Anti-Bribery & Corruption Policy    

Lumina Datamatics practices a zero-tolerance approach to bribery and corruption and is committed to act professionally and fairly in all its business dealings and relationships and in implementing and enforcing effective systems to counter bribery and corruption in any form.

Lumina Datamatics mandates compliance with all applicable anti-bribery and
anti-corruption laws in all markets and jurisdictions in which it operates. Whoever we, as a Company or as individuals, may deal with and wherever we may operate, we are committed to doing so lawfully, ethically, and with integrity.

Lumina Datamatics commitment to always act with integrity to ensure that we are trusted by our customers, colleagues, business partners, and the communities in which we operate. As part of this commitment, any form of bribery and corruption is not acceptable. We prefer foregoing business opportunities rather than paying bribes.

This Anti-Bribery and Anti-Corruption Policy has been formulated and designed to provide a framework for ensuring compliance with various legislations governing bribery and corruption globally and provides guidance on the standards of behaviour to which we must all adhere.

Anti-Sexual Harassment Policy

This policy aims at deploying an effective sexual harassment complaint resolution mechanism. This policy defines the unaccepted social interactions & provides a resolution mechanism through a robust framework in order to prevent sexual harassment in the workplace.

Objective of the Policy: 

• Commitment to ensuring a healthy, safe & secure, dignified and equitable work environment for every employee and therefore has zero tolerance for sexual harassment.
• Deploying an effective sexual harassment complaint resolution mechanism.
• To define the unaccepted social interactions & provides a resolution mechanism through a robust framework in order to prevent sexual harassment in the workplace.

This Policy applies to all employees who are employed on permanent or temporary, probationary, part-time, or working as a consultant or on a voluntary basis or engaged through an agent or contractor with Lumina Datamatics.

The Prevention of Sexual Harassment (POSH) Act requires the employer to constitute an ICC (Internal Complaints Committee) at every office location that has a minimum of 10 employees. The committee is the redressal body for workplace sexual harassment. Accordingly, Lumina Datamatics has constituted a POSH Committee at each office/branch of the company that has more than 10 employees.

Document Retention and Archival Policy

This Policy is framed by the Board of Directors of Lumina Datamatics in line with the provisions of the Companies Act 2013 and the rules framed there under:

• To outline the guidelines for the preservation period of documents/records of the Company, in sync with the commercial and legal requirements, and to reasonably safeguard them from damage, loss, alteration or destruction.
• To ensure systematic retention of records, and facilitate access to documents received or created in the course of business, in a form that is fit for all end users, by implementing good archiving procedures & processes.
• To avoid inventory of redundant documents/records to optimize usage of storage space.

Corporate Social Responsibility Policy

The Corporate Social Responsibility policy aims to:

• Promote employment-enhancing vocational skills & training.
• Provide education, including and encouraging the desire for learning and knowledge at every stage.
• Eradicating extreme hunger, promoting preventive healthcare and sanitation.
• Improving access to basic healthcare facilities for economically weaker sections of society.
• Providing financial and other facilities & assistance to economically weaker sections of the society for medical treatment.
• Environment sustainability, ecological balance, conservation of natural resources.

This policy shall be applicable to Lumina Datamatics, including its subsidiaries and includes guiding principles for the selection, implementation, and monitoring of CSR activities as well as formulation of the annual action plan.

Dividend Distribution Policy

Dividend is profits earned by the company and divided amongst the shareholders in proportion to the amount of paid up shares held by them. Simply stated it is a return on investment made by the shareholders.

The objective of this Policy is to lay down the criteria and parameters that are to be considered by the Board of Directors of the Company while deciding on the declaration of Dividend from time to time. This Policy is applicable to dividend declared/recommended on the equity shares of the Company.

Subject to the provisions of the Companies Act, 2013, dividend shall be declared or paid only out of:

1. Profit of the current year after providing of the depreciation; or
2. Profit of the previous financial year or years after providing for depreciation for previous years; or in computing profits any amount representing unrealized gains, notional gains or revaluation of assets and any change in carrying amount of an asset or of a liability on measurement of the asset or the liability at fair value shall be excluded.
3. No dividend shall be declared or paid by a company from its reserves other than free reserves.
4. No company shall declare dividend unless carried over previous losses and depreciation not provided in previous year or years are set off against profit of the company for the current year.

Equal Employment, Diversity and Inclusion Policy

The Company considers its Employees to be its most important resource and is committed to treating all associates with dignity and respect. In each location where the Company conducts business, it complies with local laws governing the employment relationship. Additionally, the Company is committed to recognizing the following rights and principles throughout its global organizations.

The Company considers its employees a pivotal part and is committed to treating all associates with dignity and respect. The Company is dedicated to creating a working environment with the highest degree of ethical and virtuous work practices by ensuring fairness at every step of the employee life-cycle; to build a progressive and diverse workforce. The Company holds in high regard the guidelines laid down under the international conventions and laws relating to slavery. It aims to maintain a safe and harmonious working environment for everyone, irrespective of work, designation, ethnicity, race, caste, nationality, gender, religion and other parameters.

The objective of this Policy is to ensure that the Employees act with integrity and treat others fairly and with respect, irrespective of their differences. The Company aims to provide its employees with an environment of equality and respect for all employees and contractors and not discriminate against any individuals based on their gender, age, disability, ethnicity, sexual orientation, family status, religious beliefs and abilities.

This policy shall apply to all full-time employees and employees engaged through contractors of the Company and its subsidiaries.

Health, Safety and Environment Policy

Lumina Datamatics believe that without a safe, clean environment as well as healthy working conditions, social justice and economic growth cannot be achieved and that a safe and healthy working environment is recognized as a fundamental human right. Employees are considered an asset to a Company, Creating and fostering a good workplace is an essential element of a successful and sustainable business.

Health and Environment at the workplace are not only to eliminate the incidence of work-related injuries, diseases, fatalities, disasters and loss of national assets and ensure achievement of a high level of occupational safety, health and environment performance through proactive approaches but also to enhance the well-being of the employee and society, at large.

Information Security Policy

The objective of this Policy is to provide the necessary awareness among employees of Lumina Datamatics, pertaining to information security and adherence to the procedures and guidelines while being at Lumina Datamatics facilities.

We will ensure an effective Information Security Management System that maintains the privacy, confidentiality, integrity, availability and continual improvement of the information to its users, as required.

Remuneration Policy

The key objectives of this policy are as follows:

• To lay down criteria and terms and conditions with regard to identifying persons who are qualified to become Directors (Executive and Non-Executive) and persons who may be appointed in Senior Management and Key Managerial positions and to determine their remuneration.

• To determine remuneration based on the Company’s size, financial position and trends and practices on remuneration prevailing in peer companies in the IT-ITES industry.

• To carry out the evaluation of the performance of Directors, as well as Key Managerial and Senior Management Personnel.

• To provide them rewards linked directly to their effort, performance, dedication and achievement relating to the Company’s operations.

• To retain, motivate and promote talent and to ensure the long-term sustainability of talented managerial persons and create competitive advantage. In the context of the aforesaid criteria, the following policy has been formulated by the Nomination and Remuneration Committee and adopted by the Board of Directors at its meeting held on 10^th February 2016.

Whistle-blower Policy

Lumina Datamatics is committed to adhering to the highest standards of loyalty, honesty, integrity, transparency and conduct of business operations in an ethical manner.

The purpose of this Policy is to provide a framework to promote responsible and secure whistleblowing. It protects employees wishing to raise a concern about serious irregularities within the Company. The Policy neither releases employees from their duty of confidentiality in the course of their work nor is it a route for taking up a grievance about a personal situation.

“Whistleblower” is defined as any Personnel who has or had access to data, events or information about an actual, suspected or anticipated reportable matter within or by the organization and, whether anonymously or not, makes or attempts to make a deliberate, voluntary and protected disclosure or complaint of organizational malpractice.

Whistleblower can lodge a complaint in one of the following ways:

• By contacting the Vigilance Officer, Ms. Divya Kumat (Email: divya.kumat@luminad.com | Phone: +91 22 6102 5274)
• By contacting the Chairman of the Audit Committee.
• By sending a complaint letter in a sealed and secured envelope marked “Private and Confidential” to the Vigilance Officer.

Risk Management Policy

Risk management is an integral component of good corporate governance and fundamental in achieving the company’s strategic and operational objectives. A Risk Management Policy provides a framework for the management of risks and mitigation of threats arising out of the environment under which the Company operates.

Every business is prone to risks that are inherent in nature, the objective of the policy is to identify the risks, mitigate the threats arising out of those risks and if possible convert and capitalize the same into opportunities. This is required to ensure sustainable business growth with stability and also transparency in reporting risks.

The Risk Management Process includes:

• Identification of Key Risks
• Assessment of Risks
• Management of Risks
• Monitoring and Reporting of Risks

Sustainability Policy

Sustainability management is an integral part of the business of Lumina Datamatics which goes beyond economic, legal or regulatory motives. The Company understands the social and ecological impact of our business and works towards being a responsible global organization by adopting sustainability practices at all levels of our business impacting the overall performance of the Company. This policy defines the framework for the sustainability of the Company and provides a governing platform for Sustainability work streams to create long-lasting value for the business, the environment and society.

The Company focuses on good corporate governance and is strengthened by our commitment to Sustainable Development. We aim to follow and promote sustainable business practices and to co-create sustainable business value for our stakeholders to achieve their sustainability goals. We believe that environmentally sustainable business operations will empower us to create a sustainable future.

Sustainable Sourcing Policy

Lumina Datamatics with the vision to be a leader in the world of content for consistently delivering superior business value to Publishers and Retailers worldwide we conduct business in a manner that improves the welfare, health, and safety of workers across our supply chain, ensures compliance with the law and adherence to ethical standards of governance and sustainability. To achieve this vision, we have put in place a policy that aligns our goals with our valued business partners and promotes a culture of responsibility towards sustainability in all our stakeholders.

This policy applies to all our immediate business partners including service and supply partners (“business partner/(s)”) based on the fundamental requirement of adherence to the internationally recognized standards on five core principles – Labour and Human Rights, Occupational Health and Safety, Environmental Sustainability, Business Integrity, and Governance.

We are committed to working with our business partners through collaborations and improvement in their process for responsible procurement based on best practices. Aligning our business partners with this policy is a journey, not a one-time event.