Date 10th October 2019

To our stakeholders:

I am pleased to confirm that Ninestars Information Technologies Private Limited reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely

Gokul Krishnan V

Managing Director

Principle 1: Businesses should support and respect the protection of internationally proclaimed right to equality in wages.
Principle 2: Businesses should make sure that they are not complicit in human rights abuses.

Ninestars Information Technology Pvt Ltd (henceforth addressed as “Ninestars”), lays out strict guidelines for protecting the rights of employees and other stakeholders. Our HR Policy and Policy for Wage and Facilities Equality enshrine female employees’ rights to fair wages, rest and recreation and protection from harassment, like their male counterparts. Our safety standards aim to provide a safe and healthy environment to employees, interns and guests. The sustainability policy commits to providing all employees across all the locations with clean, safe, healthy and fair working conditions.

All Ninestars employees must commit to adherence of existing laws and regulations, contractual obligations, internationally acclaimed human rights and the demands that good business conduct and commonly approved personal conduct require.

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labour;
Principle 5: the effective abolition of child labour; and
Principle 6: the elimination of discrimination in respect of employment and occupation Assessment, Policy and Goals

Principle 3:
Ninestars Information Technologies is one of the progressive and highly employee oriented organisation with an absolute transparent & open employee and employer relationship recognizes the freedom of assembly, including the right to form any representing forum and right to become member of any labour unions, and the right to collective bargaining. Whereas the company has been enjoying an undisputed faith & confidence of the employees ever since the inception of the organisation through a formal & structured internal Employee Grievances Redressal System and a Process oriented Resolution method. As part of our response the company never had any employee litigation in any of the forums till date and no such pending issues are there before any courts in India.

Principle 4:
Ninestars respects international conventions prohibiting compulsory labour, such as the ILO Convention that concerns forced or compulsory labour.

Principle 5
Our Commitment: Ninestars respects international conventions and legislation abolishing child labour, such as the ILO Convention concerning Minimum Age for Admission to Employment. And the company shall never entertain any digression to the international laws in this regard.

Principle 6:
Equal Opportunities policies of Ninestars is strictly in place and has been followed during the duration of this COP.
1. Ninestars is committed to promoting equal opportunities to all its employees.
2. As an organisation, Ninestars values diversity and encourages fairness and justice.
3. Equal work opportunities is created for everyone in Ninestars to work, learn, and live free from discrimination and victimisation.
4. Ninestars will always combat discrimination throughout the organisation and will use its position of influence, wherever possible, to help overcome discriminatory barriers.

ENVIRONMENTAL POLICIES:
Principle 7: Businesses should support a precautionary approach to environmental challenges.
Principle 8: Businesses should undertake initiatives to promote greater environmental responsibility.
Principle 9: encourage the development and diffusion of environmentally friendly technologies Assessment, Policy and Goals

Principle 7:
Ninestars is environment friendly by the very nature of business it pursues. We help companies go paperless contributing to conservation of forests and reduce the carbon footprints consciously.

Principle 8:
Our Commitments: Ninestars understands the importance of supporting the environment and seeks to prevent any negative environmental impact our activities might have. Ninestars has incorporated our environmental policy as a part of the Ethical Code of Conduct.

ANTI-CORRUPTION
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

Ninestars abstains works actively to combat corruption, including extortion and bribery. Corruption distorts economic decision-making, deters investment, undermines competitiveness and, ultimately, weakens economic growth.

Principle 1: Businesses should support and respect the protection of internationally proclaimed right to equality in wages.
Principle 2: Businesses should make sure that they are not complicit in human rights abuses.
Our Actions:
Ninestars has ensured that female employees enjoy all the privileges despite having domestic duties to perform and report to work on time. Female employees have been allowed to choose their work timings in accordance with their household work. The HR committee to oversee the implementation of the Policy for Equality for Wage and Facilities has ensured that a zero-tolerance approach towards any discrimination against the female employees implemented across the company locations.
Ninestars strongly believes in Freedom of expression and the right to privacy. And we will continue to strive to protect them for our users, employees, partners and stakeholders. Ninestars will take the required measures to protect our users’ basic right to privacy and freedom of expression.

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labour;
Principle 5: the effective abolition of child labour; and
Principle 6: the elimination of discrimination in respect of employment and occupation Assessment, Policy and Goals
Principle 3:

In accordance with the international Labour laws, discrimination of employees based on union membership or assembly associations is strictly not allowed in Ninestars.

Principle 4:
Forced or compulsory labour has not and will not take place at Ninestars. All employment with Ninestars is based on a mutual agreement between employer and employee.

Principle 5
Our actions: Ninestars does not directly or indirectly use or entertain child labour. It strictly adheres to the international labour laws and the ILO convention.

Principle 6:
In order to achieve fair policy, Ninestars has encouraged equality of opportunity for all people and actively promote good relations. The principles of equal opportunities and non-discrimination are present throughout the organisation and in all company activities. When recruiting, we use assessment methods such as programming tests and test cases to give equal opportunities to all qualified applicants. Similar approaches are exercised when promoting, offering training opportunities, etc.
To eliminate any conditions, procedures and individual behaviour that can lead to discrimination even where there was no intent to discriminate, Ninestars is committed to use its discretionary powers to resolve such unwanted exceptions.

At Ninestars, we strive to offer our staff members a safe, healthy and inspiring work place. We have a highly culturally diversified workforce, where we emphasize the importance of a healthy work-life balance, encouraging our employees to take time to focus on family and friends.
The company’s harassment policy is presented during the orientation and encourages employees to report any and all forms of harassment they either witness or hear about without reprimanding or breach of confidentiality to the HR team.

ENVIRONMENTAL POLICIES:

Ninestars strongly believes that conservation of environment is key to its existence and its future. Policy objectives listed here will ensure that we operate in an environment that is safe and healthy to its employees and the community we operate in.

1. Promote usage of environment friendly, bio degradable and recyclable material wherever possible.
2. Conserve water by using it wisely, and by rain water harvesting.
3. Usage of renewable energy such as solar for lighting and heating.
4. Responsible waste management to prevent pollution

Principle 8:
Pollution prevention

1. Ensure that the electric generators which uses diesel as fuel will adhere to prescribed levels of oxides of nitrogen, carbon monoxide, hydrocarbons and particulate by local pollution control authorities
2. Diesel generator sets used will be encased in an integral acoustic enclosure with a proper exhaust muffler.

Water Conservation

1. Regular inspection and replacement of faulty water tanks, taps, faucets and commodes to prevent leakage of water.
2. Minimal use of water in cleaning of floors, walls and other common areas.

Rainwater harvesting

1. Install rainwater harvesting equipment to prevent loss of rain water.
2. Ensure water harvested will be used to recharge underground water table
3. Usage of harvested water in gardening

Waste
1. Waste generated during routine office activity is segregated based on its type into organic and Inorganic.
2. Organic waste can be composted and used as fertilizer in gardening
3. Inorganic waste such as plastic, paper, wood etc are properly packed and handed over to garbage collection trucks and not dumped
4. We also encourage safe and clean disposal of electronic waste generated and handover our electronic material to certified agencies for dismantling and disposal.

Principle 9:

Ninestars shall:
1. Act according to environmental laws to limit the environmental burden on earth, air, water and ecosystem.
2. Commit to using environmentally safe products in the workplace.
3. Educate staff about company environmental regulations.
4. Evaluate the consumption of energy and other resources to determine means of control.
5. Ensure the development of environmentally protective procedures.

Usage of Paper
Ninestars has designed systems, which prevents indiscriminate printing of emails, documents and other material. Ninestars currently supports various mobile operators in converting data collected on customer acquisition forms into electronic format. Our R & D department has come up with a unique concept of utilising hand held devices to do away with these paper based customer acquisition forms altogether and capture customer data electronically including signature and photographs.

ANTI-CORRUPTION
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.
There is no single, comprehensive, universally accepted definition of corruption. Therefore, each Ninestars employee must adhere to the existing laws and regulations in his/her country of operation. Ninestars anti-corruption internal regulations apply to all its employees. Controls are made to ensure that the rules are followed.
Ninestars strictly puts down that the employees must neither directly nor indirectly receive payment, gifts, travel, overnight stays or other benefits from the company’s business partners when these are:

Gifts
It is a normal part of business life to exchange business courtesies, such as meals, transportation, recreation, facilities or small gifts. Such an exchange of business courtesies must always follow local laws and regulations and not put any employee in the position of a sense of obligation to return the favour, compromise professional judgment or create the appearance of compromise or corruption. Ninestars employees should always check with their manager or the HR department, if in doubt, and consider whether the exchange of business courtesy would be acceptable if it should become publicly known. No person acting on behalf of Ninestars is allowed to accept any amount of cash or cash equivalents (such as gift certificates or market securities and similar), regardless of sum.

Money laundering
Money laundering is the process of concealing illicit sources of money. Ninestars employees are forbidden to engage knowingly in transactions that facilitate money laundering or result in unlawful diversion.
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Bribery
No person acting on behalf of Ninestars shall attempt to influence someone in the conduct of their post, office or commission by offering an improper advantage. Nor shall improper advantage be offered to anyone for the purpose of influencing third parties in the conduct of their post, office, or commission. Correspondingly, no person acting on behalf of Ninestars shall request, accept or receive improper advantage in connection with his/her position or assignment or for the purpose of influencing a third party. Improper advantage can take different forms, including but not limited to money, objects, credits, discounts, travel, accommodation and other services.

COMMUNICATION ON PROGRESS HUMAN RIGHTS
Principle 1: Businesses should support and respect the protection of internationally proclaimed right to equality in wages.
Principle 2: Businesses should make sure that they are not complicit in human rights abuses.
The Outcomes:
100% of our female employees, including casual, temporary and contractual employees are quite satisfied with the policies. We received no employee complaints of any kind of harassment or complains suggesting discriminatory actions of any nature from them.
No claims regarding any human rights violation pertaining to Freedom of expression and the right to privacy has been made in the period covered by this Communication on Progress.

LABOUR PRINCIPLES
Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
Principle 4: the elimination of all forms of forced and compulsory labour;
Principle 5: the effective abolition of child labour; and
Principle 6: the elimination of discrimination in respect of employment and occupation Assessment, Policy and Goals
Principle 3:

Discrimination of employees based on union membership or assembly associations has not occurred at Ninestars in the period covered by the Communication on Progress.

Principle 4:
Measurement of outcome: Forced or compulsory labour has not taken place at Ninestars in the period covered by this Communication on Progress.

Principle 5
Measurement of outcome: Child labour has not been used/entertained/supported by Ninestars during the period covered by this Communication on Progress.

Principle 6:
Measurement of outcome: There have been no reports of harassment or discrimination at Ninestars in the period covered by this Communication on Progress.

ENVIRONMENTAL POLICIES:

Principle 8 & 9
Measurement of Outcomes:
Ninestars supports the environment and seeks to prevent negative environmental impact our activities might have brought in. As a consequence, all employees are obliged to follow the Ethical Code of Conduct, containing the company environmental policy. We are continually evaluating green technology possibilities at our R&D department and subsequently bringing in other measures to reduce our environmental impact.

ANTI-CORRUPTION
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.
Measurement of outcome:
All Ninestars employees must adhere to the existing laws and regulations in his/her country of operation. Staff must further obey by the internal guidelines regulating anti-corruption. There has been no report of corruption, including extortion and bribery, in the period covered by this COP report.