Policy

CORPORATE SOCIAL RESPONSIOBILITY POLICY

  1. VISION STATEMENT

    KLT, through its CSR initiatives, will continue to enhance value creation in the society and in the community in which it operates, through its services, conduct & initiatives, so as to promote sustained growth for the society and community, in fulfillment its role as a Socially Responsible Corporate, with environmental concern.

  2. OBJECTIVES
    • To serve the social, economic, cultural interest of human being in the community.
    • To directly or indirectly take up programmes that benefit the communities in & around its work centers and results, over a period of time, in enhancing the quality of life & economic well- being of the local populace.
    • To generate, through its CSR initiatives, goodwill and pride for KLT among stakeholders and help reinforce a positive & socially responsible image of KLT as a corporate citizen.
  3. COMPOSITION OF CSR COMMITTEE OF THE BOARD

    This CSR Policy has been formulated in consonance to the provisions of Section 135 of the Companies Act, 2013 read with Schedule VII (“the Act”) and in accordance with the Companies (Corporate Social Responsibility Policy) Rules, 2014 notified by the Ministry of Corporate Affairs, Government of India in 2014.
    In accordance with provisions of the above mentioned Act, and Rules, the Board of Directors of the Company has formed a committee of Board of Directors named as Corporate Social Responsibility Committee (CSR Committee).

  4. FOCUS

    The Company will undertake all such CSR Activities, as may be decided/approved by the Board of Directors which falls within the purview of the Act, Rules and amendments thereto from time to time

    The major focus areas of CSR activities would as under:
    • Promoting Education / Skill Development.
    • Promoting research and development in Agriculture, Horticulture etc.
    • Promoting heath care, medical help/assistance to the needy.
    • Empowering women
    • Setting up homes and hostels for women and orphans
    • Undertake environmental friendly measures like tree plantation
    • Rural/ Agricultural extension/ development projects

    Besides undertaking direct CSR activities, the Company may take contributions to Prime Minister’s Relief Funds and any other Government approved funds/ Schemes or Organizations / Universities/ Research institutes etc. as permitted/ allowed under the Act.

  5. CSR IMPLEMENTATION

    Programmes/ activities to be undertaken by the Company under the head CSR shall be as approved by Board of Directors (the Board) in pursuance of recommendations of the CSR Committee of the Board.

  6. CSR MONITORING

    The CSR Committee will be responsible for monitoring the progress of projects or programmes undertaken by KLT. The CSR Committee can appoint a person or external agency to monitor the progress of projects or programmes.

  7. REPORTING/DISCLOSURE OF THE POLICY

    The following regulatory disclosure requirements also need to be complied in relation to CSR activities of the Company apart from the reporting requirement as mentioned hereinabove in the Policy.

    • Composition of the CSR Committee shall be disclosed in the Board Report
    • The Board Report shall include an annual report on CSR activities in prescribed format ( by MCA) containing specified particulars i.e Brief Outline of CSR Policy, its content, the Average Net Profit for the last three financial years, and the prescribed CSR Expenditure etc;
    • If the Company fails to spend the prescribed amount, the Board shall, in its report specify the reasons for not spending the amount; and
    • The content of Corporate Social Responsibility (CSR) policy shall be displayed on the Company’s website, if any

  8. RESPONSIBILITY OF THE COMMITTEE

    The responsibilities of the CSR Committee include.

    • Formulate and recommend to the Board, a CSR policy which shall indicate the activities to be undertaken by the Company as specified in Schedule VII of the Companies Act, 2013.
    • Recommend the amount of expenditure to be incurred on the CSR activities.
    • Monitor the CSR Policy of the Company from time to time
  9. FREQUENCY OF MEETINGS OF THE CSR COMMITTEE

    CSR Committee of the Company shall meet once a year.

  10. EXCLUSION OF THE FOLLOWING ITEMS FROM CSR

    The following activity shall not form part of the CSR activities of the Company:

    • The activities undertaken in pursuance of the normal course of business of a Company.
    • CSR Projects/ programmes or activities that benefit the employees of the Company and their families.

  11. GENERAL

    In case of any doubt with regard to any provision of the policy and also in respect of matters not covered herein, a reference will be made to the Board of Directors by CSR Committee. In all such matters, the interpretation & decision of the Board of Directors shall be final.

    Any or all provisions of the CSR Policy would be subject to revision/amendment in accordance with the guidelines on the subject as may be issued from Government, from time to time.

    The Company reserves the right to modify, cancel, add, or amend any of these Rules.



PREVENTION OF SEXUAL HARASSMENT AT WORKPLACE

INTRODUCTION
In accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the Company has framed a policy for Prevention of Sexual Harassment at Workplace and adopted the same.

The objective of the policy is to provide its women employees, a workplace, free from harassment/ discrimination and every employee is treated with dignity and respect.

  1. COMMITMENT:
    • Our Company is committed to provide a work environment that ensures every woman employee is treated with dignity and respect and afforded equitable treatment.
    • The Company is also committed to promote a work environment that is conducive to the professional growth of its women employees and encourages equality of opportunity.
    • The Company will not tolerate any form of sexual harassment and is committed to take all necessary steps to ensure that its women employees are not subjected to any form of harassment.
  2. SCOPE:
    This policy applies to all categories of employees of the Company, including permanent management and workmen, temporaries, trainees and employees on contract at its workplace or at client sites. The Company will not tolerate sexual harassment, if engaged in by clients or by suppliers or any other business associates.
    The workplace includes:
    • All offices or other premises where the Company’s business is conducted.
    • All company-related activities performed at any other site away from the Company’s premises.
    • Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.
  3. DEFINITION OF SEXUAL HARASSMENT:
    “Sexual Harassment” includes any one or more of the following unwelcome acts or behavior (whether directly or by implication) namely:-
    • Physical contact and advances; or
    • A demand or request for sexual favors; or
    • Making sexually coloured remarks; or
    • Showing pornography; or
    • Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
  4. RESPONSIBILITIES REGARDING SEXUAL HARASSMENT:

    All employees of the Company have a personal responsibility to ensure that their behavior is not contrary to this policy.

    All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.

  5. COMPLAINT MECHANISM:

    Whether or not such conduct constitutes an offence under law or a breach of the service rules, an appropriate complaint mechanism in the form of “Internal Complaints Committee” has been created in the Company for time-bound redressal of the complaint made by the victim.

  6. INTERNAL COMPLAINTS COMMITTEE:

    The Company has instituted an Internal Complaints Committee for redressal of sexual harassment complaint (made by the victim) and for ensuring time bound treatment of such complaints.

      In accordance with the sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the Internal Complaints Committee will comprise of the following:
    • Chairperson - Shall be a woman employed at a senior level at workplace amongst the employees
    • Two members- Shall be amongst employees preferably committed to the cause of woman.
    • One Member - amongst Non-Governmental Organizations or associations committed to cause of woman
      The Internal Complaints Committee is responsible for:
    • Investigating every formal written complaint of sexual harassment.
    • Taking appropriate remedial measures to respond to any substantiated allegations of sexual harassment.
    • Discouraging and preventing employment-related sexual harassment.
  7. PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL HARASSMENT: The Company is committed to providing a supportive environment in which the concerns of sexual harassment shall be resolved as follows:
    1. Informal Resolution Options
      • When an incident of sexual harassment occurs, the victim of such conduct can communicate her disapproval and objections immediately to the harasser and request the harasser to behave decently.
      • If the harassment does not stop or if victim is not comfortable with addressing the harasser directly, she can bring her concern to the attention of the Internal Complaints Committee for redressal of her grievances. The Internal Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.
    2. Complaints:
      • Any employee with a harassment concern, who is not comfortable with the informal resolution options or has exhausted such options, may make a formal complaint to the Chairperson of the Internal Complaints Committee constituted by the Management.
      • The complainant shall submit 6(six) copies of the Complaint to the Complaint Committee along with supporting documents and the names and addresses of the witnesses in writing and can be in form of a letter, preferably within 3months from the date of occurrence of the alleged incident, sent in a sealed envelope. Alternately, the employee can send complaint through an email. The employee is required to disclose her name, department, division and location she is working in, to enable the Chairperson to contact her and take the matter forward.
      • The Complaint Committee shall send 1(one) of the copies received from the aggrieved woman to the accused (respondent) within a period of 7 working days.
      • The Accused (respondent) shall file his reply to the Complaint along with supporting documents and the names and addresses of the witnesses, within a period not exceeding 10 working days from the date of receipt of the documents.

    The Complaint committee have the right to terminate the inquiry proceedings or to give an ex-parte decision on the complaint, if the Aggrieved (complainant) or Accused (respondent) fails, without sufficient cause, to present herself or himself for 3 consecutive hearings convened by the

    • Chairperson, as the case may be, provided that such termination or ex-parte order may not be passed without giving a notice in writing, 15 days in advance, to the party concerned.
    • In conducting the inquiry, a minimum of 3 Members of the Complaints Committee including the chairperson, as the case may be, shall be present.
    • The parties shall not be allowed to bring in any legal practitioner to represent them in their case at any stage of the proceedings before the Complaints Committee.
    • The Internal Complaints Committee shall conduct such investigations in a timely manner and shall submit a written report containing the findings and recommendations to the Employer as soon as practically possible and in any case, not later than 10 days from the date of completion of inquiry. The Employer shall act upon the recommendation within 60 days of its receipt by him.
    • The Complaint’s Committee report will also be made available to concerned parties.
  8. MANNER OF TAKING ACTION AGAINST THE RESPONDENT

    Where the Complaints Committee arrives at the conclusion that the allegation against the respondents been proved, it shall recommend to the employer to take action which may include the following:

    • Written apology;
    • Warning;
    • Reprimand or Censure;
    • Withholding of Promotion;
    • Withholding of pay rise or increments; or
    • Terminating the respondent from service; or
    • Undergoing a counseling session or carrying out community service
    • .
  9. PUNISHMENT FOR FALSE OR MALICIOUS COMPLAINT AND FALSE EVIDENCE:

    Where the Internal Complaints Committee arrives at a conclusion that the allegation against the respondent is malicious or the aggrieved woman or any other person making the complaint has made the complaint knowing it to be false or the aggrieved woman or any other person making the complaint has produced any forged or misleading document, it may recommend to the employer to take action in accordance with the provisions of the service rules applicable to her or him.

  10. CONFIDENTIALITY:

    The Company understands that it is difficult for the victim to come forward with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter confidential.
    To protect the interests of the victim, the accused person and others who may report incidents of sexual harassment, confidentiality will be maintained throughout any investigatory process to the extent practicable and appropriate under the circumstances.

  11. ACCESS TO REPORTS AND DOCUMENTS:

    All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Company except where disclosure is required under disciplinary or other remedial processes.

  12. PROTECTION TO COMPLAINANT / VICTIM:

    The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action. The Company will ensure that victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.
    However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action

  13. CONCLUSION:

    In conclusion, the Company reiterates its commitment to providing its women employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.