IMPETECH GROUP                                                              

1. Purpose

The purpose of this Code is to establish the standards of business ethics and conduct expected of everyone who carries out work for or on behalf of Impetech Group India.

1.1. Application

The Code applies to all Employees and Service Providers of Impetech Group who should acknowledge that they have read, understood and agree to abide by the Code by signing and returning the attached declaration. The signed declaration needs to be returned to the Director - Human Resources by the Employees and annually thereafter. By Service Providers, the declaration needs to be returned to the Director submission or by signing the certificate of compliance by the Service Providers on a contract execution, as applicable.

1.2. Definitions

 

2. Introduction

2.1. Endorsement - Chief Executive

 

Impetech Group core values of Teamwork, Ownership, Pioneering Spirit and Respect for people underpins everything we do as a Company and Impetech Group demands and maintains the highest ethical standards in carrying out its business activities. This Code is a cornerstone of Company policy worldwide. It expresses the principles of our business ethics and is intended to assist all Employees and Service Providers in meeting the high standards of personal and professional integrity required of them. Strict adherence to the provisions of this Code is a condition of employment and compliance with this Code is a requirement from the Service Providers.

2.2. Explanation and scope

Impetech Group vision of pioneering energy, enriching lives is reflected in our values which encompass Teamwork, Respect, Ownership and Pioneering Spirit.

This Code of Business Ethics supports these values and applies to all aspects and operations of Impetech Group. Heads of Departments throughout Impetech Group, all Employees and Service Providers are responsible for ensuring consistent compliance with Company policies, procedures and standards within their areas of responsibility.

The Ethics Committee will ensure an independent review of the compliance with the Code within Impetech Group. The Audits will be conducted at appropriate intervals to evaluate the extent to which this Code is complied with and to identify control deficiencies so that they may be promptly corrected.

Non-compliance with the Code or non-compliance with the Company's policies, procedures and standards may result in disciplinary action being taken in accordance with Impetech Group disciplinary procedure. With respect to Service Providers, it will be up to their employing organization to take action in accordance with their own internal policies and procedures. Impetech Group expects such employing organization to take effective disciplinary action and will not continue to work with organisations that fail to do so.

If you need any advice, or have any questions on this Code, please speak to your Head of Department. Service Providers may contact any Ethics Counsellor should any further clarity be required.

2.3. Corporate policy

The Company observes both the letter and the spirit of the laws of India and of every country where it conducts business.

Employees and Service Providers should at no time be placed, or place themselves, in the position where they could be accused of illegal activity in the country in which they are operating or expose Impetech Group to criminal prosecution or otherwise as a result of their activities.

In any situation not governed by statute or explicit regulations, or where the law is ambiguous or conflicting, advice should be sought from the Director - Legal. Impetech Group, operating internationally, may encounter laws and customs applicable in one country that conflict with the law of another. Such Instances should be referred to the Director - Legal for advice.

3. Business Ethics and Practices

      3.1            Conflicts of interest

Business decisions should always be based on what is in the best interests of Impetech Group and not on personal considerations or relationships. Employees must avoid any actions or relationships which could conflict with, or appear to conflict with, the interests of Impetech Group. A conflict of interest would occur if a personal or business interest interferes with or influences an Employee's independent judgement and objectivity, or where an Employee uses his / her position within Impetech Group for personal gain.

A conflict of interest would also arise where an Employee, or his / her relatives or close friends, holds investments in, or a position or relationship with, a person or company that competes with or does business with Impetech Group. Employees should not enter into any joint venture, partnership or other business arrangement without the prior consent of one of the Ethics Counsellors. Employees must disclose all apparent or potential conflicts of interest to their line managers.

In situations other than those described above, while there is no objection to the employment of close relatives of Employees as such, inappropriate job relationships must be avoided. To that end, managers who have authority to engage Employees must not recruit relatives or close friends into their own department or location.

New members of the Board are required to declare to the Chairman of the Board any directorships of other companies and provide assurance that there will be no conflict of interest. Executive directors of Impetech Group should obtain permission from the Board of Directors of Impetech Group before joining the board of directors of another company.

      3.2            Bribery and corruption

Bribery is the offer, promise, giving, asking or acceptance of an advantage as an inducement for doing something improper in your work or in carrying out a public function. Corruption is the misuse of public office or a business position for private gain. Bribery of Public Officials or agents, whether public or private, is prohibited and individuals who engage in bribery face a real risk of imprisonment. Bribery of Public Officials or agents, whether public or private is prohibited under the Prevention of Corruption Act, 1988.

The UK Bribery Act ("UKBA") also prohibits company and its associated persons from offering, promising or giving any financial or other advantage to bring about the improper performance by another person of a relevant function or activity, to influence a Public Official in performance of his or her official functions with an intention to obtain or retain business or an advantage in the conduct of business. Further, receipt of bribe is also covered by the act and is an offence under it. The UKBA prohibits payment and receipt of bribes directly or indirectly through associated person.

The term “associated person(s)” above has the same meaning as the defined term “Service Provider(s)” used in this document.

"Facilitation Payments” are small or minor payments made to secure or speed up routine legal government actions. Facilitation Payments are bribes and prohibited under the UK Bribery Act.

We do not tolerate, permit, or engage in bribery, corruption, or improper payments of any kind in our business dealings with both Public Officials and the private sector. Employees and Service Providers must not give or receive bribes or other payments, gifts or inducements or other undue advantages (of whatever kind) to any person or persons, including Public Officials, Service Providers, or any Employees in violation of laws and the officials’ legal duties which are intended to influence a business decision or compromise independent judgement; nor must any Employees or Service Providers give money, hospitality or gifts in order to obtain business for the Company, nor receive money, gifts or inducements for having given Company business to an outside agency. Also, they must not use subcontracts, purchase orders, consulting agreements, etc., as means of channeling payments to Public Officials, to employees of business partners or to their relatives / business associates or others.

Bribery could expose the Company and / or its Employees to prosecution regardless of where such bribery took place in the world. We make no distinction between bribery and Facilitation Payments. Employees and Service Providers are therefore prohibited from making Facilitation Payments of any kind.

3.3 Gifts and hospitality

The Company's relations and dealings with Public Officials and Service Providers should at all times be such that the Company's integrity and its reputation would not be damaged if details of the relationship or dealings were to become public knowledge. It is the individual responsibility of each Employee and Service Provider to exercise good judgement so as to act in a manner that will reflect favourably upon the Company and the individual. Governments in some parts of the world may have strict legislation regarding gifts and entertainment. When dealing with Public Officials, Employees and Service Providers, on behalf of Impetech Group, should make sure that they are aware of the rules which apply in that country.

The Guidelines on Gifts and Entertainment Policy are applicable to Employees and Service Providers. From time to time Employees may be presented with gifts from other business organisations or they may present gifts to others including to the Public Officials. Any such gift that is offered, or is possibly offered, in the expectation of, or to solicit, favorable consideration of any nature must be refused and the fact of its having been offered reported immediately to the relevant Director, or, in absence of such, the line ExCo Director.

Employees must not accept money, loans, services, goods, entertainment, favours or any form of recompense from any supplier, contractor, sub-contractor, customer or competitor (or potential supplier, contractor, sub-contractor, etc.). Similarly Service Providers must not accept money, loans, services, goods, entertainment, favors or any form of recompense from any Employees.

However gifts which are of a ‘nominal value’ or hospitality which is of a ‘reasonable value’ may be

 Accepted/ given provided no ulterior motive can be attached to their provision and which have been approved by the relevant Director, or, in absence of such, the line ExCo Director. If in doubt you should consult your relevant Director, or, in absence of such, the line ExCo Director. The nominal and reasonable value is as defined under the Gifts and Entertainment Policy, please refer to the same for further information and detail.

Examples of key questions which should be considered by Employees/Service Providers while giving or accepting any gifts/hospitality are:

1. Does the action contravene local law or convention?
2. Does the action comply with the laws of India or those of the country of operations?
3. Could the action be damaging to the Company if it were publicly known?
4. Are any costs/payments, or equivalent, excessive in proportion to the benefits/services to be received?

If the proposed action of giving or accepting any gifts/hospitality appears to fail any one of these tests, it should not be progressed without upward reference and approval by the ExCo.

Compliance may sometimes confront an Employee with difficult decisions or uncertainty as to the proper course of action to adopt. In these circumstances, Employees should always refer the matter to the relevant Director, or, in absence of such, the line ExCo Director or any one of the Ethics Counsellors.

Failure to comply with the laws in this area could result in heavy penalties. Compliance with the Code is mandatory and violations will result in disciplinary action, including dismissal where warranted.

      3.4            Confidentiality and Insider Trading

During the course of work, an Employee may have access to confidential information about the Company, a supplier or customer. Information which Employees gain during the course of their employment should not be disclosed to anyone not employed by the Company, or to an Employee who does not require the information for his/her normal work activities.

If this information pertains to the Company or any other publicly traded company, is not generally available and would be likely to have an effect on a person's decision to invest or sell shares in that company then the disclosure of this information and any subsequent dealing could amount to insider trading. It is a criminal offence should you disclose insider information which results in dealing as well as a breach of your contract of employment. If in doubt, reference should be made to Impetech Group.

      3.5            Employee Contributions to Outside Organisations

An Employee may contribute lectures and articles to technical institutions and journals as long as he/she has appropriate approval from his/her manager and does not contravene the Confidentiality Section of the employee handbook or place himself/herself in a situation where

 There might be a conflict between his/her interests and the Company. Subject to these conditions, prior authorization from anyone of the ExCo members in writing and proper disclosure of sums received, and provided that the work is undertaken in his/her own time, an Employee may retain any payments for outside activities which may be connected with his/her position in the Company, or made possible by the knowledge and experience acquired in the Company's service.

        3.6          Donations, contributions and sponsorships

No donations, contributions or sponsorships can be made by the Company except where such a contribution is permitted by applicable law and has been authorised, as per the limit of such contribution, by ExCo and the Board of Directors of CIL. Such contributions must be declared in the Annual Report.

Whilst, as individuals, Employees have the right to participate in the political process, it should always be made clear that they do so in a personal capacity and are not in any way representing Impetech Group.

The donations and sponsorship payment policy establishes a policy framework for any donations and sponsorships, please refer to the same for details.

        3.7          Health, safety and the environment

We are committed to maintaining the health and safety of those working for us, to minimising our impact on the environment and to having a positive impact on the communities in which we operate. Impetech Group has Health, Safety and Environment (HSE), Security and Corporate Social Responsibility (CSR) Policies and Corporate Responsibility (CR) Guiding Principles which define Impetech Group commitments and approach to HSE, security and CSR. There is also a CR Management System which defines responsibilities and provides guidance on how these possible HSE, security and CSR impacts are identified, assessed and mitigated.

Employees should ensure that they understand the Company’s HSE, Security and CSR Policies and CR Guiding Principles and apply the Company CR Management System in their work activities in order to minimize potential health and safety, environmental, security and social impacts.

        3.8          Fair employment practice

We strive for a working environment where the opportunity exists for all individuals to play their full part in adding value to the business and to make the most of their potential. We are committed to diversity of our staff and fair employment practices. This includes providing a work place which is free of discrimination and harassment. Impetech Group will not tolerate harassment of Employees or any other form of discrimination prohibited by law, including sexual harassment. Employees must comply with Company policies on anti-harassment as may be implemented or amended from time to time.

4. Legal and Regulatory Compliance

        4.1          Regulatory Compliance

Our operations are subject to laws, rules and regulations in India as also the laws of the countries of our operations. It is the responsibility of all Employees to understand the laws applicable to their areas of operation and ensure compliance with the same. Employees having questions on how to proceed or on interpretation should consult with the Director - Legal.

        4.2          Agreements with Agents, Advisors or Consultants

Agreements with agents, advisors or consultants or other Service Providers should state clearly the services to be performed for the Company, the amount to be paid and all other relevant terms and conditions. All such agreements must be approved in advance by the Director - Legal in accordance with the Company's contracts and procurement policies and procedures and must reflect the value of the services rendered. All payments and transactions must be supported by documentary evidence.

        4.3          Import and export controls

In dealing with other countries, Employees should at all times comply with all applicable import and export controls and sanctions relating to those countries. Failure to adhere to such controls and sanctions can severely impact upon the Company and also those individuals involved. Potential penalties for non-compliance include the withdrawal of operating permits, the imposition of criminal and civil fines and imprisonment.

5. Financial Integrity and Asset Protection

        5.1          Public Disclosure

As a company whose shares are quoted on the National Stock Exchange and Bombay Stock Exchange, Impetech Group has a duty to disclose in a timely manner, accurate and complete information that is required to be so disclosed to enable investors to make informed market decisions. Public disclosures must only be made by designated office bearers of the Company. The Company has in place procedures, systems and controls to ensure that it complies with these obligations and these must be strictly adhered to. Any queries regarding disclosure should be addressed to the Company Secretary.

5.2 Financial Reporting

All funds, accounts, assets, receipts and disbursements must be properly recorded in the books and records of the Company in accordance with the Company's normal standards and procedures and in compliance with relevant legislation and regulatory requirements.

In particular:

• No funds or accounts must be established or maintained for purposes which are not fully and accurately reflected in the books and records of the Company.
• Funds and assets received or disbursed must be fully and accurately reflected in the books and records of the Company.
• No false or fictitious entries may be made or misleading reports pertaining to the Company or its operations or its financial affairs shall be issued.
• No action should be taken, directly or indirectly, to influence, coerce, manipulate or mislead anyone engaged in the performance of an audit or review of the financial statements of the Company. Authorised Employees must report all expenditures as above.

        5.3          Money Laundering

”Money laundering” refers to the conversion or transfer of property derived from a criminal offence for the purpose of concealing, or disguising, the illicit origin of that property. Impetech Group cannot be used as a vehicle for such money laundering activities.

Money laundering offences include: disclosing to the perpetrator of the offence information which may prejudice an investigation (“tipping off”); falsifying or failing to disclose relevant documents and failing to report a reasonably-held suspicion that money laundering has taken place.

All Employees have a duty to report any suspicions of money laundering to the Chief Financial officer.

        5.4          Protection of Company Assets

All Employees have a duty to ensure that Impetech Group assets are not misused or misappropriated. Assets include the physical property of the Company such as buildings, equipment, funds, accounts, technology, documents as well as less tangible assets such as intellectual property (patents, copyrights and trademarks) and Employee time. Employees also have a responsibility to safeguard the assets of third parties where those are entrusted to Employees of the Company.

6. Information Management

        6.1          Personal data

Employees need to be alert to the fact that business-held information can contain personal data. Personal data is subject to specific legislation governing how it can be kept, handled and processed particularly if the content of that data is deemed to be ”sensitive”. Reasonable safeguards should be in place to protect such data against loss, theft, unauthorised access or inappropriate use. Further detailed information can be found in Impetech Group Records Management Policy and Acceptable Systems of Use Policy and Procedure documents.

        6.2          Use and security of digital information

Increasingly, Impetech Group relies upon information which is stored and processed on digital systems and networks such information is critical to the operation of the business and is, accordingly, a valuable company asset. All Employees must ensure that data is accessed in accordance with current IT security policies and processes and that confidential information relating to the Company, its

Employees or customers is not downloaded or transmitted without appropriate authorisation.

Where an Employee identifies that data has been lost, misused, intercepted or otherwise misappropriated, this should be immediately reported to their line manager.

        6.3          Dealing with the media

Any communications with the press or media are restricted to the Company's Corporate Communications Department, ExCo and others as permitted by ExCo from time to time. All Employees who receive a direct enquiry from the press or media have a duty immediately to forward any such enquiries to the Corporate Communications Department.

7. Reporting misconduct

7.1 Introduction

This section deals with the reporting of suspicions or instances of misconduct and outlines Impetech Group commitments in terms of such reporting. Reference should also be made to the Company's HR and Grievance procedures.

        7.3          Impetech Group commitment

Impetech Group does not tolerate fraud and misconduct.

Impetech Group is committed to the prevention, detection, investigation, and reporting of all matters of misconduct covered in this Code. Wherever possible, steps will be taken by the Company to recover losses arising from such incidents and to take appropriate action against the perpetrators of such actions.

When investigating incidents or suspicions of fraud or misconduct, Impetech Group will operate an investigatory process which is fair and impartial and respects the rights of the individual. That process may involve the precautionary suspension of an individual who is under suspicion pending the outcome of the investigation. Where an allegation is proven, the matter will be dealt with in terms of the Company disciplinary procedures.

        7.4          Whistle Blower Policy

Impetech Group Whistle Blower Policy is designed to enable employees, consultants and contractors (“Individual“) to raise concerns internally at a sufficiently senior level and to disclose information which the Individual believes shows malpractice or wrongdoing which could affect the business or reputation of Impetech Group. Concerns are to be raised to any of the Ethics Counsellors, namely the Director – Legal, the Chief Internal Auditor and the Company Secretary of Impetech Group. Any individual has the right to approach the CEO of Impetech Group directly who has the right to refer the concern to the Ethics Counsellors or any other person. In the event that any of the Ethics Counsellors are the individual against whom the concern is raised, then the concern will be passed on to the CEO. For any concerns against the CEO of Impetech Group, the same will be passed on to the Chairman of the Board of Directors of Impetech Group, who will appoint an appropriate person to look into the concern.

All allegations which fall within the scope of fraud, financial malpractice, improper conduct or unethical behaviour, criminal activity, breach of company policy, health and safety and attempts to conceal any of these activities, will always be seriously considered and investigated. Reference should be made to Impetech Group Whistle Blower Policy.

      7.5            Confidentiality of information

Impetech Group and its professional advisors will treat all information received in relation to an allegation of suspected or actual fraud or misconduct in the strictest confidence. Details will not be disclosed to any other party unless there is a legitimate reason for doing so. Reference should be made to Impetech GroupWhistle Blower Policy.

      7.6            Prosecution and reporting to third parties

Any decision to refer a matter to the appropriate authorities for prosecution, or to report to the relevant regulatory or professional body, will be made in conjunction with legal counsel and other internal and external advisors on a case-by-case basis.

Acknowledgment and Understanding of Code of Business Ethics

I acknowledge reviewing and understanding the standards and policies contained in this Code of Business Ethics. I also understand that there may be additional policies or laws specific to my job. I further agree to comply with the Code of Business Ethics in addition to any additional policies or laws specific to my job.

If I have any questions concerning the meaning or application of the Code of Business Ethics, any of the Company policies, or the legal and regulatory requirements applicable to my job, I am aware that I can consult my head of department or the Human Resources Department or the Director- Legal or Company Secretary, with the belief that my questions or reports to these sources shall be maintained in confidence.

Further, I affirm the compliance of 'Code of Business Ethics' of Impetech Group.

 

Rashmi Mahajan

HR Manager

 

DRUG AND ALCOHOL POLICY

This Drug and Alcohol policy supports Impetech Group commitment to the health and wellbeing of its employees, consultants, contractors and service providers to maintain a safe and healthy environment at all Impetech Group work places. Impetech Group recognizes that alcohol and drug abuse can have a detrimental effect on everyone's work performance and behavior.

The objective of this policy is to prevent everyone at Impetech Group work places in India to others by the abuse of alcohol, illicit drugs or controlled substances.

The consumption of alcohol and consumption, possession, distribution, purchase, or sale of any illicit drug or any other controlled substance by any person while on Company premises and operational areas is strictly prohibited. Any violation of this Policy will be viewed severely and stringent action will be taken by Impetech Group.

This policy urges all the stakeholders to recognize and appreciate that consumption of drugs / alcohol in work places is also illegal.

This policy is applicable to all of Impetech Group employees, consultants, contractors and service providers at Impetech Group’ premises and workplaces in India and abroad.

 

Rashmi Mahajan

HR Manager

2D - 200 Layout
2D - 400 Furniture & Assosories
3D - 800 View

Rendering 1BHK 2500
Rendering 2BHK 3000
Rendering 3BHK 4000
Rendering 3BHK 4500

 

IMPETECH GROUP

 Purpose

The purpose of this policy is to prevent any of the workforce becoming a risk to themselves or others by the abuse of alcohol, illicit drugs or controlled substances.

1. Definitions

Term	Definition
Abuse	Incorrect, improper or harmful use of any substance in such a way as intentionally to modify mood, behaviour or performance. It does not include the appropriate use of therapeutic medication as directed by a doctor. It includes use which can be described as dependency, habituation or addiction.
Alcohol	The intoxicating agent in Beverage Alcohol, ethyl alcohol, or other low molecular weight alcohol including methyl and isopropyl.
Company	Cairn India Ltd, its subsidiaries and affiliates.
Company Business	It includes all business activities undertaken by individuals in the course of the company’s operations whether conducted on or off Company Premises for which the individual is compensated.
Company Premises	All land, property (including camps), vehicles, offices, buildings and any other faImpetechities that are owned, leased, operated or otherwise directly controlled by IMPETECH.
Controlled Substance	Any substance which may be used in the production or manufacture of narcotic drugs or psychotropic substances.
Dependence	A condition in which an individual has lost control over the use of substance in question. Even after realising negative effect, the person has an increased need to use it and is unable to stop despite attempts to cut down or quit.
Drug	Any chemical or biological substance (including alcohol) that has known mind or motor function altering effects on the human body - a general term for any substance, stimulating or depressing, that can ultimately be habituating or addictive. For purposes of this policy, drugs of concern are those that inhibit a worker’s ability to perform his or her job safely and productively.
Employee	ALL personnel working with or for Cairn – either in form of direct employees, direct consultants, third party consultants or direct contractors, people working for contractors and subcontractors.
Illicit Drug	Any drug or substance which is not legally obtainable and whose use, sale, possession, purchase or transfer is restricted or prohibited by law (e.g. street drugs such as marijuana and cocaine).
Impairment	The alteration of normal physical or mental function which results in diminished ability to perform assigned task in a safe and productive manner.
Narcotic drug	Narcotic drug means coca leaf, cannabis (hemp), opium, poppy straw and includes all manufactured drugs.

 

 

Term	Definition
Psychotropic substance	Any substance, natural or synthetic, or any natural material or any salt or preparation of such substance or material included in the list of psychotropic substances specified in the NDPS act, 1985.
Substance of abuse	This includes alcohol and illicit drugs. In addition, inappropriate use of prescription and “over the counter” medicines or other substances, may result in impairment to health, behaviour, judgment or job performance.

 

3. Procedure

To ensure compliance with the Drug and Alcohol Policy, the company will:

• Subject staff to testing and screening for drugs and alcohol abuse during pre-placement medical assessment for positions that are safety and environmentally sensitive; and during periodic and random medical examinations. Periodic Medical Examinations are done once in 3 years for employees less than 40 years of age and annually for employees who have completed 40 years of age.
• Carry out testing and / or screening for drugs and alcohol “For Cause” e.g.: post incident, substances found on site, suspected substance abuse, behaviour hazardous to personnel, operations or environment.
• Require that employees taking prescription drugs that are not recommended to be taken whilst driving a vehicle or operating machinery shall notify their supervisor.

Provide appropriate education, information, counselling and instruction necessary to have employees understand the workplace risks associated with the use and abuse of alcohol and drugs. The company may also faImpetechitate rehabilitation programs where appropriate. The company may provide reasonable assistance to a member of staff with an alcohol or drug abuse problem who is willing to co-operate in treatment for that problem.

• Require contractors to have a drug and alcohol policy in line with IMPETECH policy.

The company reserves the right at any time to inspect or search any of its own or contractor staff, any place or object on company premises to enforce this policy.

Non-compliance with the drug and alcohol policy will be viewed as a serious policy violation and disciplinary action will be taken which may lead to dismissal. Any other person violating this policy will be removed from company premises.

The contract and procurement department of the Company will include this policy as a part of contract documents for all contracts requiring man power services.

4. Responsibilities

The Managing Director and Chief Executive Officer will empower the Chief Operating Officer with the authority to implement this policy throughout the IMPETECH Group.

The Chief Operating Officer in turn will enforce the above policy through the Director HR and other Directors by divesting them with authority and resources to implement this policy.

The Human Resources department will communicate this policy to all employees and make it a part of the induction training for new employees. HR will also develop training for existing employees and supervisors who play a critical role in monitoring the implementation of this policy and assist departments in dealing with any case of non-compliance with this policy.

 

Managers are responsible for implementing this policy at all locations under their control.

Supervisors are responsible for initiating corrective action when they have reasonable cause to believe that an employee is not in compliance with the policy and to seek confidential and professional advice from the Medical Officer / Occupational Health Adviser to assess the likely safety risks of medication use reported by any employees.

Supervisors using contract personnel are required to ensure compliance with the provisions of this policy. Where practical, the agreement with the contractor should contain provisions mandating compliance with the terms of this policy. Supervisors with the assistance of the local Security Staff will implement search procedures.

All employees are personally responsible for complying with this policy for their own safety, the safety of others, and the protection of the Company’s image and interests. The staff should:

• Be familiar with the policy and ensure full compliance with the policy;
• Advise immediate supervisor if he/she is using medicines, which may have the potential to affect work performance;
• Seek help if he/she has problems related to alcohol or drug abuse;
• Advise management if he/she considers that a co-worker’s alcohol or drug abuse may be endangering the safety of other staff, contractors or the public;
• Cooperate with the responsible company personnel while conducting random medical checks for drug and/or alcohol abuse.

It is every employee’s responsibility to be fit for work.

5. Searching and Testing

Searching

Searches may be conducted to monitor compliance with the policy; consideration will be given to unannounced searches for substances of abuse on company premises, particularly in health, safety and environmentally sensitive positions.

Testing

Alcohol Testing

The recommended testing method for alcohol use is the measurement of breath alcohol concentration. This non-invasive and relatively simple method will be used in all locations and operating conditions. The maximum allowable blood alcohol concentration will be 0.03% in a test by breath analyser. Confirmatory blood alcohol testing will be carried out in case of legal requirement.

Drug Testing

The testing for drugs will be carried out in urine or other body samples (Saliva, Hair). Chain of custody and analysis procedures will be ascertained to guarantee the sample and result validity and confidentiality.

Failure to report directly for a test, refusal to submit to a test, refusal to sign the required acknowledgment form (Appendix 6), refusal to agree to disclosure of a test result to management, or a confirmed attempt to tamper with a test sample are all considered violations of this policy and are grounds for disciplinary action up to and including permanent removal from the Company.

6. Reporting unfit for work due to the influence of alcohol or drugs

Managers, with advice from the medical officer, have the right to determine if an employee is unfit for work due to the influence of alcohol or drugs. Where a Manager on observing the employee, makes the judgement that the employee is unfit for work, the employee will be referred to the medical centre and on confirmation of alcohol or drug influence, suspended immediately from duty with pay. Depending on the circumstances, action may be initiated under the disciplinary procedure.

7. References

• Drug and Alcohol Policy. Doc. No. IMPETECH/HSE/09/000002
• The Narcotic Drugs and Psychotropic Substances Act 1985
• OGP Guidelines for managers on Substance Abuse: Report No. 6.87/306 June 2006

 

Appendix - 1 Health, Safety and Environmentally Sensitive Positions

Health, safety and environmentally sensitive positions are typically positions in which incorrect action of the incumbent, or failure to act, can be a significant factor in events causing, or leading to, unsafe acts, environmental damage or material losses.

Division	Operational Activity	HSE sensitive position
ALL	Planning and execution of work	All field or site supervisory staff that have responsibility for the planning and execution of work.
Exploration and Drilling; Production	Exploration – land marine	Drivers, Explosive handlers, all marine crew (Including catering staff), seismic crew
	Drilling – land - offshore	Drill and work-over crew, roustabouts, drivers and heavy plant operators, Crane drivers, ballast control room attendant electrician, divers, wire line crew, radio operator, catering staff, rig move crew, cementing crew
FaImpetechity operations (plants, depots, pipelines, terminals)	Operations	Panel operators, field operators, oil movement operators, operation schedulers
	Maintenance	Welders, electricians, scaffolders, artisans, fitters, mechanics, riggers, crane drivers, instrument technicians, material warehouse attendants,
	Laboratories	Laboratory technician
	Construction	Crane driver, scaffolders, heavy equipment operators
	Land transport, road /rail	Drivers, riggers, vehicle maintenance staff
	Water transport	All marine operations staff working offshore, quay side crane drivers, jetty crew, shore captain
	Air transport	Air traffic controllers, aircraft maintenance staff
	HSE department	Duty medical staff, firefighting crew
	Drivers	All jobs involving driving

Appendix - 2 Guidelines for alcohol testing

Cut-off levels for alcohol in breath corresponds with blood alcohol concentration of 0.03% (30 mg per 100 ml of blood) in line with Indian regulations.

Determination of breath alcohol concentration

Breath analysis should be performed with a breath analyser that has been calibrated, standardised and approved for confirmatory testing. Breath sampling and analysis should follow the instructions accompanying the test equipment.

Where initial breath alcohol analysis shows that the cut-off level for alcohol is exceeded, the procedure is as follows:

• Breath analysis will be repeated after half an hour to confirm that the alcohol concentration exceeds the cut-off level.
• Where blood alcohol analysis is requested, blood samples should be taken immediately following the second breath analysis.

 

Appendix - 3 Guidelines for drug testing

Drugs to be tested for and their cut-off levels

Drug testing programmes should address at least the six drugs listed below. Each drug is given a detection limit or cut-off level both for the immuno assay and the confirmation test. The cut of levels may change as advances in technology or other considerations warrant identification at other concentrations

Drug	Immuno Assay	Confirmation Test
Barbiturates	200 ng/ml	100 ng/ml
Benzodiazepines	300 ng/ml	100 ng/ml
Opiates	300 ng/ml	150 ng/ml
Amphetamines	1000 ng/ml	500 ng/ml
Cocaine	300 ng/ml	150 ng/ml
Cannabinoids	20 ng/ml	10 ng/ml
Other Drugs
Methadone	750 ng/ml	100 ng/ml
Propoxyphene	300 ng/ml	300 ng/ml
Methaqualone	750 ng/ml	100 ng/ml
Lysergides	0.5 ng/ml	0.1 ng/ml
Phenocyclidines	25 ng/ml	25 ng/ml

 

Techniques and procedures:

For drugs, urine is the body fluid most often tested because it can be readily obtained by non invasive means. Reliable discrimination between the presence and absence of specific drug or their metabolites in urine is critical, not only to achieve the goals of the testing Programme, but also to protect the rights of the individuals being tested. Drug test results must be as error free as possible and defensible in the event that they are challenged in a court of law. Thus it is imperative to meet the following conditions:

-     Rigorous chain of custody procedures for test samples.

-     Reliable high quality laboratory testing and testing techniques.

-     A scientific valid evaluation and interpretation of test results.

 

Appendix - 4 Progressive Effects of Alcohol

		Progressive Effects of Alcohol
BAC (%)		Behaviour		Impairment
	•	Average individual appears	•	Subtle effects that can be
0.01–0.029		normal		detected with special tests
	•	Mild euphoria
	•	Sense of well-being	•	Alertness
	•	Relaxation	•	Judgment
0.03–0.059	•	Talkativeness	•	Coordination
	•	Joyous	•	Concentration
	•	Decreased inhibition
			•	Reflexes
	•	Blunted Feelings	•	Reasoning
	•	Dis-inhibition	•	Depth Perception
0.06–0.10	•	Extroversion	•	Distance Acuity
	•	Impaired Sexual Pleasure	•	Peripheral Vision
			•	Glare Recovery
	•	Over-Expression	•	Reaction Time
	•	Emotional Swings	•	Gross Motor Control
0.11–0.20	•	Anger or Sadness	•	Staggering
	•	Boisterous	•	Slurred Speech
	•	Stupor	•	Severe Motor Impairment
	•	Loss of Understanding	•	Loss of Consciousness
0.21–0.29	•	Impaired Sensations	•	Memory Blackout
	•	Severe Depression	•	Bladder Function
	•	Unconsciousness	•	Breathing
0.30–0.39	•	Death Possible	•	Heart Rate
	•	Unconsciousness	•	Breathing
>0.40	•	Death	•	Heart Rate

 

Appendix - 5 Selection Criteria for Breath Alcohol Analyser Instrument

The criteria for selection of an evidential breath alcohol instrument are both analytical and procedural. The instrument must conform to certain scientific standards, but also faImpetechitate procedural issues, which include, but are not limited to, data management, instrument certification, repairs, training of operating staff, portability and ease of use by law enforcement.

The instrument shall have following specifications as minimum.

1. semi conductor type of sensor,
2. portable battery operated (dry cells or rechargeable cells),
3. digital display,
4. operating temperature between 5^o to 50^o C,
5. light weight (less than 500 gms).

Following features / accessories are desirable (optional).

1. Audio alarm or visual display of different colour if the concentration is higher than the ceiling.
2. FaImpetechity of in build printer or plug of external printer device to deliver a comprehensive test record.
3. Carry case.

 

Appendix - 6 Drug Testing Acknowledgment Form

I, ______________________________________ , understand that as part of the drug

Testing process for pre-employment, periodic medical examination and or random testing; Cairn will conduct a drug test to determine my suitability for the position in which I am applying or currently hold.

I understand that a NEGATIVE drug test result is a condition of employment. I understand that if I refuse to undergo the testing, or if I produce a Positive test result for illegal drug use and or alcholol, I may be rejected for employment or terminated from employment.

I understand that if I produce a positive test result for Illegal drug use that information can be made available by court order or as part of a confidential investigation relating to employment with a criminal justice agency.

I have read and understood the information contained in this "Acknowledgement Form". I agree to undergo drug testing as part of the employment process.

 

Signature of Donor:    Date: