Integrated Policy

1. Purpose

LEI International Pvt. Ltd. (hereafter “TNV-LEI”) is committed to delivering globally trusted Legal Entity Identifier (LEI) services with integrity, efficiency, and accountability. This Integrated Policy reflects our commitment to quality, environmental protection, occupational health & safety, information security, data privacy, service excellence, and regulatory compliance.

2. Scope

This policy applies to all TNV-LEI operations, services, employees, contractors, and digital infrastructure involved in LEI issuance, renewal, update, transfer, challenge management, and associated data and support services.

3. Policy Commitments

3.1 Quality, Service & Client Satisfaction (ISO 9001, ISO 20000-1)

• Ensure client satisfaction through reliable, timely, and accurate LEI services.
• Continuously improve our processes, portals, and user interfaces.
• Monitor service levels and maintain compliance with defined SLAs and KPIs.

3.2 Environment & Sustainability (ISO 14001)

• Prevent pollution and minimize the environmental footprint of digital operations.
• Promote sustainable practices such as paperless processing, green hosting, and responsible energy use.
• Comply with all applicable environmental regulations and guidelines.

3.3 Occupational Health & Safety (ISO 45001)

• Provide a safe and healthy working environment for all employees and associates.
• Identify, eliminate, or mitigate risks related to digital operations and IT facilities.
• Encourage staff wellness, safe remote work practices, and emergency preparedness.

3.4 Information Security (ISO 27001)

• Protect confidentiality, integrity, and availability of all information assets.
• Implement role-based access control, encryption, secure authentication, and audit trails.
• Conduct regular risk assessments, VAPT, and internal security audits.

3.5 IT Service Management (ISO 20000-1)

• Deliver LEI services through robust, scalable, and resilient IT systems.
• Manage incidents, changes, and service requests with efficiency and accountability.
• Maintain service continuity, disaster recovery, and system documentation.

3.6 Data Privacy & Protection (ISO 27701, GDPR, DPDP Act 2023)

• Collect, store, and process personal and entity data lawfully, fairly, and transparently.
• Obtain clear consent, limit processing to the stated purpose, and support rights of data subjects.
• Publish and enforce a Privacy Policy, Data Protection Impact Assessment (DPIA), and breach response protocol.
• Respect cross-border data transfer laws with proper safeguards.

3.7 GLEIF & LEI Regulatory Compliance

• Adhere to the GLEIF Master Agreement, GLEIS governance principles, and LEI ROC guidelines.
• Maintain data accuracy, transparency, and audit trails in all LEI operations.
• Provide public access to LEI and LE-RD under Creative Commons Zero (CC0) license.
• Support challenge management, complaint redressal, and policy transparency.

3.8 Legal, Contractual & Statutory Obligations

• Comply with applicable Indian laws, including the Companies Act, IT Act, and DPDP Act.
• Abide by international standards, contractual obligations, and partner agreements.
• Respond promptly to legal requests, regulatory audits, or data subject complaints.

4. Policy Implementation

TNV-LEI ensures the implementation of this Integrated Policy through:

• Governance oversight by the Managing Director and Compliance Officer.
• Documented procedures, controls, and continual training of personnel.
• Measurable objectives, regular reviews, and performance evaluations.
• Open communication, stakeholder engagement, and periodic internal audits.

5. Review & Updates

This policy shall be reviewed annually or in response to:

• Changes in applicable standards or regulations,
• Organizational changes or expansions,
• Audit findings or identified gaps.