CONFIDENTIALITY & DATA PROTECTION POLICY

This Confidentiality & Data Protection Policy (“Policy”) is framed in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Digital Personal Data Protection Act, 2023 (to the extent applicable), and other Applicable Law in force in India.

This Policy is adopted by {{f1_company_name}}, a company incorporated under the laws of India and having its registered office at {{f2_company_registered_address}} (“Company”), and shall apply to all employees, directors, officers, consultants, interns, trainees, contractors, and any other persons who have access to the Company’s information (“Covered Persons”).

1. PURPOSE

1.1 The purpose of this Policy is to safeguard confidential information and personal data of the Company, its employees, clients, customers, vendors, and other stakeholders, and to ensure lawful, fair, and secure handling of such information.

2. DEFINITIONS

2.1 “Confidential Information” means all non-public information, whether written, oral, electronic, visual, or in any other form, relating to the Company or its business, including but not limited to business plans, financial data, trade secrets, intellectual property, customer information, employee data, technical know-how, processes, and strategies.

2.2 “Personal Data” means any data about an individual who is identifiable by or in relation to such data, as defined under Applicable Law.

2.3 “Sensitive Personal Data or Information” (“SPDI”) shall have the meaning assigned under Applicable Law.

3. APPLICABILITY AND SCOPE

3.1 This Policy applies to all Confidential Information and Personal Data accessed, processed, stored, transmitted, or handled by Covered Persons in the course of association with the Company.

3.2 This Policy shall apply during the term of association and shall survive termination or cessation of such association.

4. CONFIDENTIALITY OBLIGATIONS

4.1 Covered Persons shall:

(a) maintain strict confidentiality of all Confidential Information;
(b) use Confidential Information solely for authorised business purposes;
(c) not disclose Confidential Information to any third party without prior written authorisation, except as required by Applicable Law;
(d) take reasonable steps to prevent unauthorised access, use, or disclosure.

4.2 Confidential Information shall not include information that is publicly available through lawful means or required to be disclosed under law.

5. DATA PROTECTION PRINCIPLES

5.1 The Company shall process Personal Data in accordance with the following principles:

(a) lawfulness, fairness, and transparency;
(b) purpose limitation;
(c) data minimisation;
(d) accuracy;
(e) storage limitation;
(f) integrity and confidentiality.

6. COLLECTION AND USE OF DATA

6.1 Personal Data shall be collected only for lawful and legitimate purposes connected with the Company’s business or employment relationship.

6.2 Personal Data shall not be retained for longer than is necessary to fulfil the purpose for which it was collected or as required under Applicable Law.

7. DATA SECURITY MEASURES

7.1 The Company shall implement reasonable security practices and procedures, including administrative, technical, and physical safeguards, to protect Confidential Information and Personal Data.

7.2 Covered Persons shall comply with all information security policies, IT usage policies, and access controls prescribed by the Company.

8. ACCESS CONTROL AND DISCLOSURE

8.1 Access to Confidential Information and Personal Data shall be restricted to authorised personnel on a need-to-know basis.

8.2 Disclosure to third parties shall be permitted only:

(a) with prior written approval of the Company;
(b) under a valid confidentiality agreement; or
(c) where required by Applicable Law or competent authority.

9. DATA BREACH AND INCIDENT REPORTING

9.1 Any actual or suspected data breach, loss, unauthorised access, or disclosure shall be reported immediately to the designated authority of the Company.

9.2 The Company shall take appropriate remedial action and comply with breach reporting obligations under Applicable Law.

10. EMPLOYEE RESPONSIBILITIES

10.1 Covered Persons shall:

(a) safeguard login credentials and access devices;
(b) refrain from unauthorised copying, downloading, or transmission of data;
(c) return or securely destroy Confidential Information upon cessation of association;
(d) comply with lawful instructions relating to data protection and confidentiality.

11. DISCIPLINARY ACTION

11.1 Any breach of this Policy may result in disciplinary action, including termination of employment or engagement, and legal proceedings under Applicable Law.

12. AMENDMENT OF POLICY

12.1 The Company reserves the right to amend, modify, or update this Policy at any time to ensure compliance with Applicable Law.

12.2 Amendments shall be effective from the date of communication or publication.

13. GOVERNING LAW AND JURISDICTION

13.1 This Policy shall be governed by and construed in accordance with the laws of India.

13.2 The courts at {{f3_city}}, India, shall have exclusive jurisdiction, subject to arbitration where applicable.

14. ARBITRATION

14.1 Any dispute arising out of or in connection with this Policy shall be resolved by arbitration in accordance with the Arbitration and Conciliation Act, 1996.

14.2 The seat and venue of arbitration shall be {{f4_city}}, India.
14.3 The arbitration proceedings shall be conducted in the English language by a sole arbitrator appointed in accordance with the said Act.

15. ACKNOWLEDGEMENT

All Covered Persons are required to read, understand, and comply with this Policy.

For and on behalf of
{{f1_company_name}}

Authorized Signatory: _______________________
Name: {{f5_authorized_signatory_name}}
Designation: {{f6_authorized_signatory_designation}}
Date: {{f7_date}}

ACKNOWLEDGEMENT BY COVERED PERSON

Name: {{f8_employee_person_name}}
Designation / Role: {{f9_designation_role}}
Signature: _______________________
Date: {{f10_date}}

HEALTH & SAFETY POLICY

This Health & Safety Policy (“Policy”) is framed in accordance with the applicable laws of India, including the Factories Act, 1948 (where applicable), the Occupational Safety, Health and Working Conditions Code, 2020 (to the extent notified and applicable), the Shops and Establishments Acts of the relevant States, and other Applicable Law.

This Policy is adopted by {{f1_company_name}}, a company incorporated under the laws of India and having its registered office at {{f2_company_registered_address}} (“Company”), and shall apply to all employees, contractors, interns, visitors, and any other persons present at the workplace.

1. PURPOSE

1.1 The purpose of this Policy is to ensure a safe, healthy, and secure working environment and to prevent accidents, injuries, occupational illnesses, and unsafe conditions at the workplace.

2. APPLICABILITY

2.1 This Policy shall apply to all workplaces of the Company, including offices, factories, project sites, warehouses, and any other premises where Company activities are carried out.

3. HEALTH & SAFETY COMMITMENT

3.1 The Company is committed to:

(a) complying with all Applicable Law relating to occupational health and safety;
(b) providing a safe and healthy working environment;
(c) preventing workplace accidents, injuries, and health hazards;
(d) promoting health and safety awareness among employees.

4. ROLES AND RESPONSIBILITIES

4.1 Employer Responsibilities

The Company shall:

(a) provide safe working conditions, equipment, and systems of work;
(b) identify and assess workplace risks and hazards;
(c) provide necessary training, instructions, and supervision;
(d) ensure availability of first-aid facilities and emergency response mechanisms;
(e) investigate accidents and take corrective action.

4.2 Employee Responsibilities

Employees shall:

(a) comply with health and safety instructions and procedures;
(b) use protective equipment provided by the Company;
(c) report unsafe conditions, hazards, accidents, or near-miss incidents immediately;
(d) not engage in unsafe acts or practices.

5. WORKPLACE SAFETY MEASURES

5.1 The Company shall implement safety measures appropriate to the nature of work, including:

(a) safe layout and housekeeping;
(b) fire prevention and fire-fighting equipment;
(c) electrical safety and equipment maintenance;
(d) ergonomics and workstation safety;
(e) safe storage and handling of materials.

6. HEALTH MEASURES

6.1 The Company shall take reasonable measures to safeguard employee health, including:

(a) provision of clean drinking water and sanitary facilities;
(b) adequate ventilation and lighting;
(c) periodic health check-ups, where applicable;
(d) measures to prevent occupational diseases.

7. EMERGENCY PREPAREDNESS

7.1 The Company shall establish emergency response plans for situations such as fire, natural disasters, medical emergencies, or other incidents.

7.2 Employees shall familiarise themselves with emergency procedures, evacuation routes, and assembly points.

8. ACCIDENT REPORTING AND INVESTIGATION

8.1 All accidents, injuries, near misses, and unsafe incidents must be reported immediately to the designated authority.

8.2 The Company shall investigate reported incidents and take corrective and preventive measures.

9. TRAINING AND AWARENESS

9.1 The Company shall provide health and safety training and awareness programmes to employees, as required.

9.2 Employees may be required to participate in safety drills and training sessions.

10. CONTRACTORS AND VISITORS

10.1 Contractors, vendors, and visitors shall comply with the Company’s health and safety rules while on Company premises.

10.2 The Company may deny access to or remove any person who violates safety requirements.

11. NON-COMPLIANCE AND DISCIPLINARY ACTION

11.1 Non-compliance with this Policy or safety instructions may result in disciplinary action, including suspension or termination, subject to Applicable Law.

12. AMENDMENT OF POLICY

12.1 The Company reserves the right to amend, modify, or update this Policy at any time.

12.2 Any amendment shall be effective from the date of communication or publication.

13. GOVERNING LAW AND JURISDICTION

13.1 This Policy shall be governed by and construed in accordance with the laws of India.

13.2 The courts at {{f3_city}}, India, shall have exclusive jurisdiction, subject to arbitration where applicable.

14. ARBITRATION

14.1 Any dispute arising out of or in connection with this Policy shall be resolved by arbitration in accordance with the Arbitration and Conciliation Act, 1996.

14.2 The seat and venue of arbitration shall be {{f4_city}}, India, and the proceedings shall be conducted in the English language by a sole arbitrator appointed in accordance with the said Act.

15. ACKNOWLEDGEMENT

All employees and covered persons are required to read, understand, and comply with this Policy.

For and on behalf of
{{f1_company_name}}

Authorized Signatory: _______________________
Name: {{f5_authorized_signatory_name}}
Designation: {{f6_authorized_signatory_designation}}
Date: {{f7_date}}

EMPLOYEE ACKNOWLEDGEMENT

Employee Name: {{f8_employee_name}}
Employee ID: {{f9_employee_id}}
Signature: _______________________
Date: {{f10_date}}

Confidentiality & Data Protection Policy

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