1.1 This policy governs the engagement, management, supervision, and statutory compliance obligations related to contract labor employed through licensed contractors at the Organization's establishments across India, in accordance with the Contract Labor (Regulation and Abolition) Act, 1970, the rules framed thereunder by the Central and State Governments, and any other applicable labor legislation. Contract labor refers to workers who are employed by a contractor to perform work at or for the Organization's establishments, where the Organization is the principal employer within the meaning of the Act. This policy applies to all departments, business units, and establishments of the Organization that engage or propose to engage contract labor, and to all contractors, sub-contractors, and staffing agencies through which contract labor is sourced. It establishes the Organization's standards for selecting and managing contractors, ensuring the welfare and statutory rights of contract workers, and maintaining compliance with the registration, licensing, and record-keeping requirements of the Act.

1.2 The Organization shall obtain and maintain a valid certificate of registration as a principal employer under Section 7 of the Contract Labor (Regulation and Abolition) Act, 1970, for every establishment where 20 or more workers are employed as contract labor on any day during the preceding 12 months, or such lower threshold as may be prescribed by the applicable state government. The application for registration shall be submitted to the appropriate registering officer in the prescribed form and within the prescribed timeframe, along with the required fees and documentation. The registration certificate shall specify the maximum number of contract workers that may be employed in the establishment, and the Organization shall not exceed this number without obtaining an amendment to the registration. Registration certificates shall be prominently displayed at each establishment and produced for inspection upon request by any authorised inspector. The HR department, in coordination with the Legal and Compliance teams, shall maintain a centralised register of all principal employer registrations, including registration numbers, validity dates, maximum permitted headcount, and renewal schedules.

2.1 The Organization shall engage only contractors who hold a valid licence issued under Section 12 of the Contract Labor (Regulation and Abolition) Act, 1970, by the licensing officer of the appropriate government. Before entering into any contract for the supply of labor, the Organization's procurement or HR department shall verify the contractor's current licence and its validity period, the maximum number of workers the licence permits the contractor to employ, the contractor's compliance history with the Act, including any past violations, penalties, or licence suspensions, the contractor's financial stability and capacity to pay wages, provide statutory benefits, and meet welfare obligations, and the contractor's registration under other applicable labor laws including the Employees' Provident Funds Act, the Employees' State Insurance Act, and the Payment of Gratuity Act. The Organization shall maintain a list of approved, verified contractors and shall not engage any contractor whose licence has expired, been suspended, or been revoked. The contractor engagement agreement shall include specific clauses requiring the contractor to maintain a valid licence throughout the duration of the contract and to comply with all obligations under the Act.

2.2 All engagements with labor contractors shall be documented in a comprehensive written agreement executed before the commencement of any work. The agreement shall specify the precise scope and nature of the work to be performed, the maximum and minimum number of contract workers to be deployed, the duration of the contract and any provisions for renewal or extension, the wages to be paid to the contract workers, which shall not be less than the minimum wages prescribed under the Minimum Wages Act, 1948 for the applicable scheduled employment and zone, the statutory benefits to be provided including provident fund contributions, ESI contributions, bonus, and gratuity, the working conditions, safety standards, and welfare facilities to be maintained, the compliance responsibilities of the contractor and the Organization as principal employer, the reporting and documentation obligations of the contractor, the conditions for contract termination including breach of statutory obligations, and the indemnification obligations of the contractor for any liability arising from non-compliance with labor laws. The agreement shall be reviewed by Legal Counsel before execution and shall be renewed or renegotiated before expiry.

3.1 The Organization, in its capacity as principal employer, bears ultimate statutory responsibility for ensuring that contract workers employed at its establishments are provided with the welfare facilities prescribed by the Contract Labor (Regulation and Abolition) Act, 1970, and the Central or State Contract Labor Rules. These facilities shall include, at a minimum, a canteen where 100 or more contract workers are ordinarily employed, meeting the standards prescribed in the rules regarding space, seating, food quality, and hygiene; rest rooms or suitable alternative shelters for use during rest intervals and during interruptions of work due to bad weather, where contract workers are required to halt at night; sufficient supply of clean, cool drinking water at convenient locations; a sufficient number of latrines and urinals, separately for male and female workers, maintained in a clean and sanitary condition; and first-aid boxes equipped to the prescribed standard, with at least one box for every 150 workers, and an adequately trained first-aider. While the contractor is obligated to provide these facilities under the contract, the Organization as principal employer shall be liable to provide them if the contractor fails to do so within the prescribed timeframe, and shall recover the cost from the contractor.

3.2 The Organization shall ensure that all contract workers employed at its establishments are paid wages that are not less than the minimum wages prescribed under the Minimum Wages Act, 1948, for the applicable scheduled employment, zone, and skill category, or the wages specified in the contractor agreement, whichever is higher. Wages shall be paid by the contractor on or before the due date prescribed by the Payment of Wages Act, 1936, and the applicable State Shops and Establishments Act. The contractor shall disburse wages in the presence of an authorised representative of the Organization, as required by Section 21 of the Contract Labor Act, and the Organization's representative shall certify the wage disbursement. If the contractor fails to pay wages in full or on time, the Organization as principal employer shall directly pay the outstanding wages to the contract workers within the prescribed period and shall recover the amounts paid from any sums due to the contractor or from the contractor's security deposit. The Organization shall verify that the contractor is making timely contributions to the Employees' Provident Fund, the Employees' State Insurance scheme, and any other statutory funds, by reviewing the contractor's monthly challans and compliance certificates.

4.1 The Organization shall implement a structured compliance monitoring program to ensure that all contractors engaged at its establishments maintain continuous compliance with the Contract Labor Act and all other applicable labor legislation. The monitoring program shall include monthly verification of the contractor's wage registers, attendance records, and wage disbursement records to confirm timely and accurate payment; monthly review of the contractor's provident fund, ESI, and other statutory contribution challans to verify that contributions have been deposited by the prescribed due dates; quarterly verification that the contractor's licence remains valid and has not been suspended, revoked, or expired; periodic physical inspections of welfare facilities, safety conditions, and working conditions at the establishment; and verification that the contractor is maintaining all registers and records prescribed by the Act and the Rules. Where non-compliance is identified, the Organization shall issue a written corrective action notice to the contractor specifying the nature of the non-compliance, the corrective action required, and the deadline for compliance, which shall not exceed 15 calendar days. Persistent or serious non-compliance shall constitute grounds for termination of the contractor agreement.

4.2 The Organization shall maintain all registers, records, and returns required of a principal employer under the Contract Labor (Regulation and Abolition) Act, 1970, and the Central or State Contract Labor Rules, including the register of contractors engaged at each establishment, showing the name and address of each contractor, the nature of work contracted, the number of contract workers, and the dates of commencement and completion of each contract; a register of all contract workers employed at the establishment, showing each worker's name, age, gender, designation, wages, and period of employment; muster rolls and attendance records for all contract workers; wage registers showing the wages paid to each contract worker, deductions made, and net wages disbursed; and records of welfare facilities provided and maintained. These records shall be maintained in the form prescribed by the applicable rules, updated regularly, and retained for a minimum of 3 years from the date of the last entry or as required by applicable law. All records shall be made available for inspection by the Labor Inspector or any authorised officer at any time during business hours. The Organization shall also file the annual return prescribed under the Act within the specified due date for each establishment.

4.3 The Organization shall not engage contract labor for any work, process, or operation in respect of which the appropriate government has issued a notification under Section 10 of the Contract Labor (Regulation and Abolition) Act, 1970, prohibiting the employment of contract labor. The HR and Legal teams shall maintain an up-to-date register of all Section 10 notifications issued by the Central Government and each State Government in whose jurisdiction the Organization operates, and shall cross-reference these notifications against the Organization's current use of contract labor. Where a notification is issued abolishing contract labor in a process or operation currently being performed by contract workers at the Organization's establishment, the Organization shall immediately cease the engagement of contract labor for that work, absorb the affected contract workers as regular employees of the Organization where required by law or directed by the appropriate authority, and ensure that absorbed workers receive terms and conditions of employment no less favourable than those they were receiving as contract workers. The HR department shall report any Section 10 notifications relevant to the Organization's operations to the Managing Director and Legal Counsel within 5 business days of becoming aware of the notification.

5.1 This Contract Labor Policy shall be reviewed comprehensively at least once every 12 months by the HR department in consultation with Legal Counsel, the Compliance function, and the procurement or vendor management team to ensure continued compliance with the Contract Labor (Regulation and Abolition) Act, 1970, the applicable Central and State Rules, and any other relevant labor legislation. An interim review shall be triggered by any material amendment to the Contract Labor Act or Rules, the issuance of a Section 10 notification relevant to the Organization's operations, a significant finding during a labor inspection or compliance audit, a change in the Organization's use of contract labor such as engagement of a new contractor, expansion into a new establishment, or a material increase in the contract workforce, or a court order or regulatory directive affecting the Organization's contract labor practices. The HR and Legal teams shall jointly maintain an establishment-wise compliance dashboard that tracks registration status, contractor licensing, wage payment compliance, statutory contribution compliance, welfare facility status, and inspection history. This dashboard shall be reviewed by the senior leadership team on a quarterly basis. All amendments to this policy shall be approved by the Head of Human Resources and the Managing Director and communicated to all relevant managers, compliance officers, and contractors before the effective date.