Disability Policy


1.0 Purpose

Aqua Exchange understands that our commitment to inclusion begins from day one. We pledge to build a company culture where individuals with disabilities feel valued and have the support needed to reach their full potential. We will provide necessary accommodations, ensure our workplace is free from discrimination, and strive to comply with all disability laws and regulations. This policy demonstrates our unwavering belief that creating an inclusive environment for everyone fuels innovation and is vital to our company’s growth.

2.0 Policy Scope

Aqua Exchange values the contributions of individuals with disabilities and strives to create an inclusive working environment. This policy outlines our commitment to providing equal opportunities, support, and protection for:

2.1 All Potential Employees: Job applicants with disabilities will be considered based on their qualifications and will not face discrimination during the hiring process.

2.2 Our Growing Team: Whether you’re a full-time, part-time, temporary, or contract employee, an intern, or a trainee, you are protected by this policy if you have a disability. This includes anyone who acquires a disability during their time at Aqua Exchange.

2.3 Areas Covered: We aim to prevent discrimination and promote inclusion for employees with disabilities in all aspects of the workplace, including:

o Recruitment and Hiring

o Training and Professional Development

o Working Conditions and Work Environment

o Compensation and Benefits

o Opportunities for Advancement

o Our Commitment to Progress

We understand our resources evolve over time. Aqua Exchange pledges to regularly review and enhance this policy to ensure we create the most inclusive environment possible. Employee feedback is essential to achieving this goal.

3.0 Policy Details

3.1 Physical Infrastructure

Accessibility Goal: Aqua Exchange believes in creating a workspace where everyone can contribute. While our current resources may be limited, we aim to incorporate accessibility solutions whenever possible during facility updates or changes.

Open Communication: Employees facing accessibility challenges are encouraged to talk to their manager or contact Mrs. Sujatha Suri at sujathas@aquaexchange.com. Your feedback helps us prioritize modifications essential for creating a more inclusive environment.

3.2 Information and Communication Technology (ICT) 

Accessible Design: As we develop our websites, applications, and documents, we aim for accessibility for users of all abilities. Using best practices [like those in WCAG 2.1 or relevant standards] will serve as our blueprint. 

Support System: If you have difficulty accessing technology resources, contact the IT Helpdesk. We’ll collaborate with you to find solutions or workarounds. 

3.3 Reasonable Accommodations

Individualized Approach: Aqua Exchange will explore providing reasonable accommodations to qualified employees or job applicants with disabilities within our current capabilities. We are committed to creating equal opportunities. 

Examples: Currently, accommodations may include flexible scheduling, assistive technology requests, or modifications to training materials. As we grow, the types of accommodations we can offer will evolve as well. 

Requesting Accommodations: To discuss your needs, contact Mrs. Sujatha Suri at sujathas@aquaexchange.com. Confidentiality is a priority. 

3.4 Our Commitment to Growth 

We recognize that fostering a truly inclusive workplace is an ongoing process. As Aqua Exchange expands, we pledge to dedicate more resources to enhancing accessibility within the company. Your input and experiences are vital for guiding our progress in this area.

4.0 Related Policies

Section 21 of the Rights of Persons with Disabilities (RPwD) Act, 2016 is as under:

(1) Every establishment shall notify equal opportunity policy detailing measures proposed to be taken by it in pursuance of the provisions of this Chapter in the manner as may be prescribed by the Central Government.

(2) Every establishment shall register a copy of the said policy with the Chief Commissioner or the State Commissioner, as the case may be.

Rule 8 of the Rights of Persons with Disabilities (RPwD) Rules, 2017 further provides manner of publication of Equal Opportunity Policy, which are as under: –

(1) Every establishment shall publish equal opportunity policy for persons with disabilities.

(2) The establishment shall display the equal opportunity policy preferably on their website, failing which, at conspicuous places in their premises.

(3) The equal opportunity policy of a private establishment having twenty or more employees and the Government establishments shall inter alia, contain the following, namely: –
o Facility and amenity to be provided to the persons with disabilities to enable them to effectively discharge their duties in the establishment;

o List of posts identified suitable for persons with disabilities in the establishment;

o The manner of selection of persons with disabilities for various posts,

o Post-recruitment and pre-promotion training,

o Preference in transfer and posting,

o Special leave, preference in allotment of residential accommodation if any, and other facilities;

o Provisions for assistive devices, barrier-free accessibility and other provisions for persons with disabilities;

o Appointment of liaison officer by the establishment to look after the recruitment of persons with disabilities

Web Content Accessibility Guidelines (WCAG) 2.1 defines:

How to make Web content more accessible to people with disabilities. Accessibility involves a wide range of disabilities, including visual, auditory, physical, speech, cognitive, language, learning, and neurological disabilities. Although these guidelines cover a wide range of issues, they are not able to address the needs of people with all types, degrees, and combinations of disability. These guidelines also make Web content more usable by older individuals with changing abilities due to aging and often improve usability for users in general.

5.0 Definitions

“Person with disability” means a person with long-term physical, mental, intellectual or sensory impairment which, in interaction with barriers, hinders his/her full and effective participation in society equally with others.

“Person with benchmark disability” means a person with not less than forty percent of a specified disability where specified disability has not been defined in measurable terms. It also includes a person with disability where specified disability has been defined in measurable terms by a certifying authority.

“Specified disabilities” are the disability categories mentioned in the Schedule of the Act. There is also “any other category”, which allows the Central Government to add any other disability by issuing a notification.

The disability categories as mentioned in the schedule are:

Definitions as per The RPWD Act

o Locomotor disability
o Muscular Dystrophy
o Leprosy cured
o Dwarfism
o Cerebral Palsy
o Acid attack Victim
o Low vision
o Blindness
o Deafness
o Hard of Hearing
o Speech and Language disability
o Intellectual Disability
o Specific Learning Disability
o Autism Spectrum Disorder
o Mental illness
o Chronic Neurological Conditions
o Multiple sclerosis
o Parkinson’s disease
o Haemophilia
o Thalassemia
o Sickle Cell disease
o Multiple Disabilities
o Any other category (as may be notified by the Central Government.)

“High support” means an intensive support, physical, psychological and otherwise, which may be required by a person with benchmark disability for daily activities, to take independent and informed decision to access facilities and participating in all areas of life including education, employment, family and community life and treatment and therapy.

“Discrimination” in relation to disability, means any distinction, exclusion, restriction on the basis of disability which is the purpose or effect of impairing or nullifying the recognition, enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field and includes all forms of discrimination and denial of reasonable accommodation.

“Reasonable accommodation” means necessary and appropriate modification and adjustments, without imposing a disproportionate or undue burden in a particular case, to ensure persons with disabilities enjoy or exercise equal rights as others.

6.0 Procedures

6.1 Requesting Accommodations:

Who to Contact:

o Employees seeking reasonable accommodations should contact Mrs. Sujatha Suri, HR Manager, either via email sujathas@aquaexchange.com.
o Documentation: Medical documentation may be helpful to determine appropriate accommodations but is not always strictly required.
o Any information you supply related to your disability will be treated as confidential.

The Process:

Upon receiving a request, Mrs. Suri will schedule a meeting with you to discuss your specific needs and potential solutions.

Collaboration is key: You, Mrs. Suri, your manager (if needed), and relevant experts (e.g. workplace ergonomics specialist) will work together to develop an accommodation plan. Decisions on accommodations will usually be made within 10 business days or a reasonable timeframe, barring need for external guidance.

Confidentiality: Medical information and discussions about accommodations will be kept in a separate record from your personnel file.

Submission of Complaint: Employees should submit their complaint in writing to the designated Complaint Officer.

Investigation: The Complaint Officer will initiate a prompt and impartial investigation into the allegations. Confidentiality will be maintained to the extent possible.

Resolution: The Complaint Officer will work towards resolving the complaint in a fair and timely manner. Where a violation is found, appropriate corrective actions will be taken.

Review and Update: This policy will be reviewed periodically to ensure its effectiveness and compliance with any changes in legislation or organizational practices. Updates may be made as necessary to maintain a workplace that reflects the values of equality, respect, and inclusion.

6.2 Reporting Discrimination or Harassment:

Channels: Primarily, any incident should be reported directly to Sujatha Suri (HR Manager). If the situation makes this inappropriate, please contact Mr. Hema Sundar- Chief Operating Officer.

Investigation: Aqua Exchange takes any instances of discrimination or harassment based on disability seriously. All reports will be promptly and thoroughly investigated by management.

Protection: We strictly prohibit retaliation against individuals who report these concerns.

6.3 Appeals or Disputes

Decision Review: Should you disagree with a decision regarding accommodations, please initiate a review by speaking again with Mrs. Sujatha Suri. If desired, Reporting Manager can be brought into this discussion.

Resources: For more complex situations or those beyond Aqua Exchange’s control, Ms. Suri can help you locate external resources (e.g., relevant government agencies or advocacy groups).

6.4 Accessibility Concerns

Physical Building Issues: Report issues with facility access (e.g., parking, doorway width) to the Facility Manager.

Technological Challenges: Contact the IT Helpdesk if you encounter website, software, or device problems impacting your ability to utilize technology at Aqua Exchange.

Additional Note: Aqua Exchange, with Ms. Suri’s guidance, will review and update our disability policy annually to ensure alignment with best practices and changing needs of our workforce.

7.0 Policy Owner

Aqua Exchange is a growing company with a big vision. We understand that inclusivity is essential to building a strong team capable of driving our future success. Our Disability Policy sets the foundation for our ongoing commitment to providing equal opportunities and support for employees with disabilities. As we expand, this policy will evolve to reflect the changing needs of our workforce.
Sujatha Suri, HR Manager, heads this evolving effort.

Contact Information:

Sujata Suri

HR Manager

9100927754

sujathas@aquaexchange.com