HCL Procurement Policy

HCL Procurement Policy

Objective
Trust and Transparency are two of HCL’s core values. These core values, coupled with our obligations to
our customers, suppliers, employees, and communities form the foundation of this Procurement Policy.
This policy will ensure that the appropriate controls, processes, and fiduciary rigor are applied in all
HCL’s purchasing of goods and services.

Scope
This policy applies to all purchasing of goods and services in support of HCL’s internal business
operations or in support of providing goods and services to HCL’s customers

Applicability
This policy applies to all Partners/Suppliers and stakeholders of HCL Technologies LTD. and all its
worldwide subsidiaries (“HCL”).

By default, all acquired entities will be governed by this policy unless HCL declares otherwise.

Policy Guidelines
All suppliers must review and abide by our Code of Business Ethics and Conduct policy (COBEC) and our
Anti-Bribery and Anti-Corruption policy (ABAC). These guidelines set forth the minimum standards and
practices that HCL’s suppliers are required to uphold. For more details, please visit our policy document
using below URL:

https://www.hcltech.com/investors/governance-policies

Prohibition on Corrupt Behavior

Suppliers must operate with honesty and integrity. Suppliers must not engage in bribery, corruption,
paying kickbacks, acting unethically, or giving anything of value to secure an unfair advantage, whether in
dealing with the organization or an individual. Suppliers must not engage in any unethical business
activity or arrangements with any HCL employee.

Supplier Onboarding
All partner/supplier onboarding require prior Due Diligence and approvals as per HCL’s Standard
Operating Procedures and approval process.

Due Diligence
HCL will evaluate the appropriateness of each supplier prior to onboarding. Depending on the specific
goods / services, this may include reviewing their financial strength, ownership, customer set, scope of
business, geographic coverage, corporate social responsibility, sustainability, employee health and

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safety record, reputation, reference checks, and other business requirements. Suppliers will be
reviewed on a periodic basis under our Supplier Performance program.

Conflicts of Interest
No sourcing award will be granted to an entity for which a member of the “selection team” or their
family members have a vest interested. If there is any ambiguity, the concern should be raised to the
[email protected] mail box.

Customers as Suppliers
HCL may award business to suppliers who are current or prospective customers.

Supplier Diversity
Consistent with both HCL’s vision as a socially responsible business and our position in the global
marketplace, HCL supports the development of and will give special consider to small, local, and diverse
businesses. The definition of “diverse” is often specific to the country, however, it typically will include
local minority, gender, veteran, sexual orientation, disability, economically disadvantaged, and other
under-represented segments of a population.

Blacklisted Suppliers
At times, existing suppliers may be suspected of questionable activities, practices, or ethics. In
consultation with Internal Audit, the HCL’s Chief Procurement Officer may determine to temporarily or
permanently “blacklist” a supplier. A blacklisted supplier will be prohibited from receiving new business
from HCL and all current business will be terminated as soon as possible.

Sourcing
All sourcing awards require approval from Procurement and Functional team as defined in our SOPs and
approval process.

Competition
Transparent and auditable competition is crucial to validating and ensuring that HCL receives the most
value from its purchasing transactions while being consistent with this and other policies. This doesn’t
always mean that the lowest bid is selected, but that the one which appropriately balances cost, value,
risk, quality, speed, availability, and other qualitative factors is chosen.

Supplier Negotiations
In order to maintain the sanctity of the negotiation process, all commercial discussions between HCL
and a supplier must be conducted by Global Procurement Services (GPS) organization. Sourcing artifacts
are required to be maintained and stored for post-award review, as defined in the SOPs.

Compliance with Laws

Suppliers must operate in full compliance with all applicable laws and regulations of the country and
locale in which the supplier engaged. Supplier will comply with the requirements of any applicable laws,
statutes and regulations relating to the provision of the Services and comply will all applicable laws
relating to health and safety, data privacy, personal data, trans-border data flow and data protection.

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Commitment to Health and Safety

Suppliers must provide clean, safe and healthy working environment for all employees and contractors.
Suppliers must comply with all applicable, legally mandated standards for workplace health and safety in
the countries in which they operate or engaged and HCL encourages Suppliers to implement industry
best practices.

Compliance with all Applicable Environmental Laws

Suppliers must comply with all local environmental laws applicable to their operations. HCL encourages
Suppliers to focus on continuous improvement of environmental performance.

Approvals
As a mandate, suppliers are expected to follow “No PO No Work” policy of HCL. No services or goods
should be delivered without valid Purchase Order or signed contract irrevocably committing HCL to the
transaction in question . Prior to the commencement of any service, delivery of any goods, or HCL
incurring any financial obligation, approval will be required as per our approval process.

Contracts / Signature
For certain transactions, Purchase Orders must be supplemented by a signed agreement (“Contract”).
Templates, guidelines, and checklists may be developed for specific purchasing scenarios, countries, and
/ or categories, known as Contracting Standards. All Contracts must be approved by General Counsel
and Procurement as per our approval matrix.

Performance Management / Auditing

Suppliers will be evaluated periodically depending on several factors such as criticality, business volume,
maturity, customer requirements, and / or past performance. They will be assessed across several
dimensions such as their account management, service delivery, quality, pricing, invoicing practices,
contracting practices, innovation, and / or other important aspects. In addition, suppliers may be
audited to ensure compliance and adherence to their contractual obligations. HCL may conduct
announced or unannounced on-site inspections at supplier premises to monitor compliance with the
Policy guidelines. Suppliers must maintain all documentation necessary to demonstrate compliance with
the Procurement Policy on site and cooperate with HCL employee or third-party monitoring firms in
connection with such inspections.

Who Should I Contact for any Concern?

HCL is committed to help Suppliers and Partners comply with policies and processes. In case your
organization have any question or concerns regarding policy or guidelines, you may post your concerns
at [email protected] . This will be reviewed and addressed appropriately.

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