Our Policy

Work Safe Health and Safety Policy (BBS)

BEHAVIOUR BASED SAFTY POLICY

SUFALAM STREET is committed to ensuring Permanent and Temporary Employees, Visitors and Contractors are safe from risks to their health and safety whilst at work. SUFALAM STREET is committed to continual improvement of safety performance and the elimination of workplace injury and illness.

As a provider of on-hired employment services, Construction and other Services, SUFALAM STREET understands the importance of working with all stakeholders to achieve company objectives.

Objectives

The objectives of this policy are to ensure:

1. Risks to Work Health and Safety are controlled;
2. Safe systems of work are provided and maintained;
3. Permanent and Temporary Employees are provided with information, training and instruction;
4. Health and safety policies and procedures comply with legislative requirements;
5. Industry best practice standards with regard to Work Health and Safety are observed; and
6. Safety performance is continually reviewed and improved.

Responsibilities

SUFALAM STREET recognizes that management has the overall responsibility to provide a safe workplace.

Director is an Officer in accordance with Work Health and Safety law will be held accountable for implementing this policy in their area of responsibility via their annual performance reviews.

These responsibilities include

• Providing the resources to meet health and safety obligations;
• Maintaining effective communication and consultation with key stakeholders;
• Ensuring processes are in place to allow for the resolution of Work Health and Safety issues;
• Minimizing the impact of any work-related incidents; and
• Taking a pro-active approach to providing effective rehabilitation for ‘workers’ injured at work.
  

Permanent and Temporary Employees are responsible for:

1. Following all Work Health and Safety policies and procedures;
2. Ensuring their own and others safety is not affected by their actions; and
3. Reporting hazards, near misses and accidents.

Consultation

Consultation and communication of Work Health and Safety matters, applying risk management principles and the identification and elimination of the causes of injury, are key elements of performance expectations from all Employees.

Work Health and Safety performance will be an integral part of management performance reporting and will be subject to auditing processes to enable continual improvement.

Drug & Alcohol Policy

1. Purpose & Brief

This policy aims to ensure a safe, healthy, and productive work environment by addressing the use and misuse of drugs and alcohol within the Premises of SUFALAM STREET

2.Scope
This policy applies to all employees, contractors, and visitors of SUFALAM STREET

3. Prohibited behaviours

• Consumption of alcohol during work hours, including lunch breaks.
• Use or possession of illegal drugs on company premises.
• Reporting to work under the influence of drugs or alcohol.

4. Support and rehabilitation

Employees struggling with substance misuse are encouraged to seek help SUFALAM STREET offers counselling and support programs to assist in recovery.

5. Consequences of violation

Violations of this policy, such as possession of illegal drugs, will result in disciplinary actions, up to and including termination.

6. Reporting

Employees are encouraged to report any suspected violations to their supervisors or the HR department.

7. Review

This policy will be reviewed annually to ensure its continued relevance and effectiveness.

Information Technology Policy

SUFALAM STREET is committed to meet the Information Security requirements of its consumers, employees and business partners through effective implementation and continual improvement of its Information Security Management System (ISMS) by ensuring the Confidentiality, Integrity and Availability of its information assets and Information Technology infrastructure. SUFALAM STREET is also committed to comply with all relevant legal and regulatory requirements and provide the same commitment to the information assets entrusted to it by its customers and business partner

QUALITY, ENVIRONMENT, HEALTH AND SAFETY POLICY

We at “SUFALAM STREET” are Committed to constantly work towards maintaining Global Standard and Grow by providing a Safe, Healthy and Environment Friendly Work Place For all Its Employees and Associates to Produce Cost Effective Quality Products and Services at Competitive Price, Timely Delivery as Per Stated and Implied Needs of Our Business Partner By Proper Communication, Periodical Training of Employees, Strict Adherence to IMS{QHSE} and Legal Requirements, and its Continual Improvement to Enhance their  satisfaction. The Company Ensures that its operations are Carried Out in a Manner that Protects the Environment, Health & Safety and Community & Interested Parties in General.

The Aim of the policy shall be achieved at all our work areas by:

• Complying with all applicable Legal and other Requirements related to integrated management system.
• Ensuring employee compliance through mandatory training & programs on IMS awareness.
• Making the Employees responsible & accountable for all Quality, Health & Environmental issues.
• Providing adequate protection & maintaining safe working environment in all our work area for prevention of Pollution, injury & ill Health arising out of our activities.
• Conservation of natural resources through optimal utilization.
• Minimization of waste generation.
• Create Health & Environmental awareness amongst all our employees / business associates/ Interested Parties, and also make them aware of their roles & responsibilities.
• Timely review of Objectives & Targets to ensure the effective implementation of policy
• Making efforts to improve effectiveness of Integrated Management systems through Yearly review of the IMS{QHSE} Objectives & targets. 

CYBER SECURITY POLICY

1. Policy brief & purpose

SUFALAM STREET  cyber security policy outlines our guidelines and provisions for preserving the security of our data and technology infrastructure.

The more we rely on technology to collect, store and manage information, the more vulnerable we become to severe security breaches. Human errors, hacker attacks and system malfunctions could cause great financial damage and may jeopardize our company’s reputation.

For this reason, we have implemented a number of security measures. We have also prepared instructions that may help mitigate security risks. We have outlined both provisions in this policy.

2. Scope

This policy applies to all our employees, contractors, volunteers and anyone who has permanent or temporary access to our systems and hardware.

3.0 Policy elements                                                                                                                                                                                                    

3.1 Confidential data

Confidential data is secret and valuable. Common examples are:

• Unpublished financial information
• Data of customers/partners/vendors
• Patents, formulas or new technologies
• Customer lists (existing and prospective)

All employees are obliged to protect this data. In this policy, we will give our employees instructions on how to avoid security breaches.

3.2 Protect personal and company devices

When employees use their digital devices to access company emails or accounts, they introduce security risk to our data. We advise our employees to keep both their personal and company-issued computer, tablet and cell phone secure. They can do this if they:

• Keep all devices password protected.
• Choose and upgrade a complete antivirus software.
• Ensure they do not leave their devices exposed or unattended.
• Install security updates of browsers and systems monthly or as soon as updates are available.
• Log into company accounts and systems through secure and private networks only.

We also advise our employees to avoid accessing internal systems and accounts from other people’s devices or lending their own devices to others.

When new hires receive company-issued equipment they will receive instructions for:

• [Disk encryption setup]
• [Password management tool setup]
• [Installation of antivirus/ anti-malware software]

They should follow instructions to protect their devices and refer to our [Security Specialists/ Network Engineers] if they have any questions.

 

3.3 Keep emails safe

Emails often host scams and malicious software (e.g. worms.) To avoid virus infection or data theft, we instruct employees to:

• Avoid opening attachments and clicking on links when the content is not adequately explained (e.g. “watch this video, it’s amazing.”)
• Be suspicious of clickbait titles (e.g. offering prizes, advice.)
• Check email and names of people they received a message from to ensure they are legitimate.
• Look for inconsistencies or give-aways (e.g. grammar mistakes, capital letters, excessive number of exclamation marks.)

If an employee isn’t sure that an e-mail, they received is safe, they can refer to our [IT Specialist.]

3.4 Manage passwords properly

Password leaks are dangerous since they can compromise our entire infrastructure. Not only should passwords be secure so they won’t be easily hacked, but they should also remain secret. For this reason, we advise our employees to:

• Choose passwords with at least eight characters (including capital and lower-case letters, numbers and symbols) and avoid information that can be easily guessed (e.g. birthdays.)
• Remember passwords instead of writing them down. If employees need to write their passwords, they are obliged to keep the paper or digital document confidential and destroy it when their work is done.
• Exchange credentials only when absolutely necessary. When exchanging them inperson isn’t possible, employees should prefer the phone instead of email, and only if they personally recognize the person they are talking to. ● Change their passwords every two months.

Remembering a large number of passwords can be daunting. We will purchase the services of a password management tool which generates and stores passwords. Employees are obliged to create a secure password for the tool itself, following the abovementioned advice.

3.5 Transfer data securely

Transferring data introduces security risk. Employees must:

• Avoid transferring sensitive data (e.g. customer information, employee records) to other devices or accounts unless absolutely necessary. When mass transfer of such data is needed, we request employees to ask our [Security Specialists] for help.
• Share confidential data over the company network/ system and not over public Wi-Fi or private connection.
• Ensure that the recipients of the data are properly authorized people or organizations and have adequate security policies.
• Report scams, privacy breaches and hacking attempts

Our [IT Specialists/ Network Engineers] need to know about scams, breaches and malware so they can better protect our infrastructure. For this reason, we advise our employees to report perceived attacks, suspicious emails or phishing attempts as soon as possible to our specialists. Our [IT Specialists/ Network Engineers] must investigate promptly, resolve the issue and send a companywide alert when necessary.

Our Security Specialists are responsible for advising employees on how to detect scam emails. We encourage our employees to reach out to them with any questions or concerns.

3.6 Additional measures

To reduce the likelihood of security breaches, we also instruct our employees to:

• Turn off their screens and lock their devices when leaving their desks.
• Report stolen or damaged equipment as soon as possible to [HR/ IT Department].
• Change all account passwords at once when a device is stolen.
• Report a perceived threat or possible security weakness in company systems.
• Refrain from downloading suspicious, unauthorized or illegal software on their company equipment.
• Avoid accessing suspicious websites.

We also expect our employees to comply with our  internet usage policy.

Our [Security Specialists/ Network Administrators] should:

• Install firewalls, anti-malware software and access authentication systems.
• Arrange for security training to all employees.
• Inform employees regularly about new scam emails or viruses and ways to combat them.
• Investigate security breaches thoroughly.
• Follow this policies provisions as other employees do.

SUFALAM STREET will have all physical and digital shields to protect information.

3.7 Remote employees

Remote employees must follow this policy’s instructions too. Since they will be accessing our company’s accounts and systems from a distance, they are obliged to follow all data encryption, protection standards and settings, and ensure their private network is secure.

We encourage them to seek advice from our [Security Specialists/ IT Administrators.]

 

4. Disciplinary Action

We expect all our employees to always follow this policy and those who cause security breaches may face disciplinary action:

• First-time, unintentional, small-scale security breach: We may issue a verbal warning and train the employee on security.
• Intentional, repeated or large-scale breaches (which cause severe financial or other damage): We will invoke more severe disciplinary action up to and including termination.

We will examine each incident on a case-by-case basis.

Additionally, employees who are observed to disregard our security instructions will face progressive discipline, even if their behaviour hasn’t resulted in a security breach.

4.1 Take security seriously

Everyone, from our customers and partners to our employees and contractors, should feel that their data is safe. The only way to gain their trust is to proactively protect our systems and databases. We can all contribute to this by being vigilant and keeping cyber security top of mind.

PII DATA SECURITY POLICY/  PLAN

PII DATA SECURITY POLICY

Control Objective

To Control the Security of PII DATA of Customers, Employees, Visitors, Vendors etc.

SUFALAM STREET is committed to secure the PII Data of any of the Interested Parties and all the PII Data will be secured into the Server and with the Related Employees such as HR, Accounts, Sales, VP AND all the Employees has signed the NDA for not to disclose any of the Information to any of the 3^rd Party.

Description of the PII Information:

Related Interested Party	Type of PII	Location	Responsibility
Customer	Personnel Contact Details	Server	Sales Manager
Vendors		Server	Account Manager/GM
Employees		Server	HR Manager
Customer	Work Order Details	Server	Sales Manager

Now all the PII from the Related Party is Secure and Located in Server.

BUSINESS CONTINUITY POLICY/PLAN

Business Continuity Policy

Control Objective

To counteract interruption to business activities, to protect critical business process from the effects of major failure of information systems or disasters and to ensure their timely resumption.

Risks associated with information system shall be addressed in an orderly manner. The organization has a clear picture of the associated risks, has taken various steps to protect the organizational infrastructure and the information system against these risks.

Business activities can be interrupted by natural calamities like flood, fire or earthquake or else by security risk like a major virus outbreak.

SUFALAM STREET understands the impact of the interruption in the company’s business. SUFALAM STREET has thus taken specific steps for disaster recovery.

• Full data Backup of the organization’s mission critical server is taken on CLOUD.
• The Back up has taken every week so that in case of disaster the organization may not face a data loss of more than a week, in case of natural disasters like fire or flood.
• An incremental backup of the databases and transaction logs is kept to reduce the data loss to maximum of 24 hours and for a speedy restoration of the server in case of disaster.
• This ensures that the business activities linked with mails and Internet can be restored and made operational in minimum amount of downtime in case of a disaster   .
• All Data Back Up will be shifted on Google Drive Soon in order to Prevent the Data Loss in case of any Emergency Situation.
• For Physical Work: We have a Facility to Organize all activities in case of emergency.

1.Anti-Bribery & Corruption Policy

1. POLICY STATEMENT

1.1  It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to Bribery and Corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

1.2       We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.  We remain bound by local and national laws.

DEFINITIONS

“Agent”: Any individual acting as an agent, paid by the company, acting on the company’s behalf in negotiating with Third Parties.

“Bribery” / “Corruption”: Bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, to induce or reward improper conduct or to gain any commercial, contractual, regulatory or personal advantage.  It can be direct or indirect through Third Parties.

“Company”: All subsidiaries and affiliated companies.

“Conflict of Interest”: Occurs when an individual or organisation is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another.

“Donation”: A Donation is a voluntary contribution in the form of monetary or non-monetary gifts to a fund or cause for which no return service or payment is expected or made.  Contributions to industry associations or fees for memberships in organisations that serve business interests are not necessarily considered Donations.

“Employee”: For the purposes of this policy this includes all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, home-workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or joint ventures or their employees, wherever they are located.

“Facilitation Payments”: A form of Bribery in which small payments are made with the purpose of expediting or facilitating the performance by a Public Official of a routine governmental action and not to obtain or retain business or any other undue advantage.  Facilitation payments are typically demanded by low level and low income Public Officials in exchange for providing services to which one is legally entitled without such payments.

“Gifts, Invitations & Hospitality”: Invitations given or received to social functions, sporting events, meals and entertainment, gifts or customary tokens of appreciation.

“Intermediary”: Includes but is not limited to Agents, distributors, consultants, sales representatives, implementation partners, sales partners.

“Kickback”: A bribe to obtain an undue advantage, where a portion of the undue advantage is ‘kicked backed’ to the person who gave, or is supposed to give, the undue advantage. 

“Public Official”: Officials or employees of any government or other public body, agency or legal entity, at any level, including officers or employees of state-owned enterprises and officers or employees of enterprises which are mandated by a public body or a state-owned enterprise to administrate public functions. 

“Sponsorship”: Sponsorship is about partnering with external organisations to deliver mutual benefits through an exchange of monies, products, services, content or other intellectual property.

“Third Party”: Any individual or organisation you come into contact with during the course of your work for us.  This includes actual and potential customers, suppliers, business contacts, Intermediaries, government and public bodies, including their advisors, representatives and officials, politicians and political parties.

3.SCOPE

3.1. This policy applies to all Employees and relevant Third Parties of the Company and shall be communicated to them at the outset of our business relationship and as appropriate thereafter.

3.2. This policy applies in all countries or territories where the Company operates.  Where local customs, standards, laws or other local policies apply that are stricter than the provision of this policy, the stricter rules must be complied with.  However, if this policy stipulates stricter rules than local customs, standards, laws or other local policies, the stricter provisions of this policy shall apply.

4. GIFTS, INVITATIONS & HOSPITALITY

4.1. This policy does not prohibit normal and appropriate hospitality (given and received) to or from Third Parties.

4.2. You are prohibited from accepting a gift or giving a gift to a third party in the following situations:

• it is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• it is given in your name and not in the name of the Company;
• it includes cash or a cash equivalent (such as gift certificates or vouchers);
• it is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process); and
• it is given secretly and not openly.

4.3. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another.  The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and is proportionate.  The intention behind the gift should always be considered.

5. FACILITATION PAYMENTS & KICKBACKS

5.1. In many jurisdictions, making Facilitation Payments is illegal.  We do not make, and will not accept, Facilitation Payments or Kickbacks of any kind anywhere in the world. 

5.2. Where the facilitation payment is being extorted or you are being coerced to pay it and your safety or liberty is under threat or you feel you have no alternative but to pay for personal or family peace of mind, then pay the Facilitation Payment and report this to your line manager as soon as possible.

6. YOUR RESPONSIBILITIES

6.1. It is not acceptable for you (or someone on your behalf) to:

• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
• give, promise to give, or offer, a payment, gift or hospitality to a Public Official or Third Party to ‘facilitate’ or expedite a routine procedure;
• accept payment from a Third Party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
• accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
• threaten or retaliate against another Employee who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy or perceived breach of this policy.

6.2. It is your responsibility to ensure that all accounts, invoices, memoranda and other documents and records relating to dealings with Third Parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness.  No accounts must be kept ‘off-book’.

6.3. You must declare and keep a written record of all Gifts, Invitations & Hospitality according to Company practice accepted or offered, which will be subject to managerial review.

6.4. You must ensure all expense claims relating to Gifts, Invitations & Hospitality or expenses incurred to Third Parties are submitted in accordance with the Company’s expenses policy and specifically record the reason for the expenditure.

6.5. The prevention, detection and reporting of any form of Bribery & Corruption are the responsibility of all Employees.  You must notify as soon as possible if you are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.  

6.6. All Employees have the responsibility to read, understand and comply with this policy.  You should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.

6.7. Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. 

6.8 . This policy should be read in conjunction with the Company’s Gifts, Invitations & Hospitality policy, Conflicts of Interest policy and Code of Ethics.

6.9 . Employees are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their line manager or other available reporting mechanisms.

7. PROTECTION

7.1. Employees who refuse to take part in bribery or corruption, or report in good faith under this policy their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future will be protected from detrimental treatment/retaliation. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.

8.      GOVERNANCE

8.1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

8.2. It has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness.  Management at all levels are responsible for ensuring those reporting to them is made aware of and understand this policy and are given adequate and regular training on it. This training shall also be given to Intermediaries.

9. MONITORING AND REVIEW

9.1. The Company will establish and put in place appropriate performance measures and reporting systems to monitor performance against metrics and compliance with the relevant policies, procedures and controls.

9.2. HOD will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.  Any improvements identified will be made as soon as possible.

9.3. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective.  HOD will report to the Director at least annually on the application of this policy.

APPENDIX 1

“RED FLAGS”

The following is a list of possible red flags that may arise during the course of your work for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these red flags while working for us, you must report them promptly to HOD

• you become aware that a Third Party engages in, or has been accused of engaging in, improper business practices;
• if the Third Party refuses to divulge adequate information during due diligence procedure;
• you learn that a Third Party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a ‘special relationship’ with foreign Public Officials;
• a Third Party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
• a Third Party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
• a Third Party requests that payment is made to a country or geographic location different from where the Third Party resides or conducts business;
• a Third Party requests an unexpected additional fee or commission to ‘facilitate’ a service;
• a Third Party demands lavish Gifts, Invitations or Hospitality before commencing or continuing contractual negotiations or provision of services;
• a Third Party requests that a payment is made to ‘overlook’ potential legal violations;
• a Third Party requests that you provide employment or some other advantage to a friend or relative;
• a Third Party requests that you make a political contribution or donation to the party or charity of their choice before agreeing to undertake a business relationship with the Company
• you receive an invoice from a Third Party that appears to be non-standard or customized;
• a Third Party refuses to put terms agreed in writing;
• you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
• a Third Party requests or requires the use of an Agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or
• you are offered an unusually generous gift or offered lavish hospitality by a Third Party.

Whistle blowing Policy

Contents

Clause

1. About this policy……………………………………………………………………….. 1
2. What is whistle blowing?…………………………………………………………….. 1
3. How to raise a concern……………………………………………………………….. 1
4. Confidentiality…………………………………………………………………………… 1
5. External disclosures……………………………………………………………………. 2
6. Protection and support for whistle-blowers…………………………………… 2
7. Contacts…………………………………………………………………………………… 2

• About this policy

We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

This policy covers all employees, officers, consultants, contractors, [volunteers,] [interns,] casual workers and agency workers.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

• What is whistle blowing?

Whistle blowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations. It also includes the following matters specific to this workplace.

• How to raise a concern

We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact the Whistle blowing Officer (Akhilesh Kumar) or the Managing Director. Contact details are at the end of this policy.

We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

• Confidentiality

We hope that staff will feel able to voice whistle blowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern. 

• External disclosures
• The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.
• The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.
• Protection and support for whistle-blowers
• We aim to encourage openness and will support whistle-blowers who raise genuine concerns under this policy, even if they turn out to be mistaken.
• Whistle-blowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform the Whistle blowing Officer immediately.
• You must not threaten or retaliate against whistle-blowers in any way. If you are involved in such conduct, you may be subject to disciplinary action.
• However, if we conclude that a whistle-blower has made false allegations maliciously or with a view to personal gain, the whistle-blower may be subject to disciplinary action.
• Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.

Contacts

Whistle blowing Officer
Manager

HUMAN RIGHTS POLICY

1.Mission Statement

We respect the human rights of all individuals impacted by our operations, including employees, contractors and external stakeholders. Wherever we operate, we seek to avoid causing or contributing to human rights violations and to facilitate access to remedy. While governments have the primary responsibility to protect against human rights violations, we understand and accept our responsibility to respect human rights.

We consider “human rights” to be all internationally recognized human rights in the International Bill of Human Rights and Rights at Work.

2.Our Approach

In fulfilling our mission, we are guided by several principles that help define our approach:

• We are committed to and always strive to act in accordance with the Human Right Commission on Business and Human Rights, and the Voluntary Principles on Security and Human Rights.
• We do not tolerate violations of human rights committed by our employees, affiliates, or any third parties acting on our behalf or related to any aspect of one of our operations.
• We do not tolerate the use of child labour, prison labour, or any form of forced labour, slavery or servitude.
• We believe in fair employment practices and in a workplace in which all individuals are treated with dignity and respect. We do not tolerate discrimination against individuals on the basis of race, colour, gender, religion, political opinion, ethnicity, age, nationality or social origin, sexual orientation, or union membership.
• We aim to pay all employees and contractors fairly. We will enforce working hours to the best of our ability aligned with National standards, and provide fairly compensated overtime and pay for periodic holidays and time off.
• We respect the freedom of expression and right to associate of our employees and contractors, including their right to establish and to join organizations of their own choosing to bargain collectively and advance their occupational interests without our previous authorization or unreasonable interference.
• We do not tolerate threats, intimidation, or attacks against human rights defenders.
• In our relationships with host governments, contractors and third-party service providers, we do our utmost to avoid being complicit in adverse human rights impacts, including benefitting from the human rights violations caused by others.
• We monitor and try to continuously improve our human rights performance.

3.Steps We Take

To try and meet those commitments, we will aim to take several steps:

• Develop and implement supporting policies, procedures, training and internal reporting structures to embed this Policy throughout our company.
• Provide training on our human rights expectations to all new employees and all relevant existing employees.
• Provide a safe and healthy workplace for all staff, contractors and subcontractors.
• Follow the Voluntary Principles on Security and Human Rights in our dealings with public and private security providers, local communities and potential victims of human rights violations.
• Comply, and demand that all suppliers and contractors comply, with all national laws, the International Bill of Human Rights.
• Conduct human rights due diligence for all new projects and significant modifications to existing operations where there is the potential for negative human rights impacts, and seek to employ reasonable measures to mitigate those impacts.
• For relevant suppliers and third-party service providers, perform reasonable due diligence, insist that human rights terms and conditions be included in contracts (including compliance with this Policy), and require periodic human rights reporting, certifications and/or training.
• Promote human rights by contributing to public debate, supporting international agreements and commitments, and identifying opportunities to constructively engage on human rights issues relevant to the countries in which we operate.
• Only employ people above the minimum employment age set by national law. We will avoid employing individuals below 18 years of age in work that is likely to harm their health, safety or morals.
• Promote fair competition, including respect for property rights.
• Respect the history, culture and traditional ways of indigenous peoples, their standing as distinct, self-determining peoples with collective rights, and their interests in land, waters and the environment.
• Meaningfully engage with the local communities and other stakeholders affected by our operations to create and maintain transparent relationships built on mutual respect and trust.
• Establish and maintain a grievance mechanism for human rights complaints to be reported and addressed without any prejudice to the aggrieved person(s). We will report publicly on how complaints have been managed.
• Prevent, mitigate, and, where appropriate, remedy negative human rights impacts that are caused, or contributed to, by our company. In situations where we are directly linked to negative human rights impacts because of activities in our value chain, we will seek to use our leverage to prevent or mitigate those impacts.
• Take appropriate action where we identify violations of this Policy by employees or contractors
• Conduct periodic audits and reviews at different sites, of different operating units, and of different contractors, to give us confidence that we are meeting the letter and spirit of this Policy. We may conduct those audits ourselves, or use external third parties. Where appropriate, we will establish performance improvement action plans to respond to the findings of these audits and reviews.
• Communicate this policy to our employees, partners, contractors and sub-contractors and make it available to the public.
• Report on our performance against our human rights objectives and targets.

4. Scope of Policy

The Policy is applicable to our entire workforce of SUFALAM STREET, including senior executives, financial officers, contractors and members of the Board of Directors, at every site that we operate. Certain of our affiliates and joint ventures maintain their own distinct human rights policies and approaches, however we will use all rights and powers at our disposal as significant shareholders to achieve policies that will, in principle, align with this policy.

LAND RIGHT POLICY

We at “SUFALAM STREET” declared that the Land on which we are working the activities of Printing and Fabrication works is our self-property and Registered under the Assam Government.

Also a part of Land on which the Fabrication works is going on is on Rental Basis and we have the Rental Contract/Agreement from the First Owner.

The Aim of the policy shall be achieved at all our work areas by:

• Complying with all applicable Legal and other Requirements related to Land Acquisition
• Fulfill the Local and Central Govt. Rules of Land and Rental basis.

Child Labour and Remediation Policy

We at “SUFALAM STREET” declared that in our Premises there is no any Child Labour will be allowed to do the Work under age of 18 Years. This is our Strong Commitment towards the safety of Children’s and the Respect of the Indian Labour Law.

We are Strongly Committed to Fulfil the Laws Developed by the Indian Ministry of Labour and Employment {Child Labour (Prohibition & Regulation) Act, 1986}.

Hiring and recruitment policy

Policy brief & purpose

Our employee hiring, recruitment and selection policy describe our process for attracting and selecting external job candidates. This recruitment policy sample can serve as a rubric that our recruiters and hiring managers can use to create an effective hiring process.

We are committed to our equal opportunity policy at every selection stage. Hiring teams should aim for a well-planned and discrimination-free hiring process.

Scope

This recruitment and selection policy applies to all employees who are involved in hiring for our company. It refers to all potential job candidates.

Policy elements

What is the recruitment and selection process?

Generally, hiring teams could go through the following steps:

1. Identify need for an opening
2. Decide whether to hire externally or internally
3. Review the job description and compose a job ad
4. Select appropriates sources (external or internal) for posting the opening
5. Decide on the selection stages and possible timeframe
6. Review resumes in company database
7. Source passive candidates
8. Shortlist applications
9. Proceed through all selection stages
10. Run background checks
11. Select the most suitable candidate
12. Make an official offer

Stages may overlap. Hiring managers may remove/add steps as appropriate. The first five stages are mandatory in every hiring process.

Posting jobs internally

Hiring managers can post a job opening internally before starting recruiting external candidates. If they decide to post internally, they can:

• Set a deadline for internal applications
• Communicate their opening through newsletters, emails, word-of-mouth or an Applicant Tracking System’s automated emails

Creating job descriptions

Hiring managers can create job ads based on full job descriptions of each role. Job ads should be clear and accurately represent the open position. They should include:

• A brief description of our company and mission
• A short summary of the role’s purpose
• A list of responsibilities
• A list of requirements
• How to apply

The job ad’s style should be consistent with our company’s unique voice. It should be addressed to ‘you’ in a polite and engaging tone. Jargon, complicated phrases and gender-specific language should be avoided.

Employee selection stages

Our company has a standard hiring process that may be tweaked according to a role’s requirements. Our standard process involves:

• Resume screening
• Phone screening
• Assignment
• Interview

Hiring managers may choose to add/remove stages depending on the role they’re hiring for. For example, they can add the following selection stages/methods:

• Assessment centers
• Group interviews
• Competency/Knowledge or other selection tests
• Referrals Evaluation

In most cases, the stages of resume screening and interview are compulsory.

Interview feedback

Recruiters/ hiring managers should always inform candidates they interviewed that they decided to reject them. Leaving candidates in the dark can be damaging to our employer brand.

Also, we encourage hiring managers to send interview feedback to candidates. They should first though check with HR to make sure they won’t invite legal action. Being brief, respectful and keeping feedback job-related are the general rules for writing feedback emails to candidates.

 

Revoked offers

In case when a formal has to be revoked, the hiring manager and human resources department should draft and sign an official document. This document should include a legitimate reason for revoking the offer. Legitimate reasons include:

• Candidate is proved to not be legally allowed to work for our company at a specific location
• Candidate has falsified references or otherwise lied about a serious issue
• Candidate doesn’t accept the offer within the specified deadline (deadline must have been included in the offer letter)

Hiring managers and HR must notify the candidate formally as soon as possible.

Disclaimer: This policy template is meant to provide general guidelines and should be used as a reference. It may not take into account all relevant local, state or federal laws and is not a legal document. Neither the author nor Workable will assume any legal liability that may arise from the use of this policy.

Working hours policy

I. Purpose

The purpose of this Working Hours Policy is to set the standard for working hours, ensuring adequate staffing levels to meet the needs of our clients, and to provide consistency, fairness, and work-life balance for all employees.

II. Policy Statement

It is the policy of SUFALAM STREET that full-time employees will be scheduled to work 48 hours per week, while part-time employees will be scheduled in accordance with their agreed-upon hours.

III. Regular Working Hours

The standard working hours are 9:30 a.m. to 6:00 p.m., Monday to Saturday, with a one-hour break for lunch. However, some roles may require different work schedules. Employees will be informed of their specific work schedules upon hire or change in position.

IV. Flextime

SUFALAM STREET recognizes the importance of work-life balance and, where practical, offers flexible working arrangements. Employees may request changes to their start and end times or to work from home part of the week, subject to approval by their supervisor.

V. Overtime

Overtime may occasionally be required to meet business needs. Non-exempt employees will be compensated at the rate of time and a half for all hours worked beyond 48 hours in a workweek, in accordance with federal and state labor laws.

VI. Breaks

All employees are entitled to a one-hour unpaid lunch break and two 15-minute paid breaks during each 8-hour workday.

VII. Timekeeping

All employees are required to accurately record their time worked using the company’s timekeeping system. Employees must clock in and out at the start and end of their shifts, as well as for lunch breaks.

VIII. Compliance

Failure to comply with this policy, including working unauthorized overtime or not taking mandatory breaks, may result in disciplinary action, up to and including termination.

IX. Policy Review

This policy will be reviewed annually and updated as necessary to comply with changes in employment laws and business requirements.

The above policies apply to all employees of SUFALAM STREET, subject to the terms of any applicable collective bargaining agreement or employment contract.

Anti-Discrimination Policy

AIMS

SUFALAM STREET is committed to providing a safe, flexible and respectful environment for staff and clients free from all forms of discrimination, bullying and sexual harassment.

All staff are required to treat others with dignity, courtesy and respect.

By effectively implementing our Equal Employment Opportunity & Anti-Discrimination Policy we will attract and retain talented staff and create a positive working environment for staff.

SCOPE

This policy applies to:

• All staff, including: managers and supervisors; full-time, part-time or casual, temporary or permanent staff; job candidates; student placements, apprentices, contractors, sub-contractors and volunteers;
• How the Company provides services to clients and how it interacts with other members of the public;
• All aspects of employment, recruitment and selection; conditions and benefits; training and promotion; task allocation; shifts; hours; leave arrangements; workload; equipment and transport;
• On-site, off-site or after-hours work; work-related social functions; conferences  wherever and whenever staff may be as a result of their duties;
• Staff treatment of other staff, of clients, and of other members of the public encountered in the course of their duties.

In so far as this policy imposes any obligations on the Company, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual are set out in an employee’s written employment contract.

The Company may unilaterally introduce, vary, remove or replace this policy at any time.

STAFF RIGHTS AND RESPONSIBILITIES

All staff are entitled to:

• Recruitment and selection decisions based on merit and not affected by irrelevant personal characteristics; Work free from discrimination, bullying and sexual harassment;
• The right to raise issues or to make an enquiry or complaint in a reasonable and respectful manner without being victimised;
• Reasonable flexibility in working arrangements, especially where needed to accommodate their family responsibilities, disability, religious beliefs or culture.

All staff must:

• Follow the standards of behaviour outlined in this policy;
• Offer support to people who experience discrimination, bullying or sexual harassment, including providing information about how to make a complaint;
• Avoid gossip and respect the confidentiality of complaint resolution procedures; Treat everyone with dignity, courtesy and respect.

ADDITIONAL RESPONSIBILITIES OF MANAGERS AND SUPERVISORS

Managers and supervisors must also:

• Model appropriate standards of behavior;
• Take steps to educate and make staff aware of their obligations under this policy and the law; Intervene quickly and appropriately when they become aware of inappropriate behavior;
• Act fairly to resolve issues and enforce workplace behavioral standards, making sure relevant parties are heard;
• Help staff resolve complaints informally;
• Refer formal complaints about breaches of this policy to the appropriate complaint handling officer for investigation;
• Ensure staff who raise an issue or make a complaint are not victimized;
• Ensure that recruitment decisions are based on merit and that no discriminatory requests for information are made;
• Seriously consider requests for flexible work arrangements.

UNACCEPTABLE WORKPLACE CONDUCT

Discrimination, bullying and sexual harassment are unacceptable at the Company and are unlawful under legislation including:

• Sex Discrimination Act 1984 (Cth);
• Racial Discrimination Act 1975 (Cth);
• Disability Discrimination Act 1992 (Cth);
• Age Discrimination Act 2004 (Cth);

Staff (including managers) found to have engaged in such conduct might be counselled, warned or disciplined. Severe or repeated breaches can lead to formal discipline up to and including termination of employment.

Under the law staff can be held personally liable for certain breaches of discrimination law, and the Company can also be vicariously liable for staff members’ conduct.

DISCRIMINATION

Discrimination is treating, or proposing to treat, someone unfavourably because of a personal characteristic protected by the law, such as sex, age, race or disability.

Discrimination can occur:

• Directly, when a person or group is treated less favourably than another person or group in a similar situation because of a personal characteristic protected by law. For example, a worker is harassed and humiliated because of their race or a worker is refused promotion because they are ‘too old’
• Indirectly, when an unreasonable requirement, condition or practice is imposed that has, or is likely to have, the effect of disadvantaging people with a personal characteristic protected by law. For example, redundancy is decided based on people who have had a worker’s compensation claim rather than on merit.

Protected personal characteristics under Federal discrimination law include:

• Parental status or status as a career, for example, because they are responsible for caring for children or other family members;
• Racecolour, descent, national origin, or ethnic background;
• Age, whether young or old, or because of age in general;
• Sex;
• Industrial activity, including being a member of an industrial organization like a trade union or taking part in industrial activity, or deciding not to join a union;
• Religion;
• Pregnancy and breastfeeding;
• Sexual orientation, intersex status or gender identity, including gay, lesbian, bisexual, transsexual, transgender, queer and heterosexual;
• Marital status, whether married, divorced, unmarried or in a de facto relationship or same sex relationship; Political opinion;
• Social origin; Medical record;
• An association with someone who has, or is assumed to have, one of these characteristics, such as being the parent of a child with a disability.

It is also against the law to treat someone unfavourably because you assume they have a personal characteristic or may have it at some time in the future.

DISABILITY DISCRIMINATION

Employers are also required in some circumstances to make “reasonable adjustments” to facilitate employees with disabilities to perform the “inherent requirements” of the particular role they perform. An employer will be deemed to have discriminated against an employee if they fail to make these adjustments.

The “inherent requirements” of a position are the essential activities that must be carried out to fulfil the purpose of the position.

An adjustment is not reasonable if it will impose “unjustifiable hardship” on the employer. In assessing unjustifiable hardship factors to be considered include:

• The nature of the benefit or detriment to be imposed on any person concerned, including the community;
• The effect of the employee’s disability;
• The financial circumstances and the estimated amount of expenditure required to be made by the employer; The availability of financial and other assistance to the employer.

Examples of adjustments that may in some circumstances be reasonable for an employer to make include:

• Changing recruitment and selection procedures. For example, providing a sign language interpreter for a Deaf person or ensuring the medical assessor is familiar with a person’s particular disability and how it   relates to the job requirements.
• Modifying work premises. For example, making ramps, modifying toilets or providing flashing lights to alert people with a hearing loss.
• Changes to job design, work schedules or other work practices. For example, swapping some duties among staff or providing regular meal breaks for a person with diabetes.
• Modifying equipment. For example, lowering a workbench or providing an enlarged computer screen.
• Providing training or other assistance. For example, running induction programs for staff with a disability and their co-workers, providing a mentor or support person for a person with an intellectual disability, and including staff with a disability in all mainstream training.

It is not unlawful to discriminate against a person because of their disability where:

They cannot meet the inherent requirements of the job, even when the employer has made any reasonable adjustments; or providing the person with reasonable adjustments to facilitate their disability imposes an unjustifiable hardship on the employer.

BULLYING

If someone is being bullied because of a personal characteristic protected by equal opportunity law, it is a form of discrimination.

Bullying can take many forms, including jokes, teasing, nicknames, emails, pictures, text messages, social isolation or ignoring people, or unfair work practices.

Under Federal law, this behaviour does not have to be repeated to be discrimination – it may be a one-off event.

Behaviours that may constitute bullying include;

• Sarcasm and other forms of demeaning language; Threats, abuse or shouting;
• Coercion; Isolation;
• Inappropriate blaming; Ganging up;
• Constant unconstructive criticism;
• Deliberately withholding information or equipment that a person needs to do their job or access their entitlements;
• Unreasonable refusal of requests for leave, training or other workplace benefits.

Any form of bullying is unacceptable in the Company and may also be against workplace health and safety law.   The Company has a separate Workplace Anti-Bullying and Anti-Harassment Policy which employees must read and abide by, this deals with bullying and harassment that is not a form of discrimination (ie where not based on a protected personal characteristic).

SEXUAL HARASSMENT

Sexual harassment is a specific and serious form of harassment. It is unwelcome sexual behaviour, which could be expected to make a person feel offended, humiliated or intimidated. Sexual harassment can be physical, spoken or written. It can include:

• Comments about a person’s private life or the way they look; Sexually suggestive behavior, such as leering or staring; Brushing up against someone, touching, fondling or hugging; Sexually suggestive comments or jokes;
• Displaying offensive screen savers, photos, calendars or objects; Repeated unwanted requests to go out;
• Requests for sex;
• Sexually explicit posts on social networking sites; Insults or taunts of a sexual nature;
• Intrusive questions or statements about a person’s private life; Sending sexually explicit emails or text messages; Inappropriate advances on social networking sites;
• Accessing sexually explicit internet sites;
• Behavior that may also be considered to be an offence under criminal law, such as physical assault,
• indecent exposure, sexual assault, stalking or obscene communications.

Just because someone does not object to inappropriate behaviour in the workplace at the time, it does not mean that they are consenting to the behaviour.

Sexual harassment occurs in the workplace when it happens at work, at work-related events, between people sharing the same workplace, or between colleagues outside of work.

All staff and volunteers have the same rights and responsibilities in relation to sexual harassment. A single incident is enough to constitute sexual harassment – it doesn’t have to be repeated.

All incidents of sexual harassment – no matter how large or small or who is involved – require employers and managers to respond quickly and appropriately.

The Company recognises that comments and behaviour that do not offend one person can offend another. This policy requires all staff and volunteers to respect other people’s limits.

The Company will not tolerate or accept any form of sexual harassment, in the workplace or in any work-related context such as conferences, work functions and business trips. All staff members are responsible for their own behaviour, and under the law may be held personally liable if they engage in sexual harassment. The Company may also be vicariously liable for staff members found to have engaged in any form of sexual harassment.

VICTIMISATION

Victimisation is subjecting or threatening to subject someone to a detriment because they have asserted their   rights under equal opportunity law, made a complaint, helped someone else make a complaint, or refused to do something because it would be discrimination, sexual harassment or victimisation. Victimisation is against the law.

It is also victimisation to threaten someone (such as a witness) who may be involved in investigating an equal opportunity concern or complaint.

Victimisation is a very serious breach of this policy and is likely (depending on the severity and circumstances) to result in formal discipline against the perpetrator.

The Company has a zero-tolerance approach to victimisation.

VILIFICATION

Vilification is where a person commits a public act which is reasonably likely to offend, insult, humiliate or intimidate another person because of their race, sex, religion, sexuality or sexual identity. Hatred or vilification due to an attribute protected under equal opportunity laws is unlawful.

The Company will not tolerate or accept any form of hatred or vilification due to a protected attribute of another person.

Any conduct that can possibly be observed by the public or any sort of communication either verbal or in writing to the public can be considered a public act. Workplaces can be public places.

The Company may be vicariously liable for staff members found to have engaged in any form of unlawful hatred or vilification. Staff may also be sued personally or prosecuted criminally under Commonwealth or State criminal laws.

Conduct that may constitute vilification can include verbal or written statements, or even be the reproduction or distribution of already published information. Examples include:

• Offensive material on the internet, including e-forums, blogs, social networking sites and video sharing sites;
• Offensive comments or images published in a publication such as a leaflet, flyer, internal message board or workplace intranet;
• Offensive speeches at public events, work functions or in the workplace;
• Abusive comments in any public place, such the workplace, or any other place attended in connection with employment; or
• In some instances, the reproduction or distribution of already published information around the workplace.

CONFIDENTIALITY

It is unacceptable for staff at the Company to talk with other staff members, clients or suppliers about any complaint of discrimination or harassment without the Company’s express permission.

Breaching the confidentiality of a formal complaint investigation or inappropriately disclosing personal information obtained in a professional role (for example, as a manager) is a serious breach of this policy and may lead to formal discipline.

DECISIONS TO BE BASED ON MERIT

All recruitment and job selection decisions at the Company will be based on merit – the skills and abilities of the candidate as measured against the inherent requirements of the position – regardless of personal characteristics.

It is unacceptable and may be against the law to ask job candidates questions, or to in any other way seek information, about their personal characteristics, unless this can be shown to be directly relevant to a genuine requirement of the position.

RESOLVING ISSUES

The Company strongly encourages any staff member who believes they have been discriminated against, bullied, sexually harassed, vilified or victimised to take appropriate action by making a complaint in accordance with the Grievance Handling Policy.

Any staff member who has witnessed any discrimination, bullying, sexual harassment, vilification or victimisation should report this to their manager or other responsible person in the Company, or can raise a complaint in accordance with the Grievance Handling Policy.

Disciplinary Policy

Policy brief & purpose

Our Progressive Discipline policy outlines the steps we will take to address an employee’s misconduct.

We recognize that people make mistakes and our employees may not always follow our policies closely. We want to give our employees a chance to correct their behavior when possible and assist them in the process. We also want to ensure that serious offenses are thoroughly investigated and dealt with.

Scope

This policy applies to all our employees.

Policy elements

Our disciplinary process has six steps of increasing strictness. These steps are:

1. Verbal warning
2. Informal meeting with supervisor
3. Formal reprimand
4. Formal disciplinary meeting
5. Penalties
6. Termination

All these phases are official and managers should document them. HR must also keep records of the process from step 3 onwards.

Managers should let employees know when they launch a progressive discipline procedure. For example, pointing out a performance issue is not necessarily a verbal warning and may be part of the regular feedback an employee receives. If managers judge that a progressive disciplinary process is appropriate, they must clarify this to their team member and document the step.

Each step may be repeated instead of moving forward to the next step at HR or a manager’s discretion. For example, a supervisor may choose to have more than one informal meeting with their employees (step 2) before they ask HR to issue a formal reprimand (step 3.) Managers can make the decision to repeat a step if they:

• Feel that the step was not properly executed the first time.
• See signs of improvement in their employee and want to help them further.
• Believe conditions or parameters change enough to make repeating the step necessary

Explaining the steps

Step 1: When a manager or HR issues a verbal warning to an employee, they should do so privately. When appropriate, they should provide that employee with a copy of the company policy they violated, and explain our progressive discipline steps. Supervisors should provide employees with any coaching or advice they need.

Employees have [two weeks] to correct their behavior before step 2 takes effect.

Step 2: A manager (or HR if appropriate) discusses corrective actions with an employee. Employees should receive actionable feedback on how to deal with an unintentional violation. They can review coaching or mentoring methods.

Employees have [a month] to correct their behavior before step 3 takes effect.

Step 3: Employees receive a formal written reprimand. HR should inform them that if they do not correct their behavior within [one week], step 4 will take effect.

Step 4: Employees will be called in for a formal disciplinary meeting with HR, their Department Head and/or their supervisor. They will have the chance to explain their side and HR is obliged to investigate. HR must clarify that this is the final step before an employee is penalized.

Employees must correct their behavior immediately, or step 5 takes effect.

Step 5: This step encompasses any penalties that employees will receive. This usually includes detraction of certain perks and benefits (as long as they are not mandatory by law.) It may also include suspension without pay or demotion for serious offenses. We will still provide counseling in this stage if appropriate (e.g. minor cases of substance abuse.) We will apply this step uniformly and fairly. It will not result in adverse impact for protected groups.

Employees must correct their behavior within [one month] before step 6 takes effect.

Step 6: Employees who continue to violate our policies, either voluntarily or involuntarily, by this stage will be terminated. This step will follow an official investigation by HR (or legal authorities when appropriate) to ensure that terminating an employee is fair. A termination for cause will refer to employees who were guilty of severe violations or felonies.

How to invoke progressive discipline

The progressive discipline process may begin from a different step, according to the severity of an employee’s misconduct:

Performance issues. Procedure starts at stage 1. Examples are:

• Absenteeism.
• Disregarding deadlines.
• Lack of knowledge of Health & Safety standards.

Minor offenses (one-time). Procedure starts at stage 1. Examples are:

• On-the-job minor mistakes.
• Breach of dress code or smoking policy.

Serious misconduct/ Repeating an offense for which a progressive discipline procedure already took place.

Procedure starts at stage 3. Examples are:

• On-the-job major mistakes.
• Rudeness to customers or partners.
• Unwillingness to follow Health & Safety standards
•  

Severe violations. Procedure starts at stage 5. Examples are:

• Substance abuse.
• Offensive behavior.
• Retaliation against an employee.

Illegal behaviour. Procedure starts at step 6. Examples are:

• Corruption/ Bribery.
• Sexual Harassment.
• Workplace Violence.
• Embezzlement/Fraud.

HR/Department Heads can skip any of the steps if they believe they are obsolete.

For example, if an employee has received several formal reprimands for the same offense, HR may choose to terminate them directly. Or an employee may be directly suspended for a short period as a punishment.

This policy is meant to provide general guidelines. Our company reserves the right to treat circumstances in a different way from that described in this policy. But we are always obliged to act fairly and lawfully and document every stage of the progressive discipline process.

Right to appeal

Employees who were not terminated for cause or were not found guilty for illegal behavior may file an appeal. For example, if an employee thinks they were demoted unfairly, they can bring this issue to the attention of HR. HR will evaluate the situation and may organize a hearing.

Preventing progressive discipline

Disciplining an employee is never a pleasant task. For the sake of everyone involved, we will take actions to prevent the need for disciplinary action. We will:

• Communicate our policies and Code of Conduct clearly to all new hires.
• Announce any revisions or changes in our policies to all our employees in a formal manner (e.g. bulletins, newsletters.)
• Use frequent employee performance meetings to address issues before they become problems.
• Train managers to communicate, enforce and abide by policies.
• Train employees in certain policies and procedures.
• Establish a culture of respect and collaboration.

Disclaimer: This policy template is meant to provide general guidelines and should be used as a reference. It may not take into account all relevant local, state or Governmental laws and is not a legal document.

BIODIVERSITY POLICY

We at SUFALAM STREET, a global conglomerate, recognizes that conserving biodiversity is in long term interest of our businesses and society at large. Towards this, the Group shall strive to identify and implement appropriate actions within our companies and supply-chains and work with our stakeholders. This will be achieved through implementation of biodiversity management framework that is aligned with the provisions of the Convention on Biological Diversity (CBD, 1992).

In order to achieve the above in all countries relevant for our operations, we shall endeavor, through the Sustainable Business framework, to:

1. Maintain legal compliance to biodiversity-related laws and regulations;

2. Assess risks to biodiversity and associated ecosystem services from existing and planned activities;

3. Strive for no net loss of biodiversity at our operated/ owned sites having biodiversity risks;

4. Implement the mitigation hierarchy by avoiding, minimizing, restoring and if necessary, offsetting residual impacts on biodiversity;

5. Avoid operating in critical habitats and ecologically sensitive areas;

6. Avoid the introduction of any new potentially invasive, non-native species and seek to eradicate these within our operational sites;

7. Develop and implement Biodiversity Management Plans with clear targets and action plans, to support the conservation of species, habitats and ecosystems in our areas of operation;

8. Identify, engage and collaborate with key biodiversity stakeholders to integrate their knowledge, perceptions and guidance to ensure inclusive biodiversity management;

9. Contribute to the enhancement of biodiversity knowledge in collaboration with experts;

10. Provide appropriate resources to adequately manage biodiversity at our sites; 

11.Monitor, review and assess biodiversity performance against measurable biodiversity targets to drive continuous improvement, and openly communicate the results.

This policy shall be reviewed periodically for its suitability and updated as necessary.

Code of Business Ethics

Introduction

This Code is based on the following basic assumptions:

– Ethics among shareholders, owners, directors and management are a necessary element for companies in the 21st century to adequately meet their objectives, to the degree that Ethics are a key requisite in guaranteeing and balancing the rights and interests of all stakeholders involved:

employees, clients, shareholders, suppliers and business partners and the society at large.

– Ethics presuppose rigorous compliance in and by the company with applicable legislation, as well as with the Articles of Incorporation and Regulations for internal operations, where they exist.

– Ethics within the company require that shareholders and owners become guarantors of compliance in respect of obligations for directors and management.

– Even though this Code has been created with the intention of being applicable in general to all companies, it should also be understood within a general and basic framework subject to adaptation to the specific circumstances of each business; thereby ensuring that it contemplates application of the principles of ethics and sustainable development in accordance with the specific activity of the company involved.

– Ideally, the Board of Directors is responsible for drawing up the Code of Ethics for the company and the General Shareholders’ Meeting for approving that Code. Should, however, the Board also proceed with approval, that decision must be ratified by the Shareholders’ Meeting.