1. PURPOSE
Apex Instruments Company Private Limited (Apex) as an organization is committed to ensuring environmental safeguards in all endeavors to diminish any form of environmental hazards by incorporating such technology which is necessary in the course of our business operation. Apex recognizes its social responsibility as a significant rationale of its organization and values its members who are the core of its optimal performance and express its pride for the prevalence of an efficient work culture. To this end, a plausible governance should inculcate within its ambit complicity with the laws, rules and regulations that are effective and in force. Therefore, with the right approach and policies, Apex strives towards a sustainable environment, safety and governance framework. The main purpose of the business is to conduct business operations in compliance with the applicable laws in the country in relation to environmental, occupational health and safety regulations.
2. SCOPE
This policy has been created in accordance with the provisions of “Environment Protection Act, 1986” and “The Companies Act, 2013” and the rules framed thereunder, to provide its members with a safe, environment friendly workplace along with fulfilling the responsibilities towards the society.
3. APPLICABILITY
This policy is applicable to all members, directors, officers, or other people working with and associated with Apex, either temporarily or permanently, working in all branches throughout the Indian territory (collectively referred to as ‘members’).
4. DEFINITIONS
4.1. Environmental factors: Environmental factors include usage of renewable and substantial energy, responsible hazardous waste management and pollution management, preventing natural capital depletion, natural resource conservation, climate change and reduction of greenhouse emissions and operating in a carbon-neutral manner;
4.2. Social: Societal criteria include business relationships, supporting gender, diversity and inclusivity, fair labor practices, health and safety, combating discrimination, and impact on local communities;
4.3. Governance: It includes ethics, and transparency in decision-making at the administrative and management levels. It further includes the proper escalation procedures, risk management, and remuneration policies in place;
4.4. CSR: It means and includes but is not limited to:- (i) Projects or programs relating to activities specified in Schedule VII to the Companies Act, 2013 and the rules framed thereunder; or (ii) Projects or programs relating to activities undertaken by the board of directors of a company (Board) in pursuance of recommendations of the CSR Committee of the Board as per declared CSR Policy of the company subject to the condition that such policy will cover subjects enumerated in Schedule VII of the Companies Act,2013. But does not include the activities undertaken in pursuance of normal course of business of a company;
4.5. Board: Board of directors of Apex;
4.6. Conflicts of interests: A situation in which an individual working for the Group has a competing professional or personal interest. This can include, but is not limited to, financial interests, related-party business undertakings, personal relationships, non-financial personal interests and affiliations for profit and not-for-profit organizations, or with political or professional organizations. Such competing interests can make it difficult for the individual to fulfil his or her responsibilities impartially;
4.7. Health: Includes both physical state and mental state of a member
5. FAIRNESS IN THE WORKPLACE
APEX understands that in the process of recruitment and retainership, it is crucial that the individuals feel secure and valued at the work space. Apex ensures fairness and transparency in all its decisions making with respect to recruitment of potential members and promotion of existing members. Departments embrace every skilled and diligent member in Apex on an equal footing regardless of their ethnicity, gender and/or any other personal ground. The entire management ought to be notably committed to conducting themselves with the utmost sincerity, fairness and morality in order to implement stringent policies for ensuring safeguards against any form of harassment and discrimination.
5.1. Fair treatment: Apex and its members strives to create a workplace that is free from discrimination in their employment practices against any potential or existing members and shall not discriminate based on a person’s age, color, ethnicity, race, religious background, physical features, political opinion, marital status, HIV status, gender identity or on any other basis. To give effect to this practice of fair employment, Apex has a transparent policy of recruitment, screening and promotion of its potential members, and its existing members along with a HR policy, which can be accessed in the website of Apex.
5.2. Member health and well-being: Apex believes in the principle of “Health is Wealth” and prioritizes the health and well-being of its members. Apex provides certain health-care benefits for its members which includes a health check-up twice a year. Apex also allows the members to approach the Compliance Officer to address their grievances regarding and/or related to their employment and/or experienced during their course of employment, if any.
5.3. Member ethics and code of conduct: Apex has a policy of intolerance towards any such act or omission by any member which can directly or indirectly result in distress which can be physical, mental or emotional in nature of another member. The members are mandatorily required to follow the Code of Conduct and act accordingly inside the premises of Apex and in any such place where the member is acting as a representative of Apex.
6. AVOIDING CONFLICTS OF INTERESTS
6.1. No member must aid in any such act or omission which can potentially create any such situation which can give rise to a conflict of interests which can put the interests of Apex at a disadvantage.
6.2. No member must use and/or share any information relating to Apex, including information of confidential and non-confidential nature or any proprietary information for any purpose save and except while acting in the capacity of a member of Apex in the premises of Apex and in any other place where the member represents Apex.
6.3. No member must directly or indirectly engage in a business and/or employment and/or any engagement full-time or part-time in nature, during their tenure at Apex.
6.4. If during the course of employment at Apex, any member acting well within his scope of work as a member of Apex, at any time is under the impressions that his act or omission might a risk of a conflict of interests which can result in the company being in a disadvantageous position, he/she must report the same to the Compliance Officer as prescribed by Apex.
6.5. The Chief Risk & Compliance Officer shall then ensure that the identified conflict is entered into the Conflicts Inventory and Register and ensure; furthermore, in collaboration with the respective line manager and/or business head, that proper steps are taken to manage any conflict or perceived conflict.
6.6. The Board(s) of APEX entities shall, on a bi-annual basis, evaluate the adequacy and effectiveness of the measures, internal control mechanism and mitigating arrangements in relations to conflicts of interest and shall take appropriate measures to address any deficiencies.
7. ENSURING CONFIDENTIALITY
7.1. At Apex, we are devoted to ensuring the privacy and confidentiality of the organization. We are also committed to maintaining the confidentiality of all members of our workforce.
7.2. The members at Apex would have to sign a non-disclosure agreement, or shall sign a non-disclosure clause, at the time of their joining as a process for undertaking that they would not disclose any of the information they come across during their tenure at Apex, with any other individual, except such disclosure is necessary for the performance of his duty as a member of Apex, functioning within his scope of work.
7.3. Apex undertakes to maintain absolute confidentiality regarding any information, sensitive or non-sensitive in nature disclosed to it by any member during his tenure at Apex, in confidence. However, Apex might require to disclose such information when the same is necessary for the smooth functioning of State machineries
8. INCIDENT MANAGEMENT
8.1. Unless otherwise covered under any policy of the company, Apex shall designate a Grievance Redressal Officer (GRO) for looking into any incidents and/or complaints and/or grievance of any member pertaining to his employment and/or association with Apex, which includes matters relating to employment, member welfare amongst other things
8.2. An employee facing any issue and/or has any compliant and/or grievance or any other incident concerning his employment and/or work environment, and/or healthcare incentives and/or other welfare schemes can file a complaint in writing before the Compliance Officer.
8.3. Apex shall further ensure that the complaint and/or the report of incident filed are dealt with in utmost confidentiality and that the details of the complainant are made available only on a ‘need-to-know’ basis and not otherwise.
8.4. The complaint and/or report of incident shall be dealt with strictly by the Compliance Officer and the matter shall be thoroughly inquired upon within 15 days of receipt of such complaint and/or receipt of such report.
8.5. The final decision in respect of the complaint and/or grievance and/or report filed shall be taken by the HR Department in confirmation with the management of Apex.
8.6. In case the HR Department is apprised of any event and/or action depicting violation or breach of the policies and rules of Apex, or any complaint is made against a fellow member and upon enquiry in the matter, the accusations are proved to be true and correct, the HR Department shall have the right to take disciplinary action against such member. Such disciplinary action may include i) warning; ii) Written apology from offender; iii) Costs; iv) Transfer; iv) Debarring from supervisory duties; iv) Denial of employee benefits like increments/promotion/salary correction; v) Cancellation of specific work assignment; suspension and/or vi) Dismissal, as may be decided by the HR Department depending on the nature and gravity of violation.
9. CORPORATE SOCIAL RESPONSIBILITY COMMITTEE
9.1. For conducting the CSR activities, Apex shall give preference to the local area and areas around the premise of Apex where it operates, for spending the amount earmarked for its Corporate Social Responsibility activities.
9.2. A Corporate Social Responsibility Committee (CSR Committee) shall be consisting of three or more directors, out of which at least one director shall be an independent director.
9.3. The CSR Committee shall formulate and recommend to the Board, an annual action plan in pursuance of its CSR policy, which shall include the following, namely:
a. the list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of The Companies Act, 2013;
b. the manner of execution of such projects or programmes;
c. the modalities of utilisation of funds and implementation schedules for the projects or programmes;
d. monitoring and reporting mechanism for the projects or programmes;
e. details of need and impact assessment, if any, for the projects undertaken by Apex
9.4. Surplus arising in the course of implementation of the CSR projects and related activities shall NOT form part of the business profit of Apex.
9.5. Apex will set apart a minimum of at least 2% of its average net profit made during the three immediately preceding financial years, in pursuance of its Corporate Social Responsibility Policy.
9.6. CSR expenditure shall include all expenditure including contribution to corpus, or on projects or programs relating to CSR activities approved by the Board on the recommendation of the CSR Committee, but does not include any expenditure on an item not in conformity or not in line with activities which fall within the purview of Schedule VII of the Companies Act, 2013.
9.7. CSR Projects will be monitored by the Head of the CSR Committee, as chosen by the CSR Committee members, through a result-based management approach with an appropriate oversight mechanism.
9.8. The head of the CSR Committee shall co-operate with the Finance Manager and shall monitor the specific activities, to be conducted relating to the list of CSR activities given in Schedule VII of the Companies Act and allot the budget for the same out of the total budget allotted for CSR activities.
Fund disbursement and allocation for the CSR events shall be done in a transparent and simple manner.
9.9. Apex shall include an annual report on CSR in the Board Report in such format in accordance with Section 135 of the Companies Act, 2013, read with the CSR Rules, 2014.
10. DISPLAY
10.1. Apex shall display this Policy on the Apex website as well as display the same conspicuously on the notice boards of each of its offices in English.
10.2. Each employee shall view and confirm to these policies upon joining and/or upon the same being enforced by Apex