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Gender Sensitivity/Prevention of Sexual Harassment Policy

PURPOSE

Trigent (here in after referred to as “the Company”) is committed to the highest standards of openness, and accountability by providing a safe work environment free from any kind of harassment or intimidation of either a verbal or a physical nature. This policy documents procedure for redressal of complaints relating to sexual harassment at the work place in compliance with The Sexual Harassment of Women at Workplace Act, 2013.

APPLICABILITY OF THE POLICY

This policy applies to all employees of the Company.

POLICY STATEMENT

Sexual harassment as defined by the Act includes any unwelcome acts or behavior (whether directly or by implication) namely:-

  • Physical contact and advances; or
  • A demand or request for sexual favors; or
  • Making sexually colored remarks; or
  • Showing pornography; or
  • Any other unwelcome physical, verbal or non-verbal conduct of sexual nature

The type of behavior described above and any such events which causes emotional trauma is unacceptable not only in the workplace, but also in other work related settings, and not limited to, such as business trips or business related social events.

Click on the below link to access more information on the Act.


http://www.nitc.ac.in/app/webroot/img/upload/77331401.pdf

POLICY AND PROCEDURE FOR ENQUIRY AND DISCIPLINARY ACTION

If you are a victim of sexual harassment

  • Confront the individual if you are comfortable doing so.
  • Report the situation immediately to the HR representative / reporting Manager of the place where you are working.
  • Report the situation immediately to the ICC – Internal Complaints Committee by way of Email

If you observe sexual harassment around you

  • Speak to the offender as an impartial observer and try to counsel him/her.
  • Report the situation immediately to the HR representative of the place where you are working/Reporting Manager.
  • Report the situation immediately to the ICC – Internal Complaints Committee by way of Email.

Constitution of Internal Complaints Committee.

The Committee will consist of four members of the following composition:

  • The Management nominates all members. All members will hold office for 3 years from the date of appointment. The above committee is valid effective 01st November 2019.
  • All members are expected to act as a neutral, impartial and expert member in order to facilitate and expedite inquiries and follow up actions.
  • External member is appointed to bring in a degree of objectivity and outside perspective in the working of the ICC and ensure the inquiry mechanism, is objective, neutral and not influenced from possible pressures from the management.
  • Internal members are appointed who have gained the trust and confidence of the employees and should be accessible without any hesitation by the employees.

Role of the Committee

The committee’s role will include the following:

  • To take cognizance of complaints, conduct enquiries, provide assistance and redressal to the victims, recommend disciplinary action against the harasser, if necessary.
  • To recommend arrangements for appropriate counseling, security, police help if he/she so desires.

Power and Rights of Committee members

The Committee shall discuss and decide on its jurisdiction to deal with the case or reject the complaint prima facie and recommend to the management that no action is required to be taken in the matter.

The Committee may call any person to appear as a witness if it is of the opinion that it shall be in the interest of justice. The Committee shall have the right to summon, as many times as required, the respondent, or any witnesses for the purpose of supplementary testimony and/or clarifications.

After concluding its investigation, the Committee shall submit a detailed reasoned report to the Management.

If the Committee finds no merit in the allegations, it shall report to the management.

In the event the Committee finds that the allegation(s) against the respondent have been proved, it shall recommend the nature of action to be taken by the management. The following actions may be recommended:

  • Written apology
  • Undergoing a counseling session
  • Warning
  • Reprimand or censure
  • Withholding of promotion/increment
  • Terminating the respondent from service
  • Report to Statutory authorities

Complaint and Enquiry Process

A complaint should be filed through E-mail to the Committee. An aggrieved person may make a complaint of sexual harassment at workplace to the Committee in writing. If the aggrieved person desires to make an oral complaint for personal reasons, the committee shall permit him/her to make a complaint to the committee by personal appearance and make suitable record of the same.

The committee will maintain complete confidentiality of the entire proceedings.

As soon as the complaint is received, the committee should initiate action. The committee shall submit its report within a month of receipt of the complaint. The report of the Committee shall be placed before the Management for further action.

COMPLAINTS MADE WITH A MALICIOUS INTENT

If on investigation, it is revealed that the complaint was made with a malicious intent and with the motive of maligning the concerned individual/tarnishing his/her image in the company and to settle personal/professional scores, strict action will be taken against the complainant.

REDRESSAL

  • The committee will submit the enquiry report to the Management.
  • The Management upon receipt of the enquiry report, shall institute disciplinary action on the basis of the recommendations of the Committee under relevant provisions of law.

Trigent Code of Compliance

Human Rights Compliance

Respect for human rights is a fundamental value of Trigent Software Ltd. We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights in our relationships with our employees and Business Partners.

This Policy is guided by international human rights principles encompassed by the Universal Declaration of Human Rights, including those contained within the International Bill of Rights and the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

Harassment and Non-discrimination

We value and advance the diversity and inclusion of the people with whom we work. We are committed to equal opportunity and are intolerant of discrimination and harassment. We work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, colour, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, political opinion or any other status protected by applicable law. The basis for recruitment, hiring, placement, development, training, compensation and advancement at the Company is qualifications, performance, skills and experience. We do not tolerate disrespectful or inappropriate behaviour, unfair treatment or retaliation of any kind. Harassment is not tolerated in the workplace and in any work-related circumstance outside the workplace.

Freedom of Association & Collective Bargaining

We respect our employees’ right to join, form or not to join a labour union without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. The Company is committed to bargaining in good faith with such representatives.

Safe and Healthy Workplace

The safety and health of our employees is of paramount importance. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements. We work to provide and maintain a safe, healthy and productive workplace, in consultation with our employees, by addressing and remediating identified risks of injury and health impacts.

Workplace Security

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.

Conflict of Interest

Our employees and directors shall always act in the interest of our company and ensure that any business or personal association including close personal relationships which they may have, does not create a conflict of interest with their roles and duties in our company or the operations of our company. Further, our employees and directors shall not engage in any business, relationship or activity, which might conflict with the interest of our company or our group companies.

Working Hours, Wages and Benefits

We compensate employees competitively relative to the industry and local labour market, and in accordance with terms of all applicable labour legislations. We work to ensure full compliance with applicable wage, work hours, overtime and benefits laws. Our employees won’t be forced to work in excess of the number of hours permitted in law, and normal working hours won’t exceed 48 hours per week average unless the employee agrees.

Anti-corruption and Bribery

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 Page 3 integrity in all our business dealings and relationships, wherever we operate, and to implementing and enforcing effective systems to counter bribery.

It is not acceptable to:

  • Give, promise to give, or offer, a payment, gift or hospitality to secure or award an improper business advantage;
  • Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate, expedite, or reward any action or procedure;
  • Give or accept any gift where such gift is or could reasonably be perceived to be a contravention of this policy and / or applicable law.

Modern Slavery & Human Trafficking Policy

Trigent is committed to protecting human rights and prohibits all acts of human trafficking, slavery, servitude and forced or compulsory labour throughout the organization, its business and supply chain. In pursuance with the Modern Slavery Act 2015, Trigent elucidates its initiatives to mitigate/eradicate modern slavery and human trafficking from its business and supply chain. This Statement sets out the steps that Trigent as an organization has taken to ensure that no form of slavery and human trafficking exists in its business or supply chain.

As part of its initiative to identify and eliminate any modern slavery Trigent –

  • operates in licensed premises strategically limited in geographical scope to ensure optimum control and supervision of the work environment;
  • strives to build long standing relationships with local suppliers and customers to effectively communicate its business standards;
  • employs whistleblowing and grievance redressal systems to encourage reporting of concerns and/or violations;

Whistleblowing Policy -

We encourage all of our employees to report any concerns related to the direct and indirect activities of Trigent. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

What to report?

Below are the areas where non-compliance can be reported:

  • Harassment or Discrimination & Workplace Violence
  • Protection of Confidential Information and intellectual property
  • Privacy breach Page 4
  • Fraud or questionable accounting/financial reporting
  • Corruption and improper transactions,
  • Improper promotion and improper sales practices
  • Conflicts of Interest
  • Environmental Health and Safety issues
  • Insider Trading
  • Anti-competitive behaviour
  • Theft, misuse of company’s assets
  • Retaliatory action as mentioned in this policy
  • Any Illegal or unethical Practices

Channel of Communication:

  • All employees are provided the facility to report confidentially to the Top Management through the HRMS system.
  • POSH related complaints can be sent to Internal Complaints Committee
  • Harassment or Discrimination & Workplace Violence related issues can be reported to HR
  • Feedback and non-compliance about other departments can also be sent directly to the department heads.

Criticality of non-compliance:

  • Highly critical non-compliance can be sent directly to the highest management committee that comprises the Chairman and two executive directors of the organization.
  • All non-compliance reported to the top management will be classified based on criticality and they will be promptly investigated and will be resolved.
  • No retaliation or retribution for a report provided in good faith.
  • Whistleblower will get an update on the compliant and confidentiality is maintained.

Due Diligence

We undertake due diligence when considering taking on new Business Partners/Vendors and review our existing Business Partners/Vendors on a periodic basis. Our due diligence and reviews include:

  • We conduct regular assessment which have a greater degree of focus on slavery and human trafficking where general risks are identified
  • We terminate the relationship with agencies that fail to improve their performance in line with an action plan or seriously violate our belief systems.

Child Labour Policy

Trigent Sofware Ltd. endeavours to provide a conducive working environment that is characterized by equality and mutual respect. The company will not tolerate the use of child or forced labour, nor exploitation of children in any of its operations and facilities. Child labour, as defined by the International Labour Organisation (ILO) Convention is “work by children under the age of 12; work by children under the age of 14 that prevents school attendance; and work by children under of age of 18 that is hazardous to the physical or mental health of the child.

In the conduct of its business, Trigent Sofware Ltd:

  • Will not employ children that falls into the definition as stipulated by ILO Convention, notwithstanding any national law or local regulation;
  • Expects its business partners and associates to have and uphold similar standards and abide by country-governing laws in countries wherein they operate. Should violation of these Principles become known to Trigent Software Ltd. and not be remediated, we will take serious action, including discontinuation of the business relationship.

Disciplinary Code

The purpose of this code is to outline the standard conduct and rules applicable to employees at the workplace. It is accepted that a disciplinary code and procedure are necessary for the efficient running of company business, the safety and fair treatment of all employees, and for ensuring sound labour/management relations. Furthermore to provide guidelines for management to ensure the fair, just, and uniform application of disciplinary measures and to provide a reference for management engaged in applying discipline. Click here for Disciplinary Code for Trigent Software Ltd.

Corporate Social Responsibility Policy

Trigent believes that we have an obligation to society to positively impact the areas of hunger, poverty, special education, gender equality, women empowerment, and other things. Please read our Corporate Social Responsibility Policy and information about our CSR Committee and projects.

Here are the previous year’s Corporate Social Responsibility Policy and CSR Committee and projects.

Whistleblowing Policy

Trigent encourages all of our employees to report any concerns related to the direct and indirect activities of Trigent. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Click here for the Trigent Whistleblowing policy.

Click here for other compliance information related to FY2023-24, FY2022-23 and FY2020-21.

Gender Sensitivity/Prevention of Sexual Harassment Policy

PURPOSE

Trigent (here in after referred to as “the Company”) is committed to the highest standards of openness, and accountability by providing a safe work environment free from any kind of harassment or intimidation of either a verbal or a physical nature. This policy documents procedure for redressal of complaints relating to sexual harassment at the work place in compliance with The Sexual Harassment of Women at Workplace Act, 2013.

APPLICABILITY OF THE POLICY

This policy applies to all employees of the Company.

POLICY STATEMENT

Sexual harassment as defined by the Act includes any unwelcome acts or behavior (whether directly or by implication) namely:-
  • Physical contact and advances; or
  • A demand or request for sexual favors; or
  • Making sexually colored remarks; or
  • Showing pornography; or
  • Any other unwelcome physical, verbal or non-verbal conduct of sexual nature
The type of behavior described above and any such events which causes emotional trauma is unacceptable not only in the workplace, but also in other work related settings, and not limited to, such as business trips or business related social events.
Click on the below link to access more information on the Act.

http://www.nitc.ac.in/app/webroot/img/upload/77331401.pdf

POLICY AND PROCEDURE FOR ENQUIRY AND DISCIPLINARY ACTION

If you are a victim of sexual harassment:

  • Confront the individual if you are comfortable doing so.
  • Report the situation immediately to the HR representative / reporting Manager of the place where you are working.
  • Report the situation immediately to the ICC – Internal Complaints Committee by way of Email

If you observe sexual harassment around you:

  • Speak to the offender as an impartial observer and try to counsel him/her.
  • Report the situation immediately to the HR representative of the place where you are working/Reporting Manager.
  • Report the situation immediately to the ICC – Internal Complaints Committee by way of Email

Constitution of Internal Complaints Committee.

The Committee will consist of four members of the following composition:
  • The Management nominates all members. All members will hold office for 3 years from the date of appointment. The above committee is valid effective 01st November 2019.
  • All members are expected to act as a neutral, impartial and expert member in order to facilitate and expedite inquiries and follow up actions.
  • External member is appointed to bring in a degree of objectivity and outside perspective in the working of the ICC and ensure the inquiry mechanism, is objective, neutral and not influenced from possible pressures from the management.
  • Internal members are appointed who have gained the trust and confidence of the employees and should be accessible without any hesitation by the employees.

Role of the Committee

The committee’s role will include the following:
  • To take cognizance of complaints, conduct enquiries, provide assistance and redressal to the victims, recommend disciplinary action against the harasser, if necessary.
  • To recommend arrangements for appropriate counseling, security, police help if he/she so desires.

Power and Rights of Committee members

The Committee shall discuss and decide on its jurisdiction to deal with the case or reject the complaint prima facie and recommend to the management that no action is required to be taken in the matter.

The Committee may call any person to appear as a witness if it is of the opinion that it shall be in the interest of justice. The Committee shall have the right to summon, as many times as required, the respondent, or any witnesses for the purpose of supplementary testimony and/or clarifications.

After concluding its investigation, the Committee shall submit a detailed reasoned report to the Management.

If the Committee finds no merit in the allegations, it shall report to the management.

In the event the Committee finds that the allegation(s) against the respondent have been proved, it shall recommend the nature of action to be taken by the management. The following actions may be recommended:

  • Written apology
  • Undergoing a counseling session
  • Warning
  • Reprimand or censure
  • Withholding of promotion/increment
  • Terminating the respondent from service
  • Report to Statutory authorities

Complaint and Enquiry Process

A complaint should be filed through E-mail to the Committee. An aggrieved person may make a complaint of sexual harassment at workplace to the Committee in writing. If the aggrieved person desires to make an oral complaint for personal reasons, the committee shall permit him/her to make a complaint to the committee by personal appearance and make suitable record of the same.

The committee will maintain complete confidentiality of the entire proceedings.

As soon as the complaint is received, the committee should initiate action. The committee shall submit its report within a month of receipt of the complaint. The report of the Committee shall be placed before the Management for further action.

COMPLAINTS MADE WITH A MALICIOUS INTENT

If on investigation, it is revealed that the complaint was made with a malicious intent and with the motive of maligning the concerned individual/tarnishing his/her image in the company and to settle personal/professional scores, strict action will be taken against the complainant.

REDRESSAL

  • The committee will submit the enquiry report to the Management.
  • The Management upon receipt of the enquiry report, shall institute disciplinary action on the basis of the recommendations of the Committee under relevant provisions of law.

Trigent Code of Compliance

Human Rights Compliance

Respect for human rights is a fundamental value of Trigent Software Ltd. We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights in our relationships with our employees and Business Partners.

This Policy is guided by international human rights principles encompassed by the Universal Declaration of Human Rights, including those contained within the International Bill of Rights and the International Labour Organization’s 1998 Declaration on Fundamental Principles and Rights at Work.

Harassment and Non-discrimination

We value and advance the diversity and inclusion of the people with whom we work. We are committed to equal opportunity and are intolerant of discrimination and harassment. We work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, colour, national or social origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, political opinion or any other status protected by applicable law. The basis for recruitment, hiring, placement, development, training, compensation and advancement at the Company is qualifications, performance, skills and experience. We do not tolerate disrespectful or inappropriate behaviour, unfair treatment or retaliation of any kind. Harassment is not tolerated in the workplace and in any work-related circumstance outside the workplace.

Freedom of Association & Collective Bargaining

We respect our employees’ right to join, form or not to join a labour union without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives. The Company is committed to bargaining in good faith with such representatives.

Safe and Healthy Workplace

The safety and health of our employees is of paramount importance. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements. We work to provide and maintain a safe, healthy and productive workplace, in consultation with our employees, by addressing and remediating identified risks of injury and health impacts.

Workplace Security

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.

Conflict of Interest

Our employees and directors shall always act in the interest of our company and ensure that any business or personal association including close personal relationships which they may have, does not create a conflict of interest with their roles and duties in our company or the operations of our company. Further, our employees and directors shall not engage in any business, relationship or activity, which might conflict with the interest of our company or our group companies.

Working Hours, Wages and Benefits

We compensate employees competitively relative to the industry and local labour market, and in accordance with terms of all applicable labour legislations. We work to ensure full compliance with applicable wage, work hours, overtime and benefits laws. Our employees won’t be forced to work in excess of the number of hours permitted in law, and normal working hours won’t exceed 48 hours per week average unless the employee agrees.

Anti-corruption and Bribery

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 Page 3 integrity in all our business dealings and relationships, wherever we operate, and to implementing and enforcing effective systems to counter bribery.
It is not acceptable to:
  • Give, promise to give, or offer, a payment, gift or hospitality to secure or award an improper business advantage;
  • Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate, expedite, or reward any action or procedure;
  • Give or accept any gift where such gift is or could reasonably be perceived to be a contravention of this policy and / or applicable law.

Modern Slavery & Human Trafficking Policy

Trigent is committed to protecting human rights and prohibits all acts of human trafficking, slavery, servitude and forced or compulsory labour throughout the organization, its business and supply chain. In pursuance with the Modern Slavery Act 2015, Trigent elucidates its initiatives to mitigate/eradicate modern slavery and human trafficking from its business and supply chain. This Statement sets out the steps that Trigent as an organization has taken to ensure that no form of slavery and human trafficking exists in its business or supply chain.
As part of its initiative to identify and eliminate any modern slavery Trigent –
  • operates in licensed premises strategically limited in geographical scope to ensure optimum control and supervision of the work environment;
  • strives to build long standing relationships with local suppliers and customers to effectively communicate its business standards;
  • employs whistleblowing and grievance redressal systems to encourage reporting of concerns and/or violations;

Whistleblowing Policy -

We encourage all of our employees to report any concerns related to the direct and indirect activities of Trigent. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

What to report?

Below are the areas where non-compliance can be reported:
  • Harassment or Discrimination & Workplace Violence
  • Protection of Confidential Information and intellectual property
  • Privacy breach Page 4
  • Fraud or questionable accounting/financial reporting
  • Corruption and improper transactions,
  • Improper promotion and improper sales practices
  • Conflicts of Interest
  • Environmental Health and Safety issues
  • Insider Trading
  • Anti-competitive behaviour
  • Theft, misuse of company’s assets
  • Retaliatory action as mentioned in this policy
  • Any Illegal or unethical Practices

Channel of Communication:

  • All employees are provided the facility to report confidentially to the Top Management through the HRMS system.
  • POSH related complaints can be sent to Internal Complaints Committee
  • Harassment or Discrimination & Workplace Violence related issues can be reported to HR
  • Feedback and non-compliance about other departments can also be sent directly to the department heads.

Criticality of non-compliance:

  • Highly critical non-compliance can be sent directly to the highest management committee that comprises the Chairman and two executive directors of the organization.
  • All non-compliance reported to the top management will be classified based on criticality and they will be promptly investigated and will be resolved.
  • No retaliation or retribution for a report provided in good faith.
  • Whistleblower will get an update on the compliant and confidentiality is maintained.

Due Diligence

We undertake due diligence when considering taking on new Business Partners/Vendors and review our existing Business Partners/Vendors on a periodic basis. Our due diligence and reviews include:
  • We conduct regular assessment which have a greater degree of focus on slavery and human trafficking where general risks are identified
  • We terminate the relationship with agencies that fail to improve their performance in line with an action plan or seriously violate our belief systems.

Child Labour Policy

Trigent Sofware Ltd. endeavours to provide a conducive working environment that is characterized by equality and mutual respect. The company will not tolerate the use of child or forced labour, nor exploitation of children in any of its operations and facilities. Child labour, as defined by the International Labour Organisation (ILO) Convention is “work by children under the age of 12; work by children under the age of 14 that prevents school attendance; and work by children under of age of 18 that is hazardous to the physical or mental health of the child.
In the conduct of its business, Trigent Sofware Ltd:
  • Will not employ children that falls into the definition as stipulated by ILO Convention, notwithstanding any national law or local regulation;
  • Expects its business partners and associates to have and uphold similar standards and abide by country-governing laws in countries wherein they operate. Should violation of these Principles become known to Trigent Software Ltd. and not be remediated, we will take serious action, including discontinuation of the business relationship.

Disciplinary Code

The purpose of this code is to outline the standard conduct and rules applicable to employees at the workplace. It is accepted that a disciplinary code and procedure are necessary for the efficient running of company business, the safety and fair treatment of all employees, and for ensuring sound labour/management relations. Furthermore to provide guidelines for management to ensure the fair, just, and uniform application of disciplinary measures and to provide a reference for management engaged in applying discipline. Click here for Disciplinary Code for Trigent Software Ltd.

Corporate Social Responsibility Policy

Trigent believes that we have an obligation to society to positively impact the areas of hunger, poverty, special education, gender equality, women empowerment, and other things. Please read our Corporate Social Responsibility Policy and information about our CSR Committee and projects.

Here are the previous year’s Corporate Social Responsibility Policy and CSR Committee and projects.

Whistleblowing Policy

Trigent encourages all of our employees to report any concerns related to the direct and indirect activities of Trigent. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Click here for the Trigent Whistleblowing policy. Click here for other compliance information related to FY2023-24, FY2022-23 and FY2020-21.