Dealing with Allegations against Employees

A. Policy Code

IIMTS_AO_OGCR_DAE_01_2020

B. Policy Statement

Integrity, Honesty and Commitment to Customer are three of the major core values at IIMT Studies. To protect the interest of all stakeholders, the organization must ensure that every position, be it permanent, temporary, assignment-based, free-lance or honorary work with total commitment, integrity and utmost honesty. To ensure that any professional associated with IIMT Studies or it centres are accountable to all the stakeholder and also a transparent, open environment exists so that any of the stakeholder or agency associated with IIMT Studies or it’s authorised centres, share their grievances related to malpractices and maladministration by any of employees of Awarding Organization or it’s centres at any point of time, at any location.

C. Objectives of Policy

The sole aim of this policy is to ensure that a healthy, honest, transparent environment and also all stakeholders of Awarding Body or it’s authorised centres have an appropriate platform to raise their complaints – grievances related to any instance of malpractice or maladministration by any of the working professional associated with IIMTS or it’s authorised centre. The major precise objectives of this policy are as under:

1. To ensure that a transparent, accountable and honest work environment is maintained all across the organization – at AO or at it’s authorised centres.
2. The working professionals of AO or its centres remain accountable and subject to the public domain so that transparency prevails.
3. The stakeholders have an opportunity to raise any query/ question/ grievance related to :
   • i. Any misbehaviour with any of the stakeholder or public at large.
   • ii. Any instance of malpractice/maladministration or corrupt practice which violates any of the provisions of any policy of AO or its centres.
   • iii. Any issue related to services or non-fulfilment of commitment, to be ensured as per the agreed terms of contract / legal obligation of AO / it’s authorised centres.

D. Scope of Coverage of this policy

This policy will cover and will be uniformly applicable to all working professionals associated with IIMT Studies, and it’s authorised centres, at all locations across the globe and include :

• i. Employees of Permanent roll or Fulltime basis.
• ii. Professionals associated with a fixed-term contract or for a time-bound period.
• iii. Professionals working on a part-time or temporary basis.
• iv. Professionals associated on assignment based contract or on a freelance basis.
• v. Professionals in any position, cadre, with any designation, with or without remuneration, on the honorary basis or advisory role including members of Governing Body.

E. Policy Framework

1. This policy will have the following major compliance segments :

• a. Process of registering allegation/complaint or grievance.
• b. Verification and Validation of allegation/complaint or grievance.
• c. Appointing Investigating Officer / Team.
• d. Investigation Matrix.
• e. Reports and actions.
• f. Closing of complaint- grievance- allegation.
• g. Review of process and policy.

(a) Process of registering allegation / complaint / grievance :

i. The organization- Awarding Body or it’s authorised centres must have an Allegation/complaint registration or submission form on its public domain of the portal with basic guidelines explained on the form.

i. The organization- Awarding Body or it’s authorised centres must have an Allegation/complaint registration or submission form on its public domain of the portal with basic guidelines explained on the form.

iii. In case of the grievance or allegation or the complaint is against the Responsible officer, the Responsible officer will hand over the document of registration to the director or the chairman for the further process and will not involve into the proceedings in any way else the same will be treated as the case under the conflict of interest.

(b) Verification and Validation of complaint/allegation:
h. The Responsible officer, after receiving the complaint, will do a due diligence process to find out :

• 1. Credential of the complainant.
• 2. The authenticity of complaint/allegation.
• 3. Background check and past record of the professional against whom the complaint has been received or allegations are made.
• 4. The authenticity and gravity of the impact of allegations made or complaint registered
• 5. To prepare a summary of a brief report on all above 1-2-3-4 and share the same to the next level for further actions and decision.

(c) Appointing Investigating Officer:

i. The Responsible officer, depending upon the gravity of offence or allegation and the designation and position of seniority of the alleged professional. Will decide internal or external investigating officer or 2 to 3 members for the investigating team to investigate into allegations made/ complaint registered.

j. For all alleged professionals up to Manager level, the investigating officer must be from internal resources however for any alleged professional above managerial position, the investigating officer or members of investigating team must be identified from external independent and neutral resources.

k. In the case of (j) above, the investigating officer or the team should not be from the same location or premise where the alleged professional is working.

l. Based on the gravity of the offence, the investigating officer and or the team must be assigned a time frame of minimum 3 days to maximum 15 days with a maximum extension time of 3 days under the approval of the Chairman.

(d) Investigation Matrix

(e) Reports and Actions After the investigation, the reports will be submitted to wither Chairman of the governing council, and the following process will be followed :

1. The reports will be discussed by all members / reviewed by the chairman.
2. The finding will be studied in-depth, and due analysis will be made.
3. If required investigation officer/team will be asked to make a presentation and discussion may be carried out for evaluation and conclusion.
4. A final course of action may be discussed and decided by the decision making body/professional, and the responsible person may be asked to execute the decision

F. Investigation and reporting process

i. It is the responsibility of the process owner – The Responsible Officer to address every query/grievance/complaint or allegation received from any person / professional whether he or she is associated with the Awarding Body and it’s authorised centres or is an unknown/anonymous source.

ii. Depending on the nature of query/grievance/complaint or allegation received and the cadre and position of the alleged professional, the process owner will decide the investigator from internal or external independent resources under the approval of Chairman of the Governing Body.

iii. The Responsible Officer before appointing Investigating Officer or Investigating Team will do due diligence on authenticity and credentials of the complainant, and in case no substance is found during the initial due diligence process, the finding of due diligence with recommendations for appointing or not appointing investigating officer or team may be submitted to the governing body or the chairman.

iv. The process to initiate investigation has to be done in maximum 3 working days after receiving query/grievance/complaint or allegation against any professional associated with AO, or it’s authorised centre.

v. Based on the gravity of offence or allegation or complaint and the stake involved in it, the time frame of minimum 3 working days to 15 working days must be assigned to the investigator and the complainant must be informed in writing about the timeframe.

vi. Once the report with findings and recommendation is received from the investigator, the Responsible officer will ensure that the report is submitted within 24 hours to the chairman and/or the governing council, based on the gravity of the offence or the complaint.

vii. The final action, as decided by the Chairman and/or the governing council is to be executed by the Responsible officer within 3 working days following the law of natural justice.

viii. In case the complaint or grievance is against Responsible officer or director or member of governing body, the complaint must be directly dealt with by The Chairman, following steps or process clause No. I, II, III, IV, V, VI, VII of this policy, as mentioned here above.

ix. In the case of the situation, as described in D-viii, above, the role of the Responsible officer will be taken care of by one of the directors and/or the chairman.

x. In no case, a professional against whom complaint or allegation has been registered, be a part of investigation or decision making, directly or indirectly, as this will lead to a conflict of interest