injury to a supervisor, regardless of how minor it appears. The company will advise the employee of the procedure for submitting a workers’ compensation claim. If necessary, injured employees will be referred to a medical care facility. Employees should retain all paperwork provided to them by the medical facility. Failure to report a work-related illness or injury promptly could result in denial of benefits. An employee’s report should contain as many details as possible, including the date, time, description of the illness or injury, and the names of any witnesses. A separate insurance company administers the workers’ compensation insurance. Representatives of this company may contact injured employees regarding their benefits under the plan. Additional information regarding workers’ compensation is available from HR Personnel.

11. Separation & Full and Final Settlement Policy

11.1. Objective

Exit Policy is to ensure smooth separation or depart of the Employees or Trainee from the organizational works.

11.2. Scope

For All the Focus Edumatics & Scribe EMR employees

11.3. Policy

An Employee or Trainee is separated from his or her services with the Company due to the following (which have been covered in detail in different sub-clauses in this policy):

o Resignation

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o Termination o Death

11.4. Resignation

o Any employee who is intending to get relieved from the services in between the Service period / contract period shall tender his/her resignation in advance as specified in the appointment letter.

o Resignations shall be routed through the immediate supervisor/manager enable him/her to find a replacement within the notice period.

o HOD/RM empowers to forfeit the dues in case of an employee leaves the organization without a prior notice/intimation in writing.

o Employee’s Salary for the days worked during the notice period will be settled along with other dues as a Full & Final Settlement.

o Pro-rata benefits and perquisites will also be available to all employees on separation. o When the resignation has been accepted by RM/HOD, but requires final discussions with the

Resigned Employee or Trainee, HR shall undertake the Final Talks. o With a view to pick up feedback from the employee who has submitted his/her resignation, the

HR may conduct an Exit Interview. o Resignation Acceptance Letter shall indicate the date of relieving and advising him or her to

return and handover the Company properties or document(s) if any.

Handing Over & Exit Clearance Form

o Any employee who tenders his/her resignation will be on a notice period as per the agreed employment terms. During that tenure it’s the moral responsibility of such employee to hand over his possessions and properties belonging to the company to the assigned person/supervisor/manager before relieved from his/her services.

o RM shall initiate the process and the newly joined employee will take over charges & responsibilities from the outgoing employee by signing his/her release clearance form on the last day of working.

o The outgoing employee shall furnish all the information/documents relevant to the profile with the newly joined employee for a smooth functioning.

o On the final day or a day before of the employment the outgoing employee shall ensure his/her Exit Clearance Form with obtained signatures of the concerned reaches the Human Resources Department in order to process the Settlement.

o On the closing hours of the last working day the employee’s service come to cessation and stand relieved from his duties.

11.5. Termination

Termination of services of regular Employee or Trainee is made on the grounds of Long Absenteeism and/or any other Disciplinary Action(s).

In case of Termination due to any disciplinary action, the concerned employee is relieved on the very same day. All the following processes are undertaken on the same day.

o Full & Final Settlement cheque handed over

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o All Legal dues paid and receipt obtained from the employee. o Handing over all information and equipment

NOTE: All the Notices as per applicable Standing Orders shall be sent in the name of the concerned Employee through the HR head.

11.6. Separation Due to death

o On account of Death of the Employee, all processes are followed as per the above mentioned Sub-sections describing No Dues Clearance, gratuity & Full & Final Settlement.

o Cheque of dues and others is paid to the declared nominee(s) of the Employee.

11.7. Exit interview

The company may request an exit interview upon notice of termination. The purpose of the exit interview is to complete necessary forms, collect company property and discuss employment experiences with the company.

The Employee or Trainee who has submitted the Resignation shall attend the Exit Interview to share his or her opinions and views on the Company’s policies, procedures, systems and practices for improvement in these areas.

o An Exit Interview is arranged and conducted by the HR o Exit Interview shall be conducted before processing Full & Final Settlement. o In case of Separation owing to Termination NO Exit Interview is conducted.

11.8. Full & final settlement

For processing Full & Final Settlement, following aspects are thoroughly checked & calculated

1. Accumulated Leave as on date for calculating Leave Encashment which is applicable only to those who works minimum of 20 days in the organisation.

Leave encashment = Last Drawn Basic

X No. of Leaves available 30

2. Years of Service more than FIVE YEARS for Gratuity Amount 3. Information in No Dues Clearance Form for any Loan Recovery or Salary Payable 4. Employee/ Trainee who’s No Dues Clearance is not cleared due to various reasons, their

Full & Final Settlement is kept pending. After clearing all the dues, his or her Full & Final Settlement is processed.

5. In case, an Employee/ Trainee wants to be relieved early before completion of his or her specified Notice Period, Notice Pay is recovered from his or her Settlement Amount subject to discretion of DH based on the last drawn Basic Salary. All legal dues as per the normal resignation are given to the Employee/ Trainee.

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11.9. Gratuity

1. As per the gratuity act an employee who completes 5 years or more continuous service or either resigns or retires or services terminated or dismissed or discharged are liable to be paid gratuity at the rate of 15 days Basic salary for each completed year of service to a maximum of Rs. 20,00,000.

2. For the purpose of gratuity one month consists of 26 days. The payment towards Gratuity is payable to all the employees.

3. Disqualification and forfeiture of gratuity payment

Notwithstanding anything contained in this Gratuity Scheme.

o The gratuity of an employee, whose services have been terminated for any act, willful omission or negligence causing any damage or loss to or destruction of property belonging to the company, shall be forfeited to the extent of the damage of the loss.

o The gratuity payable to an employee can be wholly forfeited if: o The services of such employee have been terminated for riotous or disorderly conduct or

any other act of violation on his/her part, or o The services of such employee have been terminated for any act, which constitutes an

offence involving moral turpitude; provided that s/he commits such offence during the course of his/her employment.

11.10. Statutory deduction of income tax

The company shall deduct from the gross amount of Gratuity to which the employee is entitled, any income tax, super tax or any statutory tax, which the employee is liable to pay, and shall pay to the employee the net amount after deduction.