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152 • Annual Report 2018-19
Shaping the future of software driven business
B. Familiarization Program for the Board of Directors
Pursuant to the requirements of Regulation 25(7) of Listing Regulations, the Company conducts the Familiarization Program
for Independent Directors as well as other Directors on the Board about their roles, rights, responsibilities in the Company,
nature of the industry in which the company operates, business model of the Company, etc., through various initiatives. The
Company also shares the organizational structure and operations on a regular basis. The Company has been following these
principles since past. A few initiatives under familiarization program are elaborated at
familiarization-programme/
C. Whistle Blower Policy
The Board of Directors of the Company has adopted a Whistle Blower Policy for its employees and even for the non-employee
stakeholders for India as well as global locations. The employees are encouraged to report to the Whistle Blower Administrator,
any fraudulent financial or other information to the stakeholders, any conduct that results in the instances of unethical behavior,
actual or suspected violation of the Company’s Code of Conduct and the Ethics Policy, which may come to their knowledge. The
Board of Directors has appointed the Chairman of the Audit Committee as the Whistle Blower Administrator.
This policy provides for adequate safeguards against victimization of employees who report to the Whistle Blower Administrator.
The policy also provides for direct access to the Chairman of the Audit Committee. The Whistle Blower Policy is uploaded on the
website of the Company at
D. Complaints pertaining to sexual harassment
The details of complaints filed, disposed of and pending during the financial year pertaining to sexual harassment are provided
in the Report of the Directors.
E. Policy on Material Subsidiary
In terms of Regulation 16 of SEBI Listing Regulations, the Policy on Material Subsidiary is framed to determine the Material
Subsidiaries of the Company and to provide the governance framework for such subsidiaries. The policy to determine the
Material Subsidiaries of the Company is uploaded at
F. Disclosures on material significant related party transactions that may have potential conflict with the interests of
the Company
During the financial year 2018-19, there were no material significant transactions, pecuniary transactions or relationships
between the Company and the Promoters, Directors and their relatives and the management that has potential conflict of
interest of the Company.
Details of all transactions entered into by the Company with the related parties have been disclosed under “Related Party
Transactions” in the Notes to Accounts of the Company which form part of this Annual Report. A policy determining the
Related Party Transactions is uploaded on the website of the Company at
transactions-policy/
G. Risk management and internal control policies adopted by the Company
The report on Risk Management and Internal Control Policies adopted by the Company forms separate part of this
Annual Report.
H. Adherence to accounting standards
The Company follows the mandatory Accounting Standards prescribed by the Institute of Chartered Accountants of India (ICAI)
and to the best of its knowledge, there are no deviations in the accounting treatments that require specific disclosure.
I. Implementation of Compliance Tool
The Company has implemented the Compliance Tool to report and track the domestic compliances since September 2016.
The Company has also implemented Compliance Tool to report and track the compliances of it 11 major global locations since
April 2018. These tools are used to records and report the compliances as and when they are due. A detailed report derived
from the said tool is placed before the Board and Audit Committee during their quarterly meetings.
J. Data Protection Initiatives
Global Data Protection Regulation (“GDPR”) is Europe’s new framework for data protection which came into force in May 2018.
The purpose of GDPR is not only to harmonize data privacy laws across Europe but also to give greater protection and rights
to individuals. Applicability of GDPR is not restricted to the European residents or citizens. However, GDPR applies globally and
companies outside Europe are also required to comply with GDPR if they possess or process European persons’ personal data.