Company Policies

At Refteck, we aim to protect the rights of our employees as well as protecting the rights of our clients. There are various workplace policies and procedures in place establishing the rules of conduct within our organisation. This section highlights our commitment to integrity and our attitude towards important company issues.

Business Conduct & Compliances

Introduction

In furtherance of the principles of action, this code of business conduct is designed to set certain standards of conduct for all employees and officers of the Refteck Solutions as well as all customers/clients or its various entities such as representatives, agents and consultants. These rules do not cover every issue that may arise but set out basic principles to guide all employees and officers in carrying out their business duties. These rules are to be adapted, as the case may be, depending on local laws and regulations or should local codes of business conduct apply. However, if a local custom or policy conflicts with the code, the employee or officer must comply with the code. If any aspect of the code is unclear or is not precise enough, the employee should ask his/her supervisor as to how to handle the situation. Finally, because certain principles set out in the code are derived from legal and regulatory duties, failure to comply with certain aspects of the code could subject the offender to civil or even criminal liability.

Compliance with Laws and Regulations

Compliance with the law is the basic principle underlying the company’s policies. All employees and officers are expected to respect and comply with laws and regulations that apply to him/her. As a result of its presence in four countries throughout the world, the company’s operations are subject to the laws and regulations of these countries. Furthermore, the company has taken certain commitments at an international level in relation to compliance and promotion of guidelines such as the protection of human rights, freedom of association, elimination of forced labour, abolition of child labour, and elimination of discrimination in the field of labour and sustainable development. Although not all employees and officers are expected to be specialized in the various laws and regulations that apply to her/his business activities, it is important to know enough to determine when to seek advice from colleagues or third parties.

Refteck solutions will

  • Comply with all relevant laws and regulations of the jurisdictions where we do businesses, including international laws, and act in accordance with good integrity; and
  • Be aware of our corporate social responsibility, and perform fair and transparent business activities.
For Customers/Clients Execute appropriate agreement with our customers/clients and provide systems and services pursuant to the agreement; thoroughly manage customers/clients information in accordance with the agreement.
To Competitors Restrict ourselves from performing any acts that would impede market competition, including defamation, dumping, cartels, and other unfair/anti- competitive conducts, and perform fair and free competition.
To Suppliers Comply with relevant laws and regulations applicable to transactions with suppliers, and observe agreements with suppliers.
To Government Not provide any gift or hospitality against our policy or applicable laws, nor conduct any act that would be suspected of corruption; not involved in any bribery with government officials in any manner and in any jurisdictions.
To Society Actively undertake social contribution, such as volunteer or other community activities, to fulfil our responsibility as a good corporate citizen.

Anti Bribery and Corruption Policy

Refteck Solutions is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the company’s behalf is responsible for maintaining the company’s reputation and for conducting business honestly and professionally. The company considers that bribery and corruption has a detrimental impact on business by undermining good governance and distorting free markets. The company benefits from carrying out business in a transparent and ethical way. The company does not tolerate any form of bribery, whether direct or indirect, by or of its employees, officers, agents or consultants or any persons or companies acting for it or on its behalf. The board and senior management are committed toimplementing and enforcing effective systems to prevent and eliminate bribery, inaccordance with the set of Bribery Act. Employees and others acting for or on behalf of the company are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its anti-bribery measures, the company accepts transparent, proportionate, reasonable and bonafide hospitality and promotional expenditure, whether given or received. A breach of these policies by an employee will be treated as grounds for disciplinary action. Employees and other individuals acting for the company should note that bribery is a criminal offence that may result in imprisonment and/or an unlimited fine for the individual and an unlimited fine for the company. The company will not conduct business with customers, clients, service providers, agents or representatives that do not support appropriate anti bribery and corruption objectives.

Business Continuity Plan

The purpose of this plan is to provide a flexible response so that Admin, Logistic, and the Trading team can:
  • Respond to a disruptive incident (incident management).
  • Maintain delivery of critical activities/services during an incident (business continuity).
  • Return to ‘business as usual’ (resumption and recovery).

Plan Remit

The following services are covered by this Plan:
  • Admin team
  • Logistics team
  • Trading team
The following functions are covered by this Plan:
  • The provision of Administrative, Logistics, Trading team support to the service, wherever required.
  • Management of the Director’s diary, in terms of scheduling meetings etc.

Circumstances

This Plan will be activated in response to an incident causing significant disruption to normal service delivery/business, particularly the delivery of key/critical activities. Examples of circumstances triggering activation of this Plan include:
  • Loss of key staff or skills e.g. above normal levels of absenteeism due to illness.
  • Loss of critical systems e.g. ICT failure.
  • Denial of access, or damage to, facilities e.g. loss of a building through fire.
  • Loss of a key resource e.g. a major supplier vital to the delivery of a key service.
  • Natural calamities.

Responsibility For Activation

Role OFFICE
Chief Executive UK
Director UK
Business Manager INDIA

Process For Activation

Communication Actions

In the event of an incident and this plan being activated, the following people should be contacted. Nature of contact will depend on the incident type and time it has occurred. Contact Details
  1. Chief Executive
  2. Business Manager
The purpose of the business continuity phase of response is to ensure that critical activities are resumed as quickly as possible and/or continue to be delivered during the disruption. The Business Impact Analysis (BIA) for the Refteck sets out details of critical activities and the resources required to deliver them both in ‘business as usual’ and in crisis situations. Above mention teams will give the business continuity that is required.

Equal Employment Opportunity

This policy applies to all staff including contractors and covers all work-related functions and activities including external training courses sponsored by Refteck Solutions. It also applies for all recruitment, selection and promotion decisions. The objective of Refteck Solutions Equal Opportunity Policy is to improve business success by:
  • attracting and retaining the best possible employees
  • providing a safe, respectful and flexible work environment
  • delivering our services in a safe, respectful and reasonably flexible way

Discrimination, Sexual Harassment and Bullying

Refteck Solutions is committed to providing a workplace free from discrimination, sexual harassment and bullying. Behaviour that constitutes discrimination, sexual harassment or bullying will not be tolerated and will lead to action being taken, which may include dismissal. For the purposes of this policy, the following definitions apply: Discrimination: Direct discrimination occurs when someone is treated unfavourably because of a personal characteristic that is protected under set of Anti-harassment and bullying law.
Indirect Discrimination occurs when a rule seems neutral, but has a discriminatory impact on certain people. For example a minimum height requirement of 6 foot for a particular job might be applied equally to men and women, but would indirectly discriminate on the basis of sex, as women tend to be shorter than men.
Sexual harassment includes unwelcome conduct of a sexual nature in circumstances in which it could reasonably be expected to make a person feel offended, humiliated or intimidated reasonable person, having regard to all the circumstances, would have anticipated that the person harassed would be offended, humiliated or intimidated.
Workplace bullying may include behaviour that is directed toward an employee, or a group of employees, that creates a risk to health and safety e.g. physical and/or verbal abuse, excluding or isolating individuals; or giving impossible tasks. Refteck Solutions provides equal opportunity in employment to people without discrimination based on a personal characteristic protected under law and federal equal opportunity legislation. Under legislation it includes:
  • age
  • carer status
  • disability
  • employment activity
  • gender identity
  • industrial activity
  • lawful sexual activity
  • marital status
  • parental status
  • personal association with someone having any of these characteristics
  • physical features
  • political activity/belief
  • pregnancy
  • race
  • religious activity/belief
  • sexual orientation
So any employee found to have contravened this policy will be subject to disciplinary action, which may include dismissal. Employee must report any behaviour that constitutes sexual harassment, bullying or discrimination to their manager, head of HR department. He / She can complain directly or via mail. Employee will not be victimised or treated unfairly for raising an issue or making a complaint. Employee should feel confident that any complaint they make is to be treated as confidential as far as possible. If after investigation management finds the complaint is justified, management will discuss with the complainant the appropriate outcomes which may include: Disciplinary action to be taken against the perpetrator (counselling, warning or dismissal).
  • Staff training.
  • Additional training for the perpetrator or all staff, as appropriate.
  • Counselling for the Complainant.
  • An apology (The content of the apology to be agreed everyone who is involved).

Statement of Anti Slavery & Human Trafficking

Introduction

This policy sets out to understand all potential modern slavery and human trafficking risks related to business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in own business and its supply chains. Refteck Solutions maintains relationships with many different organisations in its supply chain, as well as directly employing number of people. In the light of the general law on employment and human rights and more specifically, the Modern Slavery Act 2015, our company is absolutely committed to preventing slavery and human trafficking in its corporate activities and ensuring that its supply chain is free from slavery and human trafficking.

Organisational Structure and Supply Chains

This policy covers all the activities of Refteck Solutions and its subsidiaries. It governs all our business dealings and the conduct of all people or organisations with whom we contract directly or who we appoint to act on our behalf. Same we expect all who have, or seek to have, a business relationship with Refteck and/or any member of our organisation, to familiarise themselves with our anti-slavery policy and to act at all times in a way which is consistent with our anti-slavery policy. Company currently operates in the following countries: United Kingdom, India, Canada, and USA.

Responsibility

The Management will liaise with other relevant departments such as the HR & Admin, Logistics and Trading teams to ensure that risk analysis and investigations/due diligence in relation to modern slavery and human trafficking is carried out as required. HR and the Training Department will ensure that employees are given adequate and regular training on the issue of modern slavery so that everyone understands and complies with this policy.

Relevant Policies and Practices

Refteck Solutions operates the following policies and practices that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. The company’s policy on DRD (Direct Report to Director) encourages all its workers, customers/clients and other business partners to report any concerns related to the direct activities of the organisation or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. This company’s policy procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can directly report to the director of the company by mail or meet directly. The nature of the complaint will determine the next course of action. We endeavour to carry out our own recruitment activities and/or to only use reputable employment agencies to source labour and we carry out appropriate background checks. Personnel responsible for the recruitment activities in any of the subsidiaries are advised to adhere to this policy by ensuring that strict verification of potential employee’s right to work is carried out before any offer of employment is made. Refteck Solutions expects its subsidiaries and all supply chain to adhere to recruitment practices that ensure that all terms of employment are voluntary. Where necessary and if required, we may request demonstration of compliance with this policy. This policy on modern slavery will be communicated to all suppliers, contractors and business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following Key Performance Indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains: Completion of House Audits by Area Managers and Business Development Managers; Use of labour monitoring and payroll systems; and Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

Breaches of this Policy

Any employees who breach this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Information & Technology

Internet Use

The internet, email id and Computer, Laptop are provided by Refteck Solutions for business use. Limited private use is permitted if the private use does not interfere with a person’s work and inappropriate sites are not accessed e.g. pornographic, gambling. Management has the right to access the system to check if private use is excessive or inappropriate. Failure to comply with these instructions is an offence and will be subject to appropriate investigation. In serious cases, the penalty for an offence, or repetition of an offence, may include dismissal. Staff needs to be aware that some forms of internet conduct may lead to criminal prosecution.

Email Use

  1. Email facilities are provided for formal business correspondence.
  2. Take care to maintain the confidentiality of sensitive information. If emails need to be preserved, they should be backed up and stored offsite.
  3. Limited private use of email is allowed if it doesn’t interfere with or distract from an employee’s work. However, management has the right to access incoming and outgoing email messages to check if an employee’s usage or involvement is excessive or inappropriate.
  4. Non-essential email, including personal messages, should be deleted regularly from the ‘Sent Items’, ‘Inbox’ and ‘Deleted Items’ folders to avoid congestion.
  5. All emails sent must include the approved business disclaimer.
To protect Refteck Solutions from the potential effects of the misuse and abuse of email, the following instructions are for all users:
  1. No material is to be sent as email that is defamatory, in breach of copyright or business confidentiality, or prejudicial to the good standing of Refteck Solutions in the community or to its relationship with staff, customers, suppliers and any other person or business with whom it has a relationship.
  2. Emails must not contain material that amounts to gossip about colleagues or that could be offensive, demeaning, persistently irritating, threatening and discriminatory, involves the harassment of others or concerns personal relationships.
  3. The email records of other persons are not to be accessed except by management (or persons authorised by management) ensuring compliance with this policy, or by authorised staff who have been requested to attend to a fault, upgrade or similar situation. Access in each case will be limited to the minimum needed for the task.
  4. When using email a person must not pretend to be another person or use another person’s computer without permission.
  5. Excessive private use, including mass mailing (“reply to all”) that are not part of the person’s duties, is not permitted.
  6. Failure to comply with these instructions is a performance improvement offence and will be investigated. In serious cases, the penalty for breach of policy, or repetition of an offence, may include dismissal.
This policy also applies to all employees, contractors and sub-contractors of Refteck Solutions who: Have an active profile on a social or business networking site such as LinkedIn, Facebook, Skype, MySpace, Bebo, Friendster or Twitter; write or maintain a personal or business’ blog; and/or post comments on public and/or private web-based forums or message boards or any other internet sites.

Computer / Laptop Use

Laptop Usage & Security

(i) All laptops acquired for or on behalf of the company shall be deemed company property. (ii) Each employee issued with a laptop is responsible for the security of that laptop & related accessories, regardless of whether the laptop is used in the office, at the employee’s place of residence, or in any other location such as a hotel, conference room, car or airport etc.

Laptops Out of Corporate Office

When an owner takes the laptop out of his/her office, he/she is expected to keep the laptop in hand or sight, or in a secure and locked location, at all times. It is the total responsibility of the owner to handle the laptop.
Installation of unauthorized / illegal software
(i) Employees are prohibited from installing unauthorized / illegal software on company provided laptops/computers. (ii) It is also recommended that use of the laptop/computer for personal requirements be kept to a minimum. (iii) The owner without the prior authorization of IT department shall not install any unauthorised software like messengers, chatting software or any malicious software, which may cause problems to the functioning of the laptop/computer. (iv) During the period, when the owner carries the laptop with them it should not be misused for the purpose of transferring data on to other storage devices. (v) If any co-worker was involved in any malpractice, he/she would be liable for disciplinary action from the organization. (vi) No external devices to be used to copy data from the laptop to transmit / transfer to other agencies while on work at their site unless it is absolute necessary.

Theft / Loss of Laptop or Computer

(i) In the event of theft, the employee will be required to lodge an FIR with the concerned police station where the theft happened. (ii) User will immediately inform Human Resources Department and approach IT department with a copy of FIR for further necessary action.

Termination of services

(i) The employee will be required to return the laptop to the IT department on termination of services with the Company. (ii) Failure to turn in the laptop may result in withholding payments such as Full & Final settlement until the laptop is returned. (iii) In the event of an employee absconding or any other unauthorized absenteeism, post availing the facility, the same will be deemed as offence and the Company will initiate legal action against such employee.