This Equal Opportunity Policy affirms the Company's commitment to providing a fair and inclusive workplace, free from discrimination, for all its employees and applicants. The Company is dedicated to upholding the rights and dignity of every individual and ensuring compliance with all applicable laws, including The Rights of Persons with Disabilities Act, 2016; The Transgender Persons (Protection of Rights) Act, 2019; and The Human Immunodeficiency Virus and Acquired Immune Deficiency Syndrome (Prevention and Control) Act, 2017.
This policy outlines the measures the Company will take to prevent discrimination and promote equal opportunity for persons with disabilities (“PwD”), transgender persons, and persons affected by HIV and AIDS.
This policy is applicable on TruBoard Private Limited, all subsidiaries, associate companies and group companies of the TruBoard Private Limited (Collectively and each, referred to as “Company”).
i) For employees with Disabilities
In order to enable employees with disabilities to effectively perform their duties, the Company shall provide appropriate and enabling common facilities and amenities that would include, inter alia, elevators or lifts, safe and potable drinking water, accessible washrooms or resting rooms, waiting rooms, canteens or cafeterias, accessible workstations, appropriate seating arrangement, accessible / reserved parking facility, if available, priority in handling issues and matters pertaining to PwDs, wheelchairs etc. The items listed here illustrative, indicative and not exhaustive in nature.
| # | Disability Type | Facilities, Amenities towards Reasonable Accommodation*, to be decided on a case-to-case basis |
|---|---|---|
| 1 | Vision Impairment |
a) Screen Reader b) Screen Magnifier c) High Contrast Display d) Document Scanner e) Handheld Magnifier |
| 2 | Hard of Hearing, Deaf |
a) Use Sign language b) Use visuals (images, videos, PPT) c) Sign language interpreter d) Hearing aid |
| 3 | Physical Disabilities |
a) Caliper b) Crutches c) Walker d) Wheelchair (Manual and/or motorized) |
*“Reasonable Accommodation” means necessary and appropriate modification and adjustments, without imposing a disproportionate or undue burden in a particular case, to ensure to PwD the enjoyment or exercise of rights equally with others.
Facilities such as auxiliary services, sign language interpreters, availability of trained staff/appropriate technology for assistance, priority in handling issues/matters concerning PwDs, quiet rooms or sensory-friendly spaces, and similar support mechanisms etc., where available, would be explored on a need-basis and implemented after feasibility analysis and relevant stakeholders’ consultation including HR, facilities, and the PwD employee resource group (as applicable).
ii) For PwD who are likely to visit Company premises e.g. visitors, customers etc.
In order to enable PwD who are likely to visit Company premises e.g. visitors, customers, applicants and other external stakeholders the facilities and amenities to be provided by the Company would include, inter alia, waiting areas or visitor meeting rooms with comfortable seating facility, elevators, safe and potable drinking water, post authorized entry into premises accessible washrooms or resting rooms in office, accessible parking facility, if available, priority in handling issues and matters pertaining to PwDs, Wheel chairs etc. The items listed here are illustrative, indicative and not exhaustive in nature.
Note: For both the above categories i) and ii), a need-based approach would be adopted for each office property basis ownership and control of the Company (owned, lease basis etc.), as per the requirements and sole decision of management of the Company.
In compliance with applicable laws, the Company prohibits discrimination against any employee or applicant on the basis of disability, gender identity, or HIV status. This includes, but is not limited to, discrimination in:
This policy applies to all persons with “specified disability” as defined in The Rights of Persons with Disabilities Act, 2016. The Company is committed to identifying and making available suitable roles for PwD across all functions and levels. Preferred minimum educational qualification for working with the Company is graduation. While the Company is cognizant of the fact that PwDs may not have had the opportunity to start or complete their graduation studies owing to several reasons, the Company may choose to relax the preferred age and/or educational qualification criteria in lieu of their skills and capabilities/experience on a case-to-case basis and this would be at its sole discretion on rare exception basis.
Livelihood opportunities for PwDs enabled by the Company would be of two types:
While the Company may initially focus on creating opportunities for persons with certain types of disabilities based on role requirements, the protections and provisions of this policy apply equally to all individuals with specified disabilities under the act. The scope of inclusion will be continuously reviewed and expanded.
Accordingly positions across various functions, sub-functions, departments, and zones spread over multiple office locations across India would be considered for PwDs basis availability of suitable PwD candidate profiles with relevant educational qualifications, work experience, skills, experience, expertise and necessary aptitude and attitude for the role, as may be sole decided by management of the Company.
Identification of posts suitable for PwDs is an on-going continuous process in the Company.
The Company’s interview and selection process shall be designed to provide an enabling environment for PwD candidates ensuring they are able to effectively communicate, showcase their skills and showcase their potential. Wherever required, the Company may seek support from NGOs or external experts specializing in the PwD domain to assist in shortlisting, review and overall selection process.
Our employees will be sensitized that any inquiry about disability would be conducted with sensitivity, without violating the individual's privacy, and solely for achieving the legitimate aim of securing reasonable accommodation for the said individual. No candidate will be required to undergo disability-unrelated medical tests beyond job-related requirements; information will be collected and used consistent with confidentiality obligations.
We would train our employees (as and when needed) to look at alternate methods of interviews for persons with hearing impairment and persons with learning disabilities from time to time. It ensures that all necessary provisions are provided to the candidate who is selected for the interview.
Cost to Company (CTC) or remuneration or salary or stipend for PwD candidates may be different, viz. higher, than that for non-PwD or able-bodied candidates upholding true spirit of affirmative action (AA) and being cognizant of the fact of limited pool of suitable PwD candidates meeting company & job profile requirements being available to fill vacancies in a particular geography or location. Such compensation shall be determined in consultation between HR and concerned function/dept head(s) basis shortlisted PwD candidate skills and capabilities/experience and job profile requirements on a case-to-case basis and final decision in this regard would be the sole discretion of Company management.
In accordance with Section 20(4) of The Rights of Persons with Disabilities Act, 2016, no employee who acquires a disability during their service shall be dispensed with or reduced in rank. If such an employee is not suitable for the post they were holding, they shall be shifted to some other post with the same pay scale and service benefits. If it is not possible to adjust the employee against any post, they may be kept on a supernumerary post until a suitable post is available or until they attain the age of superannuation, whichever is earlier.
Adequate efforts will be taken to ensure due career progression for PWDs and to evaluate their performance in a manner that is sensitive to the barriers faced by them.
Transfer and posting for PwDs in Company as per applicable Company policy will be done keeping in mind job profile requirements at that specific location and disability type involved on a case-to-case, need basis.
Aligning to code of conduct, Company policies and practices would be effective to prevent transfer posting of PwDs because of discrimination or prejudice against any employee with disability, and to prevent their victimization.
Leaves for PwDs will be as per applicable Company Policy. Special leaves for PwDs if requested, with pay and/or without pay, would be considered by Company management on case-to-case basis warranted by health situation of the particular PwD (e.g. medical treatment, surgery etc.) as maybe prescribed by competent medical professionals and prior written request received from PwD’s immediate family members.
Efforts will be made to enable retention of employees with disabilities such as flexible work arrangements, part-time or modified work schedules, wherever available, and in consultation with department, function and HR officials.
Note: There is no residential accommodation provided to any employee and the same will therefore not be applicable for PwDs as well as abled-bodied persons or non-PwDs. Company-arranged hostels/guest houses/travel lodging and related facilities, where provided, shall be available on a non-discriminatory basis, including for transgender persons and protected persons under the HIV Act.
Employee Resource Group (ERG) comprising of PwDs & other colleagues is envisaged to be constituted with an objective of furthering the cause of disability inclusion and its value chain. This ERG will be empowered to make recommendations to management for assistive devices, barrier-free accessibility of PwDs to workplaces and workstations, on a case-to-case basis for a particular location, depending on PwD persons actually engaged by the Company there and specific type of disability. The management would in all earnest allocate the needed financial and other resources towards effective and timely implementation of these ERG’s recommendations on this subject of assistive devices and barrier-free accessibility with help of facilities & administration team.
Key considerations for barrier-free movement would include physical features such as design (like suitable contrast), construction, fixtures (like clear signages), fittings, furnishings, materials, equipment (like wheelchairs), and other such facilities or amenities.
Digital accessibility will also be pursed so that PwD persons are able to access internal and external digital tools, technologies and content relevant to their job roles and responsibilities.
Illustrative examples: Wheelchair ramps, accessible restrooms, height adjustable desks, tactile paving, accessible elevators etc.
In compliance with Section 22 of The Rights of Persons with Disabilities Act, 2016, the Company shall maintain records of persons with disabilities in relation to their employment, facilities provided, and other necessary information as may be prescribed by law. These records shall be open to inspection by authorized persons.
To ensure effective implementation of this policy and compliance with applicable laws, the Company has established a unified grievance redressal mechanism.
The Company has appointed Liaison officer under this Policy. This officer shall also function as the “Complaint Officer” for the purposes of The Transgender Persons (Protection of Rights) Act, 2019, and The HIV and AIDS (Prevention and Control) Act, 2017.
Any employee or applicant who believes they have been subjected to discrimination or denied any right or facility in violation of this policy or the law may file a written complaint with the Grievance Redressal Officer. The Officer shall:
If the aggrieved person is not satisfied with the action taken, they may approach the appropriate statutory bodies, such as the District-Level Committee on disability or the Ombudsman, as applicable.
The Company is putting in place enabling policies and efforts for staff sensitization and awareness generation on inclusion of PwDs, transgender persons, and persons affected by HIV and AIDS. E-Learning modules on this subject are being designed with help of external NGOs having expertise in serving these communities by Company’s L&D team. This is meant for all employees and managers, especially those without disabilities regarding disability-related issues to prevent discrimination. Beginning FY 2026-27, at least one session or training on the subject will be scheduled per year as part of the annual learning calendar. Sensitization sessions for employees by organizing NGO visits or interactions with PwDs are being undertaken over last couple of years and this would be continued in future as well. Training will also include HIV-related safe work practices where applicable and transgender inclusion awareness.