📖 Preface

Pinnacle Blooms Network is not a conventional institution.
It is the world’s most purpose-driven child development ecosystem — built on 344 skills, 79 abilities, 19 million+ therapy sessions, and a scientifically validated, AI-empowered pathway toward self-sufficiency, school readiness, and mainstream inclusion for children with neurodevelopmental challenges.

Behind every AbilityScore® recorded.
Behind every session delivered.
Behind every parent interaction…

…stands a staff member trusted to carry the future of a child.

⚖️ WHY THIS CHARTER EXISTS

This Staff Conduct & HR Compliance Charter is the legal, procedural, operational, and ethical foundation that governs how every individual within Pinnacle must act, respond, record, behave, and lead — from entry-level therapist to national leadership.

It aligns with:

• 🏛 Indian Law & IPC Sections (406, 409, 354, etc.)
• 🌍 WHO and UNICEF codes on Child Safeguarding
• 🔬 Pinnacle’s proprietary innovations: AbilityScore®, TherapeuticAI®, TherapySphere®, …
• 📊 IPO-grade audit readiness for Bharath Healthcare P LIMITED
• 💙 Mother-built, child-first care architecture

🎯 WHAT THIS CHARTER ACHIEVES

• Codifies non-negotiable behaviors for every role
• Establishes escalation-ready processes for time, attendance, session integrity, ethics, dress, and data handling
• Creates a 5-Level Disciplinary Matrix for all violations (L1–L5)
• Launches a dedicated Conflict of Interest Governance System
• Ensures legal defensibility of all internal actions (memos, terminations, recoveries, etc.)
• Protects the Pinnacle promise to parents, partners, policymakers, and children

🧭 WHO THIS CHARTER APPLIES TO

For all: If you are part of Pinnacle — this applies to you.

📌 OUR LEGAL POSITION

This document shall be considered an official annexure to:

• Offer Letters
• Employment Agreements
• Center Operating Guidelines
• Ethics Compliance Audits
• Arbitration or Dispute Proceedings (internal or external)

Any breach of this charter is actionable under internal governance systems and applicable Indian law.

🔐 OUR ETHICAL STAND

You do not work for Pinnacle.
You stand with every mother who cried 912 days to hear “Amma”.
You serve not a brand — but a generation waiting to be heard.

📣 DECLARATION

At Pinnacle, conduct is not just about compliance.
It is about care, consistency, consequence, and courage.

This Charter will:

• Guide the right behavior
• Correct the wrong behavior
• Prevent risky behavior
• Enforce consequences where necessary
• Protect the dignity of children, families, staff, and the institution

📘 Section 1: Staff Code Of Conduct

Universal Charter for Every Staff Member Across Pinnacle Blooms Network

🔍 Purpose

To define, mandate, and enforce a unified standard of professional behavior, personal accountability, interpersonal respect, therapeutic precision, and administrative compliance across all employees of Pinnacle Blooms Network.

This Code applies across all roles — therapists, center staff, zonal heads, HR, call centers, support teams, vendors, and senior management.

⚖️ Legal Enforceability

• Treated as a legally binding addendum to every employee’s appointment contract
• Grounds for disciplinary memo, escalation, suspension, termination, or prosecution based on violation level
• A primary reference during audits, tribunals, or legal proceedings (internal or external)

📌 Core Behavioral Standards

1.1 Punctuality & Presence

• All staff must report to duty on time as per center schedules, shift assignments, or therapy calendars.
• Any delay exceeding 5 minutes must be pre-approved or justified immediately.
• Every unexcused delay = Level 2 disciplinary memo.

1.2 Biometric & Session Integrity

• Staff shall log in and out through the official biometric system — without exception.
• No backdated, pre-punched, or tampered-with entries allowed.
• Sessions must only be conducted with an assigned child + recorded in platform.
• Any session conducted without biometric or digital record = ghost session = ethical misconduct.

1.3 Therapy Accuracy & Documentation

• Every single therapy session must be conducted as per the TherapeuticAI session Plan Only. Session entries must reflect real therapy delivered. No copy-paste, delay, manipulation, or proxy entries allowed.
• AbilityScore® Refresh must be completed within 24 hours since pending.
• TherapeuticAI® Homework input must be completed within 5 minutes of the session.
• Inaccurate, pending, neglected, stalled, or delayed documentation = clinical negligence.

1.4 Dress & Appearance

• Uniform (if applicable) or formal professional dress code is mandatory.
• No chappals/slippers, faded t-shirts, flashy accessories, or improper grooming on the therapy floor.
• Every single violation = memo.

1.5 Language & Respect

• Language must always be respectful, non-judgmental, free of sarcasm, ridicule, threat, or frustration.
• Always address parents as “Sir / Madam” or regional equivalents like “Amma / Nanna” with dignity.

1.6 Confidentiality

• No staff shall discuss, display, forward, or share child data, session videos, parent phone numbers, or therapy reports on personal WhatsApp, email, social media, or any other unauthorized channel by all means.
• Violation = direct escalation to HR + Ethics Committee + IPC prosecution.

1.7 Mobile Phone & Device Policy

• No mobile usage allowed during therapy.
• Devices must remain on silent or airplane mode.
• Taking calls in session is grounds for memo unless it is emergency-approved.

1.8 Interpersonal Conduct

• Gossip, personal fights, toxic behavior, center-level favoritism, political conversations, religious bias, or caste-based talk is strictly prohibited.
• Interpersonal conflicts must be escalated to center head or HR — not left to fester on-floor.

1.9 Parent Handling Protocol

• Never promise, diagnose, or speculate.
• Never say:
  • “Your child is autistic”
  • “She won’t speak”
  • “We’ll cure him in 2 months”
• All feedback must be routed through AbilityScore Report, AbilityScore 7 Readiness Indexes Report, CT/DCT/center in-charge or designated therapist.

1.10 Financial Decorum

• No staff shall accept any gift, cash, donation, or informal payment from any parent or vendor — regardless of amount.
• Accepting a gift above ₹50 = Conflict of Interest = mandatory report.

🚨 Mandatory Conduct Declaration

Every staff member shall sign the following statement upon onboarding, and during annual compliance training:

“I acknowledge that I have read, understood, and accepted the Staff Code of Conduct. I understand that failure to comply may result in disciplinary action including warning, suspension, termination, or legal prosecution depending on the severity of violation.”

📊 Link to Disciplinary Matrix

Each clause above shall map directly to the 5-Level Disciplinary Action System in Section 7. For example:

• Violation of 1.2 (Biometric Tampering) = Level 4
• Violation of 1.6 (Data Breach) = Level 5
• Violation of 1.9 (Improper parent assurance) = Level 3 or 4 based on impact

All violations shall be processed via official memo, recorded in HRMS, and linked to the employee’s performance appraisal, promotion eligibility, and retention review.

🕰 Section 2: Time & Attendance Policy

Precision in Presence. Trust in Timelines. Excellence in Execution.

📖 Purpose

At Pinnacle Blooms Network, every minute counts — because every missed minute delays a child’s milestone.

This policy exists to:

• Enforce a scientific, shift-based, biometrically accountable system of staff presence
• Ensure therapy continuity, center discipline, and parental trust
• Maintain legal and procedural records for HR, audit, and escalation purposes

🔐 Coverage

• Therapists (Speech, OT, ABA, Behavioral, Special Educators)
• Admin Executives & Receptionists
• Center Heads & Zonal Leads
• Customer Care Executives
• Operations, HR, Finance Staff
• National or remote team members on virtual/rotational schedules

🧾 Definitions

🧭 Attendance Expectations by Role

🛑 Rules & Enforcement Clauses

2.1 Biometric is Mandatory

• Every employee must log in and out via biometric (or OTP log if remote)
• “Forgot to punch” is not valid. Repeat = misconduct.

2.2 No Proxy or Buddy Punching

• Logging in for another employee or colluding = Level 4 violation (Fraud)

2.3 Late Reporting

• Every instance of delay (> 5 mins) = L2 memo
• Three+ delays in a month = eligibility freeze for performance-linked incentives

2.4 Session Delay

• Therapists who arrive after child scheduled time will be penalized via:
• Memo + Session Recovery Instruction
• Alert to Zonal Team on missed therapy
• Parent apology protocol initiated

2.5 Early Exit without Closure

• Leaving without log-out, pending sessions, or therapy notes = L2 violation
• Includes walking out for personal reasons without approval in Pinnacle platform.
• Three+ early exits in a month = eligibility freeze for performance-linked incentives

2.6 Unapproved Leaves

• Unapproved leave tagged as Absent Without Authorization (AWA) attracts double deduction

📊 Attendance Review System (ARS)

Each center will maintain a monthly dashboard that flags:

• Top 5 punctual staff
• Top 5 delayed entries
• Repeat offenders with escalation tiers
• Biometric-device gap vs schedule discrepancy

This data will be:

• Shared with NCC, BEDC, Finance, HR, Leadership teams in real-time, refreshed every 2 seconds.
• Linked to appraisal and increment matrix
• Used to flag escalation to Ethics or Officer Relevant if falsification is suspected

🧮 Exceptions (Subject to Documentation)

All exceptions must be updated in Pinnacle within 24 hours or they become invalid.

📍 Escalation Flow

🖋 Declaration

“I understand that my time and presence are not just procedural — they are fundamental to a child’s developmental progress. I commit to full compliance with Pinnacle’s Time & Attendance Policy. I accept that violations may result in disciplinary or legal action.”

🧬 Section 3: Therapy Session Integrity Policy

Protecting the Science. Honoring the Child. Upholding the Brand.

📖 PURPOSE

At Pinnacle Blooms Network, therapy sessions are not just clinical appointments.

They are scientifically recorded interventions, directly feeding into:

• The child’s AbilityScore®
• The personalized therapy path via TherapeuticAI®
• The long-term developmental plan of over 344 skills and 79 abilities

This policy ensures accuracy, accountability, and audit-readiness of every therapy session — to uphold trust with parents, protect scientific integrity, and ensure ethical therapy delivery across 19 million+ sessions.

⚖ LEGAL FRAMEWORK

• Fully enforceable under Indian Evidence Act (as therapy logs are medical-legal records)
• Governed by The Rights of Persons with Disabilities Act, 2016
• Subject to Data Protection, Employment, and Clinical Ethics Laws
• Auditable under upcoming IPO-readiness protocols, MoWCD audits, and private investor diligence

🎯 SCOPE

• Speech, OT, ABA, Sensory Integration, Behavioral, and Special Education Therapists
• Zonal and Center-Level Therapy Leads
• Documentation, Reception & Therapy Admin Staff
• Customer Care and Feedback Analysts
• TherapeuticAI® Users and Intervention Designers

📌 NON-NEGOTIABLE THERAPY PROTOCOL STANDARDS

3.1 Session Validity

Any session not meeting these = INVALID SESSION = Audit Red Flag.

3.2 Forbidden Practices (Strictly Prohibited)

Each of these constitutes data tampering, ethical breach, and in some cases, child neglect.

3.3 Scientific Fidelity Requirements

• Therapy homework must accurately reflect:
  • Techniques therapied; skill categories addressed
  • Child’s response
  • Intervention attempted
  • Homework plan for parents, families
• Must be entered:
  • Within 5 minutes of session
  • In the assigned Pinnacle TherapeuticAI platform only
• Session time ≠ scheduled time:
  • 40-minute session must be 40 minutes active time
  • Anything < 50% duration = partial session

🧪 ABILITYSCORE® & THERAPEUTICAI® GUIDED

• Every session directly affects AbilityScore® trajectory
• Every session alters TherapeuticAI® recommendations
• Every session modifies parent trust and expectation

Falsifying a session breaks this ecosystem, risks a child’s future plan, and is treated as clinical-level fraud.

📊 THERAPY QUALITY INDEX (TQI) MONITORING

Zonal therapy auditors will randomly sample 5% of logs weekly for non-following of TherapeuticAI/session program, time mismatch, missing/wrong Fusion Module (Therapist Clinical Expertise 1* to 5* rating of the interventions in each program).

🚨 ESCALATION PROTOCOLS

🧾 SESSION INTEGRITY DECLARATION

“I understand that every therapy note I write becomes part of a child’s developmental map. I pledge that I will only log sessions that I have personally delivered, with full honesty, attention, and respect for the trust reposed in me by families and Pinnacle.”

🔐 AUDIT LINKAGE

• All session logs are linked to AbilityScore® changes
• All session logs are mapped to session videos (if enabled)
• All session logs are monitored for log-ins/out, time match, and parent feedback mismatch

📣 CLOSING STATEMENT

Every session entered without integrity is not a data error — it’s a betrayal of the child. It breaks a sacred contract between science, service, and soul. Pinnacle will treat it with the seriousness it deserves.

👔 Section 4: Appearance & Behavior Policy

Professional Dignity. Therapeutic Decorum. Culture of Confidence.

📖 Purpose

In a system like Pinnacle — built on trust, transparency, and therapeutic science — appearance and behavior are not cosmetic. They are clinical cues. They directly influence:

• Parent, Family confidence
• Child comfort
• Center discipline
• Pinnacle brand reputation

This policy ensures that every staff member — therapist or admin, junior or senior — embodies professional presence and behavioral clarity reflective of Pinnacle’s position as India’s most trusted and scientifically proven child development network.

⚖ Legal & Organizational Framework

• Labor contract codes
• Internal disciplinary governance protocols
• Rights of Children to Safe Environments Act (2021 Draft Provisions)
• Indian employment ethics and Center SOPs
• Brand usage and public-facing standards of Bharath Healthcare P LIMITED

👥 Applicability

• All center-based and teleconsultation staff
• Admins, therapists, call center agents
• Supervisors, zonal heads, and national teams when visiting centers or parents
• Public representatives of Pinnacle at schools, exhibitions, and campaigns

👗 Dress Code Policy

4.1 Therapist & Floor Staff

4.2 Admin & Front Desk

• Must wear formal Indian or Western attire; no slogans, political, or religious symbols
• Formal or business-casual footwear
• Hair & hygiene neat, presentable, and consistent with front-desk expectations

4.3 Call Center / Remote Staff

• Dress formally during Zoom/video calls with parents or school coordinators
• Background must be neutral, well-lit, and devoid of distractions or personal clutter

🔇 Verbal Etiquette Standards

4.4 Universal Speech Conduct

• Speak clearly, gently, and professionally
• No slang, regional taunts, or mimicking of child/parent behavior
• No excessive familiarity or inappropriate jokes in parent presence
• Use professional terms only (e.g., “session”, “therapy”, “support plan”)

4.5 Mandatory Phrases

• Address parents as “Sir”, “Madam”, “Amma”, or “Nanna” per preference
• Always thank the parent after each session
• “Do you have any feedback or need anything from us?” — must be asked every Wednesday

🧭 Behavioral Standards Within Centers

🚷 Prohibited Behavior

📊 Center Discipline Audit (CDA)

Each center’s Zonal Admin or Discipline Officer shall submit a monthly audit:

• Dress code compliance (random weekly check)
• Video call posture (call center or remote staff)
• Behavior-based parent feedback snippets
• Hygiene and grooming infra report (including fragrance-free zones)

This will be included in center grading and staff performance reviews.

📩 Parent-Facing Situations Policy

In any interaction — whether in person, on phone, or on video — staff must:

• Sit or stand with respectful posture
• Avoid interrupting the parent
• Smile gently, not forcefully
• Never offer a medical label or false hope
• End every interaction with a warm “Thank you for trusting us”

📜 Declaration to be Signed Onboarding & Annually

“I understand that my appearance, tone, and demeanor shape the way a child and parent experiences Pinnacle. I commit to conduct myself with full dignity, compassion, and professionalism every time I wear the Pinnacle ID.”

💬 Closing Statement

A child sees more than we say. A parent observes more than we intend. And in every moment — you are not just a staff member. You are the face of India’s most trusted child empowerment network. Dress like it. Speak like it. Be it.

📱 Section 5: Device, Internet & Communication Policy

Protecting Privacy. Enabling Precision. Enforcing Platform Discipline.

📖 Purpose

In a digital-first therapeutic environment like Pinnacle Blooms Network — where AbilityScore®, TherapeuticAI®, and session logs are driven by real-time data — personal devices, internet use, and communication must be governed with absolute integrity.

• ✅ Secure handling of sensitive child data
• ✅ Controlled use of digital communication tools
• ✅ Prevention of distraction during therapy
• ✅ Elimination of unauthorized media or content sharing
• ✅ Enforcement of IT and information security governance across all roles

⚖️ Legal & Organizational Coverage

• Indian Information Technology Act, 2000
• Indian Clinical Privacy & Data Protection Guidelines (MoHFW Draft)
• Internal Cyber & Communication Control Charter
• Evidence Act (as therapy logs and recordings are legally admissible)

👥 Who This Policy Applies To

📲 Device Usage Policy

5.1 Mobile Phones

5.2 Personal Laptops / Tablets

• Not permitted on therapy floors
• No offline bookkeeping, note-taking, or record keeping
• Personal devices cannot store therapy-related content

🌐 Internet & Platform Access

5.3 Approved Platforms

5.4 Prohibited Sites

• No external streaming platforms (Netflix, YouTube, Instagram) during shift
• No cryptocurrency, betting, or unethical sites from center IPs
• No downloading or storing pirated content, therapy tools, or games

💬 Communication Etiquette Policy

5.5 Internal Chat Groups (WhatsApp / Slack / Telegram)

5.6 Parent Communications

• All official updates through Pinnacle official handle
• WhatsApp only for session reminders, feedback, approved therapy coordination
• Never share PDFs, dashboard screenshots, photos/videos without SR authorization
• All messages must be professional, signed with name and designation

Example: “Thank you. Regards, Sangeetha – Occupational Therapist, Pinnacle Suchitra Center”

🔐 Information Security

5.7 Sensitive Data Protocols

• Child session videos, audio clips, screen shares are confidential assets
• Access to internal therapy reports restricted to assigned roles
• Device loss/theft reported within 1 hour to zonal IT & HR via SR
• No printing or downloading child records on personal drives

5.8 External Communication Control

• Media interviews, school visits, blog posts, public webinars pre-approved by National Care Center
• Speaking on behalf of Pinnacle without authorization = Level 4 violation

🧾 Device & Chat Violations Matrix

📊 Tech & Communication Compliance Audits

Monthly digital audits will verify:

• Unauthorized devices on floor (surprise inspection)
• Session log timestamp mismatches
• WhatsApp screenshot logs (HR-monitored groups)
• CRM usage vs phone follow-up gaps
• Response etiquette in call logs and email threads

🖋 Declaration of Compliance

“I understand that phones, devices, data, and messages are not casual tools — they are windows into a child’s therapy experience and Pinnacle’s credibility. I commit to full compliance with the Device, Internet & Communication Policy.”

📣 Closing Statement

Every message you send. Every session you log. Every phone call you make becomes part of a child’s record — and part of Pinnacle’s reputation. Act accordingly. Log responsibly. Communicate with care.

🔐 Section 6: Confidentiality & Data Handling Policy

Privacy Is a Right. Data Is a Responsibility. Protection Is the Pinnacle Standard.

📖 PURPOSE

Pinnacle Blooms Network handles the most sacred form of data — a child’s developmental reality. From session videos to parent discussions, from AbilityScore® records to therapy logs — every byte represents a family’s vulnerability, trust, and hope.

This policy governs the collection, usage, access, storage, transmission, and destruction of sensitive personal and therapy-related data across Pinnacle’s nationwide and global operations — and ensures full compliance with law, ethics, and scientific accountability.

⚖️ LEGAL & REGULATORY BASIS

• Information Technology (Reasonable Security Practices and Procedures) Rules, 2011 – India
• Personal Data Protection Bill – Draft (India, 2023)
• The Rights of Persons with Disabilities Act, 2016
• MoWCD Child Privacy Guidelines
• Pinnacle’s Global IP, Scientific & Clinical Governance Framework

🧠 SCOPE OF PROTECTION

📌 CORE POLICIES

6.1 Access Control

6.2 Storage & Transfer

• Therapy logs must be entered only into Pinnacle’s secure platform
• No offline records unless expressly authorized
• Any physical records must be stored in locked, access-controlled cabinets
• Data must never be transferred over: WhatsApp; Gmail/Outlook personal ID; Google Drive personal; USB drives, external HDDs, or pen drives

6.3 Destruction Policy

• Expired session notes (beyond retention period) must be shredded/digitally purged
• Unused physical reports must be destroyed by center head in HR-verified protocol
• Exit staff must surrender all physical/digital data upon last working day

6.4 Parent Consent Management

• Every child must have a signed or digitally acknowledged consent form prior to any: Assessment; AbilityScore® screening; Therapy initiation; Video recording
• Consent forms are stored in the parent CRM and governed by data retention SOP

🚫 STRICTLY PROHIBITED ACTIONS

📊 DATA ACCESS MONITORING & AUDITS

Audit reports are reviewed quarterly by the Ethics & Information Security Committee.

🧾 THIRD-PARTY & VENDOR CLAUSE

• Any third-party trainer, app, or tech provider accessing child data must sign Pinnacle’s Data Handling NDA, submit monthly audit of access log, and be approved by National Compliance Office
• Failure = Contract Termination + Legal Notice

📋 STAFF DECLARATION (TO BE SIGNED DIGITALLY & ONBOARDING)

“I understand that child data is not mine. It is protected, personal, and governed by law and ethics. I shall access it only when required for therapeutic duty and never share, misuse, or expose it without express written consent from authorized personnel.”

📣 CLOSING STATEMENT

The world runs on information. But at Pinnacle, we run on confidentiality. Because what you carelessly forward today… might be a child’s future case file, a parent’s privacy risk, or a national-level ethics breach tomorrow. So lock it. Guard it. Respect it.

⚖ Section 7: Misconduct Matrix & Disciplinary Action System

Accountability Is Not Punishment. It’s Protection — for the Child, the Parent, and the Brand.

📖 PURPOSE

This section establishes the official classification system for staff violations — and defines the action-oriented response mechanism that governs how misconduct is:

• 🧠 Identified
• 🧾 Documented
• 🚨 Escalated
• ⚖ Penalized
• 🤝 Rehabilitated (where possible)

It ensures a zero-ambiguity, legally enforceable, and audit-traceable framework to protect Pinnacle’s scientific, ethical, and human-first mission.

⚖ LEGAL BACKING

• Indian Labour Law & Model Standing Orders
• IPC Sections: 406 (Breach of Trust), 409 (Misuse of Responsibility), 354 (Verbal Misconduct)
• RPWD Act, 2016 (Rights of Persons with Disabilities)
• Internal Compliance Framework of Bharath Healthcare P LIMITED
• Terms of Employment & Offer Letter Signed by Every Employee

🧭 STRUCTURE: 5 LEVELS OF STAFF MISCONDUCT

🔍 DETAILED MISCONDUCT MATRIX

🛑 NON-NEGOTIABLE L5 MISCONDUCT (ZERO TOLERANCE)

• Biometric tampering
• Ghost sessions
• Child abuse (verbal, emotional, physical)
• Sexual harassment
• Taking gifts, money, or private favors
• Therapy fraud (fake notes, backdated entries)
• Sharing session videos/images externally
• Using therapy data for personal social media
• Willful data breach

📜 DISCIPLINARY ACTION FRAMEWORK

🔁 RECURRENCE ESCALATION RULE

• Repeating an L2 violation three times = escalate to L3
• Repeating an L3 violation = L4 Final Memo
• L4 + any future incident (of any kind) = L5 Termination Window

📊 DISCIPLINARY DASHBOARD & AUDIT TRAIL

Every memo must include:

• Date
• Incident Description
• Evidence
• Escalation Authority
• Staff Response
• Remediation (if any)
• Closure Date

Monthly reports shared with:

• Zonal Leadership
• National Ethics Committee
• Board-level Compliance Review (Quarterly)

🖋 EMPLOYEE ACKNOWLEDGEMENT

“I hereby acknowledge that I understand and accept the Disciplinary Matrix of Pinnacle Blooms Network. I accept that violations of conduct, therapy integrity, attendance, data policy, or ethical trust may result in action including termination or prosecution.”

📣 FINAL MESSAGE TO STAFF

This matrix is not a threat. It is a mirror.

• If you act with honor — it protects you.
• If you fall short once — it guides you.
• If you violate deeply — it holds you accountable.

This is how the world’s most trusted child development network protects the children it serves — and the professionals who serve them.

🫱🫲 Section 8: Staff Grievance & Fair Hearing Panel

Because Justice Should Not Only Be Delivered — It Should Be Experienced.

📖 PURPOSE

In an organization like Pinnacle Blooms Network — built by mothers, driven by science, trusted by families — we must ensure that our own staff are treated with the same fairness, clarity, and dignity that we offer every child and parent.

This section outlines the structured process for raising, reviewing, and resolving staff grievances — across interpersonal issues, policy violations, favoritism, unethical management, career obstruction, or retaliation.

This panel is not about hierarchy. It is about restoring balance and amplifying unheard voices within the organization.

⚖ LEGAL & SYSTEMIC FOUNDATION

• Indian Labour Codes on Grievance Redressal (Standing Orders, IR Code, etc.)
• Vishaka Guidelines (for gender dignity and workplace safety)
• Pinnacle’s Internal HRM Disciplinary & Appraisal Rules
• Universal Principles of Fair Hearing (Natural Justice Doctrine)

👥 WHO CAN RAISE A GRIEVANCE?

🛑 TYPES OF GRIEVANCES ACCEPTED

🛠 HOW TO RAISE A GRIEVANCE

8.1 Accepted Submission Modes

• 📝 Pinnacle Grievance Form – Service Request Route
• 📩 Email to: care@pinnacleblooms.org
• ✍️ Written letter to Center Head/Zonal HR
• ☎️ Call-in option for remote field staff

All grievances must be acknowledged within 48 working hours.

8.2 Grievance Submission Must Include

• Name (optional if anonymity requested)
• Employee ID
• Center Name
• Description of incident (date, what happened, who was involved)
• Desired outcome (if applicable)

👨🏽‍⚖️ Fair Hearing Panel Structure

Gender-matched panelist required in gender-based cases.

Escalation to National Board for L4/L5 complaints or unresolved grievances.

🔁 Case Flow Timeline

Urgent protection cases may be fast-tracked to 72 hours.

📜 Outcomes May Include

🧾 No Retaliation Guarantee

• Any retaliation, bias, or hostility following a staff grievance will be treated as a Level 4 violation
• Will be subject to panel review and penalty
• May lead to managerial disqualification from promotions

🧭 Right to Escalate

If the staff member is dissatisfied with the outcome, they may:

1. File a secondary appeal to the National Director (within 7 days)
2. Request a re-audit by an external HR compliance specialist

All escalation requests must be responded to within 7 business days.

📣 Final Note to Every Employee

We built this panel because even good systems can make mistakes. And when that happens — you deserve a way to be heard, without fear. At Pinnacle, you will never be silenced, mocked for asking, or punished for speaking the truth. Because we are not just building therapy systems. We are building a culture of courage, clarity, and fairness — for you too.

🧭 Section 9: Conflict Of Interest & Undue Benefit Policy

Transparency Isn’t Just Policy — It’s the Oxygen of Trust.

📖 Purpose

At Pinnacle Blooms Network, every staff action impacts a child’s future. This section ensures that all employees act exclusively in the best interest of the child, the family, and the institution — without being swayed by personal profit, undisclosed affiliations, or hidden agendas.

This policy establishes legally enforceable and ethically non-negotiable boundaries around conflicts of interest, undue benefit, external engagements, and parallel therapy practices.

⚖️ Legal & Ethical Basis

• Indian Labour Law & Model Employment Codes
• Prevention of Corruption Act, 1988 (undue benefit clause)
• The RPWD Act, 2016 (protecting vulnerable populations from exploitation)
• Internal IP, Ethics, and Brand Protection Agreements of Bharath Healthcare P LIMITED
• Global best practices in data ethics, therapy integrity, and child-first governance

📌 Definition of Conflict of Interest

A Conflict of Interest arises when a staff member:

• Uses Pinnacle’s platform, time, or brand to promote private gain or external interest
• Makes a decision or recommendation based on self-benefit, family ties, or external influences
• Conducts therapy, assessments, or interactions outside Pinnacle’s official framework

🚫 What Is Strictly Prohibited

9.1 Undisclosed Therapy Services

9.2 Vendor or Partner Collusion

9.3 Platform Misuse

🧾 Mandatory Declaration Protocol

🛠️ Enforcement & Actions

📊 Audit & Detection System

💼 Exit Protocol

• Fulfill employment agreement and notice period
• Submit written Resignation Notice and avail Notice Period commencement
• Obtain No Dues Certificate from Finance, No Objection Certificate from Center Admin/CT/DCT/Parents
• Sign “No Conflict of Interest Post-Exit Declaration”
• Confirm zero retention of child contacts, data, or therapy plans
• Avoid engagement with Pinnacle families or stakeholders (directly or indirectly) for 36 months post-exit unless formally documented

🧯 Whistleblower Protection

• Any staff reporting a conflict of interest or undue benefit scheme will be protected under anti-retaliation provisions
• May report via anonymous ethics form, email, or grievance panel
• Shall receive confidential review within 10 working days

📣 Closing Statement

Your decisions must be clear. Your intentions must be clean. Your loyalty must be to the child, the science, and the system.

Because at Pinnacle — there is no space for private benefit in public service. No therapy for personal profit at the cost of trust.

This is our firewall. This is our reputation. This is our way forward.

This Charter reflects not just the policies of a company — but the dreams of millions of children and mothers who’ve waited to be seen. We uphold this not as a rulebook, but as our promise to Bharat and the world.

Issued By:

Siva Satish Vemula
Human Resources, Ethics & Compliance Wing
Pinnacle Blooms Network unit of Bharath Healthcare P LIMITED
Creator – AbilityScore®, TherapeuticAI®, TherapySphere®, 7 Universal Child Development Readiness Indexes,
Author – The Voice of the Unheard

📞 +91 9100 181 181 | ✉ care@pinnacleblooms.org | 🌐 www.pinnacleblooms.or

🖋 Staff Declaration

“I understand that every therapy note I write becomes part of a child’s developmental map. I pledge that I will only log sessions that I have personally delivered, with full honesty, attention, and respect for the trust reposed in me by families and Pinnacle.”

“I understand that my time and presence are not just procedural — they are fundamental to a child’s developmental progress. I commit to full compliance with Pinnacle’s Time & Attendance Policy. I accept that violations may result in disciplinary or legal action.”

“I understand that my appearance, tone, and demeanor shape the way a child and parent experiences Pinnacle. I commit to conduct myself with full dignity, compassion, and professionalism every time I wear the Pinnacle ID.”

“I understand that phones, devices, data, and messages are not casual tools — they are windows into a child’s therapy experience and Pinnacle’s credibility. I commit to full compliance with the Device, Internet & Communication Policy.”

“I understand that child data is not mine. It is protected, personal, and governed by law and ethics. I shall access it only when required for therapeutic duty and never share, misuse, or expose it without express written consent from authorized personnel.”

“I hereby acknowledge that I understand and accept the Disciplinary Matrix of Pinnacle Blooms Network. I accept that violations of conduct, therapy integrity, attendance, data policy, or ethical trust may result in action including termination or prosecution.”

“I declare that I have no direct or indirect financial, professional, or promotional interest in any therapy, vendor, or consulting activity outside Pinnacle that may influence my decisions or compromise the trust families have placed in this institution.”

This Charter shall be contextually adapted for legal compliance in all countries where Pinnacle operates — while maintaining its universal ethical principles.

Document Version (e.g., v1.0 – June 2025), Approved by (Ethics Board, HR Head), Review Schedule (Every 6 months)