EEO & Anti-Discrimination Policy

Introduction

Indian constitution encapsulates social safeguard measures for all citizens of India in Article 15 and
Article 16.
Article 15 mandates prohibition of discrimination on grounds of religion, race, caste, sex or place
of birth.
Article 16 mandates equal opportunity in matters of public employment. Article 16(2) further states
that no citizen shall on grounds only of religion, race, caste, sex, descent, place of birth, residence
or any of them, be ineligible for, or discriminated against in respect of, any employment or office
under the State.
The United Nations Convention on Elimination of Discrimination against Women, 1979, United
Nations International Convention on the Elimination of All Forms of Racial Discrimination (1965),
the Universal Declaration of Human Rights International Covenant on Economic, Social and Cultural
Rights (1966), strongly advocate against discrimination in their respective domains.
Keya Foods International Pvt Ltd (Keya) has endeavored to capture the spirit of the above national
and international statues in EEO and Anti-Discrimination Policy.
Keya is committed to promoting equal employment opportunities and a workplace that is free of
all forms of discrimination. Equal opportunity means that all staff experience fairness, impartiality
and equal access to all career initiatives in Keya.
Keya’s commitment to equal opportunity promotes an inclusive work environment that values
and accepts the diverse cultural and social backgrounds of its staff.
This EEO and Anti-Discrimination Policy is consistent with the Keya’s pursuit of excellence. This
policy is underpinned by a set of values and key guiding principles in the building of a community
of all employees.

 

Policy Objectives

The objectives of this Equal Employment Opportunity (EEO) and Anti-Discrimination Policy are to ensure that: 

  • Keya shall comply with the provisions of the Rights of Persons with Disability Act 2016 and the Rules madethereunder.
  • Keya’s employees or potential employees do not suffer unfair discrimination in the workplace
  • Individuals and groups within Keya work in an environment where all decisions are free of discrimination, where they have equal opportunity based on relevant abilities and merit
  • Employees are encouraged to take positive action towards promoting equal opportunity throughout the organization
  • Personnel actions, such as compensation, benefits, transfers, layoffs, company-sponsored training programs, and social and recreational programs, will be administered on a nondiscriminatory basis
  • Application of labour laws to be uniformly applied in the organization

EEO and provision of services

It refers to the principle which ensures that all employees, interns, job applicants and potential employees of Keya are treated equitably and fairly, regardless of their race, sex or disability. Everyone has an equal chance when applying for jobs or promotions, training opportunities and in their working conditions. The following activities shall be conducted in a uniform manner-

  • Recruitment procedure and selection criteria, for appointment or engagement of a person as an employee;
  • Promotion and transfer of an employee;
  • Training and staff development for an employee; and
  • Terms of employment or any other employee related activity.
  • Providing of facility and amenity to the persons with disabilities to enable them to effectively discharge their duties in Keya;
  • Identification of posts suitable for persons with disabilities in Keya;
  • Separate selection process shall be adopted for persons with disabilities for various posts, training shall be provided post-recruitment and prior to promotion, preference shall be given with respect to transfer and posting,;
  • Barrier-free accessibility and other provisions for persons with disabilities shall be provided;
  • Any of the employee pertaining to Human resource department of the Company shall act as the liaising officer of Keya to look after the recruitment of persons with disabilities and provisions of facilities and amenities for such employees.

What is workplace discrimination?

Discrimination occurs when someone is treated unfavorably because of a certain attribute. Discrimination may involve some or all of the following:

  • Conduct that can be considered harassing, coercive or disruptive, including sexual harassment.
  • Making offensive ‘jokes’ about another worker’s clan, ethnic background, colour, sex or disability
  • Expressing negative stereotypes about particular groups e.g. “married women shouldn’t be working.
  • Judging someone on their political or religious beliefs rather than their work performance.
  • Using selection processes based on irrelevant attributes such as ethnic or clan group, age, sex or disability rather than on knowledge, skills and merit.

Parameters of Discrimination – Strictly Prohibited

Keya and its employees shall strive to create a workplace that is free from discrimination in their employment practices against any potential or existing employees, and shall not discriminate on a person’s:

  • Age or other circumstances
  • Colour
  • Cultural or social beliefs such as religious
  • Educational Background
  • Race
  • Ethnicity
  • Spiritual, traditional or customary beliefs
  • Political opinion
  • Physical features
  • Gender identity and expression
  • Marital status
  • Pregnancy or judging the impacts of potential pregnancy on decisions
  • Breastfeeding
  • Sexual orientation
  • Health or physical disability or impairment
  • Medical record
  • HIV status
  • Family responsibilities
  • Trade Union membership

Complaint process and procedures

How to make a complaint?

A person wishing to make a complaint of discrimination can consult and file a complaint with the EEO & Anti-Discrimination Committee. The complaint should be made in writing and addressed to chairperson of the committee within 5 working days of any such incident of discrimination.

EEO & Anti-Discrimination Committee

Sr. No. Name Designation Role in Committee
1 Jatin Mevada Head - Finance & I.T Chairperson
2 Liju Pillai Assistant Manager - HRD Internal Officer
3 Jija George Assistant Manager - Finance & Accounts Internal Officer
4 Sumeet Shahane Senior Manager - HRD HR Department Head

 

Once a complaint has been filed:

Investigation

Once a complaint has been filed an investigation will be undertaken immediately. In instances where there is an alleged respondent, the respondent will be notified immediately. The complainant and the respondent will both be interviewed along with any individuals who may be able to provide relevant information. Where the alleged discrimination is an organizational practice or procedure, that practice or procedure will be investigated immediately. Where the investigation finds systemic discrimination within the organization, that practice or procedure will be changed promptly. Once a complaint has been filed an investigation will be undertaken immediately. In instances where there is an alleged respondent, the respondent will be notified immediately. The
complainant and the respondent will both be interviewed along with any individuals who may be able to provide relevant information.
Where the alleged discrimination is an organizational practice or procedure, that practice or procedure will be investigated immediately. Where the investigation finds systemic discrimination within the organization, that practice or procedure will be changed promptly.

Mediation

Keya supports resolving matters through mediation provided that it is consistent with organizational duties, obligations and needs. Mediation can only be undertaken voluntarily. If both parties agree to participate, matters may be resolved through mediation in the following circumstances. Once the matter has been investigated and Keya has determined the facts of the case, Keya may use mediation to develop appropriate solutions to the complaint; and, in rare
instances, where the incident is an isolated event and the parties do not dispute the facts, Keya will act diligently to ensure that matters are dealt with in a manner that ensures the safety and protection of everyone within the organization.

Timelines

Keya will investigate all complaints immediately and will work towards the prompt resolution and prevention of discriminatory acts and practices. The first round of investigation and conclusion shall be arrived at within 10 working days from the date of filing of the complaint.

Fairness

All complaints will be investigated in the same manner with the aim of promoting, fairness and equality.

Confidentiality and the Right to Privacy

Keya will preserve the confidentiality of all individuals involved in a discrimination complaint. The preservation of confidentiality may be affected by the employer’s duty to prevent discrimination in/at Keya and by the alleged respondent’s right to know the nature of the complaint being made
against them and who has made it so that they can respond. If the investigation fails to find evidence to support the complaint, no documentation concerning
the complaint will be placed on the file of the respondent. Keya will retain all documentation for 12 months for informational purposes in the event that there is an internal appeal or a complaint filed with an outside agency.

Outcomes and Remedies

Keya will act swiftly to ensure that the discriminatory practice is stopped as soon as possible and may remedy the situation in a number of ways. Where the investigation determines that discrimination has occurred or the matter has been successfully mediated, outcomes may include moving the respondent to another department, changing the respondent’s job duties, or a letter of apology. Actions taken to remedy a discriminatory situation should not have a negative effect
on the complainant. The main concerns of the employer will be to ensure that the discrimination ends and to restore workplace harmony.

Appeal Process

Within 10 days from the result of first round of investigation, either the complainant or the respondent may make a written request that an investigation be reviewed stating which aspect of the investigation is inadequate. The request must be submitted to the ‘HR Department Head’ as per the EEO & Anti-Discrimination Committee, who will determine if the investigation is to be re opened in order to address the concerns raised. In case the appeal is taken up, then the investigation shall be completed within 15 working days by the same committee with the inclusion of an independent member. The result of the appeal shall be binding on the complainant for all purposes.