1.1 This policy establishes the Organization's framework for ensuring full and continuous compliance with the applicable State Shops and Commercial Establishments Acts and the rules framed thereunder, across all states and union territories in India where the Organization maintains offices, branches, establishments, or any other place of business. The Shops and Establishments Acts, enacted by individual state legislatures, regulate the conditions of employment in commercial establishments, including working hours, rest intervals, weekly holidays, annual and sick leave, overtime, employment of women and young persons, wage payment, termination, and the registration and licensing of establishments. This policy covers all statutory obligations arising under these Acts and ensures that the Organization's employment practices, policies, and administrative procedures are aligned with the specific requirements of each state Act applicable to its establishments. It applies to all employees working in the Organization's establishments in India, including full-time, part-time, temporary, and contract staff, and to all managers and administrators responsible for compliance.

1.2 The Organization shall obtain a valid certificate of registration under the applicable State Shops and Commercial Establishments Act for every establishment it operates, within the timeframe prescribed by the relevant state legislation, which is typically 30 days from the date of commencement of business. The registration application shall include all particulars required by the Act, including the name and address of the establishment, the name and address of the employer, the category of the establishment, the number of employees, and the nature of business conducted. The Organization shall ensure that registration certificates are renewed before their expiry date where the applicable Act requires periodic renewal. Valid, current registration certificates shall be prominently displayed at a conspicuous place in each establishment, accessible to inspection by employees and authorised inspectors. The HR department, in coordination with the Legal and Compliance teams, shall maintain a centralised register of all establishment registrations, including registration numbers, validity periods, renewal dates, and the responsible compliance officer for each location.

2.1 The Organization shall ensure that the working hours of all employees in each establishment comply with the daily and weekly maximum limits prescribed by the applicable State Shops and Establishments Act. In most states, the maximum working hours are 9 hours per day and 48 hours per week, with a spread-over period not exceeding 10.5 to 12 hours including rest intervals, though specific limits vary by state. Every employee shall be entitled to a rest interval of at least 30 minutes after 5 consecutive hours of work, or as prescribed by the applicable state Act. No employee shall be required or permitted to work in excess of the statutory daily or weekly maximum hours without their express consent, and all overtime work shall be compensated at the rate prescribed by the applicable Act, which is typically twice the ordinary rate of wages. The Organization shall maintain accurate and up-to-date records of the working hours of all employees, including start time, end time, rest intervals, and overtime hours, in the form and manner prescribed by the Act, and these records shall be made available for inspection by the Labor Inspector or other authorised authority at any time during business hours.

2.2 Every employee working in the Organization's establishments in India shall be entitled to at least one full day of rest in every period of 7 days, which shall normally be a Sunday unless the Organization has applied for and obtained written permission from the appropriate authority under the applicable State Act to designate an alternative day as the weekly holiday. Where the nature of the business requires employees to work on the designated weekly holiday, the Organization shall provide a compensatory day off within the same week or the immediately following week, and the employee shall be paid at the overtime rate for the hours worked on the holiday, as prescribed by the applicable Act. The Organization shall prepare and prominently display at each establishment a notice specifying the weekly holiday applicable to each category of employees, the opening and closing hours of the establishment, and the rest intervals to be observed. Changes to the weekly holiday or working hours shall be notified to the employees and the appropriate authority at least 7 days in advance, as required by the applicable Act.

3.1 Employees working in the Organization's establishments in India shall be entitled to the categories and quantum of leave prescribed by the applicable State Shops and Establishments Act, which typically include earned or privilege leave, accruing at a rate prescribed by the state Act, commonly 1 day for every 20 days worked or as otherwise specified; sick or medical leave, typically 7 to 12 days per year depending on the state; casual leave for unforeseen personal emergencies, typically 7 to 12 days per year; and national and festival holidays as declared by the state government, typically ranging from 7 to 15 days per year. The Organization shall comply with the minimum statutory leave entitlements in each state and may provide enhanced entitlements under its internal leave policy where the Organization chooses to offer more generous terms. Leave records shall be maintained for each employee in the form and manner prescribed by the applicable Act, and employees shall be informed of their leave balance at regular intervals. Unused earned leave may be carried forward or encashed in accordance with the provisions of the applicable state Act and the Organization's leave policy.

3.2 Female employees working in the Organization's establishments in India shall be entitled to maternity leave and benefits in accordance with the Maternity Benefit Act, 1961 (as amended by the Maternity Benefit Amendment Act, 2017) and the applicable State Shops and Establishments Act, whichever provides the greater benefit to the employee. Under the current provisions of the Maternity Benefit Act, eligible female employees are entitled to 26 weeks of paid maternity leave for the first two children and 12 weeks for subsequent children, with the entitlement to commence up to 8 weeks before the expected date of delivery. The Organization shall also comply with the provisions relating to work-from-home arrangements, crèche facilities for establishments employing 50 or more employees, and the prohibition on the discharge or dismissal of a woman during or on account of her maternity leave. The HR department shall ensure that all managers and employees are informed of the maternity leave entitlements and procedures, and that no adverse action is taken against any employee for exercising her maternity leave rights.

4.1 The Organization shall comply with all provisions of the applicable State Shops and Establishments Act and the rules framed thereunder regarding the conditions of employment in its establishments. This includes the timely payment of wages on or before the due date prescribed by the Act, which is typically the 7th day of the month following the wage period for establishments with fewer than 1,000 employees, and the 10th day for larger establishments; the restriction of deductions from wages to those permitted by the Act and the Payment of Wages Act, 1936; compliance with any restrictions on the employment of women during night hours, where such restrictions exist under the applicable state Act, while ensuring that the Organization does not discriminate against women in terms of employment opportunities and complies with any state-level notifications permitting or regulating night work for women; and the strict prohibition on the employment of children below the age of 14 years and compliance with the conditions prescribed for the employment of young persons aged 14 to 18 years, including restrictions on working hours and the types of work permitted.

4.2 The termination of employment of any employee working in the Organization's establishments in India shall comply with the notice period, severance, retrenchment compensation, and procedural requirements prescribed by the applicable State Shops and Establishments Act, the Industrial Disputes Act, 1947 (where applicable), and any other relevant labor legislation. The Organization shall provide the statutory minimum notice period prescribed by the applicable Act, which varies by state but is typically 30 days for employees with more than 3 months of continuous service, or pay in lieu of notice. Where applicable, the Organization shall pay retrenchment compensation at the rate of 15 days' average pay for every completed year of continuous service. The Organization shall not terminate, dismiss, or discharge any employee for reasons prohibited by law, including the exercise of trade union rights, filing of complaints with labor authorities, or participation in lawful industrial action. The HR department shall ensure that all termination actions are reviewed for compliance with the applicable state Act and that the required notices, if any, are filed with the appropriate labor authorities.

5.1 The Organization shall maintain all registers, records, and returns required by the applicable State Shops and Establishments Act and the rules framed thereunder, including the register of employees showing name, age, designation, wages, date of appointment, and such other particulars as may be prescribed; the attendance and leave register; the overtime register; the wage register; the register of fines and deductions, where applicable; and any other register or record prescribed by the state Act or rules. These records shall be maintained in the prescribed form, updated regularly, and retained for the period specified by the Act, which is typically 3 years from the date of the last entry. All records shall be made available for inspection by the Labor Inspector or any other officer authorised under the Act at any time during business hours without prior notice. The Organization shall cooperate fully with all inspections and shall respond to any notices, orders, or directives issued by the inspecting authority within the prescribed timeframe. The HR department shall designate a compliance officer at each establishment who shall be responsible for maintaining records, facilitating inspections, and reporting compliance status to the central HR and Legal teams.

5.2 This Shops and Establishments Act Compliance Policy shall be reviewed comprehensively at least once every 12 months by the HR department in consultation with Legal Counsel and the Compliance function, and an interim review shall be triggered whenever the Organization commences operations in a new state or union territory, an applicable State Shops and Establishments Act is materially amended or a new Act is enacted, a significant finding is made during a labor inspection or compliance audit, or a court order or regulatory directive necessitates a change in the Organization's compliance practices. The review shall assess the Organization's compliance status across all operating states, identify any gaps or risks, recommend corrective actions with defined timelines, and update the policy and associated procedures as necessary. The HR and Legal teams shall jointly maintain a state-wise compliance matrix that maps the specific requirements of each applicable state Act to the Organization's policies and practices, and this matrix shall be updated concurrently with any policy or legislative change. All amendments to this policy shall be approved by the Head of Human Resources and the Managing Director and communicated to all relevant employees and managers before the effective date.