1.   Purpose
The purpose of this Equal Employment Opportunities Policy is to provide guidelines to ensure that the companies of Teleperformance Group (the “Companies” or, individually, “Company”) implement and enforce policies and procedures that effectuate their commitment to equal employment opportunities, nondiscrimination, diversity and inclusion, and, where applicable, affirmative action programs for all candidates and employees, as well as equal employment advancement opportunities for employees.  In this regard, the Companies do not unlawfully discriminate on the basis of race, color, religion, sex, sexual orientation, national origin, citizenship, ancestry, age, disability, genetic information, family care status, military caregiver status, veteran or military service or obligation, reserve status, national guard status, or any other basis protected by applicable laws, and it is the policy of each such Company to fully comply with those laws that prohibit discrimination. 

2.   Coverage
This Equal Employment Opportunities Policy concerns and applies to candidates/applicants for employment, all employees of the Companies, and certain third parties that can be affected because of their relationship with the Companies.  This Equal Employment Opportunities Policy also addresses all of the Companies’ operations and every aspect of the employment relationship, including but not limited to personnel actions such as recruitment, selection procedures (such as hiring, work assignments, and shift selection), compensation decisions, employee development, training, performance evaluations, promotions, transfers, benefits, disciplinary action and Company social and recreational programs. 

3.   Definition
Discrimination means any distinction between individuals because of their national origin, sex, marital status, pregnancy, physical appearance, name, state of health, disability, genetic characteristics, cultural mores, sexual orientation or identity, age, political opinions, trade union activities, belonging to an ethnic group, nation, race or religion, or other characteristics or status. 

In the employment context, unlawful discrimination means that because of applicants’ or employees’ protected status—meaning their race, color, religion, sex, sexual orientation, national origin, citizenship, ancestry, age, disability, genetic information, family care status, military caregiver status, veteran or military service or obligation, reserve status, national guard status, or any other basis protected by applicable laws—they are treated differently with respect to their compensation, terms, conditions, or privileges of employment (for example, they are not hired or are terminated from employment), or they are limited, segregated or classified in any way which deprives or tends to deprive them of employment opportunities or otherwise adversely affects their status as employees.

 4.   Procedures
The commitment of the Companies to equal employment opportunities concerns all aspects of the employment relationship, including the following fields:

•  Recruitment & Hiring
•  Promotions & Career Advancement
•  Harassment
•  Remuneration
•  Work Conditions

4.1.      Recruitment & Hiring
Objective:
Ensure methods for sourcing candidates for employment, and for deciding those candidates to whom an offer of employment will be extended, do not discriminate against groups of people based on protected status, and that they reflect the Companies’ policy of diversity and inclusion and, where applicable, affirmative action programs. 

Measures:
Each Company shall:

• Enlarge and diversify its sources of recruitment/the pool of candidates considered for employment openings, including openings in upper level management.   For instance, Companies will work together with external partners to ensure that they understand the Companies’ commitment to this Policy, and recruit, hire, and staff accounts with equal employment opportunity principles in mind.
• Determine the duties, functions, and competencies relevant to the positions.  Create objective, job-related qualification standards related to those duties, functions, and competencies.  Ensure that they are consistently applied when choosing among candidates. 
• Abide by any diversity or inclusion standards or goals, and/or affirmative action programs, consistent with applicable laws andregulations.
• Ensure selection criteria do not disproportionately exclude certain protected groups unless the criteria are valid predictors of successful job performance and meet the employer’s business needs, consistent with applicable law.

4.2.      Promotions & Career Advancement
Objective:
Incorporate measures to ensure equal employment opportunities in employee promotions and career advancement, including employee training and development. 

Measures:

• The Companies should ensure that they develop the potential of employees, supervisors, and managers with equal employment opportunities in mind, by providing training and/or mentoring that provides workers of all backgrounds the opportunity, skill, experience, and information necessary to perform well, and to ascend to upper-level jobs. 
• Employment decisions related to promotions and career advancement in which equal employment opportunity principles should be considered include, but are not limited to, evaluating employees’ performance; making recommendations on internal transfers; employee skills or professional development opportunities; and promotions.
• The Companies should strive to put in place an evaluation system under which no advancement is blocked or favored under the influence of favoritism (see Anti-Corruption Policy) and under which unbiased individuals evaluate an employee for promotion and/or advancement on the basis of objective and job-related criteria.
•  The Companies should ensure that promotion criteria are made widely known, and that job openings are communicated to all eligible employees.
• Each Company shall abide by any affirmative action or other obligation to advance in employment qualified individuals in protected categories, as required by applicable law.

4.3.      Harassment
Objective:
Provide working conditions that are free of, and that prevent, any kind of unlawful harassment, including harassment because of race, color, religion, sex, sexual orientation, national origin, citizenship, ancestry, age, disability, genetic information, family care status, military caregiver status, veteran or military service or obligation, reserve status, national guard status, or any other basis protected by applicable laws, consistent with applicable law.

Measures:

• The Companies shall take all necessary measures to prevent sexual and other unlawful harassment, including by implementing, disseminating to all employees, and enforcing a policy prohibiting unlawful harassment and retaliation on any basis protected by applicable laws.    Such policies must include at least the following:
• the definition of unlawful harassment, a clear explanation of prohibited conduct, and specific  examples of prohibited conduct;
• Assurance that individuals who make complaints or provide information related to complaints will be protected against unlawful retaliation;
• A clearly-described complaint process that provides for more than one accessible avenue for raising complaints;
• Assurance that the Company will protect the confidentiality of harassment complaints to the extent possible, and consistent with applicable law;
• A complaint process that provides a prompt, thorough, and impartial investigation.
• Each Company should ensure that it takes immediate and appropriate corrective action when it determines that harassing behavior in violation of the policy has occurred.  The Companies shall raise the awareness of the diverse actors in the Companies by conducting periodic training of personnel on the topic of unlawful harassment and Company policies addressing this topic, and posting such policies and notices and summaries of employee rights related to unlawful sexual and other unlawful harassment in the workplace.
• The Companies will organize work discussions within the works council and the committees in charge of hygiene, safety and working conditions matters, if applicable.

4.4.      Remuneration
Objective:
Ensure that no worker is unlawfully discriminated against in terms of salary, benefits,  incentives, or other forms of compensation or remuneration.

Measures: 

• The Companies shall monitor remuneration/compensation practices on an annual basis in order to identify areas of potential concern in terms of equal employment opportunities, and put in place the necessary means in order to rectify such areas as deemed appropriate, and consistent with applicable law.
• The Companies shall also ensure that leaves of absences related to pregnancy and parental leave, among other types of leaves, or other events linked to parenting do not result in a violation of the Company’s equal employment opportunities commitment.

 4.5.      Work Conditions
Objective:
Ensure that every worker is treated with respect and courtesy. Promote policies and work arrangements that benefit the Company as well as employees in terms of their family, personal and work time.  Encourage efficiency in the use of work time, making effective measures and tools available in the Companies for this purpose.

Measures

• The Companies shall ensure that no individual is rejected or ignored in the context of work or activities of the group. This covers also job assignments as well as hours of work and rest / holidays.

• The Companies shall encourage Company-wide communication, clear and transparent, about the importance of the reconciliation of family, personal and work time.

• The Companies shall promote work arrangements, as requested by employees, that are designed to provide flexibility for employees’ personal needs, while remaining consistent with the Companies’ business needs. 

• The Companies shall comply with all applicable laws requiring modification and reasonable accommodations in the workplace for disabled applicants and employees. 

• The Companies shall monitor practices for equal employment opportunity compliance, and conduct self-analyses to determine whether current employment practices disadvantage people of certain protected categories.

5.   Training & awareness
Objective:
Incorporate measures to ensure that all Company staff and management are aware of the Company’s commitment to equal employment opportunities, nondiscrimination, diversity and inclusion, and where applicable, affirmative action programs.

Measures: 

• The Companies shall identify and implement appropriate and periodic training, for both staff and managers, on equal employment opportunity principles and laws, and best practices within the workplace for ensuring such principles are brought to Company employment decisions.  This training shall include training modules intended for employees responsible for the recruitment and the hiring process and Human Resources Department management. 

• To increase and broaden awareness, each Company shall ensure that its equal employment opportunity policies are prominently and conspicuously displayed for all employees, including on Company bulletin boards in common areas, within employee handbooks, and within manuals, as well as within training sessions, among other locations.   

• Managers are responsible for understanding and following equal employment opportunity policies in their location, and educating employees who report to them about such policies.  Managers should maintain open lines of communication, and allow employees to express their concerns about possible violations of such policies without fear of unlawful retaliation. Managers must respond to any form of unlawful discrimination or harassment reported to them, or that they observe, in accordance with the Company policies, including by taking swift action designed to stop the conduct and reporting it to Human Resources Department management.

6.   Responsibilities
Managers: Not only must managers and supervisors conduct themselves in a manner consistent with this Policy, they are also responsible for establishing and maintaining a work environment free of unlawful harassment and discrimination. Managers must respond to any form of unlawful discrimination or harassment reported to them, or that they observe, in accordance with the Company policies, including by taking swift action designed to stop the conduct and reporting it to Human Resources Department management.

Human Resources: The Human Resources Department has the same responsibilities as all other employees relative to compliance with this Policy.  At the same time, Human Resources Department personnel in the Companies have special responsibilities in preparing and implementing Company policies, identifying and conducting/arranging for training on such policies, conducting thorough investigations of the complaints that are brought forward by management or any employee under such policies; and providing appropriate coaching and support for all parties involved in possible harassment and discrimination situations. In cases where the employee is not responsive to coaching relative to Company procedure and policy, the Human Resources Department is obligated to elevate the situation to appropriate leaders of the Company for immediate action. 

Employees: Employees are responsible for reviewing, understanding, and asking any questions needed to clarify this Policy and any Company-specific equal employment opportunity policies; promoting a workplace free of unlawful discrimination and harassment by conducting themselves in a manner consistent with such policies; attending all required training on the subject matter of such policies; and immediately reporting any possible violations of such policies in accordance with the procedures set forth in their Company policies to their Human Resources Department or the CSR Committee at csr@teleperformance.com.