SOP Ireland Immigration Process Ireland Work Permit & Work Permit Extension : GLOBAL IMMIGRATION MANAGEMENT SERVICES

Transcription

1 SOP reland mmigration Process reland Work Permit & Work Permit Extension Effective date Function Name : 02-MAY-2017 : GLOBAL MMGATON MANAGEMENT SEVCES

2 Wipro T Business Confidential reland eviewer Name Designation Comments Date Venkatesh amu Gajjala Senior Manager 02/MAY/2017 Approver Name Designation Comments Date Anuj Sarin Head of GMS 02/MAY/2017 GMS Page 2 of 25

3 Wipro T Business Confidential reland Contents 1. Scope Entry Criteria/ nputs Process Flow oles and esponsibility Activity Details Sub Process 1:...14 Sub Process 2: Exit Criteria/Output Process Measures Summary Glossary evision History GMS Page 3 of 25

4 Wipro T Business Confidential reland 1. Scope The complete process and procedures involved in processing reland Work Permit and Work Permit Extension applications. The Work Permit allows foreign professionals to work in reland. The applications are processed & filed to the mmigration authority in reland is named as DJE (Department of Jobs, Enterprise and nnovation) and NS (rish Naturalization and mmigration Service) through Attorneys (PWC) in reland. WOK PEMT POCESSNG Eligibility: Total T experience of 24 Months. Last 6 months of experience in Wipro as full time employee is mandatory. Only BE/MCA degree holders are eligible to apply. 6 months of experience as regular employee in Wipro is mandatory to apply for work permit. BE/B.Tech/PG with 2 years of experience are eligible for work permit. Any other Degree with 5 years of experience are eligible for work permit. Waseans are not allowed to apply for Work Permit unless they are on roles for 6 months. Newly joined on rolls employees can apply Work Permit under General Employment Permit (which is currently applied only for AB account). For Work Permit applied under GEP, Employer (Wipro) needs to satisfy 1:1 (EEA: NON EEA) localization for deputing employees under Wipro reland entity and for Work Permits applied under CFS client also need to satisfy 1:1 localization requirement. Visa Validity: Employee is required to get visa stamped, travel and register in reland within 90 days from date Work Permit is approved. For Long Term Work GMS Page 4 of 25

5 Wipro T Business Confidential reland Permits nitial D visa will be valid for 90 days only. rrespective of visa validity employee needs to travel and register in reland within 90 days from the date of Work Permit approval. egistration: Following arrival in reland, the employee is required to register with the immigration authorities and obtain an rish residence permit. He/she should attend in person at the local Garda (police) station/gnb to process the rish residence permit. Please note that a fee of 300(Euro) and must be paid by credit card, laser card or bank giro in order to obtain a residence permit. This fee cannot be paid by cash. The following documentation will be required for presentation to the immigration officer on the day the employee attends: 1. Original passport; 2. Original work permit; 3. Proof of rish residence address (copy of utility bill, rental agreement etc.). New registrations will be handled on Monday and Tuesday of each week (8.00.am. to 9.00.pm). Whereas, Wednesday to Friday will be reserved for registration renewals by existing GNB cardholders. Tickets will continue to be issued on a first-come first-served basis, the ticket tracking system allows an individual to check the number of tickets available that day before they attend at the offices, saving time and avoiding inconvenience. f employees are residing in the Dublin Metropolitan egion they must register at the GNB offices at 13/14 Burgh Quay, Dublin 2. The registration desk opening hours are: The egistration Office at the Garda National mmigration Bureau is open to the public from: GMS Page 5 of 25

6 Wipro T Business Confidential reland Monday to Thursday: 8.00.am. to 9.00.pm Friday: 8.00.am to 6.00.pm. Converting to a multiple journey re-entry visa: The rish Embassy/Consulate will generally only issue a single entry Employment Visa. However, once the employee registers with the rish immigration authorities in reland and obtains a residence permit, the single-entry visa may be converted to a multiple journey re-entry visa. To do this, the employee have to book an appointment in on-line the system ( attend in person at the rish Naturalization and mmigration Service (NS), Burgh Quay, Dublin 2. Please note NS will not entertain those without an appointment confirmation and those who make an appointment are asked to only attend at the agreed time with NS committed to dealing with such applicants in as speedy a manner as possible. The following information will be required for submission: Completed re-entry visa application form; Original passport; Copy of work permit; Valid rish residence permit; 2 passport sized photographs; Proof of rish residence address (copy of utility bill, rental agreement etc. will suffice); - Fee 100 Euros. (Payments in the form of a Bank Draft or Postal Order, made payable to the Department of Justice, Equality and Law eform, only will be accepted). The option for postal re-entry visa applications remains in place and NS are requesting that this be considered as the preferred route if possible. The GMS Page 6 of 25

7 Wipro T Business Confidential reland documentation outlined above should be sent by registered post to the following address: e-entry Visa Processing Office rish Naturalization & mmigration Service Burgh Quay Dublin 2. Deregistration: 1. Employees must return their WP and Garda card to GMS for FT settlement. GMS team will send the Original WP (Employee copy, Employer copy (GMS will send only for CFSEP, H in reland will send employer copy for GEP) to PWC for cancellation. 2. n case there is no planned travel within months from the date of return from previous travel, the WP has to be cancelled. Non-cancellation will lead to compliance issues in applying for a Future WP. Minimum Wage The immigration law requires the employer to pay certain minimum wage for a foreign national applying for work permit. The exact amount of minimum wage may differ for various positions and types of work permit. etention of s All immigration records like visa stamp, passport copies, work permit approval letters, registration & deregistration certificates, entry and exit stamps and copies of supporting documents submitted for work permit and visa should be stored and maintained on file. etention of all immigration records for a foreign national is one of the fundamental and critical component to prove adherence to immigration compliance. GMS has to maintain such records for a period of minimum of two years for GMS Page 7 of 25

8 Wipro T Business Confidential reland countries where such specific legal requirement doesn t exist. For reland documents are retained by attorneys for 6 years for taxation purpose. WOK PEMT EXTENSON Eligibility: Employees have to raise a request in MS 2 months before the expiry of the resident permit Exception Approval Matrix GMS/_layouts/15/start.aspx#/SitePages/HomePage.aspx 2. Entry Criteria/ nputs nitiation mmigration request. equired ation. 3. Process Flow 4. oles and esponsibility = esponsible. (The person who is assigned to do the work. n general, this is needed one per row except when the responsibility is shared.) A = Accountable. (The person who is ultimately answerable for the activity or decision and has the ownership) S = Support. esources allocated to esponsible. Unlike Consulted, who may provide input to the task, Support will assist in completing the task. C = Consult. (Have information and/or capability necessary to complete the work and hence must be consulted) = nform. (Must be notified of the results of the work or a decision or action is taken but need not be consulted) GMS Page 8 of 25

9 Employee / Manager approval Verification. Processing. Dispatching GMS Coordinator Attorneys / Service Provider mmigration Authorities (DJE) Wipro T Business Confidential reland Process oles Process Steps Work Permit Process: Application nitiation Employee uploads required documents TM Approval Employee submits required hard copy documents Application Acceptance (Soft and hard copies of documents). Verification of Application & s. Sent back for clarification on documents., A,, A, A, A A, Application Acceptance sent to employee & update accepted date in system. s Consolidation & moved to processing team. s review & check. Prepare Covering Letter. Consolidate & scan all the documents, applications with Covering Letter and get authorized signature from GMS person. A GMS processing agent hands over copy of all the documents to Dispatching team. Dispatching team sends all the documents with courier tracking number to concerned signing authority( client in case of CFS and H in reland in case of GEP). System updated with information to employee GMS Page 9 of 25

10 Employee / Manager approval Verification. Processing. Dispatching GMS Coordinator Attorneys / Service Provider mmigration Authorities (DJE) Wipro T Business Confidential reland Process oles Process Steps Authorized signatory will sign and sends all the documents to Attorneys in reland and sends information about the same to GMS team. Attorneys in reland file the Application & documents to rish mmigration Authorities (DJE) in reland and sends intimation to GMS team. System updates with comments & s filing date. rish mmigration Authorities (DJE) in reland issue Work Permit Approval / Denial Letter and informs Attorneys in reland. S Attorneys in reland will collect the Original Work Permit Approval / Denial letter from rish mmigration Authorities (DJE) and send it to GMS team. S Dispatching hands over the copy of Work Permit Approval / Denial letter to GMS processing team. Work Permit Approval / Denial details will be updated in system & auto mailer sent to Employee. n case of Approval received intimation sent to employee to proceed with stamping. A, Approval copy will be sent to GMS stamping team for further processing. A typical Work Permission: Application nitiation, A, Employee uploads required documents, A GMS Page 10 of 25

11 Employee / Manager approval Verification. Processing. Dispatching GMS Coordinator Attorneys / Service Provider mmigration Authorities (DJE) Wipro T Business Confidential reland Process oles Process Steps TM Approval Employee submits required hard copy documents Application Acceptance (Soft and hard copies of documents). Verification of Application & s., A, A A, Sent back for clarification on documents. Application Acceptance sent to employee & update accepted date in system. s Consolidation & moved to processing team. s review & check. A Prepare Covering Letter. Consolidate & scan all the documents, applications with Covering Letter and get authorized signature from GMS person. GMS processing agent hands over copy of all the documents to Dispatching team. Dispatching team sends all the documents with courier tracking number to attorneys. System updated with information to employee Attorneys in reland file the Application & documents to rish mmigration Authorities (NS) in reland and sends intimation to GMS team. System updates with comments & s filing date. GMS Page 11 of 25

12 Employee / Manager approval Verification. Processing. Dispatching GMS Coordinator Attorneys / Service Provider mmigration Authorities (DJE) Wipro T Business Confidential reland Process oles Process Steps rish mmigration Authorities (NS) in reland issue Work Permit Approval / Denial Letter and informs Attorneys in reland. Attorneys in reland will collect the Original Work Permit Approval / Denial letter from rish mmigration Authorities (NS) and send it to GMS team. Dispatching hands over the copy of Work Permit Approval / Denial letter to GMS processing team. Work Permit Approval / Denial details will be updated in system & auto mailer sent to Employee. n case of Approval received intimation sent to employee to proceed with stamping. S S A, Approval copy will be sent to GMS stamping team for further processing. Work Permit Extension Process: Extension Application nitiation, A, Employee uploads required documents.,a TM approval., A Application Acceptance (soft copies of documents). A, Verification of Application & s. Sent back for clarification on documents. Application Acceptance sent to employee & update accepted date in system. GMS Page 12 of 25

13 Employee / Manager approval Verification. Processing. Dispatching GMS Coordinator Attorneys / Service Provider mmigration Authorities (DJE) Wipro T Business Confidential reland Process oles Process Steps ntimation sent to processing team to process application. s review & check. A Prepare Confirmation Letter with WP enewal Application and get authorized signature from GMS person. GMS processing agent hands over signed Confirmation Letter with WP enewal Application to Dispatching team. Dispatching team sends all the documents with courier tracking number to Employee in reland. System updates with sent update in system. GMS approval sent to Attorney in reland to accept & process extension application. Employee submits all the documents, applications & Confirmation Letter to Attorneys in reland. Attorneys in reland file the Extension Application & documents to rish mmigration Authorities (DJE) in reland and sends intimation to GMS team. System updates with comments & s filing date. rish mmigration Authorities (DJE) in reland issue Work Permit Extension Approval / Denial Letter and informs Attorneys in reland. S Attorneys in reland will collect the Original Work Permit Extension Approval / Denial letter from rish mmigration Authorities (DJE) and send it to Employee in reland, copy sent to GMS processing team. S Work Permit Extension Approval / Denial letter details will be updated in MS system. GMS Page 13 of 25

14 Wipro T Business Confidential reland 5. Activity Details Sub Process 1: WOK PEMT POCESSNG nitiation Process: n order to initiate work permit request, the Supervisor or Manager should ensure that the mmigration Diary of the employee is up-to-date. a. The immigration request should be initiated only by the Manager if the employee meets all the requirements as per the rules & regulations of the country intended to travel. b. Once the immigration request is initiated a unique application is generated in the MS system. c. The Employee completes the application with the Questionnaire, uploads all the documents and should submit the hard copies of those documents to nearest GMS Location. d. The application moves to different approving authorities like TM, VH, BU Head. e. Upon approval from all the necessary oles, the application moves to GMS for further processing. mportant Note: The start date of travel in the request must be after 8 weeks from the time of raising the application, as the filing time is 7-8 weeks. Once the online application is approved and all the documents are received (both hard & soft copies) at GMS; the allocating manager assigns the application to the concerned GMS Verification agent Verification Process: GMS Page 14 of 25

15 Wipro T Business Confidential reland The GMS verification SPOC/agent responsible should validate the information and would have to follow the below mentioned verification process: 1. Check and ensure whether the necessary documents & forms mentioned are submitted by the employee with specified requirements. 2. Application Form: Duly filled and signed application form by the Employee. Please refer Annexure-2 for Work Permit application form. 3. Passport Copies: Clear color scanned copy of Employee Passport all pages (New Passport only) & previous visa stamped pages (if applicable in New & Old). Passport must be valid for atleast 18 months at the time of application. 4. oles and esponsibilities: Clearly defined Onsite oles, esponsibilities and skills to be performed by the Employee in current assignment to be verified from the questionnaire. 5. esume: esume completed should be with start and end dates of the projects without any gaps between projects right from employee s first job with the employer's name. esume should be as per the Template/format as available on GMS Portal Checklist. Please refer Annexure-3 for Wipro esume format. 6. Data Collection Form: Duly filled Employee Data Collection Form. Please refer Annexure-4 for Data Collection Form format. 7. Appointment Letter: Copy of Wipro Appointment letter till acceptance page with Signature, Date, Place and Name filled. 8. Salary Slip: Copies of Employee s last 12 months Wipro Salary slip or Pay slip. 9. Client nvitation Letter: Copy of client nvitation letter in which client clearly states the purpose of travel, travel start & end date and the exact duration of travel. The start date given in GMS supporting documents should align with the application and invite start date 10. Degree Certificates: Scanned copy of degree certificates if employee has Master's degree; both bachelor and Master Degree Convocation certificates. Check the University Certificates or Degree Certificates & PG GMS Page 15 of 25

16 Wipro T Business Confidential reland if applicable and verify the Employee Name and details provided as per the information. 11. Photograph: Two passport size photograph of employee with white background. 12. Deputation Letter: Copy of Employee signed Deputation Letter. While initiating immigration request Deputation letter will be auto generated. Please refer Annexure-6 for Deputation letter format. This is required only in case of Work Permit applied under CFS. 13. Contract Letter: 4 contract letters issued by H with original signatures of employee and H from Wipro reland. This is required only in case of Work Permit applied under GEP. Any deviation or mismatch of information the application would be sent back to the employee asking for further clarification. Note: The applications must be completed and submitted within 3 working days failing to which the system will auto reject the application and the auto rejected application cannot be reopened. Some of above mentioned documents may not be required for specific type of WP (Ex: Atypical Work Permission). Employees can submit the document as suggested in mmigration management system applicable for their Work WP) n case of any issues or delays the same can be escalated by referring to GMS Escalation Matrix. f the application satisfies all the necessary parameters; GMS verification agent will duly approve the request and will update the formal application acceptance date in the MS system & send all the documents to the processing team Application Processing: 1. The applications will reflect under the section Under Process Application. GMS Page 16 of 25

17 Wipro T Business Confidential reland 2. The document will be thoroughly verified by the respective GMS person or manager and would be sent for authorized signature on application form and / or Contract Letter. Please refer Annexure-8 for consolidated documents sample. (AB/CFS) 3. Then the processing agent will hand over the signed documents to the Dispatching. 4. The Dispatching will pack and send all the documents to concerned person authorized signature; with courier tracking number. Please refer Annexure-9 for GMS Courier Guidelines. 5. Upon receiving the respective documents, the authorized signatory sends the documents to Attorneys in reland. Please refer Annexure-10 for Attorney details in reland. 6. Once the documents are sent to Attorneys in reland; respective authorized signatory will send an intimation to attorneys as well as GMS team about the document sent date. 7. The GMS processing agent will update the system with the dates the documents were dispatched. 8. Then the Attorneys in reland will file the application & documents with rish mmigration Authorities (DJE/NS); and would send confirmation to GMS team about the application filing date. 9. The GMS processing agent will update the system with application file date; which would send an auto mailer to employee regarding the status of the application. 10. f the application request is complete & as per the Norms, the rish mmigration Authorities (DJE) will duly approve / deny the request and would inform the Attorneys in reland to collect the Work Permit Approval / Denial Letter. 11. The Attorneys in reland will collect the Original Work Permit Approval / Denial Letter from mmigration authorities and send the same to the respective GMS. Please refer Annexure-11 for a sample Work Permit Approval letter. GMS Page 17 of 25

18 Wipro T Business Confidential reland 12. Upon receiving the Work Permit Approval / Denial Letter, the Dispatching will hand over the same to the concerned GMS processing agent / team. 13. The GMS processing agent will verify details and update the received date/approved date/validity/duration of Stay Granted/Denial information in MS system and an auto mailer is sent to the employee. 14. n case of Approval received Employee needs to proceed with stamping and the GMS processing agent will hand over the original Approval copy to stamping team for further processing. mportant Note: Employee has to complete stamping process and Travel within 3 months from the receipt of Work Permit Approval. Sub Process 2: WOK PEMT EXTENSON POCESSNG Eligibility: Employee should have spent at least 80% of the duration in reland on the existing Work permit to be able to apply for Work Permit Extension. Employees have to raise a request in MS 2 months before the expiry of the resident permit nitiation Process: n order to initiate Work Permit Extension Employee should ensure that the mmigration Diary of the Employee is up-to-date. a. Once the Extension application is initiated a unique application is generated in the MS system. b. The Employee completes the application with the Questionnaire, uploads all the documents. GMS Page 18 of 25

19 Wipro T Business Confidential reland c. The application moves to different approving authorities like TM, VH, BU Head. d. Upon approval from all the necessary oles, the application moves to GMS for further processing. Once the online application is approved and all the documents are received (hard copies) at GMS; the respective allocating manager assigns the application to the concerned GMS Verification agent Verification Process: The GMS verification SPOC/agent responsible should validate the information and would have to follow the below mentioned verification process: 1. Passport Copies: Photocopies of Employee valid Passport pages showing current rish immigration stamp and visa. f the Employee has renewed his / her passport since last work permit application; Employee has to provide a copy of the identification page from the new passport. Verify the Passport copy with D page and Address page of the Passport. Check First & Last Name. The Passport should be valid for minimum 15 months (Passport issued for more than 10 years are not acceptable). The existing Visa page to be verified and check sufficient validity. 2. esidence Permit: Copies of Employee s current rish esident Permit (Garda registration card). Please refer Annexure-12 for Garda egistration card sample. 3. Photograph: Two recent passport size photograph of employee with white background and face should be clearly visible 4. Salary Slip: Copies of Employee s last 12 months Wipro pay slips both onsite and offshore. 5. Form P60/P45 issued in reland: Please refer Annexure-13 for P60 form format. 6. esidence Address: Employee s rish residence address. GMS Page 19 of 25

20 Wipro T Business Confidential reland 7. Contract Letter: enewed contract letters issued by H from Wipro reland. This is required only in case of Work Permit Extension applied under GEP Any deviation or mismatch of information the application would be sent back to the employee asking for further clarification. Note: The applications must be completed and submitted within 3 working days failing to which the system will auto reject the application and the auto rejected application cannot be reopened. n case of any issues or delays the same can be escalated by referring to GMS Escalation Matrix. f the application satisfies all the necessary parameters; GMS verification agent will duly approve the request and will update the formal application acceptance date in the MS system & send all the documents to the processing team Extension Application Processing: 1. The applications will reflect under the section Under Process Application. 2. The GMS processing agent takes print of Authorization letter and renewal application form and gets authorized signatory s signature on the renewal application form. Please refer Annexure-14.for Authorization Letter Format, Annexure-15 for Work Permit enewal Application and Annexure- 16 for authorized signatory details. 3. Then the processing agent will scan & subsequently keep a copy of the documents in the MS system for future reference and hands over the documents to the Dispatching. 4. The Dispatching will send the documents to Employee in reland; and courier tracking number will be shared with the GMS processing agent. Please refer Annexure-9 for GMS Courier Guidelines. The GMS GMS Page 20 of 25

21 Wipro T Business Confidential reland processing agent shares the same with employee and sends an intimation to Attorneys in reland notifying regarding the renewal application. 5. The GMS processing agent will update the MS system with the dates the documents were dispatched. 6. Then the Employee in reland submits the Work Permit renewal documents to Attorneys in reland. 7. Attorneys in reland will file the Work Permit renewal application with rish mmigration Authorities (DJE). They would also send confirmation to GMS team & Employee about the application filing date. 8. The GMS processing agent will update the system with application filed date. 9. f the application request is complete & as per the Norms, the rish mmigration Authorities (DJE) will duly approve / deny the request and would inform the Attorneys in reland to collect the Work Permit enewal Approval / Denial Letter. 10. The Attorneys in reland will collect the Original Work Permit renewal Approval / Denial Letter from rish mmigration Authorities (DJE) and sends the same to the respective Employee. A copy is also sent to GMS processing team. 11. The GMS processing agent updates the Work Permit Extension Approval / Denial letter details in MS system & closes the respective application. 6. Exit Criteria/Output a. Work Permit: The rish mmigration Authorities (DJE) will duly approve / deny the request and would inform the Attorneys in reland to collect the Work Permit Approval / Denial Letter. The respective Attorneys in reland will collect the Original Work Permit Approval / Denial Letter from rish mmigration Authorities GMS Page 21 of 25

22 Wipro T Business Confidential reland (DJE) and send the same to the respective GMS. Please refer Annexure-11 for a sample copy Approval letter. The GMS processing agent will verify all the details and update the eceived date/approved date/validity/duration of Stay Granted/Denial information in MS system & an auto mailer sent to Employee. n case of Approval received, Employee needs to proceed with stamping and the GMS processing agent will send the Approval copy to stamping team for further processing. b. Work Permit Extension: The rish mmigration Authorities (DJE) will duly approve / deny the request and would inform the Attorneys in reland to collect the Work Permit enewal Approval / Denial Letter. The respective Attorneys in reland will collect the Original Work Permit renewal Approval / Denial Letter from rish mmigration Authorities (DJE) and sends the same to the respective Employee. The GMS processing agent updates the Work Permit Extension Approval / Denial letter details in MS system & closes the respective application. 7. Process Measures No Description Definition GMS Page 22 of 25

23 Wipro T Business Confidential reland 8. Summary Tasks esponsibility Templates/Checklists Verification/ Validation Mechanism Annexure-1 () eview checklists Annexure-2 (WP Application Form) Verification Annexure-3 (esume Format) Verification Annexure-4 (Data Collection Format) Verification Annexure-5 (Tripatriate Agreement Format) Verification eview Check List Annexure-6 (Deputation Letter Format) Verification eview Check List Annexure-7 (Covering Letter Format) Processing eview Check List Annexure-8 (Consolidated s Sample) Annexure-9 (Courier Guidelines) Processing Dispatching Annexure-10 (Attorney Details) Processing Annexure-11 (Work Permit Approval Sample) Processing GMS Page 23 of 25

24 Wipro T Business Confidential reland Annexure-12 (Garda egistration Card Sample) Annexure-13 (P60 Application Form Format) Verification Verification eview Check List Annexure-14 (Confirmation Letter Format) Processing eview Check List Annexure-15 (Work Permit enewal Application) Annexure-16 (Authorized Signatory details) Processing Processing eview Check List 9. Glossary Terms / Acronyms P WP MS SPOC GMS PG UG DJE TM P60 (or P45) Detail Description esidence Permit (Garda card) Work Permit mmigration Management System Single Point of Contact Global mmigration Management Services Post Graduate (Masters) Under Graduate(Bachelors) Department of Jobs, Enterprise and nnovation (mmigration Authorities) Technical Manager Certificate Of Pay, Tax and Pay elated Social NS (Form to be submitted for Work Permit Extension) 10. evision History Version (x.yy) Date of evision Description of Change /Jan/2014 OOC to Global mmigration Management Services eason for Change Change in Department Name Affected Sections Entire SOP Approved By Nagarjuna Sadineni GMS Page 24 of 25

25 Wipro T Business Confidential reland /Feb/2015 Process review Change in Approver & reviewer details and Exception Approval matrix /Aug/2015 Process review Change in eligibility criteria and added de-registration details /April/2016 Process review Change in Exception Approval Matrix /July/2016 Process review Change in Eligibility Criteria Change in VSA Validity ncorporation of egistration and De- egistration Process /Sep/2016 Process review Change in Exception Approval Matrix /MAY/2017 Process review Change in Exception Approval Matrix Entire SOP Under Scope Entire SOP Entire SOP Entire SOP Entire SOP Venkatesh Venkatesh Nagarjuna Sadineni Venkatesh Anuj Sarin Anuj Sarin GMS Page 25 of 25