HCL Infosystems Ltd.

HCL's Chemical Policy Based on Precautionary Principles

HCL's vision is to avoid the use of substances in its products that could seriously harm the environment or human health and to ensure that the company acts responsibly and with caution.

HCL believes that if reasonable scientific grounds indicate a substance (or group of substances) could pose significant environmental or human health risks, even if the full extent of harm has not yet been definitively established, precautionary measures should be taken to avoid use of the substance(s) in products unless there is convincing evidence that the risks are small and are outweighed by the benefits. HCL considers these to be substances of concern that need to be eliminated in the long term and substituted or gradually phased out in the short term.

HCL is strongly in favour of government legislation such as the Electronic Products Standard law which restricts/bans use of certain identified chemicals in Electronic Products.

HCL identifies these substances with consideration for legal requirements as mandated by the Ministry of Environment and Forest, Government of India, international treaties and conventions, RoHS legislation etc. as applicable to its area of operations and by the following criteria:

Substances with hazardous properties that are a known threat to human health or the environment;
Substances with hazardous properties that show strong indications of significant risks to human health or the environment;
Substances with hazardous properties that are known to bio persist and bio accumulates in humans or the environment.

To enforce the company's precautionary measures, HCL strives to eliminate such substances of concern in its products by:`

Maintaining a Banned and Restricted Substance List,
Choosing designs and materials that avoid the use of substances of concern,
Committing suppliers not to use these substances contractually, and
Substitution of viable alternate substances.

To demonstrate our commitment, HCL targeted the following substances for phase out;

Phthalates - Tentative timeline for its Phase out by HCL is 2012
Beryllium and its compound- Tentative timeline for its Phase out by HCL is 2012
Antimony and its Compounds- Tentative timeline for its phase out by HCL is2012.

Acceptable alternatives would be identified for the above that will not compromise product performance and will lower product health and environmental impacts. We will have appropriate management procedures to deliver this policy and review a phase out plan yearly or when required and evaluate available technical, environmental and scalable solutions. HCL is committed to continually improve the environmental quality of our products.

HCL's methodology for Identifying Harmful Chemicals in Future

At HCL, we have a dedicated team that regularly monitors the following indicators for identifying clues/proofs about new Harmful Chemicals in Electronic Industry:

1. National Legislations
2. International Legislations
3. Concerns raised by International Community
4. Environment related Publications
5. Scientific Studies on the effects of Chemicals on Environment/human-health
6. Concerns raised by NGOs
7. Concerns raised by Study-groups

Every quarter, this team classifies the information thus gathered in the following categories:

1. Chemicals which have been empirically proven to be Toxic.
2. Chemicals which are not empirically evident to be Toxic.

Every quarter, the chemicals that figure in the category 1 above are identified as Toxic Chemicals, and are included in the Class A list.

Simultaneously, Changes if any are communicated to all our suppliers as per requirement.

The chemicals that figure in Category 2 are constantly followed for any further clarity on them.

Environment Management System (EMS) at HCL

We at HCL, are committed to continually improve the conservation of natural resources, minimisation of waste & pollutants and comply with applicable legal, regulatory and other requirements relevant to our products, processes and environment. HCL is the first to achieve ISO - 14001 certification for its manufacturing facilities,

HCL follows a management system approach in delivering its policies, management of environmental aspects and reporting on objectives, goals and targets. A multi-disciplinary team drawn from relevant departments engaged in key processes such as product development, procurement, manufacturing, and corporate administration follow established procedures and action plans. The management committee reviews these procedures and plans at regular intervals and shares information with key stakeholders.

HCL Product Engineering:

The journey towards becoming a sustainable business starts with the product development activities. When any new product is developed, from the conceptual stage itself the product engineering team starts working on its environmental aspects in keeping with life cycle considerations at design stage for electronic products. Key environmental design considerations integrated in product development process include the below activities:

All the sub assemblies need to comply with HCL's chemical policy
Product design to support minimal power consumption
Product design to support easy dismantling, recycling and reuse
Products should have the capability to be upgraded
Extended product life time

EMS Related Activities at HCL

We at HCL believe that the right knowledge for environment protection and preservation is extremely vital for sustaining the drive to save our environment. The duty of protecting and preserving the environment has to be shouldered by one and all. All the environment related activities undertaken by HCL is tabulated below:

Goal	Progress	Remarks
HCL’s E-Waste Policy To encourage separate collection and recycling of end-of-life products that are otherwise land disposed.	HCL has made concerted effort in WEEE management enshrined in its chemical policy. Under HCL's GREEN BAG CAMPAIGN, launched on June 6, 2009, HCL extends its in-house recycling arrangement to all its customers regardless of when and where the product was purchased. Inculcating consumer awareness to promote separate collection and recycling of all WEEE through education.	Implemented
HCL’s energy conservation Goal	All HCL products have Green PC features and ACPI mode for power saving. In manufacturing facilities, we maximize the use of natural light to the extent possible. Installation of different capacity DG sets that consume optimum amount of diesel as per required load. Augmenting employee awareness by conducting awareness training on energy saving practices such as switching OFF computer systems monitors etc when not in use, usage of stationery and paper to a minimum and encouraging employees to reuse paper. Operational Control Procedures are implemented in all manufacturing facilities for a good working environment for employees. Special care is taken in the prevention of noise pollution, building on good safety standards for safe working of employees. Quantification of carbon footprint in order to bring transparency in our Energy Conservation initiatives and action plan to reduce the same. Use of E-mail and Intranet to reduce paper use and save printing energy.	Implemented In Progress
HCL's Natural Resources Conservation Goal	HCL practices stringent measures to recycle/reuse packaging material. Reusable packaging material received at the plant from suppliers is sent to the regional TRC (Test and Repair Center) to reuse in packaging material. Allocation of area for green belt and landscaping to reduce dust and provide a cool microclimate. Protection of the Ozone layer layer - HCL in its manufacturing facilities uses electronic durables that are CFC free. Rainwater harvesting is undertaken in some plants to replenish and improve the quality of groundwater to the extent feasible	Implemented
HCL's Policy on RoHS	HCL has undertaken a proactive stance in the absence of legislative mandates to eliminate / restrict the use of hazardous substances in all its manufactured products. With effect from 01 Jan 2008, all Desktops, Laptops, Workstations and Servers are ROHS compliant. While HCL has assured that all its products are RoHS compliant, there are few end of generation assemblies and certain low volume accessories that are not RoHS compliant. These assemblies will be phased out in due course of time with up-gradation in product design with new versions/models.	Implemented
Suppliers level agreement on EMS.	To ensure environmental compliance in the supply chain, suppliers are registered based on their proactive approach on EMS, promoting plans to reduce the impacts on environment due to their activities/material/ services. Supplier qualification is checked by the SRF (Supplier Registration Form) and verified in the SEF (Supplier Evaluation Form). Supplier/Product compliance is also included in the SAP system. The RoHS compliance status of our products can be tracked through this system	Implemented
Phasing out Toxic Chemicals.	Phasing out of PVC and BFR components from product manufacturing Monitoring international trends and working towards elimination of other substances of concern worldwide.	Implemented for PVC; BFR free product will be launched by the target date of 31st December,2010
Other EMS related Activities	No usage of polythene less than 20 microns. Safe usage and disposal of Asbestos cement sheet. Reducing consumption of stationary. Effectively reusing packing material.	Implemented

As mentioned above, HCL is in the process of internally reviewing and considering a sustainability reporting protocol, through which the company would periodically update its stakeholders on qualitative and quantitative performance on key sustainability issues, objectives and targets.