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1. Purpose
The purpose of this Diversity & Inclusion Policy (the “Policy”) is to provide guidelines to ensure that the companies of Teleperformance Group (the “Companies” or, individually, a “Company”) implement and enforce policies and procedures that effectuate their commitment to equal employment opportunities, nondiscrimination, diversity and inclusion, and, where applicable, affirmative action programs for all candidates and employees, as well as equal employment advancement opportunities for employees. In this regard, the Companies do not unlawfully discriminate and, in fact, welcome, integrate and value people from all backgrounds, including ethnicity, religion, gender, LGBTQIA (lesbian, gay, bisexual, transgender, queer or questioning, intersex and asexual or allied), national origin, citizenship, ancestry, age, disability, genetic information, family care status, social background, military caregiver status, veteran or military service or obligation, reserve status, national guard status, refugee status, or any other basis protected by applicable laws. It is the policy of each such Company to fully comply with applicable laws that prohibit discrimination.
2. Coverage
This Diversity & Inclusion Policy applies to candidates/applicants for employment, all employees of the Companies, and certain third parties that can be affected because of their relationship with the Companies. This Diversity & Inclusion Policy also addresses all of the Companies’ operations and every aspect of the employment relationship, including but not limited to personnel actions such as recruitment, selection procedures (such as hiring, work assignments, and shift selection), compensation decisions, employee development, training, performance evaluations, promotions, transfers, benefits, disciplinary action and Company social and recreational programs.
3. Definition
Discrimination, which can be direct or indirect, means any distinction between individuals because of their national origin, gender, marital status, pregnancy, physical appearance, name, state of health, disability, genetic characteristics, cultural traditions and customs, sexual orientation or identity, age, political opinions, trade union activities, belonging to an ethnic group, nation, or religion, or other characteristics or status. Direct discrimination occurs when one person is treated less favorably than another in a comparable situation on the grounds referred to above, and indirect discrimination may occur when taking an apparently neutral provision, criterion or practice would put persons having a particular religion, disability, age, sexual orientation, etc. at a disadvantage compared with other persons.
In the employment context, unlawful discrimination means that because of an applicant’s or employee’s protected status—meaning his or her ethnicity, religion, gender, sexual orientation, national origin, citizenship, ancestry, age, disability, genetic information, family care status, military caregiver status, veteran or military service or obligation, reserve status, national guard status, or any other basis protected by applicable laws—the applicant or employee is treated differently with respect to compensation, terms, conditions, or privileges of employment (for example, the applicant or employee is not hired or is terminated from employment), or the applicant or employee is limited, segregated or classified in any way that deprives or tends to deprive the applicant or employee of employment opportunities or otherwise adversely affects the status as an employee.
4. Procedures
The commitment of the Companies to diversity, inclusion and equal employment opportunities concerns all aspects of the employment relationship, including the following fields:
a. Recruitment & Hiring
Objective:
Ensure that methods for sourcing candidates for employment, and for deciding those candidates to whom an offer of employment will be extended, do not discriminate against people based on a protected status, and that they reflect this Diversity and Inclusion Policy and, where applicable, affirmative action programs.
Measures:
Each Company shall:
b. Training, Promotions & Career Advancement
Incorporate measures to ensure equal employment opportunities in employee promotions and career advancement, including employee training and development.
c. Anti-Harassment
Provide working conditions that are free of, and that prevent, any kind of unlawful harassment, including harassment because of ethnicity, religion, gender, sexual orientation/ LGBTQIA community, national origin, citizenship, ancestry, age, disability, genetic information, family care status, military caregiver status, veteran or military service or obligation, reserve status, national guard status, or any other basis protected by applicable laws, consistent with applicable law.
d. Remuneration
Promote equal pay and ensure that no worker is unlawfully discriminated against in terms of salary, benefits, incentives, or other forms of compensation or remuneration.
e. Work Conditions
Ensure that every employee is treated with respect and courtesy. Promote policies and work arrangements that benefit the Company as well as employees in terms of their family, personal and work time. Encourage efficiency in the use of work time, making effective measures and tools available in the Companies for this purpose.
Measures
5. Policy Training & Awareness
Incorporate measures to ensure that all Company staff and management are aware of the Company’s commitment to equal employment opportunities, nondiscrimination, diversity and inclusion, and where applicable, affirmative action programs.
6. Responsibilities
Managers: Not only must managers and supervisors conduct themselves in a manner consistent with this Policy, they are also responsible for establishing and maintaining a work environment free of unlawful discrimination and harassment. Managers must respond to any form of unlawful discrimination or harassment reported to them, or that they observe, in accordance with the Company policies, including by taking swift action designed to stop the conduct and reporting it to Human Resources Department management.
Human Resources: The Human Resources Department has the same responsibilities as all other employees relative to compliance with this Policy. At the same time, Human Resources Department personnel in the Companies have special responsibilities in preparing and implementing this Policy and any Company-specific policies, identifying and conducting/arranging for training on such policies, conducting thorough investigations of the complaints that are brought forward by management or any employee under such policies; and providing appropriate coaching and support for all parties involved in possible discrimination or harassment situations. In cases where an employee is not responsive to coaching relative to Company procedure and policy, the Human Resources Department is obligated to elevate the situation to appropriate leaders of the Company for immediate action.
Employees: Employees are responsible for reviewing, understanding, and asking any questions needed to clarify this Policy and any Company-specific equal employment opportunity policies or, where applicable, affirmative action programs; promoting a workplace free of unlawful discrimination and harassment by conducting themselves in a manner consistent with such policies; attending all required training on the subject matter of such policies; and immediately reporting any possible violation of such policies in accordance with the procedures set forth in their Company policies to their Human Resources Department or the CSR Committee at csr@teleperformance.com.