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Written policies, procedures and standards of conduct |
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Ajuba maintains written policies and procedures that address issues of compliance risk in each area. The compliance committee periodically reviews the policies and procedures relating to billing, collections, data security, ethics, addressal of compliance issues, implementation of corrective action and retention of records |
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Designated Compliance Officer and Compliance Committee |
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Ajuba has a designated in-house Compliance Officer and a trained Compliance Committee whose members are drawn from various functions and departments to promote and ensure a fair, objective and structured focus on compliance within the company. The committee headed by the Compliance Officer is responsible for the following: |
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Analyzing the company's industry environment, legal requirements and specific risk areas |
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Developing policies and procedures (or reviewing existing ones, as appropriate) that address adherence to compliance |
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Developing a system to solicit, evaluate and respond to complaints and problems |
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Detection of potential violations such as through hotlines and other fraud reporting mechanisms |
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Monitoring, controlling and reporting all compliance related activities to the management team |
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Conducting effective training and education |
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Ajuba's training department and compliance committee is actively involved in creating compliance awareness and promoting compliance in the following ways
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New-hire compliance training programs |
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Periodical refresher courses |
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Designing innovative compliance aids such as desktop compliance cards |
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Special compliance sections in all in-house newsletters and journals |
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Email alerts on all updates, new guidelines and breaking news |
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Promotional activities such as online quizzes on the company intranet portal ‘Touch' |
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Poster campaigns across the company premises |
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Developing effective lines of communication |
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Ajuba has implemented a mechanism to report serious concerns about suspected or known violations of laws, regulations, policies, procedures, or our Standards of Conduct without fear of retaliation. Employees are encouraged to report any non compliance immediately using appropriate communication tools such as: |
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Internal and external Hotline |
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Intranet logging |
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Approaching a Compliance Committee member |
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Compliance Voice Mail Service |
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In keeping with Ajuba's policy on fair, objective and constructive reporting, employees can choose to remain anonymous while logging complaints or issues. All communication tools are available 24 hours a day 7 days a week. To preserve anonymity, calls are not recorded and cannot be traced. Based on the nature and scope of the issues logged, the compliance officer flags them in order of priority so that the necessary investigation and relevant corrective action can be taken in a speedy and effective manner. |
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Auditing and Monitoring compliance |
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Periodical audits are conducted in each of the compliance components and the audit results are analyzed for corrective action (if any). All audits are meticulously documented and reported by the Compliance Officer and Compliance Committee to the management team and to the company at large |
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Corrective Action Policies (C.A.P.) |
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Based on audit results, corrective action could be any one or a combination of the following - |
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Refresher training program with assessments |
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Review of policies and procedures |
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One to one coaching sessions |
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Counseling |
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Disciplinary action |
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Prevention and responding to detected offense |
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In case of compliance violations or detected offenses, the disciplinary action process would follow a 4 pronged approach: |
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Level 1 - Verbal warning
Level 2 - Written warning
Level 3 - Suspension
Level 4 - Termination of service |
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However the stages could be advanced or changed depending upon the magnitude and intensity of the compliance violation. |
