HR POLICY. This policy is applicable to all employees from different divisions of Net Access India Limited.

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1 Doc. No. NAIL/HR-03 Rev. State: Page(s) 1 Issued by: Signature: Angel Mary C Manager-HR Date Issued: 22 nd April 2016 Approved by: Signature: Natarajan C CTO & Business Head Date Approved: HR POLICY 1.0 OBJECTIVES 1.1 To provide clear guidelines for application of human resources functions and systems. 1.2 To maintain consistency and predictability in decision-making. 1.3 To ensure transparency and accountability in human resources management and development. 1.4 To promote adherence to the rules and regulations governing the company. 1.5 To maintain quality standards in the management of human resources. 1.6 To provide a basis for protecting the rights of the employee and the employer. 2.0 SCOPE This policy is applicable to all employees from different divisions of Net Access India Limited. 3.0 RESPONSIBILITIES 3.1 It is the responsibility of the respective HR Manager to ensure that guidelines stated herein are strictly adhered to by the employees. 3.2 It is the responsibility of the Line Managers to provide support for the HR manager to ensure adherence of the policy by their team members. 3.3 It is the responsibility and accountability of the Business Head to review and maintain this policy 4.0 REVISIONS Revisions will include two types of review: 4.1 Ad hoc or as needed

2 Doc. No. NAIL/HR-03 Rev. State: Page(s) These types of reviews are due to developments in case laws, changes in legislation, Collective Agreements, etc They may also result from practical problems with the application of existing policies. There could be ambiguity in a present policy or the reality that the application of the policy presents unforeseen problems. 5.0 OTHER 4.2 Planned reviews These reviews will be conducted every three years. These types of reviews can be staggered for the various policies and are done to ensure that the policies are still current and are still in harmony with the big picture. While we have strived for accuracy in the contents of this document, the information provided is superseded by applicable legislation and the Collective Agreement. 6.0 POLICY GUIDELINES Office Working Hours Working hours will depend upon your area of posting. Our office works from Monday through Saturday. Many of us come in the general shift, while some work in the Morning / Afternoon / Night shifts each employee will be intimated by immediate reporting authority (IRA) regarding the `shift in which he / she has to work. The normal working hours of our company is as follows: General Shift a.m. to 6.00 p.m. Morning Shift - 8 a.m. to 4.30 p.m / 7 a.m. to 3 p.m Evening Shift - 2 p.m. to 9.30 p.m Night Shift pm to 7 a.m. Reporting late to work Every employee should report on or before the scheduled duty time. Employees leaving late from office for a day should have taken the approval of his/her supervisor for arriving late on the next day. Employees who are reporting at work continuously late for three or more days without getting approval from IRA will face disciplinary action.

3 Doc. No. NAIL/HR-03 Rev. State: Page(s) 3 Monthly Saturday Off Net Access provides one Saturday off (1 st or 2 nd or 3 rd Saturday is permissible) during the month for employees on a rotation method without affecting the service. 1. Account manager / Project leader need to inform the team members of the Saturday off details and Saturday off rotation. 2. No mutual exchange on Saturday off among employees is permissible. Miscellaneous Net Access provides subsidized lunch for Senior Executive employees who work at the Dare House Complex at the Parry House Executive Dining Hall. i. Sr. Customer Support Engineer / Executive ii. Team Leader / Sr. Team Leader iii. Project Leader / Sr. Project Leader iv. Deputy Manager / Manager Net Access provides subsidized lunch for Non Executive employees who work at the Dare House Complex at the Parry House Non Executive Hall. i. Customer Support Engineer / Executive ii. Call Coordinator iii. Junior DBA iv. Software Programmer An employee working on a Sunday or on a company declared holiday should take prior approval from his / her immediate superior. In such cases the company will reimburse the food expenses as per norms in the travel policy. The immediate superior should maintain a record of his subordinates work activities during such days. An employee working (General Shift) late - i.e. beyond 9.00 pm for valid reasons can claim dinner expenses as per norms in the travel policy. Prior intimation and approval from immediate superior should be obtained, who in turn, should maintain a record of late night work of his subordinates. A list of Festival / Public holidays will be displayed on the notice board beginning of each calendar year.

4 Doc. No. NAIL/HR-03 Rev. State: Page(s) 4 Dress Code Guidelines

5 Doc. No. NAIL/HR-03 Rev. State: Page(s) 5 Procedure LEAVE POLICY Any employee availing of any leave of absence from the company should apply for leave in advance On line or at the available form with HR. Employees should confirm with their superiors whether their application for leave has been approved or not approved application does not imply an approval. The superior has to check the leave record of the employee and the customer requirement, project timelines etc before approving the leave application. Leave will be granted subject to duties of any individual and his leave availability. Leave Eligibility Employee may avail leave as follows: (A) Casual Leave (CL) - 7 days (B) Sick Leave (SL) - 7 days (C) Privilege Leave (PL) Or Annual Leave (AL) - 22 days Casual Leave (CL) For CL purposes employee should get the approval in advance from the Immediate Reporting Authority (IRA) In case of sudden emergency, employees can avail of casual leave, by intimating their immediate superior reason and duration of leave followed by submission of leave application. Sick Leave (SL) For SL purposes employee should get the approval from IRA on the same day of leave or with prior notice of one day in advance. In case of illness the employee should intimate over phone to IRA or to HR if the IRA is not reachable and to one of his colleague on the same day. Employee who avails more than 3 days SL should produce a medical certificate. In case leave is required due to prolonged illness or any other extreme cases, it will be left to the discretion of the management to sanction leave. Privilege Leave (PL) For Privilege Leave an employee has to apply at least four weeks in advance. PL can be availed for a minimum of 3 days against planned leaves. If employee needs to take more than 5 days of PL, should get the approval from IRA one month in advance. Employees will be eligible for Privilege Leave, only after completing one year service from the date of their appointment.

6 Doc. No. NAIL/HR-03 Rev. State: Page(s) 6 Any leaves availed by employees beyond the eligibility of CL and SL, will be treated as Loss of Pay (LOP). Continuous / repeated LOP will result in other disciplinary actions, including termination of service. Exceptional approval can be provided by the respective IRA s with concurrence from HR and Business Head for employees to avail PL leave in case of any emergency, as per the PL norms. While applying for leave, an employee should either prefix or suffix it with declared holidays. For example, if an employee applies for Privilege Leave from a Wednesday through Monday, the number of days on leave will be taken as six, not five (Sunday will be included as an availed leave ). Casual leave (CL) and Sick leave (SL) will lapse after the calendar year (January to December). Employee must avail minimum 10 days of Privilege Leave (PL) in a calendar year, if not the leave will be lapsed. Privilege Leave (PL) will be carried forward to next calendar year with the maximum of 120 days up to the age limit of 50 years and with the maximum of 240 days beyond the age limit of 50 to retirement. Medical Insurance Coverage Net Access provides Group Medical Insurance Policy, For employee with more than 5 years at Net Access - Rs /- per annum For employee with less than 5 years at Net Access Rs /- per annum And Group Personal Accident Policy worth Rs. 3,00,000/- per annum for all employees from day one of joining Net Access. The Policy will be limited to the benefit of the employee only. Allowance & Transfer Benefits Allowance Employees working at corporate office are not eligible for onsite / lunch allowance. Employees whose site of work and residence are in same city will not be eligible for onsite allowance. The management may consider providing additional allowances for employees transferred to different cities. The amount of such allowance is left to the discretion of the management which shall be based on the place of domicile and place of transfer.

7 Doc. No. NAIL/HR-03 Rev. State: Page(s) 7 Transfer Benefits We believe that it is our responsibility to provide support to the employee and his/her family while on transfer. Shifting Expenses When shifting locations on transfer, shifting expenses is provided to all employees. This reimbursement can be claimed only on actual amounts paid for transportation of the personal effects and the packing, loading and unloading charges. However, the employee has to provide two competitive quotations from transporting companies, when making the claim. Mode of travel to place of transfer Travel ticket for family as per travel policy.. Training & Developments Company will provide basic training to the employee, as & where necessary and related to the job. Employee attending any Seminars / Conferences / Workshops within the city or outside the city should get prior approval from the immediate reporting authority (IRA) and the HR department. Travel & Expense Policy Overview A critical balance must be sought when requesting travel. Employee travel should be via the lowest cost alternative, consistent with good business practices. Neither luxury, nor sub-standard modes of transportation and accommodations should be used. Employee travel and the expenses associated with it will be authorized only in circumstances which are clearly consistent with the mission of the company. It will be the responsibility of each project manager to ensure that all employee travel meets this objective and that reimbursement made only for actual, reasonable business expenses in connection with authorized travel as defined in this document. In order to maintain control over expenditures, any expense submitted which does not comply with the guidelines of this procedure will not be reimbursed, unless accompanied by a valid exception by management. Expense reports must be submitted in a timely manner. All travel advances must be requested using the official company "Travel Advance Form available in HRM portal, fill-up and signed by the employee in the appropriate place and get the approval from the account manager. Subsequent to approval; travel advance may be released to the employee. Travel arrangements, including airfare, rental car, lodging and planning of meetings can be coordinated through the appropriate departmental support staff with the respective Account Manager approval. The cost allocation regarding air, car and hotel expenditures is valuable information. All reservations will be made through Admin Department if it is a planned travel. If it is an emergency travel the employee might make his / her own arrangement.

8 Doc. No. NAIL/HR-03 Rev. State: Page(s) 8 Implementation & Responsibility Managers Responsibility Managers should know current travel policy and inform their colleagues of company policy and procedures. Determine if the travel is really necessary to achieve goal. Accounts department is authorized to question any claim made by an employee and an employee is expected to provide the required information supporting his / her claim. Employee's Responsibility Notify Admin Department as early as possible of necessary travel arrangements. If you notify Admin Department of your travel plans seven (7) days or more in advance, your trip will, in most cases cost considerably less. Incur only expenses that are consistent with the business needs, and exercise care in determining appropriate expenditures Submit expense reports as outlined in the expense section on this policy, on a timely basis (within 3 days). Travel Authorization & Approval Upon determination that a trip is necessary, an official approval may be taken from the respective IRA over mail. Air Travel Air travel will be via the most direct and economical way, accommodating the comfort, needs and preferences of the employee. Use of "Non-Refundable" airfares is recommended. These fares are usually considerably less expensive than refundable un-restricted fares. Employees at Vice-President Level and above may fly business class for international flights. Employees below V.P. level should fly economy class for international flights. Business class travel is not permitted for domestic sectors. All employees will fly least expensive economy class. Employee choosing to use personal modes of travel between cities serviced by regularly scheduled airlines will be reimbursed based on least expensive airfare or actual expenses, whichever is less. Car Rental When a rental car is necessary, company authorized travel agencies cars should be utilized, if available. Employees can request either compact or intermediate size cars. Rentals for other types of cars are not permitted except with manager approval. Luxury, premium and specialty car rentals will be reimbursed only at the intermediate car rate.

9 Doc. No. NAIL/HR-03 Rev. State: Page(s) 9 Personal Auto Reimbursement When an employee uses his / her personal automobile on approved company business, the company will pay Rs 6.00 per km for car and Rs 3.00 per km for two wheeler. Company will also reimburse all actual auto fair and parking fees (with a receipt). Travel from employee's home to regular assigned work location is not a reimbursable expense. However, if the employee goes directly from home to a work assignment other than the regular work location, and the distance to the work assignment is greater than the distance to the regular work location, the employee can claim the expense. In order to receive reimbursement for mileage, the employee must complete an expense report specifying purpose of trip, start and finish odometer reading, point of origin, destination and time of trip. The employee assumes the responsibility for all parking and traffic fines. Lodging Accommodations must meet with standard policy accepted with reference to comfort, convenience and cost. Overnight accommodations have been set as an acceptable standard for all company employees. The employee is responsible for confirming that the rate being charged is also the rate listed on the travel itinerary. Any discrepancies should be reported immediately to the travel agency. All hotel reservations will be guaranteed to your personal credit card whenever the hotel insists on a credit card for confirmation. It is the employee's responsibility to cancel hotel reservations within the hotel cancellation policy time frame. Meals and Entertainment Actual, reasonable, and necessary costs for meals will be reimbursed. The employee should be guided by what he / she eats at home. Receipts are required for any meal in excess of Rs 70/-. Maximum ceiling Rs. 350/- per day For one meal: Breakfast - Rs.100/- per day (max) Lunch - Rs.125/- per day (max) Dinner - Rs.125/- per day (max) All claims to be supported with bills. If a claim is not supported with proper bill, then it has to go for higher approvals.

10 Doc. No. NAIL/HR-03 Rev. State: Page(s) 10 Customer Engagement expenses are reimbursable only with prior approval of Business Head, and must meet the following conditions: The employee's specific assignment requires the entertainment of the company's customers or potential customers, or others as appropriate. The entertainment expense is fully receipted (original receipts required) Expenses are authorized by the employee's manager The persons entertained, the place and the purpose of the entertainment must be clearly specified. Non-reimbursable expenses include, but are not limited to: Alcoholic beverages, airline club dues, rental car club membership fees, airline head seat rental, in-room movies, fines for traffic violations, insurance on life or personal property while traveling, purchase of clothing and/or other personal items, expenses for family, child, pet, home and property care while on a trip. Laundry Service Actual and reasonable laundry expenses will be reimbursed. Receipts must be provided. This applies only after the employee has been away from home for three (3) consecutive days, or if the trip has been unexpectedly extended Expense Reporting The following conditions apply when submitting expense reports: Actual and reasonable expenses are reimbursed in accordance with the provisions of this policy and procedure Employee must submit expense reports during the week after incurring the expenses, or upon returning to the office, whichever is sooner. Failure to submit expense reports within three (3) days will disqualify the employee from receiving reimbursement for expenses incurred while traveling on company business. Attach the following items in the expense report when submitting it for payment: An official mail approval on travel (for business purposes) from the respective IRA. Original or carbon copies of receipts for meal, lodging, air or auto transportation, and any other business expenses compared with our policy. Explanation of any deviation from policy, unauthorized vendors, lodging or transportation, and / or charges submitted "in lieu of" normal expenses. Along with the statement, any amount to be repaid to the company also needs to be settled. If the travel plan is cancelled or postponed the amount taken as advance against the said travel has to be settled immediately.

11 Doc. No. NAIL/HR-03 Rev. State: Page(s) 11 International Travel Expenses International travel expenses will be decided on case to case basis by HR and approved by the Business Head. LOCAL CONVEYANCE Local conveyance expenses incurred, will be reimbursed (on actual) to any employee for travel between two or more points within the city on official work Refer table below for travel mode and eligibility for various employee levels Prior to undertaking any official trip within the city, an employee has to obtain the permission or approval of his / her immediate superior Local conveyance has to be claimed from the company every month by submitting a Local Conveyance Claim form in HRM portal, which will be approved by the respective IRA latest, by 5 th of every month (for example, Local Conveyance for the month must be claimed by 5 th of the subsequent month). Travel to / from residence to office every day, will not be reckoned in the local conveyance reimbursement. Any deviation from these norms may result in rejection of claim unless otherwise approved by the IRA and the Business Head. LOCAL CONVEYANCE ELIGIBILITY Grade Travel Mode Rate per km CEO / CTO Own Car Rs.6.00 Taxi / Auto Actual, along with bills Managers, Dy. Manager, Sr. Project Leaders, Project Leader, Sr. Team Leader, Team Leader Own Car Rs 6.00 Two Wheeler Rs 3.00 Taxi / Auto Actual, along with bills Sr. Programmers, Sr. Customer Support Engineer / Executive, Programmers, Customer Support Engineer / Executive, Sales Executive, Support Staff Two Wheeler Rs 3.00 Auto / Bus Actual, along with bills

12 Doc. No. NAIL/HR-03 Rev. State: Page(s) 12 OUTSTATION EXPENSES Employees traveling on work, outside their city of residence are entitled for reimbursements of onsite allowance expenses as indicated in the table below Outstation travel of the employee has to have the prior approval & consent of the immediate superior An employee can claim outstation expenses in either of the two forms indicated o Per Diem Reimbursement that is, reimbursement for lodging based on a flat rate (Rs / day) - without any bills o On Actual Reimbursements here, the reimbursements will be on actuals, subject to production of bills for lodging as per policy. In either case, reimbursements for lodging are subject to a maximum, as indicated in the table below The eligibility regarding mode of travel in outstation centers will remain the same as in local travel. Boarding expenses can be claimed as per the norms mentioned above. Any deviation should have the approval of the Business Head, this approval / sanction has to be obtained by the employee prior to commencing the outstation travel. OUTSTATION TRAVEL REIMBURSEMENTS Grade Travel Mode Basis Allowable Limits Rs / Day Metros Major Cities Other Cities CEO / CTO Train I A/C Class / Flight Per Diem On Bills Managers, Dy. Manager, Sr. Project Leaders, Project Leader, Sr. Team Leader, Team Leader II Class A/C Train / III Class A/C Train / Luxury Bus Per Diem On Bills Sr. Programmers, Programmers, Sr. Customer Support Engineer / Executive, Customer Support Engineer / Executive, Sales Executives II Class Train / III Class A/C Train / Luxury Bus Per Diem On Bills

13 Doc. No. NAIL/HR-03 Rev. State: Page(s) 13 Mobile Policy Cut mobile spend by increasing efficiency The mobile phone is an integral part of everyday business life. Nowhere is this more evident than in smaller business. In the current economy, cost and time efficiencies are a primary concern for small business. Mobile usage policy The company will provide mobile phone for official purpose only. Do not use the mobile phone for making personal calls, other than for emergency purposes. Company encourages employees to use their own mobile instruments with company provided SIM card for official purpose. If required company may provide the mobile instrument and SIM card for senior management, Managers, Deputy Managers, Senior Project Leader, Project Leader, and Senior Team Leader. Company paid SIM will be provided to Team Leader, Senior Customer Support Engineer / Executive. Based on operational needs SIM will be provided to any engineer with the approval from IRA with reference to the classification mentioned below. Employees who are using personal phones for official purposes (those who are not provided with company owned SIM cards) may reimburse the charges incurred on approval of the IRA as per the policy of the company. We have classified our users into three different categories (A, B, C) with reimbursement amounts. A) Minimum usage Rs 150/- Per Month (Employees who provide their number for contact, and they make very few official calls) B) Medium usage Rs 250/- Per Month (Employees receive calls and make minimum outgoing official calls) C) Normal usage Rs 400/- Per Month (Employees receive calls and make outgoing official calls to vendor) Any value beyond the above mentioned limits has to be approved by the higher officials with proper justification.

14 Doc. No. NAIL/HR-03 Rev. State: Page(s) 14 Wireless Data Card may be provided for those who travel frequently for business and or those who work from home frequently on approval from the Business head. 7.0 REVISION HISTORY Revision No. Revision Date Author Revision Description 00 1 st June 2010 Sundar V Initial Issue 01 1 st November 2012 Sundar V Revision nd April 2016 Angel Mary C Revision