Equal Opportunity, Diversity, Equity, Inclusion & HIV Policy - InfraCloud Technologies Pvt. Ltd.

Policy Statement

InfraCloud Technologies Private Limited (hereinafter referred to as the “Company” or “InfraCloud”) constantly strives to create a workplace that is conducive to professional and personal growth. Our ecosystem consists of employees from varied socio-cultural background and it is our endeavor to build and maintain a working environment that encourages employees to improve their skills while having a safe space to echo their difference of opinions; especially ones that will foster change.

At InfraCloud, we believe in equal employment opportunities for all. As part of diversity and inclusivity, we value and celebrate the differences of individual employees and we strive to enable a culture of inclusivity and empowerment and ensure the protection of fundamental rights and the basic principles of equality, freedom, justice and dignity of all individuals that are enshrined in the Constitution of India.

Purpose

To build an inclusive work environment for Company’s internal & external stakeholders;
To ensure InfraCloud is an employer of choice for all groups; caste, creed, age, socio-economic status, education background, gender identity, disability, religion, marital status, age, sexual orientation, and any other aspects as applicable; and
To create a work environment with zero tolerance for any kind of discrimination on any grounds such as:
a. the denial, or discontinuation of, or unfair treatment in relation to, employment or occupation;
b. the denial of, or termination from, employment or occupation;
c. the denial or discontinuation of, or unfair treatment with regard to, access to, or provision or enjoyment or use of any goods, accommodation, service, facility, benefit, privilege or opportunity dedicated to the use of the general public or customarily available to the public;
d. the denial or discontinuation of, or unfair treatment with regard to the right of movement; and
e. the denial or discontinuation of, or unfair treatment in, the opportunity to stand for or hold any position at InfraCloud.

Scope and Applicability

This policy shall be applicable to all visitors, job applicants, full-time/part-time employees, interns/trainees, contractual employees, including temporary employees (“Stakeholder(s)”).
This policy also applies to all aspects of employment and conditions of service, including without limitation recruitment, training, working conditions, salaries, transfers, employee benefits, appraisal, progression, and career advancement.

Diversity and Inclusion Philosophy – Our Guiding Principles

InfraCloud provides equal opportunities to all individuals and has zero tolerance towards any discriminatory treatment based on race, sex, nationality, ethnicity, origin, religion, age, disability, sexual orientation, gender identification.
If InfraCloud is made aware of any medical condition of an existing employee, it will not be the cause of any differential treatment, unless it has a direct impact on business deliverables. all InfraCloud policies (as normal) will apply to such employees
InfraCloud also ensures equal opportunity in employment for qualified persons with known disabilities where there is no direct impact to business deliveries.
The privacy of every individual is respected at InfraCloud and confidentiality of all kinds of personal information/concerns are ensured for all stakeholders. If disclosure is mandated under law, suitable permissions are sought from the concerned parties and handled in accordance with applicable laws.
All processes followed from Hire to Retire of InfraCloud employees are purely on the basis of qualification, performance, skills, experience, expertise & potential. There shall be no other extraneous criteria of differentiation
Empanelment of any stakeholders including vendors and outsourced staff but not limited to these groups; are carried out in a fair manner, and in accordance with these philosophies
InfraCloud follows the principle of equal pay and terms of employment (including benefits, training, promotions, performance reviews, transfers, exits, etc.) without any bias. InfraCloud believes that all its employees should receive equal pay where they are carrying out similar work, work rated as equivalent or work of equal value
Respect for individual is at the core of our values and in line with this, all employees, and stakeholders of InfraCloud are treated with dignity and respect with zero tolerance for any perpetrators
InfraCloud ensures timely awareness on all kinds of discriminatory behaviors amongst its employees through educational sessions. All-round wellness initiatives are also conducted to ensure employees have a safe and comfortable work environment conducive to growth
No reprisal action will be taken against any individual for raising concerns with regards to matters listed within this policy. However, if such concerns are found to be raised in a fraudulent manner, it will be considered a violation of the code of conduct, and such employees may be subject to disciplinary action.
All stakeholders are required to behave and communicate respectful with one another and any atrocious communication/remark, whether oral , written, any atrocious conduct or any other means with an intention to demean a person of their class, caste, tribe, ethnicity or religion or with an ill will to discriminate such person or to deprive them of any of the facilities available to other stakeholders in general or with an intention to promote hatred among other stakeholders against such people or any other atrocity that may be caused to such persons is strictly prohibited by the Company.

Policy under Rights of Persons with Disabilities Act, 2016

Applicability: This policy is applicable to all the Specially Abled. “Specially Abled” for this purpose means a person who has a long-term physical, mental, intellectual or sensory impairment which hinders his full and effective participation in society equally with others.
Equal opportunity for Specially Abled: In accordance with the provisions of the Rights of Persons with Disabilities Act, 2016 and Rules, it is the policy of the Company to ensure that the work environment is free from any discrimination against the Specially Abled. Further, the Company will take all actions to ensure that a conducive environment is provided to the Specially Abled to perform their role and excel in the same.
Facilities and Amenities: The Company will provide facilities for easy conveyance for commuting to and from the premises of the Company in the form of the Company’s vehicle having facilities that cater to the needs of the Specially Abled.

It is the Company’s endeavor to provide adequate parking facilities for Specially Abled. The Company will also make suitable infrastructural arrangements to improve access to the office buildings.

The Company strives to provide assistive devices and barrier-free accessibility to the Specially Abled as per their convenience and as and when needed by them for the purpose of assisting them in completing the work assigned.
Training: The Company will provide proper training and guidance to each Specially Abled employee before and after his/her recruitment to a particular post to make to easier for him/her to perform his/her functions under each such post. The Company will also ensure that appropriate facilities and amenities are provided to the Specially Abled to enable them to effectively discharge their duties in the establishment.
Posts: Where it comes to notice of the Company that a certain job profile does not suit a Specially Abled, such a person shall be shifted to some other suitable post with equal pay and benefits.
Manner of selection for posts under this Policy

a. The Company shall determine whether the concerned candidate is able /suitable to perform the inherent requirements of the post;
b. After assessing the above, the Company shall identify any reasonable adjustments that may be needed, either in the work environment or the role/post offered;
c. The Company shall make the concerned candidate understand that he needs to adhere to the policies of the Company;
d. Before granting any post, the Company shall have regard to the health of the candidate and the post will be offered to the Candidate only if the work to be performed thereunder will not negatively impact the health of the candidate;
e. The Company shall maintain strict confidentiality about any medical information obtained by the Company in the above process.
Special Leave, Preference in Transfer and Posting: Leave may be availed by the specially abled employees for the purpose of medical treatment or such other emergencies which may occur during office hours. Preference is given to the specially abled to in matters relating to transfer and posting to provide them with a post in the vicinity or not far from their area of residence.

Policy under Transgender Persons (Protection of Rights) Act, 2019

Scope and Applicability: This policy has been prepared considering the provisions of the Transgender Persons (Protection of Rights) Act, 2019 (“TPPR Act”) and Transgender Persons (Protection of Rights) Rules, 2020. Under Section 2(k) of the TPPR Act, the term ‘transgender person’ means a person whose gender does not match with the gender assigned to that person at birth and includes trans-man or trans-woman (whether or not such person has undergone Sex Reassignment Surgery or hormone therapy or laser therapy or such other therapy), person with intersex variations, genderqueer and person having such socio-cultural identities as kinner, hijra, aravani and jogta (“Transgender Person(s)”).
No discrimination and other Prohibitions:
- We observe zero tolerance towards discrimination of any kind against Transgender Person. No person shall discriminate against a Transgender Person.
- No person shall harm or injure or otherwise endanger the life, safety, health or well-being, whether mental or physical, of a Transgender Person, including acts causing physical abuse, sexual abuse, verbal and emotional abuse and economic abuse.
Gender Identity: A person recognized as a ‘Transgender Person’ under the TPPR Act, shall have a right to self-perceived gender identity. Everyone should be treated with respect and dignity, regardless of their gender identity or expression. Use the individual’s chosen name and pronouns and avoid making assumptions about their gender identity.
Confidentiality and Data Privacy: Disclosure of identity can be a requirement for undertaking certain decisions and in case of any specific requirements or rights and privileges provided by the Company.
Amenities and accessibility:
- All amenities and services provided by the Company are accessible to Transgender Persons.
- All Transgender Persons will be allowed to participate in the welfare schemes rolled out by the Company. However, such accessibility and participation shall be subject to the specific terms and conditions of such a scheme.
- No person shall deny a Transgender Person the right of passage to a place or obstruct them from using or having access to a place publicly accessible or otherwise accessible for the stakeholders of the Company in general.
Safety and Security: The Company is equipped with adequate safety and security measures such as security cameras, well-lit areas, security personnel, and emergency response protocols to address potential threats or incidents of violence.
Specific Guideline for Matters of Employment: All Transgender Persons will be treated at par with people of other gender in regard to all conditions of service and matters of employment. We aim to provide a safe working environment for all and ensure that no Transgender Person is discriminated against in any matter relating to employment including, but not limited to, infrastructure adjustments, recruitment, employment benefits, promotion and other related issues. Further the Company strictly prohibits termination of any person on the basis of their transgender identity.
Specific Guidelines for Visitors: This policy aims to protect all Transgender Persons, including visitors who visit the Company physically or virtually. All amenities and infrastructure facilities at the premises of the Company are equally accessible for visitors.
InfraCloud ensures inclusion of all such people irrespective of their gender or sexual orientation.
Any person identifying as a part of the LGBTQ+ Community will be provided with equal opportunity in matters of recruitment, training, regression, employment benefits provided by InfraCloud, promotion and every other facility that is made available to all other employees of InfraCloud.
It is the responsibility of all to not discriminate against a transgender person on the basis of their gender identity and if any stakeholder is found harboring such discriminatory activity or behavior will have to face disciplinary action or legal action as the Company may deem fit.
InfraCloud will ensure secrecy of the gender status or sexual orientation of any stakeholder and will maintain the confidentiality of such information in the strictest sense.

Policy under HIV Act

Purpose: This policy has been prepared considering the provisions of the Human Immunodeficiency Virus and Acquired Immune Deficiency Syndrome (Prevention and Control) Act, 2017 (“HIV Act”) and the Human Immunodeficiency Virus and Acquired Immune Deficiency Syndrome (Prevention and Control) Rules, 2018 (“HIV Rules”) as well as the Model HIV Policy notified by the Ministry of Health And Family Welfare. Accordingly, the Company has adopted the following key principles:

a. Non-discrimination against people infected with and affected by HIV and AIDS;
b. Confidentiality related to one‘s HIV status and HIV-related data; and
c. Grievance redressal mechanism in the form of Complaints Officer
Scope and applicability: This policy shall be applicable to all visitors, job applicants, full-time/part-time employees, interns/trainees, contractual employees, including temporary employees. This policy also applies to all aspects of employment and conditions of service, including without limitation recruitment, training, working conditions, salaries, transfers, employee benefits, appraisal, progression, and career advancement.
Definitions:

a. “AIDS” means Acquired Immune Deficiency Syndrome, a condition characterized by a combination of signs and symptoms, caused by Human Immunodeficiency Virus, which attacks and weakens the body’s immune system making the HIV-positive person susceptible to life threatening conditions or other conditions, as may be specified from time to time.

b. “HIV” means Human Immunodeficiency Virus.

c. “HIV-affected person” means an individual who is HIV-positive or whose partner (with whom such individual normally resides) is HIV-positive or has lost a partner (with whom such individual resided) due to AIDS.

d. “HIV-positive person” means a person whose HIV test has been confirmed positive

e. “HIV-related information” means any information relating to the HIV status of a person and includes— (i) information relating to the undertaking performing the HIV test or result of an HIV test; (ii) information relating to the care, support or treatment of that person; (iii) information which may identify that person; and (iv) any other information concerning that person, which is collected, received, accessed or recorded in connection with an HIV test, HIV treatment or HIV-related research or the HIV status of that person.

f. “protected person(s)” means a person who is (i) HIV-Positive; or (ii) ordinarily living, residing or cohabiting with a person who is HIV-positive person; or (iii) ordinarily lived, resided or cohabited with a person who was HIV-positive.
General Guidelines

a. The known routes of transmission of the HIV are through, - (a) unprotected sexual contact with a HIV infected person; (b) sharing of HIV infected needles or syringes; (c) from HIV infected mother-to-child during pregnancy, childbirth, or breast feeding; and (d) transfusion of HIV infected blood or blood products.

b. There is no scientific or epidemiological evidence to suggest that HIV can be transmitted through ordinary workplace contact (talking to or touching the person, using the same office equipment, tools, utensils or bathrooms as the person infected with HIV).

c. With the advent of Anti- Retroviral Therapy, HIV is now a chronic manageable disease like many other noncommunicable diseases, including diabetes, hypertension and asthma. People with HIV who are regular on Anti- Retroviral Therapy remain healthy and fit to work for several years despite their infection.
Non-Discrimination Guidelines

a. Non-discrimination: There should be no discrimination on the basis of perceived or real HIV status of any person. This protection is provided not only to an HIV positive person, but also extends to immediate family members and progeny who reside or have resided in the same house of HIV infected person too, which may include other people living, cohabiting and residing with an HIV positive person. It also encompasses other people who have lived, resided or cohabited with an HIV positive person in the past.

b. Equal Opportunity: The Company strictly prohibits discrimination in the matters of employment. Further, we strive to provide equal opportunity to all in matters including, without limitation, recruitment, employment benefits, promotion and other related issues.

c. Reasonable Accommodation: On special request, the Company may also provide reasonable accommodation for people living with HIV if need be. Please note, “reasonable accommodation” means minor adjustments to a job or work that enables an HIV positive person who is otherwise qualified to enjoy equal benefits or to perform the essential functions of the job or work, as the case may be. Any decision made by the Company in this regard will be final and binding. The decision will be taken after considering following factors:
- Nature of job and role;
- Financial appetite of the Company; and
- Specific administrative requirement.
d. Termination: The Company will not terminate of any person on the basis of their HIV-status unless, such decision is made basis a written assessment qualified and independent healthcare provider who is competent shares a copy of the stating that the concerned person poses a significant risk of transmission of HIV to other person in the establishment or is unfit to perform the duties of the job.

e. Amenities and Accessibility: All amenities and services provided by the Company are accessible to protected persons. No person shall deny a protected person the right of passage to a place or obstruct them from using or having access to a place publicly accessible or otherwise accessible for the stakeholders of the Company in general.

f. A person should not be segregated on the basis of HIV status.

g. The Company does not require HIV testing as a prerequisite for obtaining employment, services or for the continuation of the same or for accessing or using any other service, resources and facility, or participation in any activity or scheme rolled out by the Company.
Confidentiality related to HIV status and HIV-related data

a. The Company understands that HIV-related information is sensitive in nature and therefore, we believe in upholding the confidentiality of the same at all times. HIV-related information means any information relating to the HIV status of a person and includes: (i) information relating to the undertaking given for performing the HIV test or result of an HIV test; (ii) information relating to the care, support or treatment of that person; (iii) information which may identify that person; and (iv) any other information concerning that person, which is collected, received, accessed or recorded in connection with an HIV test, HIV treatment or HIV-related research or the HIV status of that person.

b. We have effective and sound data management and information security systems in place along with standard operating procedures regarding disposal of physical and electronic records or files containing HIV-related information of protected persons.

c. Any HIV positive person will not be forced to disclose her or his or their status or any other HIV-related information.

d. No employee/stakeholder should disclose HIV status, or any other private information of the other person imparted in confidence or in a relationship of a fiduciary nature except by informed consent. The informed consent can be taken from the HIV infected person themselves or through their representatives.

e. All staff members are oriented on concepts of consent, disclosure and confidentiality related to HIV and AIDS and that they don‘t disclose HIV-related information. It is also the moral responsibility of co-workers and other staff members to not engage in activities which breach confidentiality.

Escalation- Grievance Redressal Process

Liaison/Complaints Officer: The People & Culture Department will ensure a Liaison Officer is designated to oversee the implementation of the provisions of required facilities/amenities as per this policy.
Any questions regarding this policy may be directed to the People & Culture Team at InfraCloud.
Any employee who would like to highlight an incident that violates this policy will need to get in touch with his/ her People & Culture representative or the Liaison Officer, as the case may be by writing to grievances@infracloud.io. On receipt of any such information the Liaison Officer shall take immediate remedial actions and further investigate the matter on an interpersonal level.
The Liaison Officer, at the first instance should try to resolve the issue informally. However, if the matter is not resolvable through informal means, the matter must be reported to the Grievance and Compliance Committee of InfraCloud.
Confidentiality: It is the responsibility of the Liaison Officer and the Grievance and Compliance Committee to maintain the confidentiality of the complainant and the accused at all times and ensure that such incidents do not attach any stigma to either of the parties.

Non-Compliance

Any person found not complying with the guidelines under this policy will face disciplinary action which may extend up to termination or/and any other appropriate legal action that the Company may deem fit in any given situation, as per the applicable laws.

Responsibility

Every member of management of the Company is responsible for giving effect to this policy.
Each location of the Company is responsible for obtaining and utilizing up‐to‐date information regarding applicable state and local laws and regulations.
The TSO Department and Managers have the functional responsibility of assuring compliance with this policy; developing, coordinating and implementing all programs; and reporting findings and progress.

Communication of the Policy

This policy will be available to all employees through Coda: Equal Opportunity, Diversity, Equity, Inclusion & HIV Policy.
Suitable material will be included in the Company publications, management conferences, and supervisory training courses relating to this policy.
All recruitment literature and employment advertising will indicate that the Company is an equal opportunity employer.

Review

This Policy will be reviewed from time to time and the company reserves the right to modify or withdraw the policy at its discretion. Management reserves the right to take disciplinary action in case of non-confirmation of the above policy regulations.