Our Code of Business Conduct states:

We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, intermediaries, donors, funding agencies, CSR partners, hospitals, doctors, patients and prospective patients or their families.

We will collectively ensure that all member of GF understand this policy through training, communication and by example.

What is a bribe?

Bribery is illegal. We cannot promise to make, pay or receive bribes.

A bribe is
(i) giving or promising to give, or,
(ii) requesting or accepting or agreeing to accept,
something of “value” to induce a person to act improperly in course of performance of his or her duties whether as an employee or in any other position.

By acting improperly, a person could make decisions that are influenced by the bribe.

The bribe may secure a grant, a donation, a contract, or benefit from that person or the organization; better payment terms or tax treatment; or it may expedite visas, permits or licenses.

The value may be financial or otherwise. It could be cash; it could be a gift, lavish hospitality or the benefit such as offer of job or work experience to a family member.

If the value were routed via a third party, it would still be a bribe.

How do you apply the policy?

The Trust does not allow any member of GF to receive or give any gifts or benefits from or to the people we deal with including but not limited to government officials, intermediaries, hospitals, doctors, patients and prospective patients or their families. The Trust seeks to ensure GF members are aware of the specific risks of bribery and corruption in their business and interactions with outside agency.

If any GF member encounters a situation of possible or actual bribery or corruption in any of the activities and interactions of GF, such member must immediately bring it to the notice of the Trustees.

Adviser Payment Policy:

GF does not engage middlemen, intermediaries, or other go-between type of people.

It is imperative that while acting for GF, the member knows with whom business is being conducted:: for example, what services are being offered; is the payment for such services appropriate; are you confident that none of that remuneration will be paid illegally to other parties – i.e., a corrupt payment or a bribe; is the party you are dealing with known to have a history of bribery or corruption?

GF members should be aware that this policy applies to any business relationship that has an inherently higher risk of bribery or corruption, including amount paid by families of children directly to hospitals. In the event, the Trust becomes aware of any illegal activity or malpractice, the Trust will take legal or other appropriate action.

Gifts and entertaining / hospitality:

The giving or receiving of gifts or hospitality could be deemed as bribery if (a) its timing is coincidental with an important decision involving the two parties; (b) it is of such a value that it could be perceived as influencing decision making; or (c) is so frequent that it could be perceived as influencing decision making. Gifts and entertaining are not prohibited by the Trust as long as they are not excessive either in value or volume and are not associated with a decision.

Adherence to Legislations:

We expect all persons we deal with to adhere to the Prevention of Corruption Act 1988, The Foreign Corrupt Practices Act 1977 and the UK Bribery Act 2010 in letter and spirit.

GF/2019

Genesis Foundation (GF) is a not for profit organization set up with a very simple thought that no child should die due to lack of funds for treatment.

GF facilitates medical treatment for critically ill under-privileged children suffering from serious life-threatening congenital heart disorders (CHD). The support required in CHD varies from specific surgeries (including neonatal), Cath Lab Interventions, along with recovery and recuperation post-surgery.

We Save Little Hearts

As on April 1, 2019, GF has supported medical treatment of over 2088 critically ill children. The children supported by the Foundation belong to families with an income of less than Rs 10,000 (USD 150 approximately) per month and the parents (or caregivers) are unable to afford treatment of these children.

100% of funds raised are used towards treatment of children as all overhead costs are borne by the founder trustees. GF is registered under Section 12-A and 80-G of the Income Tax Act, which entitles 50% tax exemption. GF is also registered under FCRA allowing it to receive foreign funds.

The following are the guiding principles for GF in all their interactions with all of its stakeholders including members of GF, government officials, donors, funding agencies, CSR partners, intermediaries, hospitals, doctors, patients and prospective patients or their families.

• We do not discriminate people based on race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability;
• We believe that a workplace should be safe and civilised; we do not tolerate sexual harassment, discrimination or offensive behaviour of any kind, which includes the persistent demeaning of individuals through words or actions, the display or distribution of offensive material, or the use or possession of weapons on our or client premises;
• We do not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol;
• We do not undertake activities which are intended or designed to mislead, including in relation to social, environmental and human rights issues;
• We will not consider potential donors, funding agencies, CSR partners, intermediaries, hospitals, doctors, or vendors who could damage the Trust’s reputation.
• We will not, for personal or family gain, directly or indirectly, engage in any activity which is detrimental to the interest of the Trust;
• We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, donors, funding agencies, CSR partners, intermediaries, hospitals, doctors, patients and prospective patients or their families. We will collectively ensure that all members of GF understand this policy through training, communication and by example;
• We will not offer any items of personal inducement to secure donors or funding or any other arrangements;
• We will not accept for our personal benefit goods or services of more than nominal value from any stakeholders, suppliers, potential suppliers;
• We will continue to strive to make a positive contribution to society and the environment by maintaining high standards of ethics; respecting human rights; respecting the environment; supporting community organisations; supporting development of all those we engage with; and managing significant corporate responsibility risks.

Any violation of these Guiding Principles should be reported immediately to the Trustees either through mail or in person. The Trust has an open- door policy for any complaints of whatsoever nature.

All sensitive situations will be treated confidentially and will be promptly investigated. No retaliatory behaviour against anyone making bona fide reports will be tolerated. If the result of the investigation indicates that corrective action is called for, such action may include disciplinary measures up to and including termination of GF’s relationship with the offender.

At Genesis Foundation. (“GF”) we are committed to creating a work environment in which all Associates can work together in an atmosphere that is open, engaging and free from sexual harassment. All persons interacting with Genesis Foundation, have the right to be treated with dignity. Sexual harassment is an offence and is, therefore, punishable. This policy sets out the way in which Genesis Foundation will prevent and deal with Sexual Harassment.

Guidelines below cover the following areas:

• 1. Scope and Applicability
• 2. Definitions
• 3. Complaints Committees
• 4. Grievance Procedures
• 5. Procedure for enquiry
• 6. Protection against Victimisation
• 7. Third Party Harassment
• 8. Deviations

1. Scope and applicability

This policy is applicable to all Associates of Genesis Foundation. For the purpose of this policy, the following people are deemed to be ‘Associates’:

• Those who are on the employment rolls of Genesis Foundation, including regular, temporary, part time or honorary Associates by whatever name called.
• This policy will also cover service providers engaged through third party.
• This Policy is applicable to all allegations of Sexual Harassment made by an Associate or Third Party, or against an Associate or Third Party, irrespective of whether Sexual Harassment is alleged to have taken place within or outside Genesis Foundation premises and within working hours or outside working hours
• There will be no exceptions to this policy

2. Definitions

a) “Sexual Harassment” - For the purpose of this policy "Sexual Harassment" shall include, but will not be confined to the following:

• i) Unwelcome sexual contact and advances, requests for sexual favours, and/or verbal or physical conduct of a sexual nature made, either explicitly or implicitly, in return for a term or condition of instruction, employment, participation or evaluation of a person’s engagement in any company activity;
• ii) Unwelcome sexual advances and/or verbal, non-verbal, or physical conduct such as loaded comments, remarks or jokes, letters, phone calls or through e-mail or any other communication mediums, gestures, showing of pornography and lurid stares;
• iii) contact or molestation, stalking, sounds or display of a derogatory nature, have the purpose or effect of interfering with an individual’s performance or of creating an intimidating, hostile or offensive environment; forcible physical touch or molestation;
• iv) Eve teasing, innuendos and taunts, physical confinement against one’s will and any other act likely to impinge upon one’s privacy;
• v) Any act or conduct by a person in authority and belonging to one sex which denies or would deny equal opportunity in pursuit of career development or otherwise making the environment at the workplace hostile or intimidating to a person belonging to the other / same sex;
• vi) Any such conduct committed by a third party or outsider in relation to an Associate of Genesis Foundation, or vice versa during the course of employment.

In addition to the above, Sexual Harassment shall also include the definition of Sexual Harassment given in the Sexual Harassment Act of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("Sexual Harassment Act") made effective on April 23, 2013

(b) Third Party” means any person or persons not on the rolls of Genesis Foundation but, in the course of work-related activities, interacting with Associates of Genesis Foundation.

(c) “Committee for the Prevention of Sexual Harassment” means a forum as defined in point 3 of this document

(d) “Appointing Authority” for the Complaints Committee will be the person responsible for “management, supervision and control” of Genesis Foundation.

3. Complaints Committee

As per The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("Sexual Harassment Act") made effective on April 23, 2013 by way of publication in the Gazette of India, the following shall constitute the Internal Complaints Committee (ICC)
(a) Internal Complaints Committee (ICC) (also referred to as “Committee” or “committee”) will consist of the following members to look into complaints of sexual harassments:
a.i. Presiding Officer of Committee (Female)
a.ii. Two Members of the Committee (from among the employees)
a.iii. One Member of an NGO

(b) Details of the Sexual Harassment Policy have been conspicuously displayed at the workplace through various medium:

• Display at Bulletin Boards across office
• Display at the home page of GENESIS-FOUNDATION.NET
• Post on GF Facebook page

Grievance and Enquiry Procedure

Prior to initiating an inquiry, the ICC may, at the written request of the Complainant take steps to settle the matter between the Complainant and the Respondent through conciliation. In case conciliation has not been opted for by the Complainant, terms of settlement have not been agreed upon or term of settlement have not been complied with, the IC shall, upon a written request from the Complainant to do so, conduct an inquiry into the complaint.

Any complaint of Sexual Harassment against an Associate or third party or vice versa, to be logged with any member of the Internal Complaints Committee (ICC). The Complainant should log their complaint with the ICC at the earliest possible and no later than 30 days from the date of occurrence of the alleged incident. The following process shall be followed for any complaints:

• The complaint may be made orally or in writing. If the complaint is made orally, the Complainant will be requested to confirm the complaint in writing and sign it.
• The Committee will meet with the Complainant, within 15 days of receipt of the complaint. They will inform the Complainant of this meeting date at the earliest.
• In case conciliation has not been opted for by the Complainant, terms of settlement have not been agreed upon or term of settlement have not been complied with, the committee shall, upon a written request from the Complainant to do so, conduct an inquiry into the complaint.
• The committee shall make an inquiry into the complaint in accordance with the principles of natural justice and shall notify in writing, the time and dates of its meetings to the Complainant and Respondent.
• At the first meeting with the committee, the Complainant will be heard and her/his statements will be recorded. The Complainant will be asked to produce any corroborative material that can substantiate the complaint.
• The committee shall have the right to terminate the inquiry proceedings or to give an ex-parte decision on the complaint, if the Complainant or Respondent fails to present themselves, for 3 (three) consecutive hearings, without sufficient cause. Such termination or ex-parte order shall not be passed without giving a notice in writing, 15 (fifteen) days in advance, to the Complainant or Respondent as the case maybe.
• The committee will provide the Accused with a copy of the statement of allegation made by the Complainant along with list of documents and names and addresses of witnesses submitted by the Complainant within a period of 7 working days from the date of the first meeting, and provide the Accused with an opportunity to submit a written response along with list of documents and names addresses of witnesses, should he/she so desire, within a period not exceeding 10 working days of receipt of the said statement and documents filed by the Complainant.
• The Complainant will be provided with a copy of the written response along with documents submitted by the Accused. If the Complainant wishes to provide any documentary evidence, she must supply true copies of those documents to the committee. Similarly, if the Accused wishes to tender any documentary evidence, he/she will be requested to provide true copies of those documents to the committee. To ensure that the documents are considered as true copies, parties will be required to sign the documents submitted.
• The committee will provide every reasonable opportunity to the Complainant and to the Accused to put forward, and defend their respective cases.
• The committee will complete the enquiry as soon as is reasonably possible, and communicate its findings and its recommendations for disciplinary action within 10 (ten days) of the completion of the enquiry, if any, to the Appointing Authority. Such report shall also be made available to Complainant and Respondent. The inquiry report shall specify details of the allegations against the Respondent, the statements made and evidence presented by the Complainant, Respondent and / or witnesses, Committee’s findings along with statement giving reasons for the findings arrived at by the committee and Committee’s recommendations.

6. Protection against Victimization:

Genesis Foundation has an obligation to ensure that a person who lodges a complaint in good faith and without malice is protected, and will not allow a person raising a concern to be victimized for doing so. In the unfortunate event where, despite the best of precautions, the Complainant would be victimized, Genesis Foundation will treat this as a serious matter and take disciplinary action against the perpetrator.

7. Third Party Harassment

Where Sexual Harassment occurs as a result of an act or omission by any Third Party or outsider, Genesis Foundation will take all steps necessary and reasonable to assist the affected Associate in terms of support and preventive action.

8. Deviations

Any deviations to this policy require approval from the Founding Trustees.

Annexure 1

Local Complaints Committee Members

Presiding Officer – Prema Sagar- Founder Trustee

NGO Member- Priti Chauhan of Aware Citizen Foundation

Location:Gurgaon

Committee Members

1. Prema Sagar

2. Jyoti Sagar

3. Dolly Malvai