a. Role and responsibilities for each position, as mentioned in the prescribed organizational chart of the centre.
b. Internal Checks & Control mechanism.
c. Role and responsibilities under the policy.
d. Investigation and reporting process.
e. Authorities and Approvals.
f. Identification of conflict of interest within the business operations, governing council and with stakeholders
(a) Role and responsibilities for each position, as mentioned in the prescribed organizational chart (wherever applicable) of IIMTS:
i. For this policy, the standard approved organizational chart will be the base document to refer to all roles.
ii. For this policy, the Master Competency Matrix Document will be considered for role and responsibilities check.
iii. The prescribed Job Description will be audited to validate and audit the possible conflict of interest in tasks and assignments ( KRAs) of each position.
iv. The roles and position titles will be as per the following role matrix/job clusters:
v. Each box in the above matrix are unique roles and must be assigned unique and non-overlapping KRAs and/or tasks and assignments.
vi. No function or assignment of roles or job titles mentioned in one box should be in conflict with the unique roles mentioned in any other box.
(b) Internal checks and control mechanism :
i. This policy defines the following categories of roles and positions/jobs in the organization or at its centres.
1. Operations and Administration.
2. Service Deliveries.
3. Compliance & Monitoring.
4. Management & Control.
5. Policy & Strategic Governance.
ii. The jobs/roles/ positions in 3 & 4 are responsible for internal checks and controls thru effective execution of all policies which they are responsible for.
iii. The jobs as mentioned category are responsible for ensuring appropriate policies and norms as well as to ensure appropriate competent professionals to ensure checks and controls for total compliance of all policies.
iv. While the roles in the categories of 1 and 2 in E (b) above are responsible for execution and documentation of all process compliance of their respective policies and processes, the roles in the categories 3,4 and 5 are responsible for the review, monitoring compliance and also for whistleblowing, reporting any possibility or instance of violation or non-compliance.
v. The horizontal boxes( boxes in clusters) of one particular function shows the hierarchy level of that function and shows accountability towards the next level or next horizontal box in the same function. This is to ensure internal control for each function for compliance.
(c) Role and responsibilities under the policy.
i. This policy defines the following categories of roles and positions/jobs in the organization and/or at its centres.
1. Operations and Administration: Executive- Administration, Executive- Operations, Executive- Accounts and Finance, Internal Examiners, Executive – Sales & Admin.
2. Service Deliveries: Executive Human Resources, Executive- CSR, Executive- IT. Teachers or Members- Learning Deliveries.
3. Compliance & Monitoring: Manager- Operations, Manager- CSR, Manager- Sales & Administration. Head- Learning Delivery, Quality Controller, External Examiner.
4. Management & Control- Responsible Officer ( Responsible Officer) , Director- Business Development, Director- Operations, Finance Controller ( Consulting)
5. Policy & Strategic Governance- Directors, Responsible Officer, Chairman, Governing Council.
ii. The above roles will have the prescribed responsibilities and accountabilities, as mentioned in their specific documents.
iii. The roles cannot have any responsibilities which overlap with other role and also cannot exchange or carry out any responsibilities of any roll, which lead to a conflict of interests.
iv. No role of anyone box in the above roll matrix can take up or carry out any responsibility or assignment of the role cluster in any other box of the same or other function as this will lead to a conflict of interest.
(d) Investigation and reporting process :
i. The roles in monitoring and compliance clusters are responsible as a whistleblower – to raise alarms as and when they see any possibility of a conflict of interest
ii. The responsible officer or professional as mentioned in (d) I above will submit a formal report in the form of mail communication, in case they see a possibility or they have observed any instance of conflict of interest, to the professional in Management and Control cluster, for that particular function or to the process owner of that policy.
iii. The mail communication must contain the following minimum information about the instance :
a. Roles or positions details where there is a possibility of a conflict of interest or where the instance has been observed.
b. The justification of explanation about the instance for reporting.
c. Details of possible impact or impact already observed due to conflict of interest to the process owner or respective senior member of Compliance and Monitoring cluster.
d. The role of the process owner is to study the report, validate the details as mentioned in the report and recommend appropriate actions and forward to the Management & Control member for further action.
e. The Monitoring and Control Member will study the report and recommendations and appoint an independent, neutral professional or team of professionals who are not below the rank of manager for further investigation and recommendation of solution.
f. The above steps ( d ) and ( e) have to appoint an investigation officer or team of officers, as mentioned in the clause ( e ) above.
g. The investigation team has to investigate and submit the report along with detailed corrective actions to be recommended to the Management & Control team.
h. The Management & Control team will take the final decision based on the recommendations by the Investigation Officer and close the instance.
i. The Management & Control team, if required will review the process, so as to seal the loophole in the process or policy to avoid any such instance in future and recommend the change in process or amendment in policy to Policy and Strategic Governance Team.
(e) Authorities and approvals.
i. The first group of roles in Service Deliveries and Operations and Administration are responsible for effective implementation of policy for their functional area and are also are designated whistleblowers in case they see any possibility or instance of non-compliance.
ii. The roles in the Compliance and Monitoring group are responsible for having internal checks and control mechanism active and operational for continuous monitoring of policy implementation and compliance. They are whistleblowers and has the same role to play for reporting and validating instance or possibilities of non-compliance of this policy.
iii. The professionals appointed for the roles in Management and Control are custodian and process owners and have final accountability to ensure zero tolerance for this policy.
iv. The professionals in the role of Management & Control are reviewing authorities and controlling authorities under this policy. To review complaints received – to review the effective implementation and also to control and block the possibility of violation and reporting.
v. The roles in Policy & Strategic Governance are the final authorities for all corrective actions under this policy under the approval of Governing Body or Chairman, within the stipulated time frame as mentioned in the clause ( d) – f-g and h.