Modern Slavery and Human Trafficking Policy
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.
Phoenix TalentX Branding India is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We have a zero-tolerance approach to any form of modern slavery and human trafficking. We are committed to ensuring that modern slavery and human trafficking do not take place within our business or supply chain.
Phoenix TalentX Branding India:
Makes their staff aware of the risks of human trafficking and modern slavery
Acts appropriately when any such risk is detected within its supplier chain
Engages with business partners that follow and adhere to modern slavery guidelines
Observes and is keen to report suspicions of hidden worker exploitation to the appropriate authorities
Positively encourages and supports employees and contractors to report such exploitation which may be occurring within their communities.
Scope of this Policy
This policy applies to all people working for Phoenix TalentX Branding and its clients.
Responsibility for Implementation
The Founder of Phoenix TalentX Branding India has primary responsibility for the implementation of this policy.
Grievance Policy: employees, suppliers, customers, and/or competitors
Our grievance procedures are a means of dispute resolution that are used to address complaints by employees, suppliers, customers, and/or competitors.
Our intention is to hear and resolve complaints in a timely manner, before they result in litigation. We encourage all parties to view grievances as a positive force that facilitates the open discussion of issues.
Our Founder serves as the ombudsman to deal with problems as they develop. Peer review of employee concerns is another popular way to address grievances at Phoenix TalentX Branding. If negotiations fail we are open to working with an Arbitrator to resolve issues.
We define a "grievance" as a formal work-related complaint, issue, and/or objection made by an employee, supplier, customer, and/or competitor.
Filing a Grievance: Concerned parties can drop a mail with proofs of grievance at firstname.lastname@example.org
The grievance should include provision of the following information:
• Full name
• Name of person/organisation (if any)
• Contact details (phone/fax/email address)
• Description of the grievance in detail
• Evidence to support the grievance
It is our responsibility to:
Accept and thoroughly investigate all Grievance Complaints
Ensure that the grievance is resolved within 90 days, depending on the severity of each case.
Treat all parties fairly throughout the grievance process.
Adhere to the no-retaliation policy when employees file a complaint against management.
Organize mediation meetings with the appropriate parties.
Practice a high level of confidentiality throughout the grievance process.
Accept and investigate all appeals.
Ensure that the final decision is implemented.
Maintain accurate and comprehensive records of each grievance.
Making Diversity and Inclusion work for all of us:
Including people from diverse backgrounds is imperative for MSMEs like Phoenix TalentX Branding.
We leverage people with diverse sets of abilities, skills, experiences and cultural backgrounds and utilise their potential regardless of who they are at individual levels.
We aim to eliminate unlawful or unethical discrimination and treat everyone with respect and dignity regardless of their background or identity, or diverse abilities, thereby making Phoenix a safe and nurturing workplace.
Our five D&I pillars: diversity, equity, inclusion, belonging and fairness
Diversity: Everyone at Phoenix has a fair chance to contribute to decision-making
Equity: We are an equal opportunity employer
Inclusion: Everyone at Phoenix has a voice at the table
Belonging: Signifies the voice of everyone at Phoenix is heard
Fairness: No discrimination and harassment against anyone
We choose to make people from all communities a part of our growth story:
People with disabilities
Women in leadership
Any other category not listed above
Our internal grievance redressal system — The CEO Process — enables employees, vendors and service providers, contract employees, clients, retainers, consultants, trainees and interns to raise any grievance or complaint across various categories like sexual harassment, discrimination, health & safety, unfair employment practices, among others. Prevention of Sexual Harassment (PSH) at the workplace provides a strong framework of confidentiality, assurance and protection to all.
Anyone may report concerns to directly to the CEO. Even for complaints regarding sexual harassment, employees can also write to the same email id.
We do not tolerate unfair treatment and discrimination towards our employees due to a person’s age, race, color, religion, gender, gender identity, ethnicity, ancestry, disability, pregnancy, marital status, national origin, sexual orientation and identity, chronic illness and/or any other status.
Our D&I policy is meaningful as everyone is welcomed and accepted the way they are despite the differences.
Our Strong and Meaningful ESG Program
We have a vision to build environmental and societal influence.
Reaching our sustainability goals:
Establish environmental goals that can help reduce carbon footprint and eliminate unnecessary waste
Build a meaningful diversity program, enhance employee health and make lasting changes in your community
Build a strong governance foundation to enhance business ethics, increase stakeholder transparency and protect privacy
OUR ESG PRINCIPLE
We will conduct our business and operations in compliance with all environmental, social and labour laws (local and central), including those relating to human trafficking and child labour. We perform a preliminary ESG diligence on our partners, clients, vendors, suppliers, etc.
OUR ESG ROLES AND RESPONSIBILITIES
We shall conduct our business operations in compliance with applicable environmental, health and safety laws or policy issued by Government of India. We minimize environmental impacts of our physical operations and if need be partner with organizations to advance sustainable development.
For social, labor and working conditions
We are committed to conduct our business and operations in compliance with applicable social and labor laws and policies issued by Government of India. We extend economic opportunity in the communities where we live and work. We promote diversity, equity inclusion, belonging and fairness at work. We adress human rights-related risks proactively
We foster a culture of transparency and ethical behavior.
We have zero tolerance and maintain adequate procedures to prevent bribery & corruption.
We maintain effective leadership and management processes
We safeguard privacy and cybersecurity
Anti-Facilitation of Tax Evasion Statement
We have a zero tolerance policy to tax evasion and the facilitation of tax evasion and this policy is fully endorsed by our senior management. We are fully committed to complying with all legislation and applicable guidelines designed to prevent tax evasion and the facilitation of tax evasion in the jurisdictions in which we, our clients, our suppliers and our business partners operate.
Our internal ESG maturity assessment:
Our organization strategy has defined ESG-related elements
Taking action is recognized as a requirement to address ESG-related activities, risks and opportunities
ESG initiatives are viewed as an investment in the organization that can create value
We are a forward-looking organization on an ESG journey to develop sustainable strategies that align with our vision.
ANTI-MONEY LAUNDERING POLICY
POLICY STATEMENT AND PURPOSE
We are committed to complying fully with all applicable Anti-Money Laundering (“AML”) laws in the conduct of our businesses. We shall comply with all applicable anti-money laundering, anti-fraud and anti-corruption laws and we shall establish processes to check for and prevent any breaches of such laws”
Towards this objective, we must conduct business only with reputable customers who are involved in legitimate business activities and whose funds are derived from legitimate sources.
Appropriate measures must be set up to ensure that we do not, even inadvertently, accept forms of payment that are known or suspected to be means of laundering money. Our employees acknowledge that failing to detect customer relationships and transactions that place our Company or our client's brand at risk, could cause irreparable harm to our reputation, leading to significant financial loss and severe penalties under applicable law.
The purpose of this Anti-Money Laundering Policy (“AML Policy”) is to prevent any involvement by our Company in money laundering activity even where the involvement may be unintentional. It requires our officers, other employees and those who work with us to recognize questionable financial transactions, and to take steps to conduct appropriate additional due diligence. If any ‘Red Flag’, whether or not listed in this AML Policy is triggered, the employees need to promptly contact our Company’s Compliance Officer (as defined below) to facilitate any further due diligence or action that may be needed.
1. Our Company shall, from time to time, designate an employee of sufficient seniority, competence and independence as the Compliance Officer to ensure compliance with the provisions of this AML Policy (“Compliance Officer”). Ms Amandeep Kaur, CEO has been designated as the Compliance Officer of the Company. All reports, complaints, doubts or concerns in relation to this AML Policy shall be raised by the people to the Compliance Officer.
CONSEQUENCES OF VIOLATION OF THIS AML POLICY
In case of violations of the AML Policy, the Compliance Officer shall, after considering inputs, if any, from the Designated Director, have the discretion to do the following:
Penalties: The Compliance Officer shall, based on the investigation reports (if any) have the discretion to recommend appropriate disciplinary action, including suspension and termination of service, against such a defaulting Person.
Depending on the nature and scale of default of the AML Policy by the defaulting Person, the Compliance Officer may also recommend to the Board to commence civil and/or criminal proceedings against such a Designated Person in order to enforce remedies available to our Company under applicable laws.