Covering equal employment opportunity for all, and equal opportunity for Persons with Disabilities under the Rights of Persons with Disabilities Act, 2016.
Document Owner: Human Resources Version: 1.0 Effective Date: 11 Aug 026
Applicable To: All employees, applicants, interns, contract staff and third parties acting on the Company's behalf Liaison Officer: [Name, Designation, Contact] Review Cycle: Annual, or upon regulatory change
1. Objective and Policy Statement
ShopSe Digital Finance (Newbazaar Technologies Pvt Ltd) is committed to building and sustaining a workplace where every individual is treated with fairness, dignity and respect, and where employment decisions are based solely on merit, competence and business need.
The Company does not discriminate against any employee or applicant on the grounds of religion, race, caste, sex, gender identity or expression, sexual orientation, disability, marital status, pregnancy, age, nationality, ethnic or social origin, or any other characteristic protected under applicable law, in any aspect of employment, including recruitment, compensation, benefits, training, promotion, transfer, or termination.
This Policy has two parts. Part A sets out the Company's general commitment to equal employment opportunity for all. Part B sets out the Company's specific obligations and commitments toward Persons with Disabilities (PwD), in compliance with the Rights of Persons with Disabilities Act, 2016 ("the RPwD Act") and the Rights of Persons with Disabilities Rules, 2017.
PART A: Equal Employment Opportunity
2. Scope
This Policy applies to all stages of the employment lifecycle at the Company, including:
Job advertisements, recruitment and selection
Compensation, benefits and performance evaluation
Training, learning and development opportunities
Promotions, transfers and succession planning
Workplace conduct, facilities and amenities
Disciplinary processes, grievance handling, and separation
It applies to all employees regardless of level or function, and to interns, consultants, contract and agency staff engaged by or working alongside the Company, as well as to candidates during the hiring process.
3. Grounds Protected Under This Policy
The Company will not discriminate against any person on the basis of:
Religion, caste, or community
Race, ethnicity, or national or social origin
Sex, gender identity or gender expression
Sexual orientation
Disability (physical, sensory, intellectual, psychosocial, or otherwise, as defined under applicable law)
Marital status, pregnancy, or family/caregiving responsibilities
Age (subject to any bona fide occupational requirements)
HIV status or other health condition, where not relevant to the ability to perform the role
Any other characteristic protected under applicable central or state law
4. Recruitment and Selection
Job descriptions and advertisements will be based on genuine job requirements and will avoid language that discourages any group from applying.
Selection will be based on qualifications, skills, experience and demonstrated potential relevant to the role.
Interview panels and hiring managers will be sensitised to unconscious bias and will avoid questions relating to marital status, family planning, religion, or other protected characteristics that are not relevant to the role.
The Company will make reasonable accommodations during the recruitment process for candidates with disabilities or other access needs, on request.
5. Fair Treatment in Employment
Compensation and benefits will be determined based on role, responsibility, experience and performance, applied consistently regardless of any protected characteristic.
Access to training, mentorship, high-visibility projects and promotion opportunities will be based on merit and business need, and will be equally available to all eligible employees.
The Company will take proactive steps to identify and remove structural barriers that may disproportionately disadvantage any group, including flexible work arrangements, accessible facilities, and inclusive policies for parental leave and caregiving.
6. Harassment and Victimisation
Discrimination, harassment, or victimisation of any employee on any protected ground, including sexual harassment, is strictly prohibited and will be addressed under this Policy and the Company's Prevention of Sexual Harassment (POSH) Policy and Code of Conduct, as applicable. Employees who raise concerns of discrimination in good faith will be protected from retaliation.
7. Reasonable Accommodation
The Company will provide reasonable accommodation to employees and candidates who require it on account of disability, pregnancy, medical condition, or religious observance, unless doing so would impose a disproportionate or undue burden on the Company. Requests for accommodation may be raised with the reporting manager, Human Resources, or, where applicable, the Liaison Officer described in Part B.
PART B: Equal Opportunity for Persons with Disabilities
This Part is issued in compliance with Section 21 of the Rights of Persons with Disabilities Act, 2016, which requires every establishment to formulate an Equal Opportunity Policy detailing the measures proposed to be taken by it to fulfil the obligations under the Act, and to register the policy with the Chief Commissioner or the State Commissioner for Persons with Disabilities, as applicable.
8. Definitions
Person with Disability means a person with long-term physical, mental, intellectual or sensory impairment which, in interaction with barriers, hinders full and effective participation in society equally with others, as defined under the RPwD Act, which recognises 21 specified disabilities, including but not limited to: blindness, low vision, leprosy cured persons, hearing impairment, locomotor disability, dwarfism, intellectual disability, mental illness, autism spectrum disorder, cerebral palsy, muscular dystrophy, chronic neurological conditions, specific learning disabilities, multiple sclerosis, speech and language disability, thalassemia, haemophilia, sickle cell disease, multiple disabilities, acid attack victims, and Parkinson's disease.
Benchmark Disability means a person with not less than 40% of a specified disability, as certified by a competent medical authority.
Reasonable Accommodation means necessary and appropriate modification or adjustment, without imposing a disproportionate or undue burden, to ensure persons with disabilities can enjoy or exercise their rights equally with others.
Barrier-free environment means an environment that enables persons with disabilities to live and work independently, and to participate fully in all aspects of life, without barriers of communication, physical access, or attitude.
9. Non-Discrimination Commitment
The Company will not discriminate against any person on the ground of disability in any matter relating to employment, including recruitment, promotion, or other related issues, and will:
Ensure that no promotion is denied to a person merely on the ground of disability.
Not dispense with, or reduce in rank, an employee who acquires a disability during service. Where an employee is unable to continue in the same post due to a disability acquired during service, the Company will, where feasible, adjust or shift the employee to another suitable post with the same pay scale and service benefits; and if no suitable post is available, the employee will be kept on a supernumerary post until a suitable post is available or the employee reaches superannuation, whichever is earlier, in accordance with Section 20 of the RPwD Act.
Provide appropriate training and skill development to employees with disabilities on par with other employees.
Ensure no employee with a disability is denied any benefit, including promotion, increment or transfer, solely on the ground of disability.
10. Posts Identified for Persons with Disabilities
[Insert list of posts/roles identified as suitable for persons with disabilities, mapped against relevant disability categories, in line with the Department of Empowerment of Persons with Disabilities' identification of posts, where applicable. This section should be reviewed and updated periodically in consultation with Human Resources.]
The Company will take proactive steps to source and hire qualified candidates with disabilities, including through partnerships with disability-focused placement agencies, NGOs, and job portals.
Recruitment advertisements, application forms, and assessment processes will be reviewed periodically to remove unnecessary barriers to candidates with disabilities.
Interview locations and formats will be made accessible on request, and candidates may request assistive devices, sign language interpretation, or additional time for assessments.
12. Barrier-Free Accessibility and Reasonable Accommodation
The Company is committed to progressively making its workplaces and digital platforms barrier-free, including:
Physical accessibility of office premises, including ramps, accessible washrooms, and accessible seating, to the extent feasible at each location.
Assistive devices and adaptive technology (e.g. screen readers, ergonomic equipment) provided based on individual need and role requirements.
Accessible formats for official communication, training material, and internal digital tools, where feasible.
Flexible work arrangements, modified schedules, or work-from-home options, where the role permits, to accommodate mobility, treatment, or therapy needs.
Sign language interpretation or captioning support for official meetings and training sessions, on request.
Employees may request reasonable accommodation through their reporting manager, Human Resources, or the Liaison Officer. Requests will be assessed promptly, in consultation with the employee, and implemented unless doing so would impose a disproportionate or undue burden on the Company, in which case the Company will discuss and document feasible alternatives with the employee.
13. Leave and Other Benefits
Employees with benchmark disabilities will be eligible for such additional leave for medical treatment, therapy, or rehabilitation as may be provided under the Company's leave policy, in addition to statutorily mandated leave.
Employees may request preference in transfer or posting, where feasible, having regard to caregiving responsibilities related to a family member's disability, consistent with Section 20(5) of the RPwD Act.
The Company will facilitate access to statutory benefits and government schemes available to persons with disabilities, where applicable.
14. Liaison Officer
In accordance with Section 21(3) of the RPwD Act, the Company has designated a Liaison Officer to look after the recruitment and matters relating to the welfare of employees with disabilities.
[Insert Liaison Officer's name, designation and contact details.]
The Liaison Officer will:
Serve as the primary point of contact for employees with disabilities and applicants seeking accommodation.
Coordinate reasonable accommodation requests across Facilities, IT, and Human Resources.
Maintain records of the number of employees with disabilities, categorised by type of disability, in accordance with the Act.
Liaise with government authorities, including the Office of the Chief Commissioner for Persons with Disabilities, as required.
Support awareness and sensitisation initiatives across the organisation.
15. Grievance Redressal
Any employee who believes they have been subjected to discrimination on the ground of disability, or whose request for reasonable accommodation has been denied, may raise the matter with the Liaison Officer or Human Resources. In accordance with Section 19 of the RPwD Act, the Company will:
Acknowledge the grievance and investigate the matter in a fair and timely manner, ordinarily within 15 working days.
Maintain confidentiality of the complainant's identity and the details of the grievance, to the extent possible.
Provide the complainant with the outcome of the investigation and any corrective action taken.
Where the employee is not satisfied with the internal resolution, inform them of their right to approach the District-level or State-level Grievance Redressal Officer/Commissioner for Persons with Disabilities under the Act.
16. Awareness and Sensitisation
The Company will conduct periodic sensitisation sessions for employees and managers on disability inclusion, unconscious bias, and appropriate workplace etiquette.
New joiners will be introduced to this Policy, the Liaison Officer, and the process for requesting accommodation, as part of onboarding.
Managers of employees with disabilities will receive guidance on inclusive people management practices.
17. Records and Reporting
The Company will maintain records of employees with disabilities (with their consent, and in compliance with applicable data protection requirements), accommodation requests and their resolution, and grievances raised under this Part. Where required under the Act, aggregate, non-identifying data will be reported to the appropriate government authority.
18. Registration of Policy
In accordance with Section 21(1) of the RPwD Act, this Policy will be registered with the Office of the Chief Commissioner for Persons with Disabilities (or the relevant State Commissioner, as applicable), and a copy will be made available to all employees and displayed at the Company's workplaces and on its intranet.
19. Roles and Responsibilities
Human Resources
Own and administer this Policy, including periodic review and updates.
Ensure hiring managers and interview panels are trained on fair and unbiased recruitment practices.
Coordinate with the Liaison Officer on accommodation requests and disability-related data.
People Managers
Apply this Policy consistently in all people decisions within their teams.
Escalate accommodation requests promptly and support their implementation.
Foster an inclusive team environment and address concerns raised by team members.
Employees
Treat colleagues, candidates and third parties with fairness and respect, consistent with this Policy.
Report any instance of discrimination or denial of reasonable accommodation through the channels described in this Policy.
20. Non-Retaliation
The Company strictly prohibits retaliation against any employee who raises a concern of discrimination in good faith, requests reasonable accommodation, or participates in the investigation of a grievance under this Policy. Any act of retaliation will itself be treated as misconduct and addressed through the Company's disciplinary process.
21. Policy Review
This Policy will be reviewed at least annually, and updated as necessary to reflect changes in applicable law, including the RPwD Act and Rules, and evolving best practice. The Company reserves the right to amend this Policy at any time, with changes communicated to all employees.
Disclaimer: This document is a policy template prepared for general guidance. It should be reviewed by qualified legal counsel and adapted to the Company's specific structure, employee strength and locations before adoption and registration, to ensure full compliance with the Rights of Persons with Disabilities Act, 2016, applicable state rules, and other equal opportunity legislation in force.