EQUAL OPPORTUNITY POLICY
We, at Leumas (“Leumas”), are committed to providing equal opportunities to all our present and prospective employees. Leumas is committed to providing a harmonious and nurturing workplace environment, free from any form of discrimination including gender identity, religious and political beliefs, race, color, caste, sexual orientation, mental or physical ability, individual characteristics including disability, for all its employees.
At Leumas, we understand the value attached with diversity and to the best of our efforts and feasibility, endeavour to foster diversity in our workforce. We aim to create a workplace promoting inclusive growth and favorable work culture wherein all the employees are treated with respect and dignity.
In furtherance of our commitment and in compliance with the provisions of the Rights of Persons with Disabilities Act, 2016 (“Disabilities Act”) read with Right of Persons with Disabilities Rules, 2017 (“Disabilities Rules”), and the Transgender Persons (Protection of Rights) Act, 2019 (“Transgender Act”) read with Transgender Persons (Protection of Rights) Rules, 2020 (“Transgender Rules”), we have formulated and implemented this equal opportunity policy (“Policy”) stating our aim, goals and commitments.
This Policy can be accessed at “https://www.leumas.cloud”.
If any Person with Disability (as defined below) or Transgender Person (as defined below), employed by Leumas have specific concerns or additional requirements, they are requested to contact the HR Department/Liaison and Complaint Officer (as defied below) from time to time, so as to enable Leumas to make suitable arrangements.
- Relevant Definitions
- “Discrimination” means any distinction, exclusion, restriction on the basis of disability and/or sexual orientation which is the purpose or effect of impairing or nullifying the recognition, enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field and includes all forms of discrimination and denial of Reasonable Accommodation.
- “Information and Communication Technology” includes all services and innovations relating to information and communication, including telecom services, web-based services, electronic and print services, digital and virtual services.
- “Person with Disability” means a person with long term physical, mental, intellectual or sensory impairment which, in interaction with barriers, hinders his full and effective participation in society equally with others.
- “Reasonable Accommodation” means necessary and appropriate modification and adjustments, without imposing a disproportionate or undue burden in a particular case, to ensure to Persons with Disabilities and/or Transgender Persons the enjoyment or exercise of rights equally with others.
- “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.
- Scope Of Policy
The Policy applies to all the present and prospective employees of Leumas. The Policy, wherever feasible and possible, also includes within its ambit any job applicants, full time/part time employees, consultants, interns/trainees, contractual employees, partners, or any other person with whom Leumas has entered into arrangements for any purpose whatsoever. It shall also cover employees who acquire any disability in the course of their employment with Leumas.
The Policy applies to all aspects of the relationship between Leumas and its employees, including recruitment, employment, promotion, transfer, training, working conditions, wages and salary administration, employee benefits and application of policies.
- Manner Of Selection
Following instructions/guidelines are required to be followed by Leumas while recruiting any person including Persons with Disabilities and/or Transgender Person:
Leumas shall employ a fair selection procedure that is transparent, based on merit, and devoid of Discrimination against Persons with Disabilities and/or Transgender Persons.
- Every job posting shall have a suitable, succinct statement about equal opportunities for People with Disabilities and/or Transgender Persons.
- The selection criteria (including job description and employee specification) will be continuously evaluated to ensure that they are non-discriminatory and only pertain to the abilities required for the position.
- Application forms shall not include health and disability related queries (unless ‘mandatory’ for the specified position). If requested, application forms will be made available in alternate formats.
- The selection/recruitment committee will have atleast 1 (One) Person with Disability to make the selection procedure fairer and more transparent.
- Facilities And Amenities
- Leumas will identify the list of posts suitable for Persons with Disabilities.
- For each of the identified posts, preference shall be given to Persons with Disabilities. Leumas shall undertake recruitments for these posts on the basis of qualifications and merit, and there shall be no Discrimination in respect of appointment, salaries, training, evaluations, promotions and general career progression on the basis of disability.
- If an employee acquires a disability during her/his employment tenure, owing to which she/he is unable to perform her current duties, Leumas shall invest in re-skilling the employee for another position. Leumas shall undertake best efforts to ensure that no employee is terminated from services, purely on account of having acquired a disability in the course of employment.
- Leumas shall continuously strive to ensure that its documents, communication and Information and Communication Technology adhere to the standards prescribed under the Disabilities Act (read with the Disabilities Rules).
- Leumas shall provide adequate facilities to enable the Persons with Disabilities to properly attend and take part in the selection procedure.
- Reasonable Accommodation: Leumas will make Reasonable Accommodations, whenever necessary, for Persons with Disabilities and Transgender Persons, as per the provisions of the Disabilities Act (read with the Disabilities Rules) and the Transgender Act (read with the Transgender Rules). Such accommodation will be provided: (i) to ensure equal opportunity in the application and selection process, (ii) to enable Persons with Disabilities and Transgender Persons employed by Leumas to perform the essential functions of a job, and (iii) to enable Persons with Disabilities and Transgender Persons employed by Leumas to enjoy the same benefits and privileges of employment as other employees.
- Further, in the course of undertaking their duties, Persons with Disabilities and Transgender Persons may approach the Liaison and Complaint Officer/HR with a request for Reasonable Accommodation, which shall be considered on a case-to-case basis. At no point in time will Leumas require any employee who is a Persons with Disabilities and/or Transgender Person to bear (directly / indirectly) any costs pertaining to the Reasonable Accommodation provided.
- All documents concerning an employee’s Reasonable Accommodation request would be maintained in the employee’s confidential file, separate from the employee’s official personnel file.
- Leumas aims to ensure that all physical infrastructure (including buildings, furniture, facilities, transportation, unisex toilets, and services relating to the workplace) adheres to the accessibility standards as prescribed under the Disabilities Act (read with the Disabilities Rules) and the Transgender Act (read with the Transgender Rules).
- Further, Leumas shall ensure that during this period, in the event it builds / leases any new facility, it shall evaluate such facility basis the above standards. Leumas shall work closely with service providers, facility managers, and other appropriate parties who manage the premises where its offices are located in order to make every effort to adhere to the accessibility and other standards set forth in the Disabilities Act (read with the Disabilities Rules) and under the Transgender Act (read with the Transgender Rules).
- Persons with Disabilities are encouraged to report any accessibility related concerns to the Liaison and Complaint Officer /the HR.
- In order to enable Persons with Disabilities and/or Transgender Persons to properly carry out their responsibilities, Leumas shall, to the greatest extent feasible, attempt to provide the required facilities and services. Leumas shall consider the unique and special needs of Persons with Disabilities and Transgender Persons who work for it.
- Special Leave
- Any Person with Disability employed by Leumas may avail extra days of special casual leave in addition to regular days of casual leave per year as per the provision of human resources policy of Leumas. The same will be treated as a request for Reasonable Accommodation and will be evaluated accordingly, on a case-by-case basis.
- Other Facilities
- For evaluation of the performance of Persons with Disabilities and Transgender Persons, Leumas will prescribe objective evaluation criteria, taking into account any Reasonable Accommodation provided.
- : For official travel, Persons with Disabilities will be provided accessible modes of transport, and shall be allowed to travel with a companion/attender. To the extent possible, Leumas shall also ensure that accessible accommodation is provided.
- : Leumas is conscious that in the course of employment, Persons with Disabilities and Transgender Persons may face issues regarding integration at the workplace. Towards this, Leumas shall take various initiatives from time to time, which shall be further outlined by the Liaison and Complaint Officer/the HR. Specifically, Leumas shall: (a) undertake sensitization training for its employees on the rights of Persons with Disabilities and Transgender Persons; (b) endeavor to ensure that Persons with Disabilities and Transgender Persons participate in all Leumas sponsored events and that such events are conducted at accessible venues; (c) participate in job fairs, training and scholarship programmes and invest in specific training and skill development of Persons with Disabilities and Transgender Persons.
- Induction And Training Material
On request, Leumas will ensure that appropriate on-the-job training is provided to Persons with Disabilities, including providing induction and training material in accessible formats, assistive aids, facility of an interpreter, scribe, etc. A request for Reasonable Accommodation, must be made before the inception of such induction or training. Further, if any Persons with Disabilities requires any specific assistance, they are requested to approach the Liaison and Complaint Officer / the HR Department.
- Maintenance Of Records
Leumas shall maintain records reflecting the following details –
- the number of Persons with Disabilities and Transgender Persons who are employed and the date from when they are employed;
- the name and address of Persons with Disabilities and Transgender Persons;
- the gender of Person with Disabilities and the nature of disability;
- the nature of work being rendered by such employed Persons with Disabilities and Transgender Persons; and the kind of facilities being provided to such Persons with Disabilities/Transgender Persons.
All Persons with Disabilities, upon joining employment, will be asked to voluntarily fill in a self-identification form with information regarding the concerned disability, and submit any medical reports and/or a certificate of disability obtained in the manner specified under the Disabilities Act (read with the Disabilities Rules). An employee can edit the information provided at any time during her/his tenure. Notwithstanding anything stated in Leumas’s handbook, Leumas shall not, except in case of fraud or willful misconduct, penalize any employee for not sharing complete information regarding his/her disability earlier. However, Persons with Disabilities will be counselled and encouraged to share complete information and all medical records and disability certificates at the earliest.
- Liaison Officer and Complaint Officer
Leumas has appointed a Liaison and Complaint officer (as specified in Schedule I below) [SA 31] to: oversee and manage the recruitment of Persons with Disabilities and Transgender Persons; make necessary provisions and ensure facilities for such employees in the establishment; and handle complaints relating to violation of the provisions of the Disabilities Act and Transgender Act.
Details of the Liaison and Complaint officer have been provided in Schedule I of this Policy.
All information obtained by Leumas in relation to individual characteristics of Persons with Disabilities shall be kept confidential and utilised in line with existing laws, with the following exceptions:
- Managers, supervisors, and human resource advisors may be informed of such individual characteristics in order to approve or provide any Reasonable Accommodation.
- Security staff may be informed of such individual characteristics to aid in securing any essential assistance in case of an emergency.
- Information regarding such individual characteristics may be provided to public officials in connection with any investigation into the compliances under applicable laws.
All information obtained by Leumas in relation to the individual characteristics of Transgender Persons shall be kept confidential at all times.
- Grievance Redressal Mechanism
- Any instance of Discrimination, including harassment, victimisation and vilification against Persons with Disabilities and Transgender Persons will be taken extremely seriously by Leumas. It is a disciplinary infraction for which you could, under the right conditions, be fired.
- Complaints and grievances in relation to Discrimination or harassment at the workplace and in any work-related circumstances outside of work may be forwarded to Liaison and Complaint Officer whose details has been delineated in Schedule I of this Policy.
- The Liaison and Complaint Officer shall enquire into the complaint within 15 (fifteen) days of receipt of such complaint, ensuring that principles of natural justice are complied with.
- The board of directors of Leumas shall take appropriate action on the enquiry report within 15 (fifteen) days of submission of enquiry report. If the employee against whom the complaint has been made is found guilty of Discriminatory behaviour, she/he will be subjected to disciplinary action, including but not limited to a reprimand, counselling, detraction of benefits for a definite or indefinite time period, demotion, denial of promotion and in case of more serious offences, suspension or termination of employment.
- In the event wherein the Liaison and Complaint Officer fails to take action within the timeline stipulated above, the board of directors of Leumas shall initiate action on such complaints suo moto.
- Leumas shall ensure that all complaints are investigated in a confidential manner. However, allegations made in bad faith and without any factual substance may also result in appropriate disciplinary action.
- Persons with Disabilities may also approach the Chief Commissioners or the State Commissioners appointed under the Disabilities Act, who are required to dispose of the complaint within a period of 60 (sixty) days (30 (thirty) days in exceptional circumstances).
- Communication Of Policy
The Policy has been communicated to all the relevant and concerned persons to the following mode:
- The Policy has been updated on the website of Leumas, ‘https://www.leumas.cloud’.
- The Policy has been affixed at a suitable place in Leumas’s premises.
- All the employees, at the time of their joining, shall be introduced to this Policy.
Details of Liaison and Complaint Officer
|30 March 2023
Responsibilities of Liaison and Complaint Officer:
The Liaison and Complaint Officer is responsible for:
- Collaborating with the multiple departments to put the action plan for making the workplace and IT systems accessible for Persons with Disabilities into practice.
- Ensuring that all staff members are aware of the Policy and, and the Persons with Disabilities and Transgender Persons are aware of their rights under the Policy and the Disabilities Act and the Transgender Act.
- Developing proactive strategies to prevent Discrimination and harassment of Persons with Disabilities and Transgender Persons and ensuring their integration at the workplace.
- Resolving and addressing grievances in a timely manner including to prevent any further harm or inconvenience to any person.