INTRODUCTION

This specifies the code of ethical business conduct of Tech Mahindra and its subsidiaries (herein
after referred to as Tech Mahindra/Company). This policy is indicative and associates are
advised to be aware of specific nuances as applicable per laws of the land. This policy applies to
all associates globally to ensure consistent understanding and application of values including
integrity, behaviour while ensuring due respect for local customs and tradition.

OBJECTIVE
The Directors, both executive and non executive, and Associates are responsible for carrying out
their duties in an honest, fair, diligent and ethical manner, within the scope of the authority
conferred upon them and in accordance with the laws, rules, regulations, agreements, guidelines,
standards and internal policies, including such other requirements which are incidental thereto. As
Directors and Associates of Tech Mahindra we have a duty to make decisions and implement
policies in the best interests of the company and its stakeholders. The Board of Directors of Tech
Mahindra is entrusted with the fiduciary responsibility of overseeing the assets and affairs of the
company. In this policy, third party means any individual or organization associates come into
contact with during the course of their work for us, and includes actual and potential clients,
customers, suppliers, distributors, business contacts, agents, advisers, and government and public
bodies, including their advisors, representatives and officials, politicians and political parties.

SCOPE
The code of conduct is applicable to:
(i)

(ii)

Both executive and non executive Directors of the company (ii) All Associates of the
company The Board of Directors of Tech Mahindra has adopted this Code of Ethical
Business Conduct as a testimony of its commitment to adhere to the standards of loyalty,
honesty, integrity and to avoid any kind of conflicts of interest. The rules and principles
set forth in this code are general in nature and the compliance with the code shall be
ensured to be read with other applicable companys policies & procedures and the
applicable laws of land wherever the company operates. The Directors and Associates
may contact the CORPORATE OMBUDSMAN for assistance in interpreting the
requirements of this code.
It is hereby clarified that the requirement to comply with this code does not constitute an
express or implied promise of continued employment with TECH MAHINDRA Any
amendments to this code shall be first approved by the Board of Directors and promptly
disclosed on the companys website. In the event, of any changes required to be
performed prior to the board approval, this would be accordingly ratified by the board of
directors in the subsequent board meeting.

The Environmental Sustainability Initiatives Of The Organisation

TechMahindra for the first time has forayed into sustainability reporting. Prior to this the
company used to report on GHG indicators via Mahindra group sustainability reports. The
first sustainability report is for financial year 2013-14 (April to March). It has been prepared
in conformance to the G3.1
Sustainability Reporting Guidelines published by the Global Reporting Initiative (GRI). The
report addresses the key sustainability topics gleaned through interactions with the different
stakeholder groups, based on the core principles of materiality and stakeholder inclusiveness.
These topics cover the full range of material economic, social and environmental impacts of
the organization. The report boundaries and exclusions are detailed below

Data measurement techniques and the bases of calculations and estimates are
furnished inthe relevant areas of the report
TechMahindra does not have any substantial divergence from the GRI Indicator
Protocols
The reporting boundaries include India operations excluding Gujarat which was
excluded due tolocation consolidation
The data is sourced from PeopleSoft platform which runs all internal processes in HR,
Financeand Project Management and is also the portal for employees to provide their
opinions andfeedback. All the data is audited by relevant third party auditors as part of
ISO and financial audits.
This report has been externally assured by KPMG. The scope and basis of the
assurance aredescribed in the assurance letter issued by KPMG. No other relationship
exists between TechMahindra and KPMG.

At Tech Mahindra our ideology of sustainability is reflected in our rigor and strategic
thinking across the organization. We believe that our operations should not affect the future of
our society, its ecological balance and life support functions. The foundation to our
sustainability initiatives is based on three key tenets.

Resource optimization of electricity, energy & water so as to reduce carbon emissions

& waste
Comply with applicable statutory and regulatory requirements.
Ensure appropriate access to safe water, sanitation and hygiene for all employees in
our premises.

Tech Mahindra aims to fulfil its environmental commitments through the following broadlevel actions

Set, monitor, benchmark and review objectives and targets on an ongoing basis for
achieving continuous improvement in environmental performance.
Creating awareness at all levels of the organization on environmental issues and across
all businesses on the laws and regulations applicable.
Ensure optimum usage of energy that is both fuel & electricity.
Report our contribution to environmental and climate-change related issues through
relevant international and national forums and to our stakeholders through appropriate
communication channels in transparent manner.
Regular communication to executive management by way of Sustainability council
meetings.
Reduce our ecological footprint through energy & water efficient measures.
Compliance with international standards like ISO 14001 with the concern to protect
the Environment.
Build transparency in organizational reporting of environmental performance to all
stakeholders
Preserve and enhance biodiversity in our campuses wherever possible.

Tech Mahindra as a global IT services & consulting company, recognizes the impacts of its
business operations on the environment due to consumption of resources like energy & water.
Hence, it makes continuous efforts to optimize resource efficiency & reduce wastes as well as
help customers reduce their environmental footprint.

Tech Mahindra's environmental management is anchored by an environmental policy. The

group policy is based on central tenets of:

Generating sustainability awareness among associates, customers, investors and

society
Ensuring a safe and motivated work environment for associates
Fostering a climate of Social responsibility and volunteering towards the community
Improve water efficiency in operations..
Adopting 3R policy that is reducing usage of natural resources and material, reusing
such material wherever practicable and exploring opportunities to recycle.
Ensure appropriate access to safe water, sanitation and hygiene for all employees in
our premises.
Developing and optimizing operations & processes that will minimize waste
generation
Disposal of wastes in an environment friendly & safe manner.
For Electronic waste, identifying appropriate vendors who are authorized by
Government with demonstrated capabilities to recycle the e-waste in eco-friendly
manner.

ustainability highlights:

Listed on DJSI - ROBECOSAM Year Book - 2015. Once amongst the 6 Indian
companies to make it to Global Yearbook

One of the only 3 Indian companies to make it to DJSI World Index

One of the 9 Indian Companies to make it through the DJSI Emerging Markets Index

Ranked #1 in the CDPs Carbon Disclosure Leadership Index 2015 with a score of
100/100.

Rated Gold in CII Sustainability Plus Corporate Assessments

Ranked 2nd in India and 3rd in Asia by CSR Channel NewsAsia Sustainability
Rankings 2015 for the first time.

Recognized as World Leader for corporate action on climate change by CDP under
Supplier Climate Performance Leadership Index - 2014-15

Recognized as World Leader for CDP under Global A List Climate Performance
Leadership Index 2014

Winner of the prestigious HYSEA award as recognition of our path breaking

initiatives in the area of Community Development & Environment Sustainability.

Won three Indo American Chamber of Commerce (I-ACE) Awards for Excellence in
CSR, Environment Health and Safety and Services (5D Imaging).

CORPORATE SOCIAL RESPONSIBILTY

The CSR vision of Tech Mahindra Limited is Empowerment through Education. For Tech
Mahindra Limited, Corporate Social Responsibility means responsible business practices
through the involvement of all stakeholders in the decision making process and in operations.
It entails having business policies that are ethical, equitable, environmentally conscious,
gender sensitive, and sensitive towards the differently abled. Tech Mahindra Limited
commits itself to creating a more equitable and inclusive society by supporting processes that
lead to sustainable transformation and social integration.

Company, as a responsible corporate entity, believes firmly in meeting its social

responsibility towards the development of the underprivileged in todays society. The Tech
Mahindra Foundation is the CSR arm of your Company. Your Company contributes 1% of
its PAT every year to fund the CSR activities undertaken on its behalf by the
Foundation. During the year 2007-08, the Tech Mahindra Foundation has made total
donations of Rs. 30 Million to meet its charitable objectives. Your Company and its
employees have added Rs. 84 Million to the corpus account which stands at Rs. 304 Million.

The Foundation essentially works with children and youth from urban, disadvantaged
communities in India. In the current year, it will reach out to as many as 80,000+ primary and
400,000+ secondary beneficiaries. Of these, at least 50% are girls/young women and 10% are
people with disabilities. The Foundation has also connected 10,000+ associates over 50,000+
hours with its beneficiaries through a robust corporate volunteering programme.
Tech Mahindra Foundations programmes have been designed in a manner that they have a
long-term, sustainable impact on the direct beneficiaries, their families and communities.
With a budget of INR 35 Cr for 2015-16, the Foundation is running 150+ projects in ten
locations of India.

The Foundations initiatives in education have positively impacted students, teachers, school
management, local governments and the communities in general through an all-round
approach to school improvement. More than 50 schools where the Foundation intervened in
2014-15 have shown better performance on academic, social, organizational and
infrastructural domains.
The flagship Shikshak Samman Award programme has reached out to over 150 teachers in
the last five years, recognizing their skills and efforts, enhancing their capacities and building
them into better, more humane teachers.
The employability programme has trained close to 12,000 youth in 2014-15, and will train
more than 15,000 this year. 75-80% of the graduates are placed in jobs upon success-ful
completion of the training, thereby filling the demand-supply gap across multiple industries
and the service sec-tor, with average salaries ranging between INR 8,000-12,000 / month.

TMF, through vibrant and innovative partnerships with the government, NGOs, CBOs and
other
organizations, will promote quality education and employability for vulnerable sections of
society. MEI will promote innovation and technology development through provision of
quality technical education.

CSR focus area for Tech Mahindra Ltd is promotion of Education. Within this broad theme
specific areas such as school education, education for employment, and technical education
are included. Persons with disability and Womens Empowerment are cross-cutting themes in
these focus areas. The interventions in these thematic areas will be prioritized to reach the
underserved segments of the population like women, economically and geographically
disadvantaged, and vulnerable and marginalized population. The company also lays emphasis
on employee volunteering in all its CSR efforts. These programmes shall be implemented
through two organizations: Tech Mahindra Foundation and Mahindra Educational
Institutions.

School Education: Education is the tool for creating an empowered, enlightened society
capable of rising to its full potential. Availability of Quality Education for all classes is the
way to ensure an equitable and just social system. TMF aims to improve the quality of school
education in India through school improvement programmes, capacity building of all
stakeholders and supplementary education.
Employability: The Tech Mahindra Foundation intends to support the Government of Indias
larger vision of skill development of youth through developing their market-oriented skills
and linking them to potential employers. This programme seeks to benefit school drop-outs,
people with disabilities, and those unable to go into higher education, among others with
specific focus on women.
Technical Education: Mahindra Education Initiative shall establish institutions of higher
learning, promote research and development and collaborate with other renowned institutions
to contribute towards the goal of high quality technical education systems in India.
Tech Mahindra Foundation (TMF) is the corporate social responsibility arm of Tech
Mahindra Limited. Instituted in 2007 as a section 25 non-profit company in India, it has been
working tirelessly since then in the areas of education, vocational training and disability, with
a keen focus on corporate volunteering.
The Foundation works with close to 100 partners across India in seven states and eight cities
of Bangalore, Bhubaneswar, Chennai, Delhi/NCR, Hyderabad, Kolkata, Mumbai and Pune.
Foundation commits itself to creating a more equitable and inclusive India by supporting
processes that will lead to sustainable transformation, social inclusion and integration.
By creating opportunities that nurture talent and enable the socially disadvantaged to utilize
their potential, the Foundation contributes to an equitable social fabric. We are committed to
inclusive growth and values of good corporate governance, ethical practices, dignity of the
individual
and
the
creation
of
a
just
and
humane
society.
Through programmes that involve both direct and indirect interventions in the community,
the Foundation has reached out to more than 200,000 beneficiaries since its inception. These
programmes are run in close consultation with government and non-government partners and
maintain a high level of quality to ensure lasting impacts.
Foundation (TMF) was established in 2007 as the corporate social responsibility (CSR) arm
of Tech Mahindra Limited. A Section 8 Company, the Foundation operates programmes
across ten urban locations in eight states/union territories of India, namely Bengaluru
(Karnataka), Bhubaneswar (Odisha), Chandigarh, Chennai (Tamil Nadu), Delhi-NCR,
Hyderabad and Visakhapatnam (Andhra Pradesh), Kolkata (West Bengal), Mumbai and Pune
(Maharashtra). Of these, Chandigarh and Visakhapatnam are the latest additions.
In FY 2014-15, Tech Mahindra Foundation is running around 136 projects in the areas of
education and employability, with the help of implementing partner organisations. The
Foundation has more than 100 partners for 2014-15, and is reaching out to as many as
125,000
children
and
youth
across
the
country.
In FY 2014-15, Tech Mahindra Foundations CSR budget is approximately INR 35 Cr. This
amount has been received as the two percent mandatory CSR contribution from Tech

Mahindra Limited, its subsidiary companies (Tech Mahindra Business Services (Hutch),
Satyam Venture, Tech Mahindra BPO and Mahindra Comviva) and interest on corpus.

They implements TMLs CSR programmes in promoting Education and Employability

through a variety of projects; which are in turn implemented by a number of NGO partners.
Since Disability is a cross-cutting theme as stated above, some projects are specifically
geared towards benefitting people with disabilities including visual disabilities. The
Foundation currently works with NGO partners across nine states of India and has a presence
in ten cities: Bangalore, Bhubaneswar, Chandigarh, Chennai, Delhi and National Capital
Region (NCR), Hyderabad, Kolkata, Mumbai, Pune, and Visakhapatnam.
The Foundation provides the broad framework for the implementation of its projects under
the three areas of Education, Employability, and Disability. It lays down the guidelines for
implementation, providing enough flexibility and freedom to its partners to contextualize the
project to suit the local beneficiary requirements. It then regularly monitors the projects
through its leadership and executive team, which is present at each location where the
Foundation operates.

Approach

TMFs approach to working in its chosen areas of Education, Employability, and Disability is
as follows:

EDUCATION
TMF believes that Education is the tool for creating an empowered, enlightened society
capable of rising to its full potential. Availability of Quality Education for all classes is the
way to ensure an equitable and just social system.
70% of Indias children are enrolled in government schools. As national level surveys have
repeatedly highlighted, the quality of education in these schools continues to remain far

below acceptable levels. This is indicated by poor learning levels among schoolchildren as
well as a high dropout rates of 41% at the elementary school level.
The quality of school education is now increasingly being assessed in terms of the multidimensional performance profiles and personality traits of students. Candidates are expected
to have independent earning, problem solving and decision making abilities to be able to
enroll in the higher & speacilsed education or employment sectors.
The National Curriculum Framework 2005 (NCF 2005) and Right to Education Act (RTE)
continuously propose new pedagogy and a shift away from widely practiced and teacher
centric classroom processes and mundane school governance to deal with the cumulative
burden of non-learning.The Foundation, with a commitment to quality and equitable
education opportunities for all, works to empower disadvantaged children through education,
creation of an enabling environment that encourages children to come to school and reduce
dropouts, and provide knowledge that facilitates improved learning for bringing a systemic
change in schooling.
With that objective, the Foundation has identified the following thrust areas:
Whole School improvement
Capacity building of teachers and other stakeholders
Supplementary education
The Foundation will work on all of the above areas with special emphasis on school
development programmes and teacher training to bring in a systemic social change.
The Foundation's work in education focuses upon three thematic Areas whole school turnaround, teacher empowerment and learning enrichment. The programmes are run in both
direct and partner implementation modes.
Through the school education programme, the Foundation has made the following key
contributions in the space of public schooling
With the whole-school turn-around programme, the Foundation has entered the government
schools six states of India. With long-term partnerships on improving their quality, the
Foundation has helped tens of thousands of children acquire grade-appropriate competencies.
The programme has also created a ripple effect in the government schooling system, inspiring
more hope and confidence in the stakeholders towards revitalizing schools as fully functional
sites of education

Teachers in over 1,000 government schools across India are benefitting from the
teacher empowerment initiatives. Multi-faceted, sustained capacity building sessions
have resulted in creating positive, empathetic attitudes among over 20,000 teachers
and 1,000+ school management professionals

The programme has nurtured a platform for lateral exchange, with over 250
government and non-government organizations, institutional, technical experts,
agencies and individuals. Through the programme, the Foundation is steadily striving
towards creating a positive environment for effective school governance where the
community is also being empowered to participate meaningfully in school education.

EMPLOYABILITY AND SKILL DEVELOPMENT

In a fast growing Indian economy, there is a gap between the supply and demand for trained
and skilled resources. In accordance with the Government of Indias vision and policy on
skill development, the Foundation enables the youth to acquire employable market. Oriented
skills and links them to potential employers, thereby facilitating the development of self
reliant and confident individuals.
TMF promotes the concept of education to employability, and runs the SMART (Skills-for
Market-Training) programme to encourage and facilitate employment opportunities for youth
from the marginalized communities. Under this programme, there are SMART and SMART+
(for persons with disabilities) centres, which are operational across India. The SMART
programme targets school dropouts and addresses the skill gap in areas like retail,
hospitality, accounting, nursing aide, plumbing, electricians, and so on.
The Tech Mahindra Foundation was launched to address the educational needs of the
underprivileged, especially children. The Foundation aims to realize its vision by creating and
supporting programs that will bring about sustainable changes, aimed at the economically
less privileged and socially disadvantaged. The Foundation was formally launched in June
2007 as an expression of understanding of these issues of social concern.
With a belief that educated and skilled young women and men are a country's true strength,
Tech Mahindra Foundation runs a large employability programme for youth, to equip them
with skills that will make them readily employable and land them in jobs with some of the
most inspiring brands of the country.
The Foundation's flagship programme, SMART or Skills for Market Training, is a model
vocational training programme for youth from underprivileged backgrounds, which helps
them to actualize their potential in a career of their choice. The SMART Programme equips
youth from urban communities with the requisite skills and attitudes for them to gainfully
participate in the new economy. The programme began in 2012 with 3 centers in New Delhi
and Hyderabad and trained 1,000 youth in the first year. In the current year, the Foundation is
running 65 centres across 10 cities of India, with over 15,000 youth on the programme.
Youth on SMART, mostly first generation learners, have a minimum educational background,
but typically lack the skills which are the jobs of today require computers, spoken English
and basic know-how of working in formal environments. They typically fulfill five criteria,
and are:

between 18 to 24 years of age

matriculated

belonging to urban locations, and socio-economically disadvantaged at large

able to read and comprehend simple English

in immediate need of a job

Right from the mobilization to admissions, through training and assessments, and till
placements and further support, each function of the programme rigorously follows a defined
set of processes, which are developed after thorough research and careful testing.
A highly rigorous training along the lines of a well-defined curriculum supported by effective
training manuals, a robust system of regular assessment, and support beyond the completion
of the course, form the essence of the SMART programme. The Foundation delivers the
programme through partner NGOs across ten locations in India. It constantly invests in highquality training and capacity building of the partners around the year.
Youth graduating from these centers have successfully filled the demand supply gap across
multiple industries and the service sector.

DISABILITY
India has more than 21 million people with some kind of disability as per the 2001 census.
Persons with disabilities continue to be discriminated against, with the focus being on their
disability instead of ability.
TMF seeks to give dignity and independence to persons with disability (with a special focus
on visual disability) through inclusive education, providing employable market-related
entrepreneurial skills, and opportunities, thereby allowing them to be self-reliant.
Tech Mahindra Foundation joined hands with Smile Foundation to empower underprivileged
youth through the livelihood programme Smile Twin e-Learning Programme (STeP). Since
January 2009 Tech Mahindra is supporting STeP centres. STeP is such an initiative of Smile
Foundation that aims at creating a pool of young and independent people, from the
marginalized section, through skill enhancement in tandem with market requirements. It is an
effort towards bridging the gap between demand and supply of skilled manpower in the fast
emerging services and retail sectors of modern India.
This national level programme trains the urban underprivileged adolescent youth in English
Proficiency, Basic Computer Education and Soft Skills for enhancing their prospects of
employment in the fast expanding retail, hospitality and BPO sectors. Besides Computer and
English language, the students and beneficiaries are also to be oriented and trained on Basic
Retail Management, Gender Issues, Personality Development and Career Counseling,
Reproductive and Sexual Health, HIV/AIDS etc.
Smile Foundation appreciates and acknowledges the invaluable support of Tech Mahindra
Foundation.

VOLUNTEERING

Volunteering is one of the core human resource strengths at all the Mahindra and Mahindra
Group companies. Tech Mahindra encourages its associates to volunteer time in CSR
activities. The Foundation works in engaging Tech Mahindra associates with the
disadvantaged communities to promote empathy and understanding of social inequalities.
TMF will continue to create opportunities in all its locations for Tech Mahindra associates to

share their time and skills in a socially constructive manner for the development of the
society. Tech Mahindra Foundations list of CSR projects (under its Programmes of
Education, Employability, and Disability) is as follows:

Mahindra Educational Institutions (MEI)

Mahindra Educational Institutions, a 100% subsidiary of Tech Mahindra Limited, is a not-forprofit companyset up under Section 25 of the Companies Act 1956 (corresponding to Section
8 of the Companies Act 2013). Mahindra Educational Institutions
MEC signifies the Rise of the New Engineer. A new paradigm made possible by a historic
collaboration involving the Mahindra Group, cole Centrale Paris and Jawaharlal Nehru
Technological University Hyderabad (JNTUH).

It works towards the following vision "Our vision is to train engineers, both men
and women, to be entrepreneurial and innovative as well as technically trained, so that
they are capable of meeting the greatest challenges of their era, globally."

MEC's leadership epitomises an unparalleled synergy of Industry and Academia,

transcending geography and embracing excellence. It includes

Vineet Nayyar, Chairman

Sanjay Dhande, Founder-Director

CP Gurnani, Board Member

The main objectives of MEI are:

1. To establish institutions of higher learning such as setting up institutions, universities,
colleges, academies, and research institutes encouraging education and research work in
different disciplines, to promote innovation and technology development, to collaborate
and/or affiliate with other universities in India and abroad for the cause of promoting quality
higher education.
2. To collaborate and cooperate with educational or other institutions in any part of the world
by exchange of teachers and scholars and generally in such manners of promoting higher
education
3. To undertake, collaborate or affiliate with any institutions, trusts, or any other bodies in
India and abroad for establishment and running of educational institutions in different
disciplines to provide tertiary education and research, award degrees, institute awards and
fellowships, provide scholarships for education, organize conferences and seminars, provide
vocational education and any other activity related to promotion of higher education.